1. Information We Collect

We respect your privacy and have implemented this Privacy Policy to explain our data collection practices, as well as individual rights you may have when you use our Services.

For All Transactions:

We collect:

Contact Information:

• Name
• Address
• Phone numbers
• Email addresses

When Renting a Vehicle:

When renting a vehicle, including being added as an authorized additional driver, or joining one of our rental programs, we may collect:

Driver Qualifications and Identity Verification:

• Driver's license information, including license number, state of issue, expiration date, and photos provided by you for verification purposes
• Insurance information
• Passport
• Proof of residence
• Personal references

Transaction Information:

• Vehicle rental information
• Rental and return locations
• Dates of the rental
• Type of rental and your vehicle preference
• Ancillary products purchased
• Airline and flight number
• Photographs you submit of receipts and/or vehicle condition through the camera feature available on some of our mobile applications and websites
• Billing information
• Charges
• Payments
• Credit card information

Loyalty and Affiliation Information:

• Pull Up Rentals Group rewards and loyalty information
• Online user account details
• Corporate Account ID numbers
• Membership numbers
• Frequent traveler or travel partner affiliations

Claims Information:

Information related to details of accidents involving our vehicles, including that of any third parties such as involved individuals, witnesses, and police reports.

Health Information:

Information about relevant health conditions you have that assist us in providing you with adaptive driving devices or related to claims involving injuries.

CCTV and Other Cameras:

Where available, CCTV video recordings and/or photographs of you in public areas of our rental locations.

When Purchasing a Vehicle:

In addition to the contact information, identity verification, and driver qualification information listed above, when you purchase a vehicle through Pull Up Rentals Group and apply for financing, we may also collect:

Financial and Personal History Information:

• Income
• Credit history
• Employment history
• Other personal information required to complete the credit application

Car Sale Transaction Information:

• Vehicle purchased
• Purchase price
• Vehicle trade-in
• Ancillary products purchased

When Contacting Us for Accident Management Assistance Services:

In addition to the contact information, driving qualification, transactional, and health information listed above, when you contact us for accident management assistance purposes (which we may administer on behalf of the entity that refers your details to us, such as your insurer, manufacturer, employer, dealership, fleet management provider, or breakdown provider), we may also collect:

Claims Information:

Information related to details of accidents, including that of any third parties such as involved individuals, witnesses, and police reports:

• Insurance details
• Information about the incident to determine who is at fault
• Vehicle details
• Credit repair details
• Details regarding your vehicle repair needs and your onward mobility needs

When Using Our Websites and Mobile Applications:

We collect:

Browser Information:

• Web logs
• Geo-location

Internet or Other Activity Information:

• Browsing or search history
• Information regarding your interactions with our websites, mobile applications, emails, or advertisements

Your Device Information:

• Unique device identifiers
• IP address
• Operating system
• Location information
• Device connections (which may be via Bluetooth or other connection services through our mobile application)

Location Information (where enabled and with your permission):

Our websites use location information (such as postal code, city, metropolitan, or geographic area) from your device to provide services, such as finding a branch or location.

When using your mobile device, location information and device connections are used to provide you with notifications, offers, confirm rental status information, or provide other information to enhance your experience.

Where available, allowing use of location information can enable you to locate the vehicle assigned to you or to expedite your pickup and return by allowing access when in proximity to your assigned vehicle.

Permissions to use your device’s camera enable you to upload your photo ID and/or the vehicle’s condition for expedited services (where available). Permissions to use your device’s precise geolocation information, camera, or Bluetooth connection can be turned off at any time by changing the settings in the mobile application or on your device. Some features or service options may not be available when these items are turned off.

Through Our Use of Cookies and Other Automated Data Collection Technologies:

Except where consent may be required by applicable law, when you visit our websites, use our mobile applications, open or click on emails we send you, or interact with our advertisements, we or third parties automatically collect certain information using technologies such as cookies, web beacons, clear GIFs, pixels, internet tags, web server logs, and other data collection tools. For more information, please see the “Cookie Policy” and the “Social Media Platforms and Advertising Networks” section below.

