We are Phoenix Motorhomes LLC, a U.S. company, which, together with our subsidiary company, in Canada Holiday Home Car LTD, provides and supports vehicle rental and sales services.
We respect your privacy and are committed to protecting the personal data we hold about you. This policy explains what data we collect about you, how we collect it, the measures we take in our efforts to keep your data secure and the uses and disclosures we make of it. We also explain the options you have in relation to your personal data.
DATA WE COLLECT
We collect the personal data we need to provide the services you request from us, for our operational uses and disclosures (see below) or for such other purposes as you authorize.
We collect your data directly from you, through various channels, and from companies involved in our provision of services to you, including our licensees.
You may provide us with certain information in connection with a transaction or in your interactions with our websites and at our locations. When you are asked to provide personal information, you may decline. If you choose not to provide the information, you may not be able to use some products or services. The personal information we may collect includes:
- Your name, contact information, date of birth, driver’s license number and expiration date;
- Vehicle rental information, including the location of where the vehicle is rented, date of rental, type of rental;
- Your credit card details;
- Phoenix Motorhomes LLC online user account details;
- Information you provide regarding your marketing preferences or in the course of participating in surveys or promotional offers;
- Financial information that may be necessary to facilitate the purchase of a vehicle (Additional notices, if necessary, will be provided to you at the time of that transaction.)
- Additional contact information about you that we may obtain through third parties with whom we do business (e.g. travel agents, tour operators, rental lead providers or similar providers).
INFORMATION COLLECTED AND STORED AUTOMATICALLY
By visiting our websites, certain information may be automatically provided to us by your computer. For each visitor to our websites, our webservers automatically recognize the visitor’s domain name or IP address. An IP address is a number assigned to your computer when you connect to the Internet. As part of the protocol of the Internet, webservers can identify your computer by its IP address. In addition, we may collect your browser type and operating system as well as your internet service provider (ISP), referring and exit pages, date and time stamp, and/or clickstream data.
We collect similar information when visiting our websites with your mobile device, including mobile device brand, model, mobile operation system and carrier.
VEHICLE OPERATION AND LOCATION DATA
Our vehicles may be equipped with the manufacturer-provided or certain on-board technology such as OEM equipment (“On Board Technology”). Some or all on board functionality may or may not be active during rental periods. On Board Technology may provide us use of, disclosure of, or access to (1) crash data and, (2) operational condition, mileage, diagnostic and performance reporting of vehicles (“On Board Data”), as permitted by law.
HOW YOUR INFORMATION MAY BE SHARED
We may disclose the information we collect from and about you to our subsidiaries and Licensees for the purpose of providing the transactions you have requested and (with your consent) marketing purposes. In addition to those stated within this Policy, On Board Technology data from rental vehicles may be disclosed to, accessed by or used by Phoenix Motorhomes LLC, our subsidiaries, emergency service providers, insurance specialists and others who may assist in investigating an accident, service operators, or those with whom we have a legal or contractual obligation to provide such data. These lists are subject to change from time to time and you should periodically check the site for changes.
We also may disclose your information to other third parties:
- when required by law or in response to legal process;
- without legal process in response to a request from law enforcement relating to a criminal investigation;
- to protect our rights, privacy, safety or property, or of the public;
- for administrative or technical support or other business purposes to facilitate our transactions with you
- to analyze our data, conduct mobile analytics services, or to maintain and improve our services;
- to permit us to pursue available remedies or limit damage that we may sustain;
- to enforce the terms of any rental or sales agreement;
- to assist with the administration of fines, tolls (electronic or toll by plate), penalties, and collection
- Newsletters, Social Media Campaigns, Special Offers and Updates – We will occasionally send you information on products, services, special promotions, contests, customer satisfaction surveys, events, and opportunities to interact with Phoenix Motorhomes LLC and our community. You can sign up to receive these emails and social media campaigns from us on our newsletter sign up page and/or during checkout while renting a product;
- We may disclose your personal information to third-party service providers (such as a Point of Sale or payment processor to bill you for goods or services. These service providers may be located in a country different from your country of residence, such as the United States or Canada. These service providers are contractually required to maintain the confidentiality and security of your information. However, your information may be accessible to authorities in accordance with applicable laws.
- We may also share aggregated or de-identified information about our customers with our advertising and marketing partners.
- Service-Related Announcements – We will send you service-related announcements when it is necessary to do so. For instance, if you are on the road in one of our vehicle and require assistance, we might send you an email or text-based notification.
