Private Policy 

Brownstone Car Rental  cares deeply about the privacy of its visitors and users. To that end, this Privacy Policy (“Privacy Policy”) describes how Brownstone Focus L.L.C., together with its affiliated companies worldwide (“Brownstone Car Rental”, “we”, “our”, or “us”), collect, use, and share your Personal Information, as well as an explanation of the data rights you may have in that Personal Information. This Privacy Policy applies to all Brownstone Car Rental users, including unregistered visitors, registered users, and premium users (collectively, “Users”, “you”, or “your”), and to all Brownstone Car Rental services, including our websites (including www.Brownstone Car Rental and any of its subdomains, the “Website”), web applications (“Brownstone Car Rental Apps”), mobile applications (“Mobile Apps”), and related services (collectively, the “Services”). This Privacy Policy is not intended to override the terms of any contract you have with us, nor any rights you may have under other applicable data privacy laws.

Prior to accessing or using our Services, please read this policy and make sure you fully understand our practices in relation to your Personal Information.  If you read and fully understand this Privacy Policy, and remain opposed to our practices, you must immediately leave and discontinue all use of any of our Services.  If you have any questions or concerns regarding this policy, please contact us here.

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2. User Information 

2.1. User information:

To provide you the Services, we must collect Personal Information relating to an identified or identifiable natural person (“Personal Information”). We collect Personal Information you provide us, from your use of the Services, and from other sources. Here are the types of Personal Information we collect about you:

1. Information you provide us. When you register for our Services, sign up for any Brownstone Car Rental events, subscribe to our blog(s) or newsletter(s), purchase and/or register domain names, use any of our Services; and/or when you contact us directly by any communication channel (e.g., Brownstone Car Rental’s support tickets, emails), you may provide us Personal Information, such as name, email address, phone number, payment information (for Users with Paid Services), information you include in your communications with us and with other users on our platform, and Personal Information contained in scanned identification documents (such as an ID card, driver’s license, passport, or official company registration documents).  

2. Information we collect when you use the Services. When you visit, download, and/or use any of our Services, we may collect aggregated usage Personal Information, such as Visitors’ and Users’ browsing and ‘click-stream’ activity on the Services, session heatmaps and scrolls, non-identifying Personal Information regarding the Visitor’s or User’s device, operating system, internet browser, screen resolution, language and keyboard settings, internet service provider, referring/exit pages, date/time stamps, etc

3. Information we collect from other sources. We may receive Personal Information about you from third-party sources, such as i) security providers , fraud detection and prevention providers for example to help us screen out users associated with fraud, ii) social media platforms, when you log-in or sign-up using your social media account, we may receive Personal Information from that service (e.g., your username, basic profile Personal Information) and in some cases, we may collect Personal Information from lead enhancement companies which help us to improve our service offering; iii) advertising and marketing partners in order to monitor, manage and measure our ad campaigns.

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2.2. Users of users ‘Personal Information’

We may also collect Personal Information pertaining to visitors and users of our User’s websites or services (“Users-of-Users”), solely for and on our Users’ behalf (as further described in Section ‎6 below).

2.3. Brownstone Car Rental jobs applicant information

We also collect information that is provided to us by Brownstone jobs candidates (“Applicants”), when they apply to any of the open positions published at https://www.brownstonerental.com, by e-mail or otherwise (as further described in our Privacy Policy for Job Applicants).

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3. Why do we collect such ‘Personal Information’

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We use your Personal Information for the following purposes:

1. To provide and operate the Services;

2. .To further develop, customize, expand, and improve our Services, based on Users’ common or personal preferences, experiences and difficulties;

3. To provide our Users with ongoing customer assistance and technical support;

4. To be able to contact our Users with general or personalized service-related notices and promotional messages (as further detailed in Section 8 below);

5. To help us to update, expand and analyze our records to identify new customers;

6. To facilitate, sponsor, and offer certain contests, events, and promotions, determine participants’ eligibility, monitor performance, contact winners, and grant prizes and benefits;

7. To analyze our performance and marketing activities;

8. To create aggregated statistical data and other aggregated and/or inferred information, which we or our business partners may use to provide and improve our respective services;

9. To provide you with professional assistance.

10. To enhance our data security and fraud prevention capabilities; and

11. To comply with any applicable laws and regulations.
    
    We may use techniques like “machine learning” (European law refers to this as “automated decision-making”) to help us improve our services. When we use machine learning, we either: (i) still have a human being involved in the process (and so are not fully automated); or (ii) use machine learning in ways that don’t have significant privacy implications (for example, reordering how applications might appear when you visit the Brownstone Car Rental App Market). We may also use machine learning to help us monitor, identify, and suspend accounts sending spam, or engaging in other abusive or fraudulent activity.
     

We use your Personal Information for the purposes set out in Section 3 where:

1. Our use of your Personal Information is necessary to perform a contract or to take steps to enter into a contract with you (e.g. to provide you with a website builder, to provide you with our customer assistance and technical support);

2. Our use of your Personal Information is necessary to comply with a relevant legal or regulatory obligation that we have; or

3. Our use of your Personal Information is necessary to support legitimate interests and business purposes (for example, to maintain and improve our Services and the effectiveness of Brownstone Car Rental by identifying technical issues), provided it is conducted in a way that is proportionate and that respects your privacy rights.

