Last Updated: January 1, 2020
scope of disclosures
This California Privacy Notice (the "CA Disclosures") supplements the information contained in our 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 the CCPA.
personal information disclosures
When we use the term "personal information" in these CA Disclosures, we 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.
- Deidentified, aggregated or anonymized information that is maintained in a form that is not capable of being associated with or linked to you.
- 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.
- Information relating to our job applicants, employees, contractors and other personnel of Zipcar, which is not governed by these CA Disclosures.
collection and use of personal information
We collect various categories of personal information in connection with our services. Please review the what personal information we collect and how we use it 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:
|Category of Personal Information Collected||Categories of Sources|
|Identifiers, such as your name, address, phone number, email address, date of birth, Zipcard number, passport information, driver's license information, or other similar identifiers.||
|California Customer Records (Cal. Civ. Code § 1798.80(e)), such as driver's license number, insurance information, passport number, credit card information, bank account information or other payment information.||
|Protected Classification Characteristics, such as age and gender.||
|Commercial Information, such as products or services purchased or considered and your use of the Zipcar services, including reservation details.||
|Biometric Information, such as facial geometry used for identity verification purposes.||
|Internet/Network Information, such as device information, log, and analytics data.||
|Geolocation Data, such as information about your physical location collected from geolocation features on your device, including your IP address and GPS (e.g. latitude and/or longitude).||
|Sensory Information, such as pictures of you and recordings of phone calls between you and us, where permitted by law.||
|Professional/Employment Information, including the business or organization you are associated with and, where applicable, your title with that business or organization and information relating to your role with the business or organization.||
|Other Personal Information that you provide to us directly or through a third-party service, including messages you send us through our services or on social media. This information could include the college or university you attend or are affiliated with, your driving records, claim information and driver behavior information.||
|Inferences, including information generated from your use of the Sites reflecting your preferences.||
Please note: In addition to the categories of sources identified above, we may collect information from publicly available sources and other third-party information providers in order to supplement the information we have otherwise collected.
purposes for collecting personal information
We collect, use, sell or disclose personal information about you for one or more of the purposes:
- To fulfill or meet the reason you provided the information, such as to create your account, process your transaction or respond to your inquiry.
- To communicate with you, including via email, text message, push notification and/or telephone calls.
- To operate, maintain, and provide to you the features and functionality of the services.
- To verify your identity, confirm the authenticity of your identity documents, and protect against fraud or misrepresentation.
- To market to you, including through email, direct mail, phone, push notification and/or text message.
- 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 website, third-party sites, or on other devices you may use.
- To recognize you and remember your information when you return to our Sites and services.
- To help maintain the safety, security, and integrity of our services, including our Zipcars, technology assets, users and business.
- For testing, 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.
disclosure of personal information
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, marketing and advertising services, and other similar services, subject to contractual terms restricting the collection, use and disclosure of your personal information.
- Third parties at your request. We share your personal information with third parties with your consent or at your direction.
- Businesses as needed to provide services. We may share personal information with third parties you engage with through our services, or as needed to fulfil your request or transaction, including, for example payment processing services.
- Our affiliate companies. We may share your personal information with other companies owned or controlled by Zipcar, and other companies owned by or under common ownership as Zipcar, 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) and any subsidiaries it owns;
- 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 Zipcar;
- 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;
- Primary account holders. If you sign up for Zipcar through an associated or affiliated primary account such as a business or university, we may share your information with the primary account holder.
- Other third parties. From time to time, we may disclose your personal information to third parties who use this information to market to you, to perform analytics and conduct research, or for other purposes, in accordance with their own privacy policies and terms.
- 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 the Sites 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 Zipcar’s assets, whether as a going concern or as part of a bankruptcy, liquidation, or similar proceeding, in which personal information held by Zipcar about consumers is among the assets transferred or is otherwise relevant to the evaluation, negotiation or conduct of the transaction.
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.
your california privacy rights
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 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).|
how to exercise your california consumer rights
to exercise your right to know or right to deletion
To exercise your Right to Know and/or your Right to Deletion, please submit a request by:
- Filling out and emailing CCPArequest@zipcar.com our California Resident Right to Delete Request Form and/or our California Resident Right to Know Request Form with the subject line "California Rights Request," or
- Calling 1-866-4ZIPCAR (1-866-494-7227).
We will need to verify your identity before processing your request, which may require us to request additional personal information from you or require you to log into your account. 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 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.
to exercise your right to opt out of personal information sales
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 may 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.
If you are a Zipcar member, please click here to login to your account. Once you have logged in to your account, please select the "Do Not Sell My Info" link in the footer of the website and follow the instructions provided in the pop-up window to be added to our Do Not Sell List. If you have set your browser to block or reject pop-ups, you may need to change your settings to allow the Do Not Sell pop-up to appear.
If you are not a Zipcar member, please follow the instructions set forth in the Third Party Tracking and Online Advertising section below. We do not otherwise “sell” personal information of non-members.
third party tracking and online advertising
We utilize third-party partners to engage in online advertising. These ad networks, social media companies and other third-party businesses collect your personal information directly from your browser or device through cookies or similar tracking technology when you visit or interact with our Sites, use our apps or otherwise engage with us online. These third parties use your personal information to serve relevant ads on our Sites, on other websites or mobile apps, or on other devices you may use, 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.
minors under age 16
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 CCPArequest@zipcar.com to inform us if you, or your minor child, are under the age of 16.
california's "shine the light" law
At the time of this writing, we do not provide your personal information to third parties for their direct marketing purposes, as described in California's "Shine the Light" law (Civil Code Section §1798.83). To opt-out of having your personal information disclosed to third parties for their direct marketing purposes in the future, Zipcar members can follow the instructions provided in the To Exercise Your Right to Opt Out of Personal Information Sales and non-members can email us their name and contact information at CCPArequest@zipcar.com with the subject line "Shine the Light Opt-Out".
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.
updates to these CA disclosures
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 send an email to firstname.lastname@example.org.
Alternatively, inquiries may be addressed to:
35 Thomson Place
Boston, Massachusetts 02210