SAFETY POLICY AND DATA PROTECTION

Through this document (hereinafter, "Privacy and Cookies Policy"), the privacy and cookies policy of the websites http://www.autoreisen.es/, http://www.autoreisen.com/ and http://www.arcarhire.com (hereinafter, the "Portals") is regulated under the ownership of Special Prices Auto Reisen, S.L (hereinafter, "AUTOREISEN"), a company situated in Calle San Francisco, 5, Edificio Santander Planta 8º 38002 Santa Cruz de Tenerife and with Tax Identification Number (CIF) B38086500, which makes this information available to the user(s) of the Portals (hereinafter, "the users"). The contact email address is: datospersonales@autoreisen.es.

This Privacy and Cookies Policy will be translated into several languages in the development of the activity of AUTOREISEN and its corporate quality policy, services and customer support. Notwithstanding the foregoing, in the event of any dispute regarding the interpretation or implementation of the conditions contained in this policy, the parties agree that the Spanish version of the Privacy and Cookies Policy shall prevail over any other language version for all legal purposes.

1. DUTY OF INFORMATION AND TRANSPARENCY.

In this regard, AUTOREISEN informs the users of the Portals that, pursuant to article 5 of the Organic Law 15/1999, of December 13, on the Protection of Personal Data (hereinafter, LOPD), this entity holds personal data files, properly notified and/or registered with the Spanish Agency for the Protection of Personal Data (AEPD), regarding users and/or interested parties who, freely and voluntarily, want to provide them in order to allow an effective access to contents, provide services or develop the requested actions, and that are made available to them through these Portals. Particularly, their data will be included in the "Web Users File" with the main purpose of managing requests for information, reservations and car rentals made through the Portals, as well as sending advertising to those interested in possible offers and specific commercial promotions on such services. Once web users hire the services of AUTOREISEN, their personal data are also included in the "Customers File" in order to comprehensively manage the contractual relationship between the parties. The information on these files can be extended through the official website of the AEPD, Registered Files section, by accessing the link www.agpd.es.

Unless specifically stated otherwise, it will considered necessary to complete all data indicated as mandatory in the various forms that are made available through the Portals. If the data deemed necessary or compulsory are not provided, AUTOREISEN may freely decide not to register the user, where appropriate, or deny access to contents, services or activities provided by this company through the said Portals.

The user shall fill in the forms provided through the Portals with true, accurate, complete and updated data, responding to the damages that may be caused to AUTOREISEN or to third parties as a result of failure to comply with such aspect. It is recalled that this update is important in terms of compliance with the principle of data quality (article 4 of the LOPD.).

Finally, the user or person who legally or voluntarily represents him/her may exercise at any time his/her right of access, rectification, cancellation and opposition (ARCO rights), in accordance with the provisions of the LOPD and its implementing regulations, that is, Royal Decree 1720/2007, of December 21, approving the implementing regulations of the LOPD (RLOPD). If you so want, you can send us your request to exercise your personal rights to the email address datospersonales@autoreisen.es in order to process them properly according to the applicable regulations.

Notwithstanding the foregoing, AUTOREISEN will take all appropriate measures to provide the interested party will all the necessary information under the principle of transparency.

2. CONSENT OF THE INTERESTED PARTY.

The recording of the personal data of users by using the electronic forms provided through the Portals or, where appropriate, by sending emails, or any other electronic and/or telematic means or not to AUTOREISEN shall include the user's explicit consent to process his personal data. AUTOREISEN may contact the user, interested party or person affected for him/her to declare, clarify or specify such consent in line with the previous information transmitted by AUTOREISEN. All this in accordance with the applicable regulations.

3. PROCESSING OF PERSONAL DATA FROM MINORS.

In general, the Portals are not intended for minors, so that their access and use, including the services and contents provided through them, is prohibited to those, unless they have authorization and express prior consent from their legal representatives and the necessary legal capacity is held for these purposes. The legal representatives of minor will be considered, in any case, as fully responsible for the acts carried out by the minors in their care as provided by current legislation.

AUTOREISEN will obtain the unequivocal consent of the users of the Portals to the processing of their data. In the case of minors over fourteen years old, the processing of data may be carried out with their consent, except in those cases where the law requires the assistance of their legal representatives as provided for in article 13 of RLOPD. In the event of minors under fourteen years old, the consent of their legal representative will be always required.

