Avis Car Sales Privacy Policy

Last Updated: January 1, 2020

This California Privacy Notice (the "CA Disclosures") supplements the information contained in the Avis Car Sales Privacy Notice and applies solely to individual residents of the State of California ("consumers" or "you").

These CA Disclosures describe how we collect, use, disclose, and otherwise process personal information of individual residents of the State of California, either online or offline, within the scope of the California Consumer Privacy Act of 2018 (CCPA). Unless otherwise expressly stated, all terms in these CA Disclosures have the same meaning as defined in our Privacy Notice or as otherwise defined in the CCPA.  These CA Disclosures do not apply to any other Avis Budget Group entity or to the practices of any independent franchise or licensee. 

For purposes of these CA Disclosures only, we use the term "personal information" to mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. 

For the purposes of these Disclosures, personal information does not include:

• Publicly available information from government records.

• Information maintained in a form that is not linked to a particular individual, such as deidentified, aggregated or anonymized information.

• Information excluded from the CCPA's scope, such as:

• Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;

• Information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994. To understand how we process personal information in connection with car financing and other financial service activities, please refer to the Financial Privacy Notice. 

• Information relating to our job applicants, employees, contractors and other personnel of Avis Car Sales, which is not governed by these CA Disclosures. 

• Information we collect from individuals that test drive our vehicles, when the test drive is arranged through the Avis Budget Group rental business. Please refer to the Avis Budget Group Privacy Notice (www.Avis.com/Privacy) for disclosures on how this information will be collected, used and disclosed in connection with a test drive, or, if the test drive is facilitated through an independent location or franchise (a "licensee"), the privacy policy of that licensee will apply.

We collect various categories of personal information in connection with our services. The categories of personal information we collect may vary depending on the ways in which you engage with us or the products or services you use. Please review the Our Collection of Personal Information section of the Privacy Notice to learn more about the personal information we collect.

In the last 12 months, we have collected the following categories of personal information: 

We collect, use, sell or disclose personal information about you for one or more of the following purposes:

• To fulfill or meet the reason you provided the information, such as to process your transaction or respond to your inquiry, including to complete a vehicle purchase transaction. 

• To facilitate test drives of eligible vehicles, the evaluation of your trade-in vehicle and the transfer of the purchased vehicle into your possession. 

• To communicate with you, including via email, text message, push notification, social media and/or telephone calls.

• To operate, maintain, and provide to you the features and functionality of the services. 

• To market to you, including through email, direct mail, phone or text message, and to run our contests, sweepstakes or promotions.

• To personalize your experience and to deliver custom content and product and service offerings relevant to your interests, including targeted offers and ads through our websites, third-party sites, or on other devices you may use.

• To recognize you and remember your information when you return to our websites and services.

• To help maintain the safety, security, and integrity of our property and services, including Avis Car Sales vehicles, technology assets, and business.

• For testing, training, research, analysis, and product development, including to develop and improve our services.

• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.

• To ensure the security of our or another's premises, property or other assets.

• To defend, protect or enforce our rights or applicable terms of service. 

• To prevent fraud or the recurrence of fraud. 

• To evaluate, negotiate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Avis Car Sales' assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Avis Car Sales about consumers is among the assets transferred or is otherwise relevant to the evaluation, negotiation or conduct of the transaction.

• To comply with applicable law. 

As described in our Privacy Notice, we share personal information with third parties for business purposes or we may sell your personal information to third parties, subject to your right to opt out of those sales (see The Right to Opt-Out of Personal Information Sales below). 

We disclose your personal information to the following categories of third parties:

• Our service providers: We engage a number of third-party service providers that perform business or operational services for us or on our behalf, such as website hosting, infrastructure provisioning, IT services, customer service, email delivery services, administrative services, marketing and advertising services,  and other similar services, subject to contractual terms restricting the collection, use and disclosure of your personal information for any other commercial purpose.  