4. How we share your ‘Personal Information’

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We may share your Personal Information with service providers and others (or otherwise allow them access to it) in the following manners and instances:

Third Party Service Providers:  Brownstone Car Rental has partnered with a number of selected service providers, whose services and solutions complement, facilitate and enhance our own. These include hosting and server co-location services, communications and content delivery networks (CDNs), data and cyber security services, billing and payment processing services, domain name registrars, fraud detection and prevention services, web analytics, e-mail distribution and monitoring services, session recording and remote access services, performance measurement, data optimization and marketing services, content providers, and our legal and financial advisors (collectively, “Third Party Service Provider(s)”). 
 

In case that Brownstone Car Rental shares personal data with a Third Party Service Provider that provides AI services, Brownstone Car Rental will ensure that the Third Party Service Provider is under a contractual obligation not to use the data in order to train or improve its AI models.

4.1.We may share the Personal Information of our Users and Users-of-Users with various third parties, including certain service providers and law enforcement officials.

The Personal Information may be shared solely in accordance with this policy.

Law Enforcement, Legal Requests and Duties: Brownstone Car Rental may disclose or otherwise allow access to any categories of your Personal Information described in this Privacy Policy pursuant to a legal request, such as a subpoena, legal proceedings, search warrant or court order, or in compliance with applicable laws, if we have a good faith belief that the law requires us to do so, with or without notice to you.

4.2.

Protecting Rights and Safety:  Brownstone Car Rental may share any categories of your Personal Information described in this Privacy Policy if we believe in good faith that this will help protect the rights, property or personal safety of Brownstone Car Rental, any of our Users, any Users-of-Users, or any member of the general public, with or without notice to you.

4.3.

Brownstone Car Rental Subsidiaries and Affiliated Companies: We may share your Personal Information internally within our family of companies, for the purposes described in this Privacy Policy. For example, we may share your Personal Information with Brownstone Car Rental.com Inc., our US-based subsidiary, in the course of facilitating and providing you (and your Users-of-Users) with our Services.
Sharing Personal Information by Brownstone Car Rental subsidiaries and affiliated companies in the European Union, the United Kingdom and Switzerland with Brownstone Car Rental’s subsidiaries located outside these regions will only take place under an approved transfer mechanism, such as the relevant Standard Contractual Clauses.

4.4.

In connection with a change in corporate control: In addition, should Brownstone Car Rental or any of its affiliates undergo any change in control, including by means of merger, acquisition or purchase of substantially all of its assets, your Personal Information may be shared with the parties involved in such event.

4.5.

Upon Your Further Direction: The Brownstone Car Rental Services enable you, through different techniques, to engage and procure various third party services, products and tools for enhancing your web or mobile sites, including, without limitation, applications and widgets offered to you by third parties through the Brownstone Car Rental Website (including the Brownstone Car Rental App Market), eCommerce payment providers, third party designers who may assist you with your website, etc. (collectively, “Third Party Services”). If you choose to engage with such Third Party Services, they may have access to and process Personal Information of your Users-of-Users collected through your web or mobile sites. For example:

a) Framed Pages: our Services may enable you to integrate Third Party Services directly into your web or mobile sites, such as via page framing techniques to serve content to or from Third Party Services  or other parties (“Frames”). In these circumstances, the Third Party Services may collect Personal Information from your Users-of-Users.

b) App Market Developers: We allow third party developers (“Third Party Developer(s)”) to develop and offer their own applications via the Brownstone Car Rental App Market (“Third Party App(s)”) to Users, which you may integrate into your web or mobile sites. Each Third Party Developer is bound by the Brownstone Car Rental App Market Partner Agreement, which among other things, restricts the ways in which such developers may access, store, share, and use the Personal Information you and/or your Users-of-Users provide to them.

c) Social Media Features: Our Services may enable you to integrate certain Social Media features, widgets, and single sign on features, such as “Facebook Connect,” or “Google Sign-in” (“Social Media Features”) into your web or mobile sites. These Social Media Features may collect certain Personal Information from your Users-of-Users such as identifiers, including name, alias, unique personal identifier, online identifier, internet protocol address, email address, or other similar identifiers. Social Media Features are hosted either by a third party or directly on our Services.

Please note that in the examples listed above in this Section 4.6, Brownstone Car Rental merely acts as an intermediary platform allowing you to procure the services of such Third Party Services (including, but not limited to, Third Party Developers, Third Party Apps and Social Media Features) with which you are interacting directly, and at your discretion. In this respect, Brownstone Car Rental acts as a service provider to you, disclosing information to the Third Party Services on your behalf. Brownstone Car Rental will share your Users-of-Users’ Personal Information with Third Parties Services only upon your direction or with your permission and is not, and shall not be, in any way responsible for such Third Party Services processing of such Personal Information, or liable with respect thereto.