- if the rights of another individual might be violated and;
- otherwise with your consent.
Phoenix Motorhomes LLC Services are intended for general audiences and not for children under the age of 18. We do not knowingly collect personal information from children under the age of 18 and if we become aware of such collection, we will take reasonable steps to delete any such information as soon as practicable.
You may be able to disclose information about yourself in the course of contributing user-generated content on publicly-available areas of our services, such as impressions. Your Phoenix Motorhomes LLC user profile and any information you post there will be publicly available. Your content may also be shared with users of other social media services to which you have chosen to share, consistent with your privacy settings on those services. Such information is unencrypted, public information, may be accessed or recorded by us, and there is no expectation of privacy or confidentiality in such information. Any information you submit in the course of such activities can be read, collected, or used by other users. We cannot prevent you receiving unwanted messages from other users. If you wish that a specific content generated by you shall be removed from publicly-available areas of our services, please contact us at email@example.com.
HOW WE PROTECT YOUR INFORMATION
The security of the information you provide is very important to us and we try to provide secure transmission of your information. For all transactions on all of our websites, we use Secured Sockets Layer (SSL) technology to secure the transfer of information. While we strive to protect your personal information, we cannot guarantee the security of any data transmission over the Internet. Once we receive your information, we take steps that we believe are reasonably appropriate to protect it, from loss, misuse, unauthorized access, disclosure, alteration and destruction to ensure the data’s integrity. We use a combination of technological, physical, administrative and organizational controls as well as non-disclosure or confidentiality agreements as we deem appropriate to protect your data. Despite our best efforts, however, no security measures are completely impenetrable.
If you have a user name and password for any of the features on our websites, you have the responsibility of keeping your password secret. You should not reveal your password to anyone. We will not ask you in an unsolicited telephone call or email for your password. In addition, you should take reasonable precautions when using a computer that is not your own or in a public setting.
GLOBAL DATA TRANSFERS AND PROCESSING
We will use your information in the country in which your service and transaction occurs. Please be aware that, unless prohibited by law, your use or continued use of our websites and mobile applications signifies your express consent that information may be transferred to or stored on servers and processed outside the country of your residence, including any of the countries where we do business. Please also be aware that the privacy laws of the United States or other countries where information may be stored may not be as comprehensive or offer as much protection as the laws of other countries including your country of residence. You may request us not to make such transfers, but if you do, we may not be able to provide some, or all of our products or services to you.
With respect to personal data received or transferred, Phoenix Motorhomes LLC is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, Phoenix Motorhomes LLC may be required to disclose personal data in response to lawful requests by public authorities.
CHANGES TO THIS POLICY
The accuracy and completeness of the information we collect is very important to us and we make efforts to ensure that the information we have is accurate and up-to-date. In addition to the options provided to you in this Policy, if you wish to opt-out of direct marketing or review, amend, correct, or update personally identifiable information we have collected about you contact us using the information provided below.
For email marketing please use the unsubscribe link located at the footer of each email. For certain countries, you may also have rights to object to some processing of personal data or to have your personal data removed. You may contact us via email at firstname.lastname@example.org.
In the event we cannot resolve your privacy complaints to your satisfaction, we provide a third party, free of charge, to resolve any dispute. Specifically, we have engaged with International Centre for Dispute Resolution and its U.S. arm, The American Arbitration Association (AAA).
Phoenix Motorhomes LLC
12301 W Butler Drive
El Mirage, AZ 85335
(877) 749 6646
ADDITIONAL PROVISIONS APPLICABLE TO PROCESSING OF PERSONAL INFORMATION OF EEA RESIDENTS
For individuals residing in the EEA, this outlines certain additional information that Phoenix Motorhomes LLC is obligated to provide to you, as well as certain rights you have with respect to the processing of your personal information, pursuant to applicable local laws. This Appendix will control to the extent it conflicts with any provision in the main body of this Privacy Statement.
If you are making a rental, or visiting our website or mobile site, in the following countries, the data controller will be listed as below.
Phoenix Motorhomes LLC Data Protection Officer may be contacted by email or at the following address:
Data Controller: Phoenix Motorhomes LLC
Contact: Phoenix Motorhomes LLC; 12301 W Butler Drive, AZ – El Mirage, 85335
PURPOSES AND LEGAL BASIS FOR PROCESSING
The legal bases for Phoenix Motorhomes LLC processing activities include processing such information as necessary to comply with our contractual obligations, compliance with our legal obligations, protecting the safety of our employees, guests and others, for our legitimate business interests, and pursuant to your consent.
The particular legal basis for the processing of your personal information is based on the purpose for which such information was provided or collected:
- Surveys: Completion of surveys is voluntary – we process the information obtained from surveys on the basis of your consent and in furtherance of our business interests, including marketing, service improvements, and analytics.
- On-property Collection:
- When you make a reservation and rent an RV from us, we process your name, address, payment information, contact information, along with the details of your rental (departure and return day and time, vehicle information and information regarding additional authorized drivers), on the basis of our contractual relationship with you.
- We collect certain additional personal information during check-out/check-in at our properties (such as Driver’s license, DOB), as necessary to comply with our legal obligations.
- Social Media: Participation in Phoenix Motorhomes LLC sponsored social media activities and offerings is voluntary – we process information obtained from social media participation on the basis of your consent and in furtherance of our related business interests, including for marketing, service improvements, and analytics and service personalization.
- Promotions and Contests: Participation in sweepstakes, contests and other promotional offerings is voluntary – we process the information obtained from such participation based on your consent and as necessary to administer the offering.
- Direct Marketing: We use your personal information to send you marketing messages on the basis of your consent. You may withdraw your consent for direct marketing communications at any time by contacting us email@example.com.
We retain personal information about you for the time necessary to accomplish the purpose for which such information was collected, usually for the duration of any contractual relationship and for any period thereafter as legally required or permitted by applicable law. Our retention policies reflect applicable statute of limitation periods and legal requirements.
DATA SUBJECT RIGHTS
Residents of the EEA have the following rights:
- Access, Correction and Erasure Requests: You have the right to:
- Ask us to confirm whether we are processing your personal information
- Receive information on how your data is processed
- Obtain a copy of your personal information
- Request that we update or correct your personal information
- Request that we delete personal information in certain circumstances
- Right to Object to Processing: You have the right to request that Phoenix Motorhomes LLC cease processing of your personal information:
- For marketing activities, including profiling
- For statistical purposes
- Where such processing is based on our legitimate business interests, unless we are able to demonstrate a compelling legitimate basis for such processing or we need to process your personal information for the establishment, exercise or defense of a legal claim
- Right to Restrict Processing: You have the right to request that Phoenix Motorhomes LLC limit the processing of your personal information:
- While Phoenix Motorhomes LLC is evaluating or in the process of responding to a request by you to update or correct your personal information
- Where such processing is unlawful and you do not want Phoenix Motorhomes LLC to delete your data
- where Phoenix Motorhomes LLC no longer requires such data, but you want us to retain the data for the establishment, exercise or defense of a legal claim
- Where you have submitted an objection to processing based on our legitimate business interests, pending our response to such request
- Where we limit the processing of your personal information pursuant to your request, we will inform you prior to re-engaging in such processing.
DATA PORTABILITY REQUESTS
You have the right to request that we provide you or a third party that you designate with certain of your personal information in a commonly used, machine readable format. Please note, however, that data portability rights apply only to personal information that we have obtained directly from you and only where our processing is based on consent or the performance of a contract.
Your requests may be submitted digitally to firstname.lastname@example.org or writing to
Phoenix Motorhomes LLC, 12301 W Butler Drive, AZ – El Mirage, 85335
We will respond to all such requests within 30 days of our receipt of the request, unless there are extenuating circumstances, in which event we may take up to 60 days to respond. We will inform you if we expect our response to take longer than 30 days. Please note, however, that certain personal information may be exempt from such rights pursuant to applicable data protection laws. In addition, we will not respond to any request unless we are able to appropriately verify the requester’s identity. We may charge you a reasonable fee for subsequent copies of data that you request.
If you have concerns about our data practices or the exercise of your rights, you may either contact us.
RIGHT TO WITHDRAW CONSENT
You have the right to withdraw your consent to any processing that we conduct solely based on your consent (such as sending direct marketing materials to your personal email account). You may withdraw your consent to marketing activities by following the instructions on any marketing email(s), or by contacting email@example.com.
(also referred to as profiling) and Automated Decision Making: We use personal information to divide large groups of consumers into sub-groups of consumers (known as segments) based on some type of shared characteristics such as geography, behavior, or demographics.
INTERNATIONAL DATA TRANSFERS
We may transfer the personal information we collect about you pursuant to the purposes described in this Statement to countries that have not been found by the European Commission to provide adequate protection. In particular, we transfer your personal information to the United States. We use appropriate safeguards for the transfer of personal information among our affiliates in various jurisdictions.