This policy was last updated on 07/18/2023.

Entegral is a suite of products and services (collectively “Services”) that streamlines the vehicle claim and repair process to help get vehicles and their owners back on their way. Entegral enables communication and collaboration between vehicle repair shops and service providers, insurance carriers, automotive manufacturers, Enterprise Rent-A-Car and its family of companies, and other collision industry professionals.

To learn more about how your data is collected and processed, please select the nature of your relationship with Entegral.

I AM A CLIENT OF ENTEGRAL, SUCH AS A REPAIR FACILITY, INSURANCE COMPANY, FLEET MANAGEMENT COMPANY, OR ONE OF THEIR EMPLOYEES

Entegral Holdings, LLC and its UK subsidiary Entegral Holdings Limited UK (collectively, “Entegral”) are subsidiaries of Enterprise Holdings, Inc. (“EHI”). Entegral products may be licensed to Enterprise Rent-A-Car and its family of companies (for purposes of this Privacy Policy, “Entegral”, “we” or “us”). We offer this privacy policy to explain our data collection and use practices.

WHAT INFORMATION WE COLLECT

Information collected about you

You may provide us with certain information in connection with a transaction or in your interactions with the Services. We may collect the following types of personal information from you:

- Name
- Addresses
- Telephone or fax number
- Email address
- Username and login credentials
- For Sole Proprietors, VAT registration number, Tax ID number or similar
- Company registration number
- Banking and payment information

Information automatically collected about you

Entegral may collect certain information automatically through the Services such as:

- Browser information and information about your computer setup (such as your Media Access Control (MAC) address, computer type, screen resolution, operating system version, and Internet browser type and version)
- Information collected through cookies, pixel tags and other similar technologies
- IP addresses and other log information (such as the time of the visit and the page(s) that were visited)
- Information about your use of the Services

Information collected from third parties

In addition to the information described above, Entegral may collect information about you from other sources, including:

- Your employer
- Data brokers who provide information to assist us to better communicate our products and services, including email acquisition services, data hygiene services, and market research partners and platforms. 

Why we use cookies

We use cookies for the following purposes:

- To provide you with the service you have requested. We use these cookies to enable you to move around our sites and apps and to use their features — for example, to provide secure login.
- To analyse and improve your browsing experience. We use these cookies to analyse site usage so we can measure and improve performance — for example, to make sure that the website looks consistent, to gather statistics about its use and to know if you use features of our site. They also allow our sites to remember choices you make (such as your username or the region you are in) and to provide you with enhanced and more personalised features. Some newer web browsers incorporate "Do Not Track" features. Our websites may not currently respond to "Do Not Track" requests or headers from these browsers. To learn more about your options for not having this information used by certain service providers, visit our Cookie Consent Tool. Opting out of this practice does not opt you out of being served advertising — you will continue to receive generic ads. 

Children's privacy

Our websites and online marketing are not directed to, and Entegral 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 Entegral in accordance with the "Contacting Entegral" section below.

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 us to enter into a contract with you and provide services to you, including:

- To send you important information regarding the Services, changes to Entegral terms and conditions or policies and/or other administrative information.
- To respond to your enquiries and fulfil your requests, such as to send you email alerts.
- To provide products and services you request, for example, to process your payments, have your order delivered to you, communicate with you regarding your purchase and provide you with related customer service.
- To provide the functionality of the services and products requested.

Where necessary for us to comply with a legal obligation, including:

- To share information with government and regulatory authorities when required by law or in response to legal process, obligation or request. 

Where you have given consent, including:

- To combine your name with your geographical location so that we can provide you with better targeted and personalised marketing.
- To send you marketing communications and other information that we believe may be of interest to you, including information about trade shows.
- To personalise your experience on the Site by presenting products and offers tailored to you.
- To facilitate satisfaction surveys or user survey requests.

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

- To enable Entegral business purposes, such as data analysis, audits, researching and developing new products and services, enhancing the Site, improving the Services and Software Products, developing marketing events, identifying usage trends and determining the effectiveness of Entegral promotional campaigns.
- To permit you to register and participate in technology forums and other events with Entegral.

