Privacy Policy

Table of contents 

1. Who processes your Personal Data?

2. What Personal Data do we collect about you?

3. For what purpose do we process your Personal Data?

4. Who are the recipients of your Personal Data?

      4.1. Categories of recipients

      4.2. International transfers

5. How long do we keep your Personal Data?

6. What rights can you exercise regarding the processing of your
Personal Data?

7. How do you exercise your rights?

8. How do we protect your Personal Data?

9. What rules apply to the processing of your Personal Data when you
click on links placed on our website, redirecting to our partners’ or other
sites?

10. Changes to this Privacy Policy

1. Who processes your Personal Data?

Easy Move Limited,

whose registered office is El Salam Road Villa 604/3,street #3 Diar El Rabowa Beside Bridgestone, South Sinai Governorate 46619, Egypt (hereinafter referred to as “we”, “us”

or “our(s)”) is the “Data Controller” of your Personal Data collected

and processed via this website, our mobile applications, our rental stations or

through any other contact you may have with us in order to offer you mobility

solutions and services.

The terms “Easy
Move”, “we”, “us” or “our” that we use in
this policy refer to Easy Move Limited. In accordance with the applicable
regulations on the protection of personal data, Easy Move Limited is the
“Data Controller”.

Easy Move Limited
is a member of the Easy Move Mobility Group. The term “our Group”
refers to Easy Move Mobility Group.

When you
communicate Personal Data to us or when we collect Personal Data about you, we
undertake to use it in accordance with this Policy.

2. What Personal Data do we collect about you?

As a provider of
mobility solutions, we collect and process various categories of Personal Data
in connection with this website and our mobile applications and in order to
provide you with our products and services.

By Personal Data,
we mean not only data that identifies you directly, but also data that
identifies you indirectly.

The categories of
Personal Data that we collect in the context of our services and the use of our
website and our mobile applications include the following:

·        
-Your identification data: surname, first name, email address, telephone
number, postal address, date of birth, account identifier

·        
-If applicable, identification data of additional driver(s): surname,
first name, email address, telephone number, postal address

·        
-Your driver’s licence and that of any additional driver(s);

·        
-Payment data: account numbers, card numbers, etc;

·        
-Financial data: your invoices;

·        
-As the case may be, data relating to traffic violations or other fines
and penalties;

·        
-Information about your flight in the event that the pickup location of
your vehicle is an airport;

·        
-Information on your vehicle reservation, in particular for the
management of any loyalty programs;

·        
-Data relating to your navigation on our website or our mobile
applications;

·        
-Data relating to your satisfaction surveys or from your interactions on
our dedicated social media pages;

·        
-Voice, audiovisual and electronic data: recordings of your
communications by email, chat or telephone with our customer service
department;

·        
-Information collected through our Connected Vehicle (if the vehicle
that you rent is a connected vehicle) : vehicle status, damage or accident
information, vehicle performance data, operational and diagnostic data, mileage
information, acceleration and braking speeds, fuel consumption and fuel levels,
tire pressure, odometer readings, vehicle location and other vehicle
information. For any information regarding the data processing of Easy Move’s
connected vehicles, please consult the dedicated Privacy Policy; and

·        
-Data related to cookies and other similar technologies. For information
on the use of cookies, please consult our policy.

We collect most of
your personal data directly from you, but we may receive data from third
parties, including the competent authorities in charge of managing fines for
traffic violations.

3. For what purposes do we process your Personal Data?

We collect and
process your Personal Data for various purposes and on the following legal
bases:

Purposes of the processing

Legal basis of the processing

The creation and
management of your customer account.

This processing
activity is based on the acceptance of the terms and conditions of use of our
website or our mobile applications.

The management of
your reservation and rental contract, in particular for:

– confirming,
modifying or cancelling your reservation;

– to communicate
with you regarding your reservation and rental (for example, to provide you
with information about your reservation and rental, to send you reminder
notifications before you return your vehicle, to answer your questions or
suggestions);

– manage your
rental;

– manage your
payment and invoices;

– manage the
collection of amounts due including costs such as fines for traffic
violations; damages to the vehicle, or compensation for damage to the
vehicle);

– managing any
claims;

– purchase and
manage insurance for your Vehicle.

These processing
activities are necessary for the execution of the rental services contract
that you enter into with us.

You can choose to
register your credit card for your future bookings.

i.       
The checking of your driver’s license

ii.       
This validation can be carried out (i) manually by our customer
service department or (ii) using a facial recognition device.