Legal representatives of minors will always decide in the best interest of the child, a guiding principle which also applies to AUTOREISEN in its specific activity, which could also reject the access of a minor to the Portals or to any of its services or contents, even with the authorization or appropriate parental or legal consent. Similarly, despite such authorization or consent, AUTOREISEN reserves the right to prevent such access or use of the Portals, services or contents by virtue of the lack of legal capacity of sufficient judgment of the minor in accordance with the provisions of the Spanish legislation.

In those cases, AUTOREISEN will coordinate the necessary procedures to ensure that the age of the child and the authenticity of the consent given by parents, guardians or legal representatives have been effectively verified (art. 13.4 RLOPD).

4. SAFETY.

AUTOREISEN has adopted and apply safety protection levels required by law regarding your personal data, in accordance with the appropriate safety standards detected, and tries to install and/or apply other means and technical or organizational additional protection measures to strengthen the general safety of files containing personal data, systems, communications and corporate organization. However, the user should be aware that safety measures in Internet are not impregnable in any way. For these purposes safety measures and other obligations associated with the new European General Data Protection Regulation (hereinafter, GDPR) will be specially considered:
http://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32016R0679&from=ES

In the event of personal data breach, the procedure included in the GDPR will be complied with.

5. DUTY OF SECRECY AND CONFIDENTIALITY.

AUTOREISEN undertakes to fulfill the duty of secrecy and confidentiality regarding the personal data contained in the personal data files under its responsibility, in accordance with the legally enforceable legislation at all times.

6. COOKIES POLICY.

6.1. Applicable regulations.

Article 22 of Law 34/2002, of July 31, on the information society services and electronic commerce (LSSICE), concerning the rights of recipients in business communications by electronic means, provides that service providers may only use data storage and retrieval devices in recipients' terminal equipments when they have given their prior informed consent.

For that purpose, these recipients and end-users should be provided with clear and complete information on their use, particularly, on the purposes of the processing of data, in accordance with the provisions of the LOPD. When it is technically possible and effective, the consent of the recipient to accept the processing of data may be provided by using the appropriate settings of the browser or other applications.

This shall not prevent any technical storage or access for the sole purpose of carrying out the transmission of a communication by an electronic communications network or, to the extent strictly necessary, for the provision of an information society service expressly requested by the recipient.

6.2. User consent and cookies: general rule and exception.

In general, when the installation and/or use of cookies involves the processing of personal data, whether we use own or third-party cookies and whether they are temporary or permanent, prior informed consent of the user to install and/or use them should be requested by the people responsible. Therefore, both obligations must be fulfilled: the duty of information and obtaining the consent of the user.

The only exceptions will be those cookies that exclusively allow communication between the user's equipment and the network and, strictly, those used to provide a service requested by the user. For example, the so-called "technical cookies" (e.g. those necessary by the platform or application for the same navigation); the "customization or configuration cookies" (e.g. allowing the page to recognize the user's language, etc.) and the "safety cookies" (e.g. detecting repeated and failed attempts to connect to a site) would be excluded.

6.3. Integrated legal policies.

In light of the above, the cookies policy is complemented and jointly integrated with the privacy policy of Portals.

6.4. Are cookies used on these Portals? What are they?

So far cookies are neither used nor served in the Portals, that is, files or devices downloaded to the user's terminal equipment (a personal computer, a smartphone, a tablet, etc.), regardless of their nature and with the purpose of storing data, that may be updated and retrieved by the entity responsible for their installation.

Cookies allow navigation through these Portals, as well as certain uses and services thereof, so that we warn you that disabling or blocking them may affect the use thereof as well as the aforementioned uses and services arranged through them.

6.5. What cookies do we use in the Portals?

So far cookies are neither used nor served in the Portals, which does not prevent from doing it later on by AUTOREISEN.

Cookies may be ours or from third parties. Our own cookies are those sent to the user's terminal from AUTOREISEN (editor), being managed by them, while third-party cookies are those sent to the user's terminal from other domains or equipments not managed by AUTOREISEN (editor), but by other entity that manages the data obtained through cookies.

Likewise, the previous cookies may be temporary or permanent. The first ones are a type of cookies designed to collect and store data while the user accesses the Portals with the main purpose of storing information for the provision of the service requested by the user on a single occasion. However, with the second ones data are still stored on the user's terminal and they may be accessed and managed during a period defined by the person responsible for the cookie.

Cookies may also be technical by allowing the user to navigate through the Portals and use the different options or services provided through them, for example, monitor traffic and data communication, identify the session, access restricted areas, remember the elements of a contractual request, use safety features during navigation, store contents to broadcast videos or sound or share contents through social networks.