• Third parties at your request. We share your personal information with third parties with your consent or at your direction, including where necessary to validate your eligibility for third-party financing. 

• Our affiliate companies.  We may share your personal information with other companies owned or controlled by Avis Car Sales, and other companies owned by or under common ownership as Avis Car Sales, which also includes our subsidiaries (i.e., any organization we own or control) or our ultimate holding company (i.e., any organization that owns or controls us, such as Avis Budget Group, Inc.) and any subsidiaries it owns, particularly when we collaborate in providing the services to you;

• Businesses as needed to provide services. We may share personal information with third parties you engage with through or to provide our services, or as needed to fulfil your request or transaction, including, for example, payment processing services or vehicle title and registration services or third-party travel booking services. If you arrange for a test drive through an independent Avis Budget Group licensee, we will share personal information as needed to facilitate that service. 

• Security providers. We may share your personal information with third-party security providers, for example, to detect, prevent, or otherwise address actual or suspected fraud, harassment, security or technical issues, violations of any law, rule, regulation or the policies of Avis Car Sales;

• Business partners. We may disclose personal information to third parties with whom we partner to provide contests, joint promotional activities or co-branded services, and such disclosure is necessary to fulfil your request or application; 

• Ad networks and advertising partners. We work with third party Ad Networks and Advertising Partners to deliver advertising and personalized content to you on our services, on other sites and services you may use, and across other devices you may use. These parties may collect information directly from your browser or device when you visit our services through cookies or other tracking technologies. This information is used to provide and inform targeted advertising, as well as to provide advertising-related services such as reporting, attribution, analytics and market research; 

• Analytics providers. We work with third party analytics providers to better understand the demographics of our users and visitors, and to personalize, enhance and improve our services; 

• Social networks. We may disclose personal information, such as a unique identifier, hashed email address, or information automatically collected through tracking technologies, to social networks for the purpose of displaying personalized advertising and content on those social networks; 

• Law enforcement and third parties pursuant to legal request. From time to time, we may disclose personal information as reasonably necessary to respond to law enforcement requests and as required by applicable law, court order, or governmental regulations;

• Third parties in the context of a corporate transaction. We may disclose personal information as reasonably necessary to evaluate, negotiate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Avis Car Sales' assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Avis Car Sales about consumers is among the assets transferred or is otherwise relevant to the evaluation, negotiation or conduct of the transaction.

In addition, we may disclose personal information to our financing partners with whom we work to facilitate vehicle financing and leasing. Please refer to our Financial Privacy Notice to learn more about how we use and disclose personal information in connection with these financial services. 

In the previous 12 months, we have disclosed all of the categories of personal information we collect, explained in the table above, to third parties for a business purpose. 

In the previous 12 months, we have sold, or we may sell in the future, the following categories of personal information to third parties: Identifiers (such as your name, email address and contact information), Commercial Information (such as products sold or considered) and Inferences (generated from your interactions with our services) to third parties such as our affiliates, business partners, and other third parties who may use this information to communicate with you or to offer you products and services that may be of interest to you, such as vehicle warranty services or roadside assistance.  

Additionally, as is common practice among companies that operate online, we have permitted third party advertising networks, social media companies and other third party businesses to collect information directly from your browser or device through cookies or similar tracking technology when you visit or interact with our website, use our apps or otherwise engage with us online. For example, they may collect Internet/Network Information, such as a cookie or device ID, browsing history and website usage, Geolocation Data, and Inferences generated from your browsing history and interactions with our online website as well as other sites and services. These third parties use this personal information to serve targeted advertising or to personalize content and perform other advertising-related services such as reporting, attribution, analytics and market research. These third-party businesses may use such information for their own purposes in accordance with their own privacy statements, which may include reselling this information to additional third parties, including other advertising networks. To learn more, please see the Online Advertising section of our Privacy Notice. 