Retention of your personal information

We retain your personal information for as long as we need to fulfil our business needs and legal requirements.

Who we share information with

Our service providers

We will share your information with third parties, such as

- Any affiliate of Entegral for the purposes described in this Privacy Policy;
- Vendors, consultants and other service providers who need access to such information to carry out work on our behalf such as website hosting or data analysis, including, but not limited to, the use of Google Analytics (http://www.google.com/policies/privacy/partners/), payment processing, order fulfilment, product distribution, infrastructure provision, IT services, customer service, email delivery services, credit card processing, auditing services and other similar services to enable them to provide services;
- Agents and distributors to facilitate the provision of Entegral products and services, which may include marketing communications.

Government authorities

Your personal information may also be shared with government authorities as described above.

Sale, merger or change in control

Your information may also be transferred to another company in the event of a transfer, change of ownership, reorganisation, or assignment of all or part of Entegral's businesses or assets. This will occur if the parties have entered into an agreement under which the collection, use and disclosure of the information is limited to the purposes of the business transaction, including a determination whether or not to proceed with the business transaction. If required by law, you will be notified via email or prominent notice on our websites of any such change in ownership or control of your personal information or as otherwise may be required or permitted by law.

Testimonials

We may post customer testimonials on our websites which may contain personal information. We may use a third-party provider to manage this process. This provider would be responsible for obtaining your consent as necessary, removing content upon your request and answering any questions you may have.

Global data transfers and processing

In order for us to operate and provide you with services globally, the information you provide us or that we collect may be transferred or accessed by entities outside of your jurisdiction, including:

- Administrative and technical support based in the United States: Entegral maintains some of its global information systems in the United States. If you provide us with, or if we collect personal information about you, outside the United States, we will transfer your personal information to the United States.  

For residents of the European Economic Area, United Kingdom and Switzerland, when we transfer your personal information and process it in the United States, we do so in accordance with approved standard contractual clauses. 

- Third-party service providers: We utilise third-party service providers who are located outside of the European Economic Area, such as call centre support and IT providers. When we transfer your personal information to our third-party service providers who are located outside the EEA, we use approved standard contractual clauses.

Your rights

EU General Data Protection Regulation (GDPR) and UK Data Protection

If GDPR or UK Data Protection is applicable to your transaction in the European Economic Area or United Kingdom, you have the right to:

- Opt out of some collection or uses of your personal information, including the use of cookies and similar technologies and the use of your personal information for marketing purposes, and the anonymisation of your personal information for data analyses;
- Access your personal information, rectify it, restrict or object to its processing, or subject to exemptions under law, request its deletion;
- Receive the personal information you provided to us to transmit it to another company;
- Withdraw any consent provided; and
- Where applicable, lodge a complaint with your supervisory authority.
- Contact our Data Protection Officer (DPO@ehi.com) or submit a privacy complaint through our Global Privacy Portal form.

California

Under the California Consumer Privacy Act (CCPA), California residents have certain rights with respect to personal information about them that we have collected. If you are a California resident, you may exercise the following rights regarding your personal information, subject to certain exceptions and limitations:

- Right to access the personal information we have collected about you and learn how we collect this information, our purpose in collecting it and the types of parties we may have disclosed it to;
- Right to correct inaccurate personal information;
- Right to delete the personal information we have collected from you;
- Right to opt out of our sale(s) of your personal information; and
- The right not to receive discriminatory treatment for the exercise of [the relevant] privacy rights conferred by the CCPA.

Virginia

Under the Virginia Consumer Data Protection Act (CDPA), Virginia residents have certain rights with respect to personal information about them that we have collected. If you are a Virginia resident, you may exercise the following rights regarding your personal information, subject to certain exceptions and limitations:

- Right to confirm the processing of and access to your personal information;
- Right to correct inaccurate personal information we have collected from you;
- Right to delete the personal information we have collected from you; and
- Right to opt out of targeted advertising. 

You also have the right to appeal the decision we have made in connection with your privacy rights request. Please submit all appeal requests by replying to the communication resolving your original request or emailing us at privacyrequests@ehi.com.

Virginia, Colorado and Connecticut

Under the Virginia Consumer Data Protection Act (CDPA), the Colorado Privacy Act and the Connecticut Data Privacy Act, residents of those states have certain rights with respect to personal information about them that we have collected.  If you are a Virginia, Colorado or Connecticut resident, you may exercise the following rights regarding your personal information, subject to certain exceptions and limitations:

- Right to confirm the processing of and access to your personal information;
- Right to correct inaccurate personal information we have collected from you;
- Right to delete the personal information we have collected from you; and
- Right to opt out of targeted advertising. 

Virginia and Colorado residents have the right to appeal the decision we have made in connection with your privacy rights request. Please submit all appeal requests by replying to the communication resolving your original request or emailing us at privacyrequests@ehi.com.

Nevada

While we do not sell your data, under Nevada law, residents still may submit a request to not have their data sold.  If you are a Nevada resident, you can exercise this right by emailing us at privacyrequests@ehi.com.

Canada

If you are a resident of Canada, outside of Quebec, you have the right to:

- Access your personal information and rectify it;
- Withdraw any consent provided; and
- Where applicable, lodge a complaint with your supervisory authority.

Quebec

Quebec residents have certain rights with respect to personal information about them that we have collected. If you are a Quebec resident, you may exercise the following rights regarding your personal information, subject to certain exceptions and limitations:

- Right to access the personal information we have collected about you;
- Right to correct your personal information if you discover that any of it is inaccurate, incomplete or out of date;
- Right to request that we delete the personal information we have collected from you;
- Right to object to and restrict the processing of your personal information that is no longer accurate or necessary;
- Right to withdraw your consent given for processing of your personal information; and
- Right to receive the personal information we have collected from you in a structured, commonly used and machine-readable format.

Exercising your rights

You may exercise any applicable rights described above by accessing our Global Privacy Portal on our Contact Us page. If you wish to lodge a complaint with a supervisory authority, in Europe you may contact the necessary supervisory authority.

We may require additional information from you to verify your identity and residence before we can process your request. For California and Virginia residents, wishing to exercise rights under their state's privacy law, you may be required to provide your driving licence or official state identification document in order to provide proof of residence.  Please make sure that you redact your photograph and all identifying information, other than your name, address and driving licence number.  We also reserve the right to restrict access to your information or to limit your rights (e.g., if such disclosure is prohibited by law or if the rights of another individual might be violated).  In some instances, this may mean that we are able to retain your personal information even if you withdraw your consent.

California residents may designate an authorised agent to make a CCPA request on your behalf by completing and signing the form available here.

In Canada, you may contact the Privacy Commissioner of Canada by visiting https://www.priv.gc.ca/cu-cn/index_e.asp or at Office of the Privacy Commissioner of Canada, 30 Victoria Street, Gatineau, Quebec, K1A 1H3. If you live in British Columbia, Alberta or Quebec, please refer to the following resources. In British Columbia, you may find information on how to exercise your rights at the British Columbia Office of the Information and Privacy Commissioner website. In Alberta, you may find information on access requests here and making complaints here. In Quebec, you may find information on your privacy rights here at the Commission d’accès à l'information du Québec website.

Marketing preferences

You have the right to object to direct marketing. You will be able to opt out of direct marketing communications from Entegral by following the instructions in each communication you receive. You may also contact Entegral in accordance with the "Contacting Entegral" section below.

You can opt out of display ads you see on non-Entegral sites by clicking on the ad choices icon in the ad or through the privacy settings on the site. 

Changes to this Policy

As necessary, we will update our Privacy Policy to reflect changes in our privacy practices. If required by law we make any material changes, we will notify you by email (sent to the email address specified in your account) or by means of a notice on this site or as otherwise may be required or permitted by law, prior to the change becoming effective. We encourage you to periodically review this site for the latest information on our privacy practices.

Contacting Entegral

If you have any questions about this Privacy Policy or wish to contact our Privacy Officer, you may submit your request to privacy@entegral.com or privacy-eu@entegral.com.