When Participating in Surveys or Promotions:

We collect:

• Marketing preferences
• Feedback on services provided

2. Information We Collect from Third-Parties

Third parties provide us with additional information about you or your household, including:

Referral Sources:

• Third-party online booking sites (who provide us general contact information and a booking confirmation number to facilitate the rental)
• Your employer (general contact information)
• Credit unions, third parties who assist us if you have a credit hire/repair claim
• Your insurance provider (general contact and policy information)
• Vehicle sales sites (who provide us, upon your request, your contact information when you inquire about a specific vehicle for sale)
• Where applicable, our Refer-A-Friend, or similar programs
• Hotel, airline, and membership clubs who provide us your general contact information and booking information

Verification and Authentication:

• Third parties who, for fraud prevention purposes, provide us with (if relevant financial) and identity-related verification and document authentication
• Credit and financing partners, including credit reporting agencies, who facilitate the completion of credit applications when financing a vehicle purchase or applying for a business rental

Service Providers:

• Franchisees and fulfillment providers who provide us information regarding your rental transactions
• Service providers, such as customer support (customer service-related information and inquiries made by you), security services (footage of you from our CCTV system), and customer survey providers (your response to our customer service surveys)
• Marketing providers who provide information to assist us in better communicating our products and services, including email acquisition services, data hygiene services, data brokers, and market research partners and platforms
• Social media content you have made available to the public

Vehicle Data and Technology

Our Vehicles - Connected Car and Telematics Data:

Our vehicles may be equipped with GPS, telematics devices such as pre-installed event data recorders, global positioning devices, and other communications systems that may be connected to the Internet or cellular services. We (and at times the vehicle manufacturer and other authorized third parties) may collect information from these telematics devices, other services, and technologies and use and share it as described below or as otherwise set out in this Privacy Policy.

You may also choose to accept or purchase optional devices that enable you to collect certain vehicle data. Please refer to the manufacturer’s terms and conditions and privacy policy.

The use of telematics devices and other pre-installed services and technologies are subject to our rental terms and conditions and, in some cases, the vehicle manufacturer’s and/or technology provider’s terms and conditions and privacy policy. For other vehicle manufacturers, please visit their respective websites. Some or all of these features may be turned on at all times, even when other services or other media in the vehicle are turned off. If you are unsure whether your rental vehicle contains telematics devices or technologies or systems, please speak to a member of our team at the rental location.

Vehicle Data We Collect:

Depending on your type of rental, we collect and use vehicle data as follows:

• Fuel Information: Used to facilitate recording and billing for fuel charges.
• Odometer Information: Used to facilitate billing for mileage charges (where applicable) and to help us manage our fleet.
• Vehicle Diagnostic and Performance Information: Used to help identify vehicle maintenance needs and manage the fleet.
• Mobile Device or App Connections: Helps us issue certain commands to the vehicle to facilitate or expedite your rental or to facilitate your transaction.

• Location Information: Enables roadside assistance providers to provide you roadside assistance, enables emergency service providers to dispatch emergency services to you, assists us in recovering a vehicle we reasonably believe is lost, stolen, or abandoned, and facilitates the vehicle return process (where remote return is available) and billing purposes.
• Event Data Recorders: Used in certain claims situations in connection with accident investigations and claims-related efforts.

Infotainment Systems and Vehicle Manufacturer Apps:

If you pair a mobile device with our vehicles’ navigation or infotainment systems and choose to use OnStar, Apple CarPlay, Android Auto, or other similar third-party software, applications, virtual assistants, video or voice recording devices, features, settings, profiles, or services on the vehicle, or if you choose to use any navigational features on the vehicle’s infotainment systems or other devices, your personal information and other data may be transferred and stored on these systems.

We cannot guarantee the privacy or confidentiality of such information. You should delete all such personal information and other data from these systems or devices before the vehicle is returned to avoid subsequent occupants of the vehicle accessing this information.

If you download a mobile app made available by a vehicle manufacturer or other third party and register or enroll the vehicle in that app, your use of the app may result in the sharing of telematics data and other information (including location information and personal information) with the vehicle manufacturer or other third party. Your use of these apps is strictly governed by the third-party mobile apps’ terms and conditions and privacy policies. Before the vehicle is returned, you should either remove the app from your mobile device or delete the vehicle from the app.

Loyalty Programs and Financial Incentives

You have the option of enrolling in one of our loyalty programs. These programs offer benefits related to your transactions with us. There is no obligation to join one of these programs; however, your employer may choose to use our loyalty program to facilitate its company travel program.

If you or your company choose to enroll in one of these programs, you may cancel your membership at any time by contacting us directly. Our collection of certain personal information about you, including name, address, email, phone number, driver’s license information, date of birth, credit card or other payment information, company affiliation, and frequent traveler program information (where available) allows us to operate the loyalty programs and provide participant benefits such as discounts, rental credits, and vehicle benefits.

You may have the option to link a Pull Up Rentals Group loyalty program account with an account you have with a select partner. When linked, we and the partner will share information as described at the time you link your accounts.

