PreferRent.com Portal
Annex 1 to the Terms and Conditions
PRIVACY AND COOKIE POLICY
I PRIVACY POLICY
This Privacy Policy applies to the processing of personal data by PreferRent (the “Controller”, “we”, “us”, “our”) and describes how we process your as user’s, lessee’s or rental company’s representative’s personal data in the PreferRent Rental Portal (the “Portal”).
This Privacy Policy describes the practices and purposes of personal data processing for the provision of services in the Portal. It also describes how a person may exercise its rights as a data subject. We process personal data in accordance with the General Data Protection Regulation (the “GDPR”) and other applicable laws. Unless otherwise specified, the terms in this Privacy Policy have the same meaning as the terms in Article 4 of the GDPR.
To ensure that personal data are processed in a transparent manner, this Privacy Policy explains the following:
1 What personal data are processed;
2 How we acquire your personal data;
3 For what purposes and on what legal basis your data are processed;
4 How long we will be processing your personal data;
5 When personal data may be shared with third parties;
6 Information about personal data transfer outside the EU;
7 Processing of children’s personal data;
8 Automatic decision making;
9 Your rights arising out of the GDPR;
10 Amendments to the Privacy Policy;
11 Contact details of the Controller.
By using our services provided through the Portal, you are representing that you have read and agree to our Privacy Policy. Otherwise, please immediately discontinue the use of our services.
1 What personal data are processed
To provide you with our services and achieve the purposes stipulated in the next section, we are processing certain personal data related to you. Below, we have indicated what categories of personal data we process.
Registration data – in order to provide our services, we are processing your personal data which you provide us upon registering your account in the Portal. Such registration data may include your name, surname, personal identification number or date of birth, e-mail address, phone number, and country of registration.
Identification data – to provide our services to you directly, we may have to identify you. Identification data may include your first name, last name, personal identification number or date of birth. In case you are acting as a representative of the lessee, we may also process information about your position in the company to ensure your representation rights.
Contact data – to be able to contact you, we may process your e-mail address, phone number and address.
Payment data – to carry out necessary payments, we may process your payment data, which may include your account number, sent payments and other information related to payments.
Transaction data – to carry out the service, we may process different kinds of data related to the requested and fulfilled transaction, such as information about the requested service, cancellation of agreements, and Rental Points transactions.
Credit Rating data – to manage financial risks, we may process your personal data related to credit risks, past and current liabilities, debts, missed payments and other data. Based on this information, we will assign a user ranking and rating and creditworthiness information.
Technical data – to ensure smooth provision of our services, we may process technical data, which may include your device’s Internet Protocol address (IP address), browser information, information about your device’s operating system, settings, language, date of device and other necessary information which may also be acquired through the use of cookies in our Portal.
2 How we acquire your personal data
During the provision of our services, we may acquire your personal data from you directly or from third parties.
Some of the personal data we acquire directly from you when you register your account or when you are using our Portal services. If you register your account or identify yourself through third-party services embedded in the Portal (such as Smart ID), we will receive information about your identity from the relevant identification service provider, such as SK ID Solutions, when you are using the Smart ID solution.
Additionally, in certain situations as prescribed in the Privacy Policy, we may acquire your personal data from enterprise registries, credit risk registries, debt registers and others, such as SIA „CREFO Rating” and AS “CREFO Birojs”, in order to evaluate whether you are a financially reliable party. In order to calculate your User ranking and rating in accordance with the Portal’s Terms & Conditions, we may also receive personal data/feedback regarding the provided services from rental companies (“Rental Companies”).
Lastly, we may also acquire your personal data from entities which you are representing.
3 For what purposes and on what legal basis your data are processed
In this section we provide you details about the purposes for which we may be processing different categories of personal data as well as identify the legal basis under which we are processing your personal data.
