Dealer Rent A Car LLC Effective

1.  Introduction

Dealer Rent A Car LLC, a company organised under the laws of the United Arab Emirates and operating from Abu Dhabi, United Arab Emirates (“Dealer Rent A Car”, “we”, “us” or “our”), respects the privacy of its customers, authorised drivers, website visitors, prospective customers and other individuals whose personal data we process.

This Privacy Policy explains how we collect, use, store, disclose and otherwise process personal data in connection with:

• vehicle enquiries, reservations and rentals;
• our website, mobile pages and online booking facilities;
• communications by telephone, email, SMS, WhatsApp or other digital channels;
• payment, security deposit and credit-card authorisations;
• vehicle tracking, recovery and fleet-management systems;
• traffic fines, tolls, parking charges, accidents and insurance claims; and
• our other products, services and business

We process personal data in accordance with applicable laws of the United Arab Emirates, including Federal Decree-Law No. 45 of 2021 Concerning the Protection of Personal Data, to the extent applicable.

2.  Who Controls Your Personal Data

The entity responsible for processing your personal data is:

Dealer Rent A Car LLC

Al Salam St, Al Danah, E18 03, Abu Dhabi, United Arab Emirates Telephone: +971 2 4466600

Email: drive@casanova.ae

Privacy-related enquiries and requests may also be sent to drive@casanova.ae.

3.  Personal Data We Collect

Depending on your interaction with us, we may collect the following categories of personal data.

3.1  Identity information

• full name;
• date of birth and age;
• nationality;
• gender, where shown on an identity document;
• signature;
• Emirates ID details;
• passport and visa details;
• photographs and copies of identity documents; and
• company name, trade-licence information and authorised representative details where the tenant is a legal entity.

3.2  Driver and licence information

• driving-licence number;
• issuing country or authority;
• licence issue and expiry dates;
• permitted vehicle categories;
• copies or images of the driving licence;
• details of additional authorised drivers; and
• information required to determine whether a licence is recognised in the

3.3  Contact information

• residential or business address;
• email address;
• telephone and mobile number;
• WhatsApp number; and
• emergency-contact information where

3.4  Reservation and rental information

• booking dates and rental period;
• vehicle category and allocated vehicle;
• pickup and return locations and times;
• rental-agreement number;
• agreed mileage limit;
• starting and ending mileage;
• fuel level;
• vehicle inspection and condition reports;
• photographs or videos of the vehicle;
• additional-driver information;
• rental extensions, amendments and cancellations;
• customer instructions and preferences; and
• communications concerning the

3.5  Payment and financial information

• payment method;
• credit- or debit-card information processed by us or an authorised payment provider;
• cardholder name;
• billing address;
• transaction references;
• rental charges;
• security deposit and pre-authorisation information;
• payment history;
• refunds;
• outstanding balances;
• chargebacks;
• insurance excess and damage charges; and
• information associated with a credit assessment undertaken through Al Etihad Credit Bureau where legally permitted and reasonably necessary.

We may retain masked or tokenised card details and payment authorisations. Full card details may instead be held by the relevant payment processor in accordance with its security requirements.

3.6  Driving, vehicle and location information

Vehicles may be fitted with GPS, telematics, security or fleet-management technology. Depending on the equipment installed, we may collect:

• vehicle location;
• route and journey information;
• date and time of vehicle use;
• mileage and odometer information;
• speed or driving-event information;
• ignition status;
• fuel or battery information;
• diagnostic and maintenance information;
• unauthorised movement alerts;
• geographic-boundary alerts;
• vehicle-recovery information; and
• information concerning the activation of an immobilisation or disabling function, where fitted and lawfully

Vehicle tracking is used for legitimate rental, safety, security, recovery, payment-default, fleet-management and legal-compliance purposes. It is not intended to be used for unrelated surveillance.

3.7  Traffic, toll and incident information

• Salik, Darb and other toll records;
• traffic fines and offences;
• parking violations;
• impoundment records;
• police and accident reports;
• details of witnesses and third parties;
• insurance claims and correspondence;
• photographs, videos and damage reports;
• repair estimates, invoices and technical assessments;
• roadside-assistance records; and
• information concerning the loss, theft, misuse or recovery of a

3.8  Communications and electronic records

We may retain communications exchanged through:

• telephone calls;
• email;
• SMS;
• WhatsApp;
• website forms;
• social-media channels; and
• other electronic communication

This may include messages, voice notes, photographs, PDFs, identity documents, payment confirmations and rental instructions.

Telephone calls may be recorded where permitted by law and where an appropriate notice is provided.

3.9  Website and technical information

When you use our website or online services, we may collect:

• IP address;
• device and browser type;
• operating system;
• referring pages;
• pages visited;
• booking-session information;
• approximate location derived from an IP address;
• website activity;
• cookie identifiers; and
• error, security and diagnostic

4.  How We Collect Personal Data

We may obtain personal data:

• directly from you;
• from an additional driver or a person booking on your behalf;
• from your employer, company, travel agent, hotel or booking partner;
• from payment processors and banks;
• from Al Etihad Credit Bureau, where a lawful and appropriate credit check is undertaken;
• from government, police, traffic, toll, parking and licensing authorities;
• from insurers, loss adjusters, repair facilities and roadside-assistance providers;
• from GPS, telematics and vehicle-security systems;
• from publicly accessible or legally authorised sources; and
• from our website, systems and communications with

A person providing information about another individual must have authority to do so and should ensure that the individual is informed about this Privacy Policy.