The amount and nature of these benefits will be determined by the extent of your participation in our loyalty programs. We may adjust the terms of participation from time to time. Please be advised that we may continue to process information about you in connection with your transactions with Pull Up Rentals Group. If you choose to terminate your membership or exercise any rights to the deletion of your personal data, we may be unable to provide you with all of the benefits of the loyalty programs or associated partner programs.

Children's Privacy

Our websites and online marketing are not directed to and Pull Up Rentals Group does not knowingly collect personal information from children under the age of 18 or your country's age of minority. If you nevertheless believe that your child has provided us with their personal information and you need to let us know to delete it, please contact us using the link at the top of this page.

3. How We Use Information About You

We use the information we collect from you or about you to provide you with our services and for the following purposes:

Where it is necessary for the performance of a contract which governs the services we provide to you, including:

• To assist the transactions that you (or someone on your behalf, by corporation or other entity) request, such as reserving, renting, purchasing, leasing motor vehicles, fleet management services, or providing accident management services.
• To communicate important information regarding your reservation, rental, lease, or purchase of a vehicle. These communications are transactional in nature and will be sent to you via email, text, or calls.
• To provide customer service related to your interactions with us or to respond to your inquiry.

Where necessary for us to comply with a legal obligation:

• To use and share information about your vehicle's location with emergency services in the event that you are involved in a road accident.
• To use and share information with government and regulatory authorities when required by law, traffic regulation, or in response to legal processes, obligations, or requests, including checking appropriate sanction lists or for maintaining public security.

Where it is necessary for our legitimate interests, and where our interests are not overridden by your data protection rights:

• To communicate important information about your rental and provide you great service. These communications, which are transactional in nature, will be sent to you via email, text, or calls.
• To assist us in providing better products and services: for example, to evaluate the performance of our staff, assess the quality of products and services received, and help us improve our websites, facilities, and services. Unless where consent may be required by applicable law, your feedback may be requested via email, text, or call.
• To compile statistics and analysis about our customers' use of our websites, products, and services. These statistics are used only to enable us to provide better customer service, products, features, and functionality to you and other customers in the future.
• Where permissible, to develop a profile of you and your interactions with us so that we can provide tailored offers, opportunities, and services that may be of interest to you. To enhance your advertising experience, including cross-device tracking. This means we may collect and combine data from your various devices to show you ads that are relevant to your interests.
• To protect our legal rights and manage the security of our networks and property, including to protect our websites from spam and abuse. For example, we will use CCTV to ensure the security of our premises.
• For loss prevention, we maintain a record of individuals whose past interactions with us indicate they may present a non-payment, safety, or fraud risk.
• For fraud prevention purposes, to verify identity and authenticate identity-related documentation as well as additional points of contact for rental-related communications through personal references.
• To use and share your information with third parties to permit us to pursue available remedies or limit damage that we may sustain and to enforce the terms of any rental agreement or our websites' terms and conditions.
• To enable us to use vehicle data systems for purposes listed in the Vehicle Data section above, such as assisting in recovering a vehicle we reasonably believe is stolen or abandoned; and to facilitate the vehicle return process (where remote return is available) and billing purposes.
• Unless where consent may be required by applicable law, we may use personal information for marketing and promotional purposes, including to advertise products and/or services we think you may be interested in. This may include linking your activity across our websites and mobile apps.
• To aggregate personal information collected about you and use it for any lawful purpose.
• To transfer your data as described in the “Global Data Transfers and Processing” section.
• To receive, use, and share your information with third parties to prevent, detect, and report fraud and protect our business interests and rights, privacy, safety, and property, or that of individuals and the public. We will do this to respond to law enforcement requests, collect unpaid bills, to avoid liability for penalties you incur (e.g., traffic citations), and for claims processing purposes.

4. Retention of Your Personal Information

We retain your personal information for as long as we need to fulfill our business purposes, as set out below:

• Rental Transactions: We may keep the data associated with your rental agreement for up to seven years from the date of the rental or in accordance with our business needs, subject to other local legal requirements. We keep records of payments you have made for two years from the date of the transaction (depending on the location of the rental).
• Car Sales: We keep the data associated with the sale of a vehicle for up to ten years from the date of sale, subject to other local legal requirements.
• Claims: We keep the data associated with claims involving our renters or other individuals for the life of the claim and up to ten years from the conclusion of our obligation, subject to other legal requirements.
• Customer Service-Related Queries: We keep general queries for three years unless you make a complaint, in which case, we keep complaint data for seven years.
• Marketing and Analytical Purposes: We keep data linked to cookies and other online identifiers for up to three years. We keep other marketing information, such as email subscription and loyalty enrollment data, for up to seven years after your last interaction with us.
• Disputes & Law Enforcement: If we are involved in litigation or a governmental or regulatory investigation, then we keep data throughout the period of litigation or investigation and for five years after that. If a settlement means that we must keep data for longer, then we keep data for the period required to administer the settlement.
• If we provide data to law enforcement agencies, then we keep a record of this for one year beyond the end of the investigation.

