1. Object and Scope of the Privacy Policy
SW MOVE Rent a Car, hereinafter referred to as SW MOVE, is strongly committed to protecting the privacy and security of those who access and use its institutional website and online car reservation system, in compliance with the legal obligations arising from the General Data Protection Regulation (GDPR) and other applicable data protection legislation.
Our goal is to establish guiding principles for the correct and responsible use of technological resources, ensuring the safeguarding of SW MOVE’s reputation, organizational security, and user protection.
Please read this Privacy Policy carefully, as your relationship with SW MOVE and access to its institutional website and online car reservation system implies prior and express acceptance of its conditions. By accessing our website and reservation system, you authorize the collection and processing of your personal data according to the rules defined herein.
2. General Principles of the Car Reservation Platform Usage
2.1 – Scope
When using SW MOVE’s institutional website and online car reservation system, hereinafter referred to as the “Car Reservation Platform,” the principle of responsible use applies to all users. SW MOVE reserves the right to change these conditions and take measures if it determines that the use of its technological resources is not in accordance with the established guidelines.
The use of the Car Reservation Platform for commercial purposes or any other purposes incompatible with SW MOVE’s institutional objectives is not permitted.
Users are expected to conduct themselves in accordance with applicable laws and this policy. Ignorance of these laws does not excuse violations.
2.2. Restrictions
The use of SW MOVE’s Car Reservation Platform must not violate the established norms or applicable legal provisions, especially those related to cybersecurity, personal data protection, and cybercrime.
Responsible use includes avoiding actions that could interfere with other users or services, whether internal or external to SW MOVE, such as:
- Engaging in illegal or illegitimate activities.
- Disrespecting the physical and moral integrity of SW MOVE employees and the public.
- Creating, transmitting, or accessing content that infringes intellectual property rights.
- Conducting private activities, such as cryptocurrency mining or selling services/products.
- Attempting unauthorized access or identifying system vulnerabilities.
- Any actions not previously mentioned that may interfere with the security and responsible use of infrastructures.
Resources provided by the Car Reservation Platform cannot be sold, rented, or transferred to third parties.
Unauthorized use of the Car Reservation Platform is considered misuse and subject to disciplinary and criminal procedures.
2.3 Responsibility for the Car Reservation Platform
This Policy applies to data directly provided by the user or collected during access to the Car Reservation Platform.
SW MOVE cannot accept responsibility for any losses or unauthorized access to personal information beyond its control and not covered by this Policy.
SW MOVE will never ask users to provide personal or account information through unsolicited communication. Users are responsible for keeping their personal and account information secure and not sharing it with others.
The Car Reservation Platform may contain links to other websites, online platforms, and email addresses of companies not affiliated with SW MOVE. This Privacy Policy does not apply to third-party links. When using a link to a third-party website/platform and providing personal data, data processing will be subject to the recipient’s privacy statement, not SW MOVE’s responsibility.
3. General Data Protection Regulation (GDPR)
The GDPR sets the rules for the processing of personal data and is mandatory for all public and private organizations across the EU. It applies to both automated and manual data processing, regardless of how personal data is stored.
3.1. Data Controller
SW MOVE Rent a Car, with taxpayer card no. ${NIPC}, located at ${Address and Postal Code}, is the “Data Controller” of your Personal Data collected and processed through this Car Reservation Platform or our rental agencies.
3.2. Users
Users of SW MOVE’s Car Reservation Platform are considered all individuals who enter their data into the platform for vehicle reservations.
In compliance with the GDPR, these users are also designated as “data subjects,” except for entities whose data does not constitute information about an identified or identifiable living person.
Access authorization to the Car Reservation Platform implies acceptance of this policy, remaining valid as long as the user’s relationship with SW MOVE or access rights exist. This authorization may be suspended or canceled for non-compliance or security reasons. Authorizations are personal and non-transferable, and users must keep their access credentials confidential.
3.3 – Collected Information and Purpose
Personal data includes any information, regardless of its nature or support, relating to an identified or identifiable individual. An identifiable person can be identified directly or indirectly, particularly by reference to an identifier like an identification number or specific elements of their identity.