Cookies may also be customized, that is, those cookies allowing the user to access the service with some predefined features based on certain criteria associated with their own terminal, for example, the type of browser through which you access the service, the local configuration from which you access the service, etc.

Our cookies can be analytical, that is, those cookies allowing the person responsible therefor to monitor and analyze the behaviour of the websites' users to which they are linked. The information gathered through this type of cookies is used to measure the activity of Portals and to create navigation profiles of users in order to make improvements based on the analysis of the use of data by the service users.

6.6. Who uses cookies?

The information that would be collected through the portal cookies (in the event that they are served later on) could be used by AUTOREISEN.

6.7. Management and configuration of cookies.

From the information provided in this policy, and in the event that cookies are served later on, we inform you that you could manage their use through the browser installed on your terminal highlighting the following options:

      * Google Chrome:
      https://support.google.com/accounts/answer/61416?hl=en

      * Mozilla Firefox:
      https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences

      * Microsoft Internet Explorer:
      https://support.microsoft.com/en-us/help/17442/windows-internet-explorer-delete-manage-cookies

      * Safari:
      https://support.apple.com/kb/PH21411?viewlocale=en_US&locale=es_ES

6.7.1. Visualization and management of cookies.

All browsers offers users the possibility of searching, viewing and managing cookies installed on a particular website and obtain information regarding the duration thereof and how to remove/block them, as indicated in the following section. Then a series of information links regarding the most popular browsers is shown:

      * Google Chrome:
      https://support.google.com/accounts/answer/61416?hl=en

      * Mozilla Firefox:
      https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences

      * Microsoft Internet Explorer:
      https://support.microsoft.com/en-us/help/17442/windows-internet-explorer-delete-manage-cookies

      * Safari:
      https://support.apple.com/kb/PH21411?viewlocale=en_US&locale=es_ES

6.7.2. Blocking and deletion of cookies.

If the users wants to disable, restrict, block or delete cookies, they shall modify the browser settings used in their terminal. Different browsers offer various configuration options regarding the installation of cookies, for example:

• That the browser rejects all cookies and, therefore, no cookie from any website is installed in your terminal.
• That the browser warns you before the installation of the cookie takes place so that you decide whether or not to accept the installation thereof.
• That the browser only rejects third-party cookies from websites you visit but not those in use by the website you surf.

For the aforementioned purposes, the following information links regarding the main browsers can be visited:

      * Google Chrome:
      https://support.google.com/accounts/answer/61416?hl=en

      * Mozilla Firefox:
      https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences

      * Microsoft Internet Explorer:
      https://support.microsoft.com/en-us/help/17442/windows-internet-explorer-delete-manage-cookies

      * Safari:
      https://support.apple.com/kb/PH21411?viewlocale=en_US&locale=es_ES

6.8. Update of our Cookies Policy.

AUTOREISEN reserves the right to modify this Cookies Policy at any time in order to match the performance of the company at all times and future legislative, doctrinal or case-law developments that may be applicable or recommended, previously and reasonably informing users where possible. In any case, we recommend you that each time you access the Portals, you carefully read this privacy and cookies policy. If there is any query or dispute regarding our privacy and cookies policy, users can contact AUTOREISEN through the email address: datospersonales@autoreisen.es

6.9. More information of interest.

For more information, we recommend you to read the following additional documentation:

- Guide of the Spanish Data Protection Agency (AEPD) regarding the use of Cookies: http://www.agpd.es/portalwebAGPD/canaldocumentacion/publicaciones/common/Guias/Guia_Cookies.pdf
- Ruling 4/2012 of the Data Protection Group, Article 29, on the exemption from the requirement of cookie consent and Working Document 02/2013 providing guidance on how to apply for consent to the user in the event of when serving cookies, respectively:
http://ec.europa.eu/justice/data-protection/article-29/documentation/opinion-recommendation/files/2012/wp194_en.pdf y http://ec.europa.eu/justice/data-protection/article-29/documentation/opinion-recommendation/files/2013/wp208_en.pdf

7. MODIFICATION OF THE PRIVACY AND COOKIES POLICY.

AUTOREISEN reserves the right to modify this Privacy and Cookies Policy in order to match future regulatory or case-law developments that may be applicable. For this purpose, we recommend you that each time you access the Portals, you carefully read this policy. If there is any query or dispute regarding our privacy and cookies policy, the user can contact us through the email address: datospersonales@autoreisen.es.

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