5. Our Service Providers and Business Partners

We may share your contact, driver qualification, transactional, device information, claims information, financial and personal information, and car rental transactional information with:

• Payment, administrative, and technical support providers.
• Insurance replacement, corporate rental, or other partners to facilitate vehicle repair, rental transactions, and rewards programs with Pull Up Rentals Group.
• Vehicle recovery agents.
• Debt collection providers.
• Credit Reporting Agencies.
• Identity and address verification providers.
• Claims processors.
• Vehicle manufacturers and their vehicle repair providers and/or roadside assistance providers.
• Fleet providers.
• Other providers for vehicle repair and damage assessment purposes.

Health Information

We may share your health-related information (if applicable) with:

• Claims processors.
• Adaptive device providers.

Contact and Transactional Information

We may share contact and transactional information with:

• Toll and citation processors.

Contact, Transactional, Loyalty, and Affiliation Information

We may share your contact, transactional, loyalty, and affiliation information with:

• Insurance replacement, corporate rental, or other partners to facilitate rental transactions and rewards programs with Pull Up Rentals Group.
• Companies that conduct customer research or satisfaction surveys on our behalf.
• Communication providers to send email, text, and other marketing and service-related communications to you on our behalf.
• Customer support providers, such as live chat providers, to offer customer service.
• Commercial account partners to manage their accounts with us, including payments owed under rental agreements or other agreements.

Web and Mobile Information

We may share web and mobile information with:

• Analytics and technology providers for location-based services and to analyze, enhance, and manage data to provide, maintain, and improve our services.
• Web and mobile application session replay partners to improve the browsing experience and troubleshoot errors.

Government Authorities

Your personal information may also be shared with government authorities as required by applicable laws or regulations.

6. Sale, Merger, or Change in Control

Your information may be transferred to another company in the event of a transfer, change of ownership, reorganization, or assignment of all or part of Pull Up Rentals Group's businesses or assets. Such transfers will only occur under agreements that limit the use of your information to business transaction purposes. If required by law, you will be notified via email or a prominent notice on our website.

7. Testimonials

We may post customer testimonials on our website that include your contact information. We use a third-party provider to manage this process, including obtaining your consent, removing content upon request, and answering related questions.

8. Social Media Platforms and Networks

We use third-party digital platforms, such as Google and Meta, to serve relevant ads, including on non-affiliated platforms. These ads may be personalized based on your use of our website, mobile apps, and other sites over time. For more details or to opt-out, see our Cookie Policy or the “Your Rights” section below.

Our websites may also include social media features (e.g., a Facebook button). These features may collect your IP address, pages visited on our site, and may set cookies. Social media features are governed by the privacy policies of the companies providing them. If you prefer not to have your data collected through social media plug-ins, log out of your social media account before visiting our site and delete relevant cookies.

9. Your Rights

Although Pull Up Rentals Group operates exclusively in Georgia and the United States, we recognize your rights to:

• Opt out of certain data collection or uses of your personal information, including cookies and marketing.
• Access, correct, restrict, or object to the processing of your personal information, or request its deletion, subject to legal exemptions.
• Receive the personal information you provided in a portable format.
• Withdraw any consent provided (withdrawal does not affect the lawfulness of prior processing).

To exercise these rights or make a privacy-related complaint, please contact us at support@pulluprentals.com

10. U.S. State-Specific Rights

Residents of certain U.S. states, including California, Colorado, Connecticut, Delaware, Iowa, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Virginia, Texas, and Utah, may have specific rights regarding personal information collected about them. If you are a resident of one of these states, you may exercise the following rights regarding your personal information, subject to applicable exceptions and limitations:

• Right to Confirm and Access: Confirm the processing and access the personal information we have collected about you, including how we collect, use, and share it.
• Right to Correct: Correct inaccurate personal information.
• Right to Delete: Request the deletion of personal information we have collected from you.
• Right to Opt-Out: Opt-out of the sale or sharing of your personal information for targeted advertising purposes.
• Right to Non-Discrimination: Not receive discriminatory treatment for exercising your privacy rights.

