Privacy Policy

  1. Background

We take the protection of personal data seriously and comply with all the legal requirements regarding data protection to ensure maximum protection of your privacy.

The responsible party, that is, the data controller and service provider is Car Sharing Services Malta Ltd, located at 5, Salvatore Psaila Street, Victoria (Gozo) (hereinafter referred to under its brand name "GoTo Malta").

This privacy policy describes the personal information we collect from you and how we use that information. It covers both our collection and use of information when you use GoTo Malta website and GoTo Malta Malta mobile application (our "Sites"), as well as the kinds of information we collect when you join GoTo Malta and use our services. This privacy policy does not apply to other Internet or mobile sites or applications even if accessed via our Sites. By submitting your personal information to us, you consent to GoTo Malta's use and disclosure of your personal information as set forth in this privacy policy. If you do not agree with the terms of this privacy policy, please do not submit any personal information to GoTo Malta. If you have any questions or concerns regarding our privacy policy, please contact us at privacy@goto.com.mt. This privacy policy is incorporated into, and part of, the Subscriber Contract.

1.1. Automated decision making

GoTo Malta does not conduct automated decision making (including profiling) on our Sites users or customers.

1.2. Privacy of children

We do not knowingly solicit or collect individually identifying information from children under the age of 13.

  1. What kinds of personal information do we process?

Personal information means information that identifies you as an individual, or that we can combine with readily available information to identify you as an individual. Processing means any operation or series of operations carried out with or without the aid of automated procedures in relation to personal data, such as the collection, collation, organisation, sorting, storage, adaptation or alteration, reading, retrieval, use, disclosure by transmission, dissemination or any other form of provision, comparison or linking, restriction, erasure or destruction.

We only collect and use personal data from our users which is necessary to provide content for our Sites and our services.

When you use our Sites, our servers automatically log certain information about your use of our Sites that is reported by your computer or mobile device, such as device type, device identifier, network provider, the IP address assigned to your device, browser type or application used, operating system, browser language, and general country/city location (or precise location if location-based services are used by you). We also collect information about how you use our Sites, such as the pages you visit or links you click on.

We also collect your personal information that is necessary to provide GoTo Malta services. To start and terminate the individual lease of our vehicles, it is necessary that we record the starting position and final position, the distance driven, the quantity of fuel used and the time and date of lease. We also process your personal data provided in course of the registration for our services in order to set up your customer account and to contact you for contract related purposes. We collect this data from you in order to fulfil our contractual obligations towards you, and failure to provide such data may mean we are unable to accept you as a client.

Detailed information on what data we collect is provided below.

  1. What are the legal grounds for our processing of your personal information?

The principal purposes for which we collect and store your personal and financial information are to process your application, allow you to reserve and use our vehicles, authorise payment, bill you, respond to your inquiries, improve and communicate with you about our products and services and maintain your account with us.

The collection and use of the personal data of our users take place regularly only with the user's consent. Insofar as we obtain the consent of the data subject for the processing of personal data, Art. 6 para. 1 lit. a GDPR shall apply as the legal basis for the processing of personal data.

An exception applies in those cases in which prior consent cannot be obtained for justifiable reasons and the processing of the data is permitted by legal regulations. For the processing of personal data necessary for the performance of a contract to which the data subject is a party, Art. 6 para. 1 lit. b GDPR is the legal basis. This also applies to processing operations that are necessary for carrying out pre-contractual measures.

The legal basis for such processing of personal data is that the processing is necessary to fulfil a legal obligation to which we are subject,.

If processing is necessary to safeguard a legitimate interest of our company or a third party and if the interests, fundamental rights and freedoms of the data subject do not outweigh this first interest, then the legal basis for processing is that the processing is necessary to fulfil a legal obligation to which we are subject.

  1. Processing of data before registering to the GoTo Malta services

4.1. Cookies

GoTo Malta uses cookies, content and other technologies that are placed in the browser on your computer or mobile device, and can be used to help recognise you on the Sites and improve the user experience.

No personal data is stored in the cookies we use. The cookies we use are also not combined with personal data. In this respect, these cookies cannot be attributed to any particular person. When a cookie is activated, it only receives an identification number. Personal data such as name, IP address, etc. are not assigned to this identification number at any time. Using cookie technology, we only receive anonymous information, such as which pages of our Sites have been visited, etc.

There is a distinction made between two different types of cookies - session ID cookies and persistent cookies. A session ID cookie expires when you close your browser. We use session cookies to maintain session state and user identity. A persistent cookie remains on your hard drive for an extended period of time. We use persistent cookies and content to help remember user preferences and improve the user experience. We also use persistent cookies for re-marketing/targeting to make internet offerings more relevant to Internet users. This technology enables us to address internet users who have already expressed an interest in our Sites on the websites of our partners with GoTo Malta advertising. The insertion of the advertisement is completely anonymous: no personal data is stored at any time and no user profiles are combined with personal data.

