At Enterprise Holdings, Inc., through our independent regional subsidiaries (collectively “Enterprise Holdings”) and network of independent franchisees and fulfillment partners operating the Enterprise Rent-A-Car, National Car Rental, Alamo Rent A Car, as well as other various programs, features and services (" Enterprise Holdings", "we", "our" or "us" as referred to in the policy below), we respect your privacy.  We have implemented our privacy policy ("Privacy Policy") and cookie policy ("Cookie Policy") to explain our data collection, use, disclosure, and transfer practices, as well as individual access rights you may have when you use our sites and services, including global reservations and other rental services.

We host and maintain this website on behalf of a franchisee or fulfillment partner. For information about their privacy practices, please see below.

At SFAKIANAKIS S.A. we respect your privacy. We have implemented this privacy policy (“Privacy Policy”) to explain our data collection and use practices. You can learn more in the sections below.

WHAT INFORMATION WE COLLECT

Information Collected About You

You may provide us with certain information in connection with a transaction or in your interactions with our websites and at our locations. We collect the following types of personal information from you:

• Your name/surname, your address, your email, your date of birth, contact telephone number.
• Your Enterprise, Alamo or National rewards information, online user account details, membership/corporate ID numbers, passport information and frequent flyer or travel partner affiliations and your credit card details.
• Vehicle rental information, including the location of where the vehicle is rented, date of rental, your arrival flight number, your type of rental and your preferences.

As a franchisee of Enterprise Holdings, Inc. and/or any of its relevant subsidiaries (“Enterprise”), Enterprise may share with us your reservation and booking information. For these transactions, we and Enterprise are independent data controllers. We also share information about you with Enterprise, as described below in the section titled “Who We Share Information With”.

Third parties provide us with additional information about you, including:

• Referral sources, such as third party online booking sites (who provide us general contact information and a booking confirmation number to facilitate the rental), your employer (general contact information), and your insurance provider (general contact and policy information).
• Hotel, airline and membership clubs, who provide us your general contact information and booking information.
• Credit reporting agencies, which, for fraud prevention purposes, provide us with identity-related information.
• Service Providers, such as customer support (customer service-related information and enquiries made by you).
• Third Parties that cooperate with us, such as road assistance companies, road care assistance, insurance companies, public authorities, lawyers, credit card organizations and banks.

With your consent, we will access location-based information or collect location markers from your mobile device or based on your IP address. We will use this information to provide you with notifications related to our locations, return information, local offers or other information that we think will be helpful in providing you with better services. We do not use this information to specifically locate you for any reason other than to provide you the service. With your consent, our application will utilize your device's camera. If you have allowed us to utilize your location information or your device's camera in the past and wish to revoke the permissions, please change the settings on your device.

VEHICLE OPERATION AND LOCATION DATA
Your vehicle may be equipped with (i) emergency notification functionalities such as an eCall System and (ii) telematics systems and infotainment ("Telematics Systems") which are independently controlled by the manufacturer ("OEM") of your vehicle. The eCall System is provided in order to ensure that you and your passengers receive appropriate assistance in the case of an emergency. eCall will automatically call and provide information regarding the accident to emergency services. We will also use, disclose and have access to this information. In the event that a vehicle has been reported as potentially or actually lost or stolen, we will request access to the necessary Telematics Systems data from the relevant OEM. Contact details of the OEMs along with their applicable privacy disclosure which may include system and service limitations, warranty exclusions, limitations of liability, descriptions of use, disclosure and retention of information, your individual rights, and any data transfer outside the European Economic Area may be found on the OEM’s websites or may be available via the vehicle dashboard.

Telematics Data will be shared with emergency service providers, others who assist in responding to an accident, telematics service operators or those with whom we have a legal or contractual obligation to provide such data.

When you use any satellite navigation or infotainment system in this vehicle, you are responsible for any information that is stored in the systems as a result of your use. We cannot guarantee the privacy or confidentiality of such information, and you must wipe it before you return the vehicle to us. If you do not do this, the next users of the vehicle will be able to access this information.

CHILDREN’S PRIVACY
Our websites are not directed to and do not knowingly collect personal information from, children under the age of 18 or your country's age of minority. If you nevertheless believe that your child has provided us with their personal information and you need to let us know to delete it, please contact us using the contact us email address.