For vehicle reservations via the Car Reservation Platform, SW MOVE collects the following mandatory data:
- Flight arrival date
- Flight return date
- Vehicle pick-up location (airport or locality)
- Flight number or pick-up location
- Vehicle drop-off location (airport or locality)
- Flight number or drop-off location
- Credit card type (VISA, MASTERCARD, MAESTRO, DINERS, AMEX)
- Credit cardholder’s name
- Credit card number
- Credit card security code
- Credit card expiration date
- Driver’s name
- Driver’s email
- Driver’s birth date
- Driver’s fiscal residence address
- Driver’s residence address in Portugal
- Driver’s phone contacts
- Driver’s passport number
- Driver’s passport issuance place
- Driver’s passport issuance date
- Driver’s passport expiration date
- Driver’s license number
- Driver’s license issuance place
- Driver’s license issuance date
- Driver’s license expiration date
SW MOVE collects navigation data on the Car Reservation Platform, including IP addresses, ports, protocols, dates, times, browser user-agent, and cookies.
Information collected is processed for relationship purposes between SW MOVE and the data subject, fulfilling normative/legal obligations, and protecting SW MOVE’s rights, interests, property, and security.
SW MOVE commits to seeking express consent before using information for purposes other than those expressly stated in this Policy.
3.4 – Information Processing and Retention Period
SW MOVE commits to lawful, fair, and transparent data processing, collecting only necessary and pertinent information for its intended purpose, retaining it for the minimum necessary period, and providing access, updating, and deletion as requested within legal constraints.
Legal requirements may mandate data retention for a minimum period. If no specific legal requirement exists, data will be stored and retained only for the minimum necessary period for its collection or processing purpose, after which it will be deleted or anonymized unless retained for a distinct, subsisting purpose.
3.5 – Data Subject Rights
SW MOVE ensures data subjects can exercise the following rights:
- Right to be informed: Data subjects have the right to obtain information about their personal data and its processing.
- Right of access: Data subjects have the right to confirm if their data is being processed and access their personal data and related information.
- Right to rectification: Data subjects can request correction of their personal data at any time.
- Right to erasure: Data subjects can request deletion of their data if no valid grounds for continued use exist or its use is unlawful.
- Right to restriction of processing: Data subjects can request processing limitation in specific situations, such as data accuracy disputes or unlawful processing.
- Right to data portability: Data subjects can receive their data in a structured, commonly used, machine-readable format and request direct transmission to another organization.
- Right to object: Data subjects can object to data processing, compelling SW MOVE to cease processing unless overriding legitimate grounds exist.
Data subjects can exercise these rights by submitting a written request to:
- Email: ${company email}
- Address: ${Address and Postal Code}
3.6 – Sharing of Collected Information
Collected information is not shared with third parties without the data subject’s consent, except in specific situations:
- To public entities for statistical purposes and fraud prevention
- Legal obligations requiring disclosure in response to judicial or administrative authorities
In such cases, data sharing occurs when SW MOVE believes, in good faith, it is legally required and after thorough evaluation of legal requirements.
SW MOVE will notify users when possible and take reasonable steps to ensure third-party data use aligns with this Privacy Policy. Personal data necessary for user functions will not be commercialized with third parties.
SW MOVE will take appropriate measures to protect transmitted personal data.
3.7 – Technical, Organizational, and Security Measures
Collected information will be processed only within the identified purposes, according to SW MOVE’s internal policies and using technical and organizational measures designed for associated risks.
Periodically, SW MOVE reviews its security policies and procedures to ensure system security and protection. However, as internet information transmission is not completely secure, SW MOVE cannot guarantee the security of data transmitted to its Professional Exit Platform.
3.8 – Non-compliance and Incident Response
SW MOVE’s incident response team analyzes security incidents and non-compliance cases, notifying management and the infractor if identified, and may suspend access to the Car Reservation Platform or take other mitigating measures. Personal data incidents are reported to the Data Protection Officer.
3.9 – Data Transfer Outside the European Union
If personal data collected by SW MOVE is shared with third parties outside the EU, SW MOVE ensures the transfer complies with legal provisions, particularly regarding the adequacy of data protection in the destination country and applicable transfer requirements.
Transfers outside the EU or to international organizations, fulfilling legal obligations, are considered in the public interest as per the law.
4. Contact for Suggestions or Complaints
For any doubts, complaints, or comments regarding this Privacy Policy and the Car Reservation Platform usage, please send a written request to:
- Email: ${company email}
- Address: ${Address and Postal Code}
Without prejudice to other administrative or judicial recourse, users can file a complaint with the National Data Protection Commission or another competent supervisory authority if they believe SW MOVE’s data processing violates current legal regulations.
5. Amendments to the Privacy Policy
SW MOVE may modify this Privacy Policy, with amendments becoming effective 30 days after publication on the institutional website.
SW MOVE encourages periodic review of this Privacy Policy for updates.