As a California resident, you may be able to exercise the following rights in relation to the personal information about you that we have collected (subject to certain limitations at law): 

The Right to Know	You have the right to request any or all of the following information relating to your personal information we have collected and disclosed in the last 12 months, upon verification of your identity:  • The specific pieces of personal information we have collected about you;  • The categories of personal information we have collected about you;  • The categories of sources of the personal information;  • The categories of personal information that we have disclosed to third parties for a business purpose, and the categories of recipients to whom this information was disclosed;  • The categories of personal information we have sold and the categories of third parties to whom the information was sold; and  • The business or commercial purposes for collecting or selling the personal information.
The Right to Request Deletion	You have the right to request the deletion of personal information we have collected from you, subject to certain exceptions.
The Right to Opt Out of Personal Information Sales	You have the right to direct us not to sell personal information we have collected about you to third parties now or in the future. If you are under the age of 16, you have the right to opt in, or to have a parent or guardian opt in on your behalf, to such sales.
The Right to Non-Discrimination	You have the right not to receive discriminatory treatment for exercising these rights. However, please note that if the exercise of these rights limits our ability to process personal information (such as in the case of a deletion request), we may no longer be able to provide you our products and services or engage with you in the same manner.
"Shine the Light"	California residents that have an established business relationship with us have rights to know how their information is disclosed to third parties for their direct marketing purposes under California's "Shine the Light" law (Civ. Code § 1798.83).

 

Please note, when you submit a request to us, that request will only be processed with respect to Avis Car Sales. If you would like to make a request relating to personal information held by one of the other brands (such as Avis or Budget Rental), you will need to submit a separate request to that specific brand.

To exercise your Right to Know and/or your Right to Deletion, please submit a request by:

• Filling out our California Resident Rights Request Form, or

• Calling 866-284-7669.

We will need to verify your identity before processing your request, which may require us to request additional personal information from you. We will only use personal information provided in connection with a Consumer Rights Request to review and comply with the request. 

In certain circumstances, we may decline a request to exercise the rights described above, particularly where we are unable to verify your identity, if the rights of another individual might be violated or as otherwise permitted by law. If we are unable to comply with all or a portion of your request, we will explain the reasons for declining to comply with the request.

Unless you have exercised your Right to Opt Out of Personal Information Sales, we may sell personal information to third parties for monetary or other valuable consideration. The third parties to whom we sell personal information may use such information for their own purposes in accordance with their own privacy statements, which may include reselling this information to additional third parties. 

  

To exercise the Right to Opt Out of Personal Information Sales, you may submit a request by calling 866-284-7669 or by clicking the following link:

Please also refer to the Online Advertising section of our Privacy Notice to learn more about how third party ad networks, social media companies and other third party businesses collect information from you when you visit our website and the opt-out choices you may have in relation to those activities.

We do not sell the personal information of consumers we know to be less than 16 years of age, unless we receive affirmative authorization (the "Right to Opt In") from either the minor who is between 13 and 16 years of age, or the parent or guardian of a minor less than 13 years of age.  Please contact us at ABGprivacy@avisbudget.com to inform us if you, or your minor child, are under the age of 16.  

California's "Shine the Light" law (Civil Code Section §1798.83) provides certain rights to California residents that have an established business relationship with us with regard to the disclosure of certain types of personal information to third parties for their direct marketing purposes. To opt-out of having your personal information disclosed to third parties for their direct marketing purposes, please click the Do Not Sell My Personal Information link above and provide your contact information to be added to our suppression list.  

In certain circumstances, you are permitted to use an authorized agent to submit requests on your behalf where (i) you provide sufficient evidence to show that the requestor is an authorized agent with written permission to act on your behalf and (ii) you successfully verify your own identity with us. 

We will update these CA Disclosures from time to time. When we make changes to these CA Disclosures, we will change the "Last Updated" date at the beginning of these Disclosures. All changes shall be effective from the date of publication unless otherwise provided in the notification.

If you have any questions or requests in connection with these Disclosures or other privacy-related matters, please address inquiries to us as described in the Key Contacts section of the Privacy Notice.