HOW WE USE INFORMATION ABOUT YOU
We use the information we collect from you or about you to provide you with our services and for the following purposes:

Where it is necessary for us to enter into a contract with you and provide services to you for the duration of the contract, including

o To assist the transactions that you request, such as reserving & renting vehicles.
o To provide customer service related to your interactions with us or to respond to your enquiry.
o To enroll you in our loyalty programs and send non-promotional information relating to your ongoing membership of these programs.
Where necessary for us to comply with a legal obligation, including
o To share information about your vehicle's location with emergency services in the event that you are involved in a road accident.
o To share information with government and regulatory authorities when required by law or in response to legal process, obligation, or request.
Where it is necessary for our legitimate interests, as listed below, and where our interests are not overridden by your data protection rights, including
o To communicate important information about your rental, such as arrival and return alerts.
o To assist us in providing better products and services: for example, to evaluate the performance of our staff, to assess the quality of products and services received and to help us improve our websites, facilities and services.
o To compile statistics and analysis about our customers' use of our websites, products and services.
o To protect our legal rights and manage the security of our networks and property. For example, we will use CCTV to ensure the security of our premises and we maintain Do Not Rent lists of customers that are non-payment or safety risks.
o To share your information with third parties in order to prevent fraud and protect our business interests and rights, privacy, safety and property, or that of the public. We will do this to collect unpaid bills, to avoid liability for penalties you incur (e.g. traffic citations) and for claims processing purposes.
o To share your information with third parties in order to permit us to pursue available remedies or limit damage that we may sustain and to enforce the terms of any rental agreement or our websites' terms and conditions.
o To enable us to use telematics (e.g., for the purposes of tracking mileage and location in the event of theft and to alert us if the telematics systems has been removed or tampered with).
o To gather from road assistance or insurance companies’ information of your personal details about your accident condition and share them with third parties, to defend the legitimate interest of our company.
Where you have given consent, including
o To send you text messages in order to provide you with time sensitive communications related to your transaction (e.g., construction delay at airport branch), loyalty and rewards information and customer experience surveys.

RETENTION OF YOUR PERSONAL INFORMATION
We retain your personal information for as long as we need to fulfill our business purposes, as set out below:

• Rental transactions: The data associated to your rental agreement is stored and may be used for longer than the time we need the data to provide our services to you, in order to fulfill and defend the legal interests of our company and as long as it is prescribed by the relevant Government Laws (including Tax, civil or other legal provisions).

• Customer service related queries: The data associated to your customer service queries are stored for 10 years and may be used to fulfill and defend the legal interests of our company as long as it is prescribed by the relevant Government Laws ((including Tax, civil or other legal provisions).

• Disputes & law enforcement: Your data may be shared with the public authorities and will be used to fulfill and defend the legal interest of our company as long as it is prescribed by the relevant Government Laws ((including Tax, civil or other legal provisions).

WHO WE SHARE INFORMATION WITH

AFFILIATES
We share the information we collect about you with our affiliates (“Affiliates”) for the purpose of:

Sub-Franchisees: The nature of the business and operations require us to share your reservation and booking information with our sub-franchisees in and out of E.U. For these transactions, the sub-Franchisee is an independent data controller or equivalent under applicable law and will maintain its own privacy policy in respect of the rental data that you provide to the sub-Franchisee, regardless of whether such data is collected through Affiliates websites or other online platforms and / or its Subsidiaries or is collected by the sub-Franchisee at the service points. You are encouraged to check the privacy policy of the sub-Franchisee that is applicable to your transaction.

Our Service Providers And Business Partners: We will share your information with third parties, such as (1) credit card organizations, banks, administrative and technical support providers, Tour Operators, Travel Agents, insurance companies, road assistance companies, lawyers other customers or partners, (2) companies who conduct customer research or satisfaction surveys on our behalf, (3) customer support providers, such as the provider of our live chat feature, in order to provide you customer service, (4) debt collection providers, (5) claims processors and public authorities in and out of the Greek territory.