I AM A VEHICLE OWNER, CUSTOMER OF A REPAIR FACILITY, OR CUSTOMER OR CLAIMANT OF AN INSURANCE COMPANY

The information below is intended to provide general descriptions about information processed by Entegral on behalf of its clients.  Most of the information about you is provided to Entegral by repair facilities and insurance companies in the course of managing your claim and repairing.   Please refer to their specific privacy policies for more information on how they collect, use and share your data.       

Examples of information Entegral processes on behalf of its clients

- Contact information, including name, phone numbers and email address
- Vehicle information, including VIN, make, model, colour and odometer reading
- Claim information, including insurance company, policy number, claim information, policy limits and adjuster name
- Repair information, including photos and descriptions of damage, estimates, approvals, parts and repairs performed
- When enabled on Entegral apps, your geolocation
- When enabled on Entegral apps, photos from your mobile device
- Services requested, including rental car reservations, tow dispatches, repair facility appointment scheduling, and any other services you request through Entegral websites or mobile apps

How Entegral uses information about you

- To allow repair facilities to manage their day-to-day operations and repair estimating activities. This includes creating and modifying repair estimates, capturing photos of vehicle damage, electronically communicating with repair approvers for authorisations, and parts ordering.   Some Entegral products help repair facilities to manage their operations, such as job scheduling, parts inventory, document storage, invoicing, reporting and HR functions, such as scheduling, timekeeping and compensation information.
- To allow insurance companies and repair facilities to provision additional services for their customers. These services can include scheduling an appointment at a repair facility, reserving a rental car or requesting a tow service.
- To provide websites and apps, such as Smart Assist, which allows users to expedite their claims and vehicle repairs by entering certain information about the claim and/or repair themselves. This includes entering details of the accident, uploading images of damage, scheduling an appointment at a repair facility, reserving a rental car, requesting a tow provider and communicating with the relevant parties.

How Entegral gets my information

As mentioned above, most of the information about you is provided to Entegral by repair facilities and insurance companies in the course of managing your claim and repairing your vehicle. Some information is provided directly by you, for example information you enter into Entegral websites or mobile apps, such as Smart Assist.  

Some information is collected automatically when you use Entegral services and apps, such as computer type, operating system, browser settings, IP address and how you interact with the service or app.

With your consent, the Entegral services and apps will access location-based information from your mobile device, such as precise geolocation, zip or postcode, city, metropolitan area or geographic region from your mobile device. This information will be used to identify nearby repair facilities, rental car locations and/or dispatch towing services. Also with your consent, the services and mobile apps will access your device's camera or photo album to allow you to upload photos of your vehicle and damage. If you have allowed the services or apps to utilise your location information or your device's camera in the past, and wish to revoke the permissions, please change the settings on your device.  

Who Entegral shares information with

- Service providers and business partners such as technical support providers and other providers in the claim and repair process, such as repair facilities, insurance companies, tow vendors and rental car companies;
- Law enforcement and government and regulatory authorities, when we are required to do so by law or in response to legal process, obligation or request;
- As directed by you or by a data controller, such as a repair facility, insurance company or fleet manager, to facilitate the processing of your claim and repair.

Global data transfers and processing

In order for Entegral to operate and provide services globally, the information you provide us or that we collect may be transferred or accessed by entities around the world, including:

- Administrative and technical support based in the United States. Entegral maintains some of its global information systems in the United States. If you provide us with, or if we collect personal information about you, outside the United States, we will transfer your personal information to the United States.  When we transfer your personal information and process it in the United States, we do so in accordance with U.K.- and European Commission-approved standard contractual clauses.
- Third-party service providers. We use third-party service providers who are located outside of the European Economic Area, such as call centre support and IT providers. When we transfer your personal information to our third-party service providers who are located outside the EEA, we use European Commission-approved standard contractual clauses.

Your rights

If Entegral receives a request from an individual to access, update or delete personal information we have collected on behalf of a client in the course of providing services, we will direct that individual to the relevant client.