(i) This
processing is necessary for the performance of the rental services contract
that you enter into with us.

(ii) The use of
the facial recognition solution is based on your consent.

Fight against
credit card fraud.

This processing
is based on our legitimate interest in protecting ourselves against credit
card fraud.

Fight against
Fraud and other Criminal Activity

We may obtain
information about you from credit reference agencies and fraud prevention
agencies to assess creditworthiness and prevent fraud and other criminal
activity. This information may include a search that will appear on your
credit report and be visible to other credit providers. Please see section 3
for further details of the agencies and databases we access or contribute to
and how this information may be used. Further information is available on request.

This processing
is based on our legitimate interest in protecting ourselves against fraud and
other criminal activity relating to the rental and use of our vehicles.

Conducting
satisfaction surveys to improve your experience with our products / services.

This processing
is based on our legitimate interest to have a better knowledge of its
customers’ needs and to improve its services and customer service.

Chatting in real
time on our website.

This processing
is based on our legitimate interest in answering users’ questions about our
products and services.

Conducting
business development and marketing activities, including:

i- sending emails
and SMS notifications about special offers and promotions;

ii- recording
your rental history to suggest our products and services to you when you
search for new bookings or to send you special offers and benefits;

iii- managing
your loyalty program and membership card;

iv- organizing
contests and prize draws;

v – sending
emails about a booking we have not completed or about the status of your
booking requests;

vi – the
management and updating of the prospect database.

Our commercial
and marketing activities, i.e. the sending of commercial messages to promote
our products and services (i to iv) are subject to your consent.

In the event that
you are already our customer, you may receive commercial messages for
products and services similar to those we have already provided to you.

The sending of
these messages will be based on our legitimate interest in communicating about
our products and services.

Processing
activities included in category (v) are based on our legitimate interest to
simplify and speed up the reservation process for our customers.

Processing
activities included in category (vi) are based on our legitimate interest to
manage our prospect database.

The management of
fines and penalties, in particular for:

– the transfer of
information to the police or other enforcement agencies or issuing
authorities to enable them to identify the driver (or potential driver) of
our vehicle in the event of a driving offence or suspected driving offence;

This processing
activity is based on our legal obligations, in particular our obligation
under legislation such as the Road Traffic Act 1988 and other similar
legislation.

The management
and maintenance of a list of customers representing certain risks to our
business and/or staff, with regard to:

– payment
incidents resulting in legal proceedings;

– traffic
accidents or repeated damage;

– inappropriate
or abusive conduct towards our employees or our customers;

– the use of our
vehicles in violation of the general rental conditions including the use of
our vehicles for criminal or alleged criminal activity.

This processing
activity is based on our legitimate interest, in particular our interest in
asserting our rights, to prevent risks and fraud related to the execution of
your contract and to prevent and manage abusive behavior towards our
employees.

In this respect,
we seek to maintain a fair balance between the need to process your Personal
Data and respect for your rights and freedoms, in particular the protection
of privacy. If you appear on this list of at-risk customers, your reservation
request will be rejected. You may challenge this decision by sending an email
to the following address: info@EasyMove.com

Video
surveillance on our premises.

This processing
activity is based on our legitimate interest in ensuring the safety of
property and persons in our stations, by a deterrent effect or in such a way
as to be able to identify the perpetrators of damage, theft or aggression.

Analysis of
navigation data on our website and mobile applications.

This processing
is based on our legitimate interest in improving our products and services.


4. Who are the recipients of your Personal Data?

4.1. Categories of recipients

If necessary, your
personal data may be communicated:

a. to our
employees, our authorized representatives, other companies within our Group and
our franchise network, our agents and intermediaries mandated to provide you
with our products and services;

b. to our
subcontractors, in particular our IT service providers for hosting, maintenance
or development purposes, who assist us in providing you with our products and
services or collection agencies which help us recover unpaid orders or to
authenticate  These may be entities that are members of our Group or
external service providers;

c. to our insurance
services companies to purchase and manage insurance for your vehicle;

d. advertising
agencies, marketing agencies, social networking and digital agencies to help us
carry out advertising, marketing and sales campaigns and to analyze the
effectiveness of these campaigns;

e. to law
enforcement bodies (and their foreign counterparts in the case of offences
committed abroad) and other public and private sector bodies for the purposes
of dealing with alleged or actual road traffic or driving offences and/or
associated fines; and private parking companies dealing with alleged or actual
breaches of contract;

f. for the
management and updating of the list of persons presenting certain contractual
risks, to the vehicle rental industry generally and its staff.

g. to companies
providing operational support to our business including authentication of you,
your driving licence and driving history (including but not limited to the DVLA
and  Synectics Solutions Limited);

h. to our partners or
those of our Group, in particular to enable you to collect loyalty points when
you are a member of their program:

Use of Facebook

All Facebook
features and services available on our website or applications are governed by
the Facebook Privacy Policy, which you can read for more information about your
rights and settings options.