Enterprise:
We share your personal information with Enterprise for the following purposes:
• To manage your rental and for Enterprise to communicate with you about or assist with your rental.
• In relation to any incident arising from your dealings or an additional authorized driver's dealings with Enterprise if Enterprise thinks that, as a result of such incident, you or an additional authorized driver could be a risk for future rentals.
• In order for Enterprise and its third party service provider to carry out phone customer satisfaction surveys.
• To send you marketing communications about similar products or services which Enterprise thinks may be of interest to you, including targeted advertising on Enterprise sites, selected partner sites and social networks.
• To compile statistics and analysis about you – and any applicable additional authorized drivers’ – use of Enterprise’s products and services, including statistics based on anonymized data, which enable Enterprise to provide you and other customers in the future with better customer service, products, features and functionalities.

When sharing such information with Enterprise, we and Enterprise operate as independent data controllers. Enterprise maintains its own privacy policy in respect of the information we provide Enterprise. You are encouraged to review Enterprise’s privacy policy, which can be found here: https://privacy.ehi.com/en-gb/home.html

When we share your personal data, we require that all parties respect the security of your personal data and treat them according to law. We do not allow our service providers to use your personal data for their own purposes and we only allow them to process your personal data for specified purposes and in accordance with our agreement.

Government Authorities
Your personal information may also be shared with government authorities as outlined above.

Sale, Merger or Change in Control
Your information may also be transferred to another company in the event of a transfer, change of ownership, reorganization or assignment of all or part of our businesses or assets. This will occur if the parties have entered into an agreement under which the collection, use and disclosure of the information is limited to those purposes of the business transaction, including a determination whether or not to proceed with the business transaction. You will be notified by an announcement to social media and by this webpage.

GLOBAL DATA TRANSFERS AND PROCESSING
The information you provide us or that we collect may be transferred or accessed by entities around the world, including:
• Enterprise: If you book a reservation with us or with an Enterprise corporate-owned location, we will transfer your personal information to Enterprise. Enterprise Holdings, Inc. is based in the United States and has corporate-owned locations in the United States, Canada, Germany, Spain, France, Ireland and the United Kingdom.
• Third Party Service Providers: We utilize third party service providers who are located inside and outside the countries where we are located, such as a) to EAN Data Services UK Ltd., b) to Enterprise Holdings Inc and / or their related affiliates and / or companies providing support services, which retains the right to franchise Enterprise systems (please check the personal data policy of Enterprise Holdings Inc to: https://privacy.ehi.com/en-gb/home.html, c) all companies acting as independent controllers, d) TSD Rental LLC (operating as processor).

YOUR RIGHTS
Your rights may include the right to: 1) ask us for a copy of your personal information, 2) request that we correct your personal information, 3) request that we erase certain categories or types of information, 4) request that we restrict certain processing, 5) obtain the information you provide in a structured, machine readable format and 6) to transfer some of this information to other organizations. You have the right to object to processing of personal information on the basis of our legitimate interests. Where we have asked for your consent to process information, you have the right to withdraw this consent at any time.
We reserve the right not to allow access to your information or to limit your rights (e.g. if such disclosure is prohibited by law or if the rights of another individual might be violated). In some instances, this may mean that we are able to retain your personal information even if you withdraw your consent.

The right to file a complaint to the Personal Data Authority
You have the right to file a complaint to the Personal Data Protection Authority for the issues concerning the processing of your personal data. For the Authority's jurisdiction and how to file a complaint, you can visit its website https://www.dpa.gr «Citizens Rights» «How to file a complaint with the DPA?», where detailed information is available.

CHANGES TO THESE POLICIES
As necessary, we will update this Privacy Policy to reflect changes in our privacy practices. If we make any material changes, we will notify you on this site or as otherwise may be required or permitted by law, prior to the changes becoming effective. We encourage you to periodically review this site for the latest information on our privacy practices.

DATA CONTROLLER CONTACT INFORMATION
If you are making a rental, or visiting a website or mobile site, in the following countries, the data controller will be listed as below.

Country: Greece

Data Controller: Sfakianakis S.A.

Contact Information

24th Seneka Str, 118 55, K.Kifissia
Tel: 0030 210 3493400
Email: dataprotection@sfakianakis.gr