5.  Why We Process Personal Data

5.1  Reservations and rental agreements

We may process personal data to:

• respond to enquiries;
• create and manage reservations;
• verify identity, age and driver eligibility;
• prepare and perform rental agreements;
• assign, deliver and collect vehicles;
• register additional drivers;
• process extensions, replacements and rental closure;
• document vehicle condition; and
• provide customer

5.2  Payments and account administration

We may process personal data to:

• collect rental charges;
• take or release security deposits and card pre-authorisations;
• charge authorised amounts;
• issue invoices and refunds;
• pursue overdue amounts;
• administer payment disputes and chargebacks;
• conduct fraud and risk checks; and
• undertake credit assessments where reasonably necessary and legally

5.3  Vehicle safety, security and recovery

We may process personal data to:

• locate and recover vehicles;
• respond to suspected theft, fraud, unauthorised use or abandonment;
• protect customers, vehicles and other road users;
• detect use outside authorised areas;
• support maintenance and breakdown response;
• investigate misuse or contractual breaches; and
• lawfully disable or immobilise a vehicle where permitted, operationally safe and justified by serious contractual default or security concerns.

5.4  Accidents, damage and insurance

We may process personal data to:

• record pre-existing and return-condition damage;
• investigate accidents and incidents;
• obtain police reports;
• assess damage and repair costs;
• administer insurance claims;
• recover uninsured losses or contractual charges;
• deal with third-party claims; and
• protect or exercise legal

5.5  Legal and regulatory compliance

We may process personal data to:

• comply with UAE laws and lawful authority requests;
• transfer or process traffic fines and violations;
• respond to police, court, insurance, transport or regulatory authorities;
• retain required commercial and accounting records;
• prevent and investigate unlawful activity; and
• establish, exercise or defend legal

5.6  Communications

We may process personal data to:

• send reservation confirmations;
• send payment reminders;
• provide collection, return and extension instructions;
• communicate safety, accident or vehicle-recovery information;
• exchange rental documents through WhatsApp or other agreed channels; and
• respond to questions, complaints and

5.7  Service improvement and administration

We may process personal data to:

• manage our fleet;
• maintain service quality;
• train personnel;
• conduct internal audits;
• produce aggregated business statistics;
• protect our systems; and
• improve our website, booking process and customer

5.8  Marketing

Where required, we will obtain your consent before sending promotional communications by email, SMS or WhatsApp.

You may withdraw your marketing consent or unsubscribe at any time. Service-related communications concerning an active or completed rental are not marketing communications and may continue where necessary.

6.  Legal Grounds for Processing

Depending on the circumstances and applicable law, we may process personal data where:

• processing is necessary to enter into or perform a rental agreement;
• you have provided valid consent;
• processing is necessary to comply with a legal obligation;
• processing is required to protect the interests of the data subject;
• processing is necessary to establish, exercise or defend legal claims;
• processing is necessary for permitted public-interest or authority-related purposes; or
• another lawful ground recognised under applicable UAE law

Where processing is based on consent, consent may be withdrawn, subject to any processing that remains necessary or lawful on another basis.

7.  Vehicle Tracking and Immobilisation

Our rental vehicles may contain GPS or other tracking and security technology. We may review location or telematics information where reasonably necessary to:

• locate a vehicle;
• manage the rental;
• investigate a late or failed return;
• respond to overdue rental payments;
• respond to traffic fines exceeding the applicable contractual threshold;
• detect suspected theft, fraud, unauthorised use or movement outside the UAE;
• arrange emergency, breakdown or recovery assistance;
• protect the vehicle or other persons; or
• comply with a lawful

Where a vehicle has an immobilisation or disabling function, it will only be considered where permitted by law and where it can be activated safely.

We will ordinarily issue written or electronic notice before using that function, except where immediate action is reasonably necessary to address suspected theft, fraud or a serious safety or security risk.

Tracking information will be accessible only to authorised personnel and relevant service providers, subject to appropriate controls.

8.  Credit Checks

Where Dealer Rent A Car reasonably considers it necessary to assess payment risk, particularly for long-term rentals, post-paid arrangements or material overdue balances, we may request a credit report or related information from Al Etihad Credit Bureau.

Any credit check will be conducted only where legally permitted and subject to any notice, consent or authorisation required by applicable law or the relevant bureau.

Credit information will not be used for unrelated purposes.

