This policy was last updated on April 20, 2020.
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 website and/or our mobile application (or “app”). We collect the following types of personal information from you:
- Your name, gender, contact information, date of birth, driver’s license information, number and expiration date, language preference, and emergency contact information;
- Vehicle rental information, including the location of where the vehicle is rented, date of rental, type of rental and your preferences;
- Your credit card details, online user account details, customer membership/corporate ID numbers, passport information, business name and contact information (if applicable) and school affiliation (if applicable);
- Information you provide regarding your marketing preferences or in the course of participating in surveys or promotional offers;
- Photographs you submit of you and your driver’s license including your invoice receipts, if applicable, through camera features that may be available on our mobile application and/or website; and
- Information about relevant health conditions you have that assist us in providing you with adaptive driving devices.
Third parties provide us with additional information about you, including:
- Background check companies who provide us with information about your driving/motor vehicle record and driver’s license status.
- Identity verification companies who provide us with information about you in order for us to verify your identity.
- Service Providers, such as customer support (customer service-related information and enquiries made by you), customer survey providers (your response to our customer service surveys) and marketing providers (information to assist us to better communicate our products and services or the products or services of our affiliates).
We will access location-based information of the vehicle from hardware retrofitted in the vehicle. We will use this information solely to enable you to locate an available vehicle or to provide you with other information that we think will be helpful in providing you with better services. We are only able to identify you using the location-based information allowing you to locate the vehicle if you log into our mobile application.
With your consent, our app will utilize your device’s camera but only during the application registration process when you are required to take a selfie photograph which we then match against the picture displayed on your driver’s license and also prior to a trip if you wish to report damage or other issue with the rental vehicle prior to trip initiation. 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.
We are not responsible for any data that is left in the vehicle 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.
Telematics data may be shared as needed with law enforcement, emergency service providers, and others who assist in responding to an accident or incident, telematics service operators and/or those with whom we have a legal or contractual obligation to provide such data.
Our website, app and online marketing are not directed to and MoceanLab does not knowingly collect personal information from children under the age of 18. 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 by emailing us firstname.lastname@example.org or by calling us at 833-MoceanLab1 or 833-662-3261.
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
- To assist the transactions that you request, such as reserving and renting motor vehicles.
- To provide customer service related to your interactions with us or to respond to your enquiry.
- Where necessary for us to comply with a legal obligation, including
- To share information about your vehicle’s location with emergency services in the event that you are involved in a road accident.
- 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
- To communicate important information about your rental. These communications, which are transactional in nature, will be sent to you via email, SMS or calls.
- 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 website, app and services.
- To compile statistics and analysis about our customers’ use of our websites, products and services. These statistics are used only to enable us to provide better customer service, products, features and functionality to you and other customers in the future.
- To develop a profile of you and your interactions with us so that we can provide tailored offers, opportunities and services that may be of interest to you.
- To protect our legal rights and manage the security of our networks and property, including to protect our website and app from spam and abuse.
- 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.
- 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 terms and conditions. We will also disclose your information to third parties if the rights of another individual may be violated.
- To enable us to use vehicle data systems for purposes listed in the Vehicle Data section above.
- To assist us in providing you with the most appropriate vehicles, such as those with adaptive driving devices. In some cases, this will require us to infer or explicitly collect information about your health or physical condition.
- To send you certain promotional or targeted marketing communications, opportunities and services from us or our Affiliates that may be of interest to you.
- To send you text messages in order to provide you with time sensitive communications related to your transaction, extended rental opportunities, customer experience surveys, marketing promotions such as coupons, discounts, or last-minute specials.
We will not use the information collected from you for any purpose that is materially different from the purpose(s) disclosed.
Security of Your Personal Information
We make reasonable efforts to ensure a level of security appropriate to the risk associated with the processing of your personal information. We maintain organizational, technical and administrative measures designed to protect your personal information within our organization against unauthorized access, distribution, loss, alteration or misuse. Whenever we share your personal information with others, we also insist that they do the same. Your personal information is also only accessible to a limited number of personnel who need access to the information in order to perform their duties and when we share with or receive personal information about you from others all data transmissions are encrypted. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of your account has been compromised), please contact us immediately by email at email@example.com or by calling us at 833-MoceanLab1 or 833-662-3261.
Your user registration information is password-protected. You may edit your user registration information by using your user name, email address and password. We strongly recommend that you do not divulge your password to anyone and when you register with us, we provide you with instructions on how to select a strong password. You may change your password at any time and all password resets are communicated to you using only the email address that you submitted to us. Also, remember to sign out of your registration account and close your browser whenever you have finished your browser session.
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:
- Marketing purposes: We keep data linked to cookies and other online identifiers up to three years.
- Rental transactions: We keep the data associated to your rental agreement for up to seven years from the date of the rental, subject to other local legal requirements. We keep records of payments you have made for two years from the date of the transaction.
- Customer service related queries: We keep general queries for three years, unless you make a complaint, in which case, we keep complaints data for seven years.
- Disputes & law enforcement: If we are involved in litigation or a governmental or regulatory investigation, then we keep data throughout the period of litigation or investigation and for five years after that. If a settlement means that we have to keep data for longer, then we keep data for the period required to administer the settlement. If we provide data to law enforcement agencies, then we keep a record of this for two year(s) beyond the end of the investigation.