You can prevent cookies from being stored by selecting the appropriate settings in your browser; however, if you reject all cookies, some areas of our Sites may not function well or at all.

Our legitimate interest lies in the aforementioned data processing processes and the purposes pursued with them. For this purpose, the legal basis for such processing is that the processing is necessary for the purposes of our legitimate interests.

4.2. Third party ad network providers and other service providers

GoTo Malta may use third party ad network providers and other service providers to help present customised content and offers across various platforms, including the Internet or our Sites. These providers use cookies or similar technologies on your computer or mobile device to help present, better target, and measure the effectiveness of their content and advertisements, using data gathered over time and across their networks of web pages to determine or predict the characteristics and preferences of their audience. We may share certain non-personal information about you (such as age and zip code) with certain ad network and service providers to help them deliver more relevant content and advertisements through their networks. Third party advertisers or service providers we use or provide information to may use cookies, web beacons, or similar technologies in connection with offers, content, and services offered through the Sites, including to help operate ad networks. The use of cookies, web beacons, or similar technologies by content and ad network providers is subject to their own privacy policies, not ours.

We may use advertising platforms provided by Facebook, Google and others to promote interest-based advertisements to you (or to not show you certain advertisements) and to measure how users interact with those advertisements. We may do this using web tracking tools or by converting the email address, phone number or other contact information you have provided to us into a unique value that these platforms may compare to a unique value created from the information you provided to those platforms. Please visit Facebook for information on Facebook's advertising privacy policies and how to opt out https://www.facebook.com/about/privacy. If you would like information on how to control Google Ads, please visit the Google privacy policy at https://policies.google.com/privacy?hl=en. We may also use similar advertising programs for other social media sites you use. If you would like to opt out, please adjust your Facebook, Google and other social advertising settings, use the opt-out features in the advertisement.

Our Sites includes social media features, such as the Facebook Like button and widgets, such as the Share This button that runs on our Sites. These features may collect your IP address, which page you are visiting on our Site, and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on our Sites. Your interactions with these features are governed by the privacy policy of the company providing it.

Our Sites may include links to other websites or mobile applications whose privacy practices may differ from those of GoTo Malta. If you submit personal information to any of those websites, your information is governed by their privacy policies. We encourage you to carefully read the privacy policy of any website you visit or mobile application that you use.

The legal basis for such processing is our legitimate interest lies in the aforementioned data processes.

4.3. Advertising via non-personalised newsletters

If you provide us with your email address by using a form “Subscribe to our Newsletter” on our Sites, we may use this for sending you a non-personalised newsletter.

No data is passed on to third parties in connection with data processing for the dispatch of newsletters. The data will be used exclusively for sending the newsletter.

We collect your email address for this purpose. The identification of your email address and your mobile phone number is carried out by the double opt-in procedure. This means that after processing your data you will receive a separate confirmation email. You will only receive advertising emails after clicking on the link contained in the email confirming your subscription. In addition, we store your IP addresses and the time of registration and confirmation. The purpose of the procedure is to be able to prove your registration and, if necessary, to clarify possible misuses of your personal data.

The data will be deleted as soon as it is no longer needed for achieving this purpose of its collection. To unsubscribe, use the link at the bottom of the newsletter. No data is passed on to third parties in connection with data processing for the dispatch of newsletters. The data will be used exclusively for sending the newsletter.

The legal basis for the dispatch of the non-personalised newsletter as a result of the provision of services is Article 7 para. 3 UWG (Law on Unfair Competition).

4.4. Other

If you contact our customer service using contact form on our Sites, by e-mail or telephone, GoTo Malta collects the information and data (including personal data) provided by you in order to be able to process your request. A further collection and processing of your personal data will only take place if you have given your consent.

  1. Information collected during or after registering for GoTo Malta services

5.1. Registration process

During registration process GoTo Malta collects information that you voluntarily submit to us, which could include your name, email address, postal address, telephone number, passport or national identity card details, should these be required in order to securely identify you, a picture and driver's license, your credit card or other payment information, a PIN, security response and password of your choice. In addition, we will also collect your credit card or other payment information. In addition, we also collect information on your IP address, and the date and time of registration. We may also collect information such as your driving record from you, from regulatory bodies where you live, or from third parties. We use this information to process your application. Additionally, we may also use this information to detect and deter fraud, theft, or abuse of our service.

Your data will be kept for the entire duration of your subscription. After the termination of your contract, all personal data will be irretrievably deleted, unless there are legal retention periods. During the retention period, the personal data required for commercial and tax obligations will be completely blocked and will no longer be accessible for further data processing.

The legal basