Legal / Car Rental Privacy Addendum

Car Rental Privacy Addendum

Version 1.0 (Draft) Effective: Pending legal review
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Draft — Pending Legal Counsel Review

This document is a working draft prepared for engineering and product review. It has not been reviewed or approved by qualified legal counsel and does not yet constitute a binding notice. The lawful bases and retention periods below reflect the platform's current implementation and are subject to change before launch.

1. Scope & Controller

This Addendum supplements the OnFire Privacy Policy and describes how we process personal data specific to peer-to-peer car rentals. Where it addresses data protection under the EU/UK General Data Protection Regulation (GDPR), OnFire acts as controller for the platform data described here. Owners who receive renter data to fulfil a rental act as independent controllers for their own use of that data.

2. Data We Process & Lawful Basis

For car rentals we process the following categories of personal data on the GDPR lawful bases shown:

Data Purpose Lawful basis (GDPR Art. 6)
Driving licence details & licence image Verify the renter is eligible and legally permitted to drive; fraud prevention Art. 6(1)(b) performance of the rental contract; Art. 6(1)(c) legal obligation; Art. 6(1)(f) legitimate interests (fraud prevention, safety)
Date of birth Confirm the minimum driver age for the listing; payment and identity verification Art. 6(1)(b) contract; Art. 6(1)(f) legitimate interests (age eligibility, fraud prevention)
Vehicle condition photographs (start/end of trip) Evidence of vehicle state at handover and return; resolve damage, mileage, and fuel disputes Art. 6(1)(b) contract; Art. 6(1)(f) legitimate interests (dispute resolution, establishing/defending legal claims)
Booking, pricing & payment records Process the rental, deposits, payouts, and refunds; meet tax/accounting obligations Art. 6(1)(b) contract; Art. 6(1)(c) legal obligation (financial record-keeping)

A licence image and date of birth are handled as identity-grade personal data with restricted access. We do not use these for advertising or profiling.

3. Who We Share It With

  • The Owner, to the extent needed to verify eligibility and complete the rental (for example, confirmation that a valid licence was checked).
  • Payment processors, to place deposit holds, take payment, and issue refunds and payouts.
  • Identity/fraud-check providers, where used to validate licence or age data.
  • Authorities, where required by law or to establish, exercise, or defend legal claims (for example, following an incident or a lawful request).

4. Retention Periods

We keep personal data only as long as needed for the purposes above, using two windows measured from the end of the trip:

PII minimization window — 90 days (default)

Renter identity-grade PII — driving licence details and image, date of birth, and free-text notes — is redacted or scrubbed by default 90 days after the trip ends.

Financial / legal-hold window — 7 years (default)

Non-PII booking and financial records (amounts, dates, fees, payout and refund records) are retained for a default 7 years to meet tax and accounting obligations, after which the record is archived.

Open-dispute exception

Where a deposit claim or dispute is open, related evidence (including condition photographs) is preserved beyond the 90-day PII window until the case reaches a final outcome, so it remains available to resolve the claim fairly.

These default periods may be adjusted where a longer or shorter period is required by law. The PII window is always shorter than or equal to the financial window.

5. Your Rights

Subject to law, you may request access to, correction of, or erasure of your personal data, and may object to or restrict certain processing. Because some records are kept to meet legal obligations or to defend legal claims (for example, financial records and open-dispute evidence), we may not be able to erase all data on request until those obligations lapse. To exercise your rights, contact [email protected]. See the main Privacy Policy for full details and how to lodge a complaint with a supervisory authority.

This Addendum forms part of the OnFire Privacy Policy for the purposes of car rentals.

Draft document — pending legal counsel review. Not yet effective.