By using one of our
website/applications, you can:

– Use Facebook
social plug-ins, such as “like” or “share” our content on
the Facebook Platform;

– Accept cookies
from our website or applications (also known as “Facebook Pixel”),
which will help us understand your activities, including information about your
device, how you use our services, the purchases you make, and the ads you view,
whether or not you have a Facebook account or are logged in to Facebook.

When you use these
Facebook features, we collect data that helps us to:

– Display ads that
may be of interest to you on Facebook (or Instagram, Messenger or any other
Facebook service);

– Measure and
analyze the effectiveness of our website

4.2. International transfers

In order to provide
you with our products and services, we may use service providers located
outside the European Union (in particular in the United States, Morocco and
Israel). In the event that the vehicle is booked abroad, data transfers will be
carried out in the country in question in order to provide you with our
mobility solutions.

Depending on the
assumptions, some recipients may be located in countries recognized by the
European Commission as providing an adequate level of protection of personal
data or in countries that have not been recognized by the European Commission
as providing such a level of protection. In any case, we have implemented
appropriate protection measures to protect your personal data in accordance
with data protection regulations.

For more
information about the countries to which your personal data may be transferred,
their level of data protection and the potential protective measures
implemented by EC, click here.

5. How long do we keep your Personal Data?

Your personal data
are kept for different periods of time, depending on the purposes of the
processing concerned:

Purposes of the processing

Data retention periods

The creation and
management of your customer account.

For the duration
of the business relationship and 5 years after the end of the business
relationship.

The processing of
your reservation and rental contract, in particular for:

– Confirming,
modifying or cancelling your reservation;

– Communicate
with you regarding your reservation and rental (for example, to provide you
with information about your reservation and rental, to send you reminder
notifications before you return your vehicle, to answer your questions or
suggestions);

– manage your
rental;

– manage your
payment and invoices;

– manage the
collection of sums due (including subsequent costs such as fines for traffic
violations, or compensation for damage to the vehicle);

– managing
claims;

– taking out and
managing your vehicle insurance.

For 5 years after
the end of the reservation. 

Monitoring of
connected vehicles.

The data are kept
for a period of 12 months. In the event of damage or offences against
property, investigation of damage and accidents caused to the vehicle,
personal data may be retained until the cases are resolved (including until
the closure of any legal or judicial proceedings).

Verifying your
identity and to carry out credit and fraud prevention checks prior to
releasing a vehicle to you at the start of the rental and where subsequently
required.

13 months from
the effective payment

Fight against
Fraud and other criminal activity.

For the duration
for which the risk exists which may in some cases be indefinitely where fraud
or criminal activity has been identified. Where no fraud or criminal activity
is identified the data is subject to the retention periods as set out in this
section 5.

The improvement
of our products and services according to your preferences by carrying out
satisfaction surveys.

3 years from our
last contact.

Chatting in real
time on our website.

3 years from our
last commercial contact.

Conducting
business development and marketing activities, including:

Sending emails
and SMS notifications about special offers and promotions;

Recording your
rental history to suggest products/services to you when searching for new
bookings or to send you special offers and benefits;

sending emails
relating to a booking that we have not completed or reporting the status of
your booking requests;

managing your
loyalty program and membership card;

organizing
contests and prize draws;

the management
and updating of the prospect database.

– if you are a Easy
Move customer, 3 years from the end of the business relationship with EC.

– If you are not
a Easy Move customer, 3 years from the collection of your personal data OR
from the last time you requested information from us.

The management of
fines, in particular for:

-the transfer of
information to the police or other enforcement agencies or issuing
authorities to enable them to identify the driver (or potential driver) of
our vehicle in the event of a driving offence or suspected driving offence;

For the time
necessary to identify the driver responsible for committing the offence
giving rise to the contravention, which should not exceed 45 days from
receipt of the contravention. However, relevant information may be retained
for a longer period of time from the receipt of the request, for reasons of
archiving.