|
Purpose |
Personal data categories |
Legal basis |
|
To provide our Portal’s services by registering your account |
Registration data |
Necessary to perform our contract with you to provide our services (Art. 6.1.b GDPR). Furthermore, if you are acting as representative of lessee or Rental Company, processing of your data is also based on our legitimate interests to perform a contract with entity you are representing (Art. 6.1.f GDPR) |
|
To provide our Portal’s services (confirmation of reservations) |
Identification data, Contact data, Transaction data. |
Necessary to perform our contract with you to provide our services (Art. 6.1.b GDPR) |
|
To confirm your rights as lessee’s or Rental Company’s representative (if applicable) |
Identification data |
It is our legitimate interest (Art. 6.1.f GDPR) to ensure that you have a right to represent lessee or Rental Company and conclude agreements |
|
Transfer of personal data to Rental Company to conclude rental agreement |
Identification data, Contact data, Transaction data, user’s ranking and rating information and creditworthiness information |
Necessary to perform our contract with you to provide our services (Art. 6.1.b GDPR) Sharing data with Rental Companies is necessary for the provision of our service. Without it, you would not be able to conclude agreement with Rental Company. |
|
Transfer of personal data to Rental Company in case of claimed unauthorized access to your Portal’s account |
Identification data, Technical data and other available data |
It is our and our partners’ (Rental Companies’) legitimate interest (Art. 6.1.f GDPR) to obtain evidence and investigate the claimed unauthorized access to determine whether lease agreement with the Rental Company has been breached. |
|
To manage financial risks of rental company and determine your creditworthiness information (if you are lessee yourself) |
Credit Rating data (if you are lessee yourself) acquired from third-party databases (e.g., credit risk agencies) |
Your consent (Art. 6.1.a GDPR) The determination of your creditworthiness information is an integral part of our service and without providing your consent, we may refuse to provide our services to you. |
|
User ranking and rating |
Credit Rating data, transaction data, feedback received from rental company |
It is our legitimate interest (Art. 6.1.f GDPR) to ensure that our partners (Rental Companies) and we can manage financial risks when providing services |
|
To carry out Rental Point Program |
Identification data, Transaction data, Payment data |
Necessary to perform our contract with you to provide our services (Art. 6.1.b GDPR) |
|
Review of complaints from you or from rental company about you |
Identification data, other information provided to us in the complaint |
It is our legitimate interest (Art. 6.1.f GDPR) to ensure the quality of the Portal and provided services |
|
Accounting |
Identification data, Contact data, Transaction data |
It is our legal obligation (Art. 6.1.c GDPR) arising from accounting laws to process supporting documents of the transactions |
|
To inform you about news, special offers and general information about our services |
Identification data, Contact data (e.g., e-mail address, phone number, etc). |
Your consent (Art. 6.1.a GDPR) or our legitimate interest (Art. 6.1.f) to inform our existing customers about our services or provide them relevant news. You have a right at any time to opt out from receiving such information or withdraw your consent for personal data processing for this purpose. |
|
To ensure security of our Portal, to detect and address technical issues |
Technical data (incl. data from cookies) |
It is our legitimate interest (Art. 6.1.f GDPR) to protect the integrity and security of our Portal and improve it. |
When we are processing your personal data for the purposes of concluding or performing a contract with you (Art. 6.1.b GDPR), the required information is necessary to do so. Otherwise, we will not be able to provide you with our services.
We may also process your personal data for other legitimate purposes if:
(i) You have given us your consent for such processing (Art. 6.1.a of the GDPR);
(ii) The processing of your data is necessary to ensure you with our services (Art. 6.1.b of the GDPR);
(iii) The processing of your personal data is necessary for us to comply with legal obligations (Art. 6.1.c of the GDPR);
(iv) We have legitimate interests which are not overridden by your interests or fundamental rights (Art 6.1.f of the GDPR).
If we are processing your personal data for other purposes than those indicated in the table above, we will make sure that such processing is compatible with the purposes for which the personal data were collected. When possible, we will inform you about new data processing purposes.
4 How long we will be processing your personal data
We will retain your personal data only for as long as necessary for the purposes set out in this Privacy Policy.
Your Registration data, Identification data and Contact data shall be retained as long as you have a registered account in the Portal and for an additional five (5) years after the respective account has been deleted. User ranking and rating, Creditworthiness information and Credit rating data shall be retained for five (5) years or until required for the protection against potential claims. This information together with Transaction data are retained in order to protect ourselves in case a claim is brought against us in relation to our services.
Identification, Payment and Transaction data related to the rental agreements with the Rental Companies are kept for five (5) years or as long as applicable accounting laws require.
If your personal data is included in service agreements, terms and conditions or other agreements concluded with us, we may also store this data until the termination of respective agreement and after that until the end of limitation period of the possible claims arising from such agreement unless there is other legitimate purpose for retaining the data longer (e.g., for accounting purposes).