Brownstone Car Rental does not control and is not responsible for the actions or policies of any Third Party Service, and your use of any Third Party Service is at your own risk. We encourage you to review any privacy policy accompanying a Third Party Service and ask such Third Party Service for any clarifications you may need before deciding to install and/or use their services. 

5. Where do we Store/Process your ‘Personal Information’?

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Brownstone processes data about individuals across the world and may transfer your Personal Information outside of your country. Your security, privacy and confidentiality are our top priority and that's why Brownstone Car Rental conducts a vetting process that includes an assessment of the privacy laws in those countries to validate they have strong data protection laws.

5.1.

User's personal information is controlled by Brownstone Car Rental.com Ltd. in Israel, which the European Commission considers as a country offering an adequate level of protection for the Personal Information of E.U. Member State residents (see here).

5.2.

If you are in Europe, the U.K., or Switzerland, when we transfer your Personal Information to a location outside of Europe, We will make sure that (i) there is a level of protection deemed adequate by the European Commission or (ii) that the relevant Standard Contractual Clauses are in place (i.e., the applicable module of the Standard Contractual Clauses for the transfer of personal data to third countries pursuant to Regulation (E.U.) 2016/679 of the European Parliament and of the Council from June 4, 2021, as available here, and the ICO’s International Data Transfer Addendum to the E.U. Commission Standard Contractual Clauses version B1.0, in force from 21 March 2022, as it is revised under Section ‎‎18 of its Mandatory Clauses), or (iii) we comply with Data Privacy Framework as applicable to data transfers to the United States and specified in clause 5.4 below, or (iv) we use another legally recognized transfer mechanism in the applicable jurisdiction.

5.3.

We may store and process Personal Information in the USA, Europe, Israel, or other jurisdictions, whether by ourselves or with the help of our affiliates and service providers.

Brownstone Car Rental’s data storage providers are contractually committed to protect and secure your data.

Among other things, Brownstone Car Rental will ensure that there is the adequate level of protection or that relevant Standard Contractual Clauses are in place for the international transfer of our EU users’ data.

When Brownstone Car Rental transfers E.U. Personal Information to a third country that the European Commission did not find will adequately protect your information, Brownstone Car Rental ensures that it has taken additional measures to comply with the European data protection laws.

Data Privacy Framework: Brownstone Car Rental and its covered entities DeviantArt, Inc., InkFrog, Inc, Modalyst, Inc and SpeedTab, Inc, complies with Data Privacy Framework (“DPF”) that embeds the EU-U.S. Data Privacy Framework (“EU-U.S. DPF”), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (“Swiss-U.S. DPF”) as set forth by the U.S. Department of Commerce, European Commission, UK Government, and Swiss Federal Administration regarding the collection, use, and retention of personal information transferred from the European Union, the United Kingdom (and Gibraltar), and Switzerland to the United States. Brownstone Car Rental has certified to the U.S. International Trade Administration (ITA), within the U.S. Department of Commerce that it adheres to the Data Privacy Framework Principles. If there is any conflict between the terms in this Policy and the Data Privacy Framework Principles, the Data Privacy Framework Principles shall govern. Brownstone Car Rental’s commitment to subject the personal information described in this Policy to the Data Privacy Framework is subject to the enforcement and investigative powers of the United States Federal Trade Commission.

To learn more about the Data Privacy Framework Program visit  https://www.dataprivacyframework.gov, 

Brownstone Car Rental may share personal information with third parties under certain circumstances described in this Policy, subject to obligations under the Data Privacy Framework Principles extend to third parties acting as agents who help us run our business and provide services, and Brownstone Car Rental remains liable should a third party acting as our agent process personal information subject to this Policy in a manner inconsistent with this Policy, except where Brownstone Car Rental is not responsible for the event giving rise to the damage. 

In compliance with the Data Privacy Framework Principles, Brownstone Car Rental commits to resolve complaints about our collection or use of your personal information.  E.U., UK and Swiss individuals with inquiries or complaints regarding our  Data Privacy Framework policy should first contact us at: info@BrownstoneRental.com.

Brownstone Car Rental.com  commits to cooperate and comply respectively with the advice of the panel established by the EU data protection authorities (DPAs) and the UK Information Commissioner’s Office (ICO) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) with regard to unresolved complaints concerning our handling of personal data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF.

Brownstone Car Rental.com has further committed to refer unresolved  Data Privacy Framework complaints to an alternative dispute resolution provider located in the United States. If you have an unresolved privacy, or data use, concern that we have not addressed satisfactorily, please contact our U.S.-based third-party dispute resolution provider TRUSTe at https://feedback-form.truste.com/watchdog/request for more information or to file a complaint.  The services are provided at no cost to you.

If you have such an unresolved complaint, under the recourse mechanism you may contact the applicable  EU Data Protection Authorities (free of charge). Brownstone Car Rental commits to cooperate with the DPAs and comply with the advice given by such authorities.

If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, you may - under certain conditions described on the Data Privacy Framework website - invoke binding arbitration when other dispute resolution procedures have been exhausted. For more information on this option, please see Annex I of the Data Privacy Framework Principles.

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