9.  Disclosure of Personal Data

We may disclose personal data to:

• our employees and authorised representatives;
• payment processors, banks and card networks;
• insurers, brokers, claims handlers and loss adjusters;
• vehicle manufacturers, maintenance providers, garages and repair facilities;
• roadside-assistance, towing, recovery and repossession providers;
• GPS, telematics, security and fleet-management providers;
• booking platforms, travel agents, hotels or corporate-account partners;
• IT, cloud-hosting, cybersecurity, communications and document-storage providers;
• accountants, auditors, lawyers, debt-recovery providers and professional advisers;
• Al Etihad Credit Bureau, where applicable;
• police, courts, public prosecutors, traffic departments, transport authorities, toll operators, parking authorities and other government bodies;
• prospective purchasers, investors or successors in connection with a legitimate corporate transaction; and
• other parties where you direct or authorise us to make the

We do not sell personal data as a standalone commercial product.

10.  International Transfers

Some service providers may process or store personal data outside the UAE.

Where personal data is transferred internationally, we will take reasonable steps to ensure that the transfer is permitted under applicable UAE law. This may include using an approved transfer mechanism, contractual protections, an adequacy basis, consent where appropriate or another lawful exception.

11.  Data Retention

We retain personal data only for as long as reasonably necessary for the purposes for which it was collected, including to:

• perform and administer the rental;
• process delayed traffic fines, tolls and parking charges;
• handle accidents, damage and insurance claims;
• comply with accounting, tax, regulatory and recordkeeping requirements;
• resolve disputes;
• recover outstanding amounts; and
• establish or defend legal

Retention periods may differ by record type:

• rental agreements, invoices and payment records may be retained for the legally required accounting or contractual period;
• accident, damage, insurance and litigation records may be retained until the relevant claim and applicable limitation periods have expired;
• copies of identification documents may be retained for the period reasonably required for rental, compliance, fraud-prevention and legal purposes;
• GPS and telematics records may be retained for a shorter operational period unless required for an incident, dispute, overdue rental, legal request or claim; and
• marketing records may be retained until consent is withdrawn or the information is no longer

When information is no longer required, we will delete, anonymise or securely dispose of it, subject to lawful backup and archival practices.

12.  Data Security

We use reasonable administrative, physical and technical measures designed to protect personal data against unauthorised access, disclosure, alteration, loss, destruction or misuse.

These measures may include:

• access controls;
• user authentication;
• secure payment processing;
• encryption where appropriate;
• personnel confidentiality obligations;
• system monitoring;
• document-handling procedures;
• vendor controls; and
• secure deletion or disposal

No system is completely secure. Customers should avoid sending full payment-card information through unsecured messaging channels unless specifically instructed through an approved process.

13.  Your Rights

Subject to applicable UAE law and any lawful exceptions, you may have the right to:

• obtain information about the processing of your personal data;
• request access to personal data held about you;
• request correction of inaccurate or incomplete data;
• request deletion of personal data;
• request restriction or suspension of certain processing;
• object to or stop processing in applicable circumstances;
• request transfer of personal data where applicable;
• withdraw consent where processing depends on consent; and
• complain about the handling of your personal

These rights are not absolute. We may retain or continue processing information where required for contractual, payment, traffic, insurance, legal, regulatory, fraud-prevention or claims-related purposes.

We may verify your identity before responding to a request. Requests may be sent to drive@casanova.ae.

14.  Cookies and Online Technologies

Our website may use necessary cookies or similar technologies to:

• operate booking functions;
• retain session information;
• protect the website;
• prevent fraud;
• remember preferences;
• measure website performance; and
• understand how visitors use our

Where required, non-essential analytics or advertising cookies will be used only after appropriate consent.

Browser settings may allow you to restrict cookies, although disabling necessary cookies may affect website functionality.

15.  WhatsApp and Digital Communications

Where you communicate with us through WhatsApp or another third-party communication service, that provider may independently process information under its own terms and privacy policy.

We may retain relevant messages, attachments and confirmations as part of the rental record, including where they document:

• a booking;
• an amendment or extension;
• vehicle condition;
• payment instructions;
• an accident or damage report;
• a notice of default;
• consent or authorisation; or
• another material

Customers should ensure that the telephone number supplied to us is secure and under their control.

16.  Children

Our vehicle-rental services are not directed to children. A driver must be at least twenty-one years old.

We do not knowingly collect personal data directly from children for vehicle-rental purposes, except where information is incidentally and lawfully supplied in connection with an accident, emergency, insurance claim or legal obligation.

17.  Third-Party Websites and Services

Our website or communications may contain links to third-party services.

We are not responsible for the privacy, security or content practices of independent third parties.

18.  Complaints

Please first contact us at drive@casanova.ae if you have a concern about our processing of personal data.

We will review the concern and respond within a reasonable period. You may also have the right to submit a complaint to the competent UAE data-protection or regulatory authority.

19.  Changes to This Privacy Policy

We may amend this Privacy Policy to reflect changes in our services, technology, operational practices or legal requirements.

The updated policy will be published with a revised “Last Updated” date. Material changes may also be communicated through our website, email, WhatsApp or another suitable channel.

20.  Contact Us

Questions, requests and complaints concerning this Privacy Policy may be directed to:

Dealer Rent A Car LLC

Al Salam St, Al Danah, E18 03, Abu Dhabi, United Arab Emirates Email: drive@casanova.ae

Telephone: +971 2 4466600