Technical data shall be kept for up to one (1) year or longer if it does not contain personal data of an identified or identifiable natural person.
If necessary, we will also retain and use your personal data (including data you have communicated to us) to the extent necessary to comply with our legal obligations or ensure the protection of our legal rights (e.g., to resolve disputes and enforce our legal agreements).
If you do not sign in to your account for more than two years, your account will be deleted. However, please note that your personal data may be retained and processed even after your account is deleted for the time periods stipulated above.
5 When personal data may be shared with third parties
For the purposes of provision of our services, we may share your personal data with the rental companies with whom you will conclude rental agreements. Personal data processed by rental companies are subject to the privacy policy of the respective rental company. Generally, the rental companies may process your personal data, among other purposes, to evaluate whether to conclude an agreement with you and to confirm whether the User can represent a lessee in respect to the conclusion of a rental agreement. For full information on the rental company’s privacy practices, please see the respective rental company’s privacy policy.
We may share your personal data with persons who are authorized by us and with our cooperation partners, which help us to ensure our services and may act as our data processors, acting as IT service providers (including, but not limited to, e-mail service providers, website maintenance services, server providers or maintainers, etc.), marketing service providers, payment service providers and others. When sharing your personal data with third parties, we will carry out all necessary activities to ensure that third parties ensure adequate protection of your personal data.
Additionally, we may share your personal data in the following situations:
(i) After receiving a substantiated request in accordance with the procedures of applicable law, we may share your personal data with persons so authorized by law (e.g., investigation authorities);
(ii) When necessary to protect our interests protected by law (e.g., when a person has infringed upon our interests) we may share personal data with courts, bailiffs or other relevant state institutions;
(iii) If necessary, to our partners, such as auditors, lawyers and other specialists or consultants, financial institutions, insurers; also, on a need-to-know basis, data may be shared with our shareholders, financiers and potential buyers of our business or part of it;
(iv) To payment service providers to the extent necessary to make or receive payments;
(v) To PreferRent Investments and/or other PreferRent group companies for administrative purposes.
We will not share your personal data with third parties if there is no legitimate purpose and legal basis for this.
In certain situations when we are cooperating with third parties (e.g., by using financial service providers), in addition to this Privacy Policy, the privacy policies of the respective third parties will also be applicable to the processing of your personal data. We encourage you to familiarize yourself with the respective privacy policies. However, we do not assume any liability for their content.
6 Information about personal data transfer outside the EU
We do not transfer personal data outside the European Union and European Economic Area Member States. However, we are using payment service providers which are located and which process personal data in the United Kingdom, which is not part of the European Union since 1 st January 2021, yet, according to conditional interim regime agreed under EU-UK Trade and Cooperation Agreement, until 1st July 2021 the free movement of data applies to transfer of data to and from United Kingdom. From 1st July 2021 we will ensure the necessary safeguards for the transfer of your personal data to the United Kingdom. The transfer of personal data shall be based on standard data protection clauses adopted by the European Commission concluded between us and the data recipient established in the United Kingdom if the European Commission will not have adopted a decision determining that the United Kingdom ensures adequate data protection standards (adequacy decision) or if conditional interim regime for data transfers will not be prolonged. For more information about the applied safeguards and where to obtain copies of them, please contact us by using our contact information as indicated below.
7 Processing of children’s personal data
We do not target anyone under the age of 18 (“Child” or “Children”) for use of our services in the Portal.
We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a holder of parental responsibility over a Child and you are aware that your Child has provided us with personal data, please contact us. If we become aware that we have collected personal data from a Child without receiving parental authorization, we will take the necessary steps to remove that information from our servers.
8 Automatic decision making
We carry out automatic decision making to determine User ranking and rating in accordance with the terms set out in the Portal’s Terms and Conditions section 6. Also, we automatically determine your creditworthiness information in line with our internal risk policies based on Credit Rating data acquired from third-party databases (e.g., from credit rating agencies). In case you believe that a user’s ranking and rating or creditworthiness information is not calculated correctly, you have a right to request human intervention to express your view and to contest the decision by contacting us.
