Privacy and Cookies

Your privacy is important to us. We value the trust you have placed in us, and are committed to protecting and protecting any personal data you give us. This document describes how Goldenage Technologies OÜ, Narva mnt 38-40e, Tallinn, Estonia, Registration number: 12943267, use and process your personal data. It also tells you how you can contact us if you have questions.

Goldenage offers the services through its own websites and through other online platforms such as partners’ websites and social media. The information that follows applies to all of these platforms. Goldenage may amend the Privacy and Cookies Policy periodically. If you disagree with this Privacy and Cookies Policy, you should stop using our services.

Privacy

What kind of personal information does Goldenage use?

When you make a reservation, you are asked for your name, email address, phone number, passport, driver licence, credit card and age. You might also be asked for your home address, payment information, the names of additional drivers and your preferences or special requests.

To make it easier to manage your reservations, you can open a user account. This allows you to save your personal settings, review previous bookings and manage future reservations. Please note that the feature is not yet available to all users.

When you visit our websites, even if you do not make a reservation, we may collect certain information, such as your IP address, browser info, and information about your computer’s operating system, application version, language settings and pages that have been shown to you. When you make a reservation, our system registers through which means and from which websites you have made your reservation. We may also receive information about you when you use certain social media services.

Why does Goldenage collect, use and share your data?

  1. Reservations – We use your personal data to complete and administer your online reservation and forward your reservation details to the Supplier.
  2. Customer service – We provide customer service 24/7 from our local offices. Sharing your details with our service staff allows us to respond when you need us.
  3. Reviews – We use your contact information to invite you by email to write a review. This can help other people to choose the vehicle that suits them best.
  4. Account administration – We offer a user account facility on our website. We use the information you give us to administer this, allowing you to manage your reservations, take advantage of special offers, make future reservations more easily and manage your personal settings.
  5. Marketing activities – We also use your information for marketing activities, as permitted by law. With your consent – if consent is required under local law – we may also send you other regular newsletters by email. You can opt out, or unsubscribe, from marketing communications at any time using the “Unsubscribe” link in each newsletter.
  6. Other communications – There may be other times when we get in touch by email, by post, by phone or by texting you, depending on the contact information you share with us. There could be a number of reasons for this:
    • We may need to respond to and handle requests you have made.
    • If you have not finalized a reservation online, we may email you a reminder to continue with your reservation. We believe that this additional service is useful to you because it allows you to carry on with a reservation without having to fill in all the reservation details from scratch.
    • When you use our services, we may send you a questionnaire or invite you to provide a review about your experience.
    • We may also send you other material related to your reservations, such as how to contact Goldenage or the Supplier if you need assistance. We may also send you material related to upcoming reservations or a summary of previous reservations you made through Goldenage.
  7. Market research – We sometimes ask our customers to take part in a survey. Any additional personal details that you give us as part of the research will be used only with your consent.
  8. Fraud prevention – We may use personal data for the detection and prevention of fraud and other illegal or unwanted activities.
  9. Improving our services – We use personal data for analytical purposes, to improve our services and to enhance the user experience.

Social media

We use social media to promote our Supplier’s vehicles and offers, and to promote, improve and facilitate our own services. Your social media provider will be able to tell you more about how they use and process your data in such cases.

How does Goldenage share your data with third parties?

In certain circumstances, we may share your personal data with third parties.

  • Suppliers: In order to complete your reservation, we need to transfer relevant reservation details to the Supplier. This may include information such as your name, your contact details, your payment details, the names of additional drivers and any additional info you specify when making a reservation.
  • Goldenage offices: In order to support you during the reservation process and throughout your rental, your details may be shared with subsidiaries of the Goldenage.
  • Third-party service providers: We may use service providers (such as “document verification service” or “fraud detection service”) to process your personal data strictly on our behalf. These processors are bound by confidentiality clauses and are not allowed to use your personal data for their own purposes or any other purpose.
  • Competent authorities: We disclose personal data to law enforcement and other governmental authorities insofar as it is required by law or is strictly necessary for the prevention, detection or prosecution of criminal acts and fraud.

Customer reviews

After your rental period has ended you will be invited to submit a review. This invite may ask for information about the vehicle, the Supplier, and the destination. If you don’t want to use your name with the review the review can be displayed on the website anonymously. By completing a review, you are agreeing that it can be displayed as described in detail in our Terms and Conditions.

Overseas transfers of personal information

Given that the Internet is a global environment, using the Internet to collect and process personal information necessarily involves the transmission of data on an international basis. Some of the data processors engaged to process personal information may be based outside of the European Economic Area and your personal information may be transferred outside of that area in order for us to fulfil our contractual obligations to you. In this case Goldenage will ensure an adequate level of protection for the rights and freedoms of data protection in relation to the processing of your personal data. Therefore, by providing us with your personal information in accordance with the above, you acknowledge and agree to our processing of your personal information in this way. We use a variety of security technologies to help protect your personal information from unauthorised use, access or disclosure. Whilst information travels on the Internet, all personal information is encrypted using SSL technology. SSL is a special mechanism that automatically encrypts any information sent by you on our secure pages.