The management
and maintenance of a list of customers representing certain risks to our
business and/or staff, with regard to:

– payment
incidents resulting in legal proceedings;

– traffic
accidents or repeated damage

– inappropriate
or abusive conduct towards our employees or our customers;

– the use of our
vehicles in violation of the general rental conditions including the use of
our vehicles for criminal or alleged criminal activity.

 3 or 5
years from the date of creation or modification of the last rental and
depending on the nature of the event.

Video
surveillance on our premises.

No more than a
month.

Analysis of
navigation data on our website and mobile applications.

Please, refer to
our Cookie Policy  https://www.Easy Move.co.uk/cookie-policy


6. What rights can you exercise regarding the processing of your
Personal Data?

Within the limits
and conditions allowed by the regulations in force, you can:

– access to
your Personal Data and obtain further information on the characteristics of the
processing we carry out;

– have your
Personal Data corrected, updated and deleted, it being specified
that deletion can only be carried out when (i) the data is no longer necessary
in relation to the purposes for which it was processed, (ii) you withdraw your
consent and there is no other legal basis for the processing, (iii) you object to
the processing of your personal data and there is no compelling legitimate
reason for the processing (iv) it has been established that your personal data
has been processed unlawfully, (v) the personal data must be deleted in order
to comply with one of our legal obligations

– you object to
the processing of your Personal Data based on legitimate interest, which you
can check by taking a look the table shown in the part “For what purposes do we
process your Personal Data” and in particular the column “Legal basis of the
processing”

– you object to
the processing of your Personal Data for commercial prospecting purposes

– receive the
personal data you have provided us with or request us to pass them on to a
third party when the processing of your personal data (i) has been carried out
by automated means and (ii) is based on your consent or on the execution of a
contract binding us

– request
the limitation of the processing of your Personal Data, which means
that we will not be able to use your Personal Data for a defined period of
time. You can exercise this right when:

a) you dispute the
accuracy of your personal data for a period of time that allows us to verify
the accuracy of your personal data;

b) the processing
of personal data is unlawful and you object to the deletion of your personal
data and instead demand that its use be restricted;

c) we no longer
need your Personal Data but they are still required for the establishment,
exercise or defence of legal claims;

d) you object to
the processing for reasons relating to your particular situation, while we are
checking whether the legitimate reasons pursued by Easy Move Limited  take
precedence over your own.

– withdrawing
your consent to treatment based on your consent

– submit a
complaint to a Supervisory Authority. In England, the Supervisory
Authority is the Information Commissioner’s office at ico.org.uk.

7. How do you exercise your rights?

If you would like
to know more about the provisions of this privacy policy or to contact our Data
Protection Officer, you can also write to us at the following address

El Salam Road Villa
604/3,street #3 Diar El Rabowa Beside Bridgestone, South Sinai Governorate
46619, Egypt

To exercise your
rights, you must prove your identity by clearly indicating your surname, first
names, driver ID and any useful information enabling us to identify you (such
as the place and date of your last vehicle rental). You must also give us the
e-mail address or the physical address to which you would like the reply to be
sent to you.

8. How do we protect your Personal Data?

Easy Move Limited
is committed to protecting the information it collects through this website.

In particular, ECI
uses appropriate physical, technical and organizational security measures to
prevent unauthorized or unlawful processing, accidental loss of or destruction
of or damage to your personal data.

Easy Move Limited’s
systems are configured with data encryption, or scrambling technologies, and
industry-standard firewalls. When you send personal information to a Easy Move
Limited website over the Internet, your data is protected by “Transport
Layer Security” (TLS) technology to ensure safe transmission.

Any credit card
transaction you make through Easy Move Limited websites is done through our
secure server technology. This technology notably: 

a) assures your
browser that your data is being sent to the correct computer server, and that
the server is secure; 

b) encodes the
data, so that it cannot be read by anyone other than the secure server; 

c) checks the data
being transferred to ensure it has not been altered. 

9. What rules apply to the processing of your Personal Data when you
click on links placed on our website, redirecting to our partner’s or other
sites?

On this site you
will find various links to the websites of our partners (e.g. for travel
services). We would like to draw your attention to the fact that this Privacy
Policy does not apply to the processing of your Personal Data by our partners
or other third parties, which may occur when you visit their websites, and that
we are not responsible for such data processing. If you would like information
on how these partners and third parties process your personal data, we invite
you to consult their Privacy Policies.