9 Your rights arising out of the GDPR
In accordance with the General Data Protection Regulation, you have certain rights in respect to processing of your personal data. In situations stipulated by the GDPR, you have the following rights:
(i) Right of access
(ii) Right to rectifications
(iii) Right to erasure
(iv) Right to object
(v) Right to withdraw your consent
(vi) Right to restrict the processing of personal data
(vii) Right to data portability
To request the fulfillment of your rights, please contact us via e-mail: privacy.lv@preferrent.com. Please note that for the fulfillment of your requested right, we may be required to process additional personal data and may request your identification.
In situations where you are not satisfied with our data processing activities, you always have the right to submit a complaint to the Latvian Data State Inspectorate (e-mail: info@dvi.gov.lv; web-page: www.dvi.gov.lv) or your national data protection authority (you can find your data protection authority on the following website: https://edpb.europa.eu/about-edpb/board/members_en).
10 Amendments to the Privacy Policy
We reserve the right to unilaterally update this Privacy Policy at any time. The updated version of the Privacy Policy will be available on our Portal. We recommend reviewing this Privacy Policy regularly, so that you remain informed of any changes.
11 Contact details of the Controller
If you have any questions regarding your personal data processing or this Privacy Policy, please contact us by writing to our e-mail address: privacy.lv@preferrent.com or by using the contact information below:
“PreferRent” SIA
Registration number: 40203174630
Registered address: Maskavas iela 240-3, Riga, LV-1063, Latvia
This Privacy Policy is in force from May 14, 2021
II COOKIE POLICY
This cookie policy applies in addition to our Privacy Policy. Our Privacy Policy informs you on how PreferRent (also “we”, “us”, “our”) collects, shares and processes your personal data. This Cookie Policy applies to the use of cookies when you are using our rental portal (the “Portal”). Our Cookie Policy is an integral part of our Privacy Policy (available here) and includes the following information:
1 What are cookies;
2 Use of cookies by PreferRent;
3 What types of cookies we use;
4 Third-party cookies;
5 How to control cookies;
6 More information;
7 Amendments to this Cookie Policy;
8 Contact details.
For the purposes of this Cookie Policy, the term “cookies” will cover both cookies and methods similar to cookies in browsers (such as pixels, beacons, tags and others).
1 What are cookies
Cookies are small text files that are placed on your computer by the websites you visit. They are widely used to ensure functionality of websites, to make websites more efficient, as well as to provide useful information to website owners, such as the number of visits to websites.
The use of cookies has become standard practice on most websites and applications. However, if you do not want to use the features provided by the cookies, you can manage and control them by using your browser to not accept or delete them from your browser history.
You can find more information about cookies, as well as how they can be managed or deleted, at www.aboutcookies.org.
2 Use of cookies by PreferRent
Our Portal uses cookies managed by us (first-party cookies) as well as third-party cookies. Cookies are stored on your device when you visit and are using the Portal.
Mostly, cookies are used to identify the registered user, to ensure the security of the Portal, to analyze visitors’ use of the Portal, and to improve as well as to ensure general functionality of the Portal.
If you are a registered user of the Portal, certain information acquired from the cookies may be linked to your account and combined with other information we hold about you. Otherwise, information acquired from cookies is not used to identify unregistered visitors to our Portal.
3 What types of cookies we use
Necessary cookies – necessary cookies are used to ensure the functionality of the Portal, for example, to remember your log-in details, to ensure security, and so on. Without the respective cookies, the Portal cannot properly function. Therefore, their usage is necessary and is not subject to your consent.
The necessary cookies may include cookies for the purposes of authentication (to remember your login state) and for the provision of security (e.g., to protect user data from unauthorized access).
|
Cookie |
Provider |
Purpose |
Retention period |
|
CONSENT |
PreferRent |
Determines whether the user has accepted the cookies |
1 year |
|
ARRAffinity |
PreferRent/ Microsoft |
Used for load balancing |
1 year |
Functional cookies – functional (also called “preference” cookies) cookies allow the Portal to remember the settings you choose, which affects the way the page is displayed. Use of these cookies is based on our legitimate interests to ensure you the full functionality of the Portal.
|
Cookie |
Provider |
Purpose |
Retention period |
|
N/A |
N/A |
N/A |
N/A |
Analytical cookies – analytical cookies allow us to track our visitors’ behavior on the Portal and understand how they are interacting with the Portal on an aggregate level. The use of these cookies is based on our legitimate interests to analyze our visitors’ behavior and interactions with the Portal in order to improve it.