Note: Pull Up Rentals Group shares personal information for targeted advertising purposes but does not otherwise engage in “sales” of personal information as defined by applicable state laws. You can opt-out of such sharing by clicking the "Privacy Choices" link in the footer of our website and submitting a request through our Privacy Portal.

Additionally, we engage in social media advertising activities that we treat as targeted advertising under applicable laws. To opt out of targeted advertising, you can toggle off the Advertising button on the website via the “Privacy Choices” link or submit a request by contacting us at support@pulluprentals.com

We may share the following categories of personal information with social media platforms and advertising networks for targeted advertising:

• Online identifiers
• Commercial information
• Internet or other electronic network activity information
• Coarse, non-precise geolocation data
• Inferences drawn from the above categories

Depending on your state of residence, you may also have the right to appeal decisions regarding your privacy rights requests. To appeal, reply to the communication resolving your original request or email us at support@pulluprentals.com

6. Updates to Our Privacy Policy

We periodically update our Privacy Policy and Cookie Policy to reflect changes in our practices. If any material changes are made, we will notify you via email (to the address associated with your account) or by posting a notice on our website, as required by law. We encourage you to review our website periodically for the latest updates to our privacy practices.

7. Global Privacy Policy

This policy was last updated on January 1st, 2025

At Pull Up Rentals Group, we respect your privacy and are committed to protecting your personal information. This Privacy Policy explains how we collect, use, disclose, and transfer your data, as well as your rights regarding your information. It applies to all services offered by Pull Up Rentals Group.

For more information about our privacy practices, contact us at support@pulluprentals.com

3. How We Use Information About You

We use the information we collect from or about you to provide our services and for the following purposes:

Where it is necessary for the performance of a contract governing the services we provide:

• To facilitate transactions that you (or someone acting on your behalf, such as an employer or business entity) request, such as reserving or renting motor vehicles or providing accident management services
• To communicate important information regarding your reservation or rental (e.g., confirmations, updates, or changes). These communications are transactional in nature and will be sent via email, text, or calls
• To provide customer service related to your interactions with us or to respond to your inquiries
• To enroll you in loyalty programs and manage your participation in them
• To process vehicle returns, billing, or account-related communications

Where it is necessary to comply with legal obligations:

• To share vehicle location data with emergency services in the event of a road accident
• To respond to legal requests, comply with applicable laws, traffic regulations, or public safety requirements
• To check sanction lists, meet regulatory obligations, or respond to law enforcement requests

Where it is necessary for our legitimate interests, provided your data protection rights are not overridden:

• To communicate important rental-related information and provide quality customer service via email, text, or calls
• To evaluate the performance of our staff, assess the quality of services received, and improve our facilities, websites, and services
• To compile statistics and analyses about customer interactions with our services and use these insights to improve
• To develop a profile of your interactions with us for tailored offers, services, or advertising (including cross-device tracking for personalized advertising)
• To protect our legal rights, networks, and property, including the use of CCTV for security purposes at our locations
• To prevent losses by maintaining records of individuals who may pose non-payment, safety, or fraud risks
• To verify and authenticate your identity and documentation for fraud prevention purposes
• To pursue remedies or enforce terms of any rental agreement, including collecting unpaid bills or processing claims

• To use vehicle data (e.g., location or diagnostics) to assist in managing your rental, including recovery of lost, stolen, or abandoned vehicles
• To market products or services we believe may interest you unless otherwise restricted by applicable law

You may withdraw your consent at any time by contacting us at support@pulluprentals.com. Withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal.

4. Retention of Your Personal Information

We retain your personal information for as long as necessary to fulfill the purposes outlined in this Privacy Policy, comply with legal obligations, resolve disputes, and enforce agreements. Retention periods are determined based on the nature of the information, the purpose of processing, and applicable legal requirements.

Disputes and Law Enforcement:

• If involved in litigation, governmental, or regulatory investigations, we retain the relevant data for the duration of the proceedings and five years thereafter. If a settlement requires longer retention, we will comply accordingly
• Records of data provided to law enforcement agencies are retained for one year beyond the conclusion of the investigation

5. Who We Share Information With

As a provider of transportation solutions in Georgia and the U.S., Pull Up Rentals Group may share your personal information to facilitate transactions and provide a seamless customer experience.

Subsidiaries:

We share your contact, driver qualification, transactional, loyalty, health, optional, claims, and other relevant information with subsidiaries of Pull Up Rentals Group for the following purposes:

• Providing the services and transactions you have requested
• Sending you marketing communications (with your consent, if required)

Our subsidiaries' employees in IT, marketing, operations, and customer service divisions use your data as described in this Privacy Policy. A complete list of subsidiaries is available on request and subject to change.