- Your Right to Know or Right to Delete Personal Information Requests: We keep a record of your right to know or right to delete personal information requests that you send us for two years and we do not share these records with any third party unless it is legally necessary for us to do so. (applicable only to California residents)
Who We Share Information With
Our Service Providers And Business Partners
We will share your information with trustworthy third parties, such as (1) payment, administrative, insurance and technical support providers, corporate rental or other customers or partners to facilitate the rental transaction and/or to maintain our vehicle fleet, (2) companies who conduct customer background, identification, verification and other research or satisfaction surveys on our behalf, (3) communication providers which send email and other marketing and service-related communications to you on our behalf, (4) customer support providers, such as the provider of our live chat feature, in order to provide you customer service, (5) debt collection providers, (6) claims processors, (7) analytics and technology providers for location-based services and to analyze, enhance and manage our data in order to provide, maintain, and improve our services, and (8) our advertising and marketing partners and third-party media properties, including social media sites, if any, with whom we may share aggregated or de-identified information about our customers, to allow them to send targeted advertising messages on our behalf (subject to confidentiality agreements as appropriate).
Please note that all of your credit card payment information is handled, stored and processed by our payment processor in accordance with payment card industry data security standards. We do not store, process or transmit any cardholder data on our systems and we rely entirely on our payment service provider to handle these functions.
Your personal information may also be shared as needed with government authorities for law enforcement, emergency service providers and other government authorities who assist in investigating and/or responding to an accident or incident. Aggregated information may be shared with government authorities as outlined above, including the Los Angeles Department of Transportation and LA Metro for the procurement of future permits or as otherwise required by local city reporting requirements.
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 MoceanLab’s business 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 via email or prominent notice on our website for thirty (30) days of any such change in ownership or control of your personal information or as otherwise may be required or permitted by law.
We may post customer testimonials on our website which may contain personal information. We use a third-party provider to manage this process. This provider is responsible for obtaining your consent as necessary, removing content upon your request and answering any questions you may have.
Selling Your Personal Information
We do not sell to or share with others your personal information to any third party for monetary compensation or for other valuable consideration. We do not sell to or share with others your personal information to any third party for monetary compensation or for other valuable consideration.
International Data Transfers And Processing
In order for us to operate and provide you services, the information you provide us or that we collect may be transferred or accessed by other entities located outside the United States of America, including:
- Affiliates: Some of our Hyundai corporate family of affiliates are located abroad. Please refer to our Affiliates section under Who We Share Information With.
- Third Party Service Providers: We utilize trustworthy third party service providers some of whom are located or have operations outside the United States of America, for such services as payment processing, call center support, claims processors and IT providers.
Other rights you have may include: 1) accessing and asking for a copy of your personal information, 2) to correct it, and 3) to delete certain categories or types of information.
Please note that under California law, as applicable to California residents, your personal information includes any information that can be reasonably linked directly or indirectly to a particular consumer or particular household.
If you have a complaint, you may also contact the Complaint Assistance Unit of the Division of Consumer Services of the California Department of Consumer Affairs in writing at 1625 North Market Blvd., Sacramento, CA 95834, or by telephone at (916) 445-1254 or (800) 952-5210.
If you are a California resident, effective January 1, 2020, you are now afforded additional rights under the California Consumer Privacy Act (CCPA). Under the CCPA, California residents are afforded the right to contact us and submit to us a request to know any or all of the following:
- Specific pieces of personal information that we have about you
- The categories of personal information we have collected about you
- The categories of sources from which personal information about you was collected
- The categories of personal information about you that we sold or disclosed for a business purpose
- The categories of third parties to whom the personal information about you were sold or disclosed for a business purpose; and
- The business or commercial purpose for collecting or selling personal information about you
As a California resident, you are also afforded
- the right to have your personal information deleted or transferred to a designated third party;
- the right to opt-out of any sale of your personal information to a third party; and
- the right not to be discriminated against should you exercise any of your CCPA rights.
If you are a California resident, you or your legally authorized agent acting on your behalf may submit your personal information requests by emailing us at firstname.lastname@example.org or by calling us at the following toll free number: 833-MoceanLab1 or 833-662-3261. Please note that when receiving your requests we have the obligation and right to use reasonable means to verify your identity when processing your request. We perform this verification procedure at no cost to you or your legally authorized agent. Upon receiving your verified request, we will confirm receipt of the request within 10 business days and we will provide a substantive response within 45 calendar days. Please note that because we have no plans to sell your personal information to a third party, your right to opt-out of a selling of your personal information is not applicable.
We also reserve the right not to respond to or to deny a request to know or a request to allow access to or deletion of your information or to limit your rights under certain circumstances (e.g. if the request poses an unreasonable risk, we are lawfully entitled to do so, we are lawfully entitled to maintain an archive copy of your information despite a request to delete, if it is necessary to detect security incidents or if the rights of another individual might be violated, or if the request requires that we or our service provider undertake a search or provide an accessible format when the information that is the subject of the request does not lend itself to a search or does not lend itself to the format being requested by the individual making the request). In some instances, this may mean that we and our service provider(s) are able to retain your personal information even if you withdraw your consent or if a California resident, we and our service provider(s) can maintain an archive copy of your personal information on a backup system notwithstanding a request to delete your personal information. Moreover, we have the legal obligation not to transmit to you or others certain information deemed highly sensitive (assuming that we even have such information) but we should always be able to provide you with information about whether we have such highly sensitive information about you.
Please also do not submit personal information requests to any of our service providers directly because unlike us, they are not required to respond to personal information requests that they may receive directly from our consumers.
Requesting Information About Third Parties
California Civil Code section 1798.83 entitles residents of California to request information about the third parties with whom MoceanLab has shared personal information in the immediately preceding calendar year and if those third parties ever used such information for direct marketing purposes. California residents may submit one request per calendar year in the form of a report that details (a) the categories of information MoceanLab shared and (b) the name and address of the third parties with whom MoceanLab shared such information. California residents may submit their request by contacting us by email at: email@example.com.
Changes To These Policies
This policy was last updated on October 31st, 2019.
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