|
Cookie |
Provider |
Purpose |
Retention period |
|
_utmz |
|
Provides information on how visitor has reached our Portal. |
1 year |
|
_utma |
|
Keeps track of the number of times a visitor has seen our Portal. |
1 year |
|
_ga |
|
Registers a unique ID that is used to generate statistical data on how the visitor uses our Portal. |
1 year |
Marketing cookies – marketing cookies allow us to provide you with the content most relevant to you based on your interaction with our Portal and to provide you with direct marketing advertisements on other media sites not owned by us. The use of these cookies is based on our legitimate interests to market our services to people who have interacted with the Portal.
|
Cookie |
Provider |
Purpose |
Retention period |
|
_fbp |
|
Retargeting users on Facebook |
1 year |
Information acquired from the use of cookies will either be used in aggregate format or will be retained in accordance with our Privacy Policy when we have a legitimate purpose and legal basis for such data processing.
4 Third-party cookies
Some of the cookies enabled on your device when you visit our Portal are owned by third-party service providers. Third-party service providers’ cookies help us to provide you our services, help us understand usage and your interactions with our Portal and provide the possibility for us to provide direct marketing advertisements on third-party sites to help support and maintain our services. We will use these cookies for the purposes provided for in this Cookie Policy or our Privacy Policy. However, these third parties may use your data collected by their cookies for their own defined purposes, which we cannot control. By accepting third-party cookies, you are also consenting to the privacy policies on the processing of your personal data of the respective third-party service providers.
Below you can see which third-party service providers may have access to the information from their own cookies set on your device. Please note that the links below are to third-party websites over which we have no control, and we are not liable for their content.
Google Analytics service – Google Analytics is a web analytics service provided by Google that tracks and reports website traffic. Google uses the data collected to track and monitor use of our Portal. For more information on the privacy practices of Google, please visit the Google Privacy & Terms webpage: https://policies.google.com/privacy?hl=en.
Facebook – we are using Facebook services to provide you with relevant advertisements based on your visit to our Portal when you visit the social network. For more information on the privacy practices of Facebook, please visit the Facebook Cookie Policy: https://www.facebook.com/policy/cookies/.
Microsoft – Microsoft cookies are used to ensure the stability of our Portal. For more information on the privacy practices of Microsoft, please visit the Microsoft Privacy Statement: https://privacy.microsoft.com/en-us/privacystatement.
Hotjar – we use Hotjar’s services to track and monitor the use of our Portal by our visitors and to analyse the behaviour of our visitors. The collected information is used to improve our Portal. For more information on the privacy practices of Hotjar, please visit the Hotjar Privacy Policy: https://www.hotjar.com/legal/policies/privacy/.
5 How to control cookies
When you visit our Portal, we set the cookies which are required for us to enable you to use our services.
Most browsers (Firefox, Google Chrome, Internet Explorer, etc.) allow you to control cookies through the browser settings. For example, you can set your browser for it to block the possibility to store any or specific cookies on it, delete cookies or inform you about situations when new cookies are stored on the browser.
By clicking the “help” button on your browser, you can find instructions on how to prevent the browser from storing cookies, as well as what cookies are stored already and delete them if you want to. Changes to the settings must be made for each browser that you use.
However, please note that without saving certain cookies, it is possible that you will not be able to access or fully use all the features and services of our Portal, since some functionalities of the Portal are dependent on the cookies.
6 More information
Information about how we process personal data in respect to the use of cookies is available on our Privacy Policy, which is available here.
You can learn about cookies, including how to see what cookies have been set and how to manage and delete them by visiting www.aboutcookies.org, www.allaboutcookies.org or other corresponding websites available on the internet. Please note that these are links to third-party websites over which we have no control.
7 Amendments to this Cookie Policy
We reserve our right to unilaterally update this Cookie Policy at any time. The updated version of this Cookie Policy will be available on our Portal. We recommend reviewing this Cookie Policy regularly, so that you remain informed of any changes.
8 Contact details
If you have any questions regarding your personal data processing or this Cookie Policy, please contact us by e-mail: privacy.lv@preferrent.com or by using the contact information below:
“PreferRent” SIA
Registration number: 40203174630
Registered address: Maskavas Street 240-3, Riga, LV-1063, Latvia
This Cookie Policy is in force from May 14, 2021