Cookies

A cookie is a small amount of data that is placed in the browser of your computer or on your mobile device. This Privacy and Cookies Policy applies to cookies and similar technologies (hereafter together referred to as “cookies”).

Why are cookies used?

Cookies allow you to be recognized as the same user across the pages of a website. They will also make sure you are recognized when you return to a website. There are different types of cookie and different ways of using them. Cookies can be categorized according to their function, their lifespan and according to who places them on a website.

The use of cookies

Goldenage uses the following types of cookie:

  • Technical cookies: We use technical cookies to show you our website, to make it function correctly, to create your user account, to sign you in and to manage your reservations. These technical cookies are absolutely necessary for our website to function properly.
  • Analytics cookies: We use these cookies to gain insight into how our visitors use the website, to find out what works and what doesn’t, to optimize and improve our website and to ensure we continue to be interesting and relevant. The data we gather includes which web pages you have viewed, which referring/exit pages you have entered and left from, which platform type you have used, date and time stamp information and details such as the number of clicks you make on a given page, your mouse movements and scrolling activity, the search words you use and the text you type while using our website. We also make use of analytics cookies as part of our online advertising campaigns to learn how users interact with our website after they have been shown an online advertisement – which may include advertisements on third-party websites. However, we will not know who you are, and will only obtain anonymous data.

How long do cookies stay active?

The cookies we use have varying lifespans. The maximum lifespan we set on some of them is 2 years from your last visit to our website. You can erase all cookies from your browser any time you want to.

Third-party cookies

Goldenage uses the services of trusted and recognized online advertising and marketing companies. Goldenage may also use third-party providers for analytical purposes, such as Google Analytics. To enable their services, these companies need to place cookies.

The providers we use are committed to building consumer awareness and establishing responsible business and data management practices and standards.

When it comes to online advertising and marketing, only work with companies that are members of the Network Advertising Initiative (NAI) and the Interactive Advertising Bureau (IAB). Members of NAI and IAB adhere to industry standards and codes of conduct. NAI and IAB members allow you to opt out of the behavioral advertising. Visit networkadvertising.org and youronlinechoices.com to identify the NAI members that may have placed an advertising cookie file on your computer. To opt out of an NAI or IAB member’s behavioral advertising, simply check the box that corresponds to the company from which you wish to opt out.

In order to control the collection of data for analytical purposes by Google Analytics, you may want to use Google Analytics Opt-out Browser Add-on.

Cookie access

Only Goldenage has access to empireluxuryclub.com cookies. Cookies placed by third parties can be accessed by these third parties.

Managing cookie preferences

Using your browser settings you can set which cookies to accept and which to reject. Where you find these settings depends on which browser you use. Use the “Help” function in your browser to locate the settings you need. If you choose not to accept certain cookies, you may not be able to use some functions on our website.

Web beacons

Goldenage sometimes uses web beacons. A web beacon is a tiny graphic image of just one pixel that’s delivered to your computer either as part of a web page request or in an HTML email message. Either directly or through service providers, we use these pixels as part of our online advertisements either on our website or on third-party websites to learn whether a user who is being shown an online advertisement also makes a reservation; to track conversion with partner websites and to analyze the traffic patterns of users to optimize the services we bring to you.

Personal data security

In accordance with European data protection laws, we observe reasonable procedures to prevent unauthorized access and the misuse of personal data. Only authorized personnel are permitted to access personal data in the course of their work. We do not store your card details during online payment process.

Age limitations

The services offered by Goldenage are not available to children under 18 years old. If we receive information from a child under 18 years old, we reserve the right to delete it.

Review or remove your personal data

You have the right to review the personal information we keep about you. You can request an overview of your personal data by emailing us at web@empireluxuryclub.com. Please write ‘Request personal information’ in the subject line of your email and include a copy of your passport to help us prevent unauthorized individuals from accessing your personal data.
If the personal information we have for you is incorrect, we will update it at your request. You can also ask us to remove your personal data from our customer database by sending an email to web@empireluxuryclub.com with ‘Request for removal of personal information’ in the subject line. However, we may need to retain certain information, for example for legal or administrative purposes, such as record keeping or to detect fraudulent activities. You can delete your user account at any time by signing into your account and choosing to remove your account.

Who is responsible for the processing of personal data?

Goldeange controls the processing of personal data on its websites and other properties. If you have any suggestions or comments about this privacy notice, please send an email to web@empireluxuryclub.com

Last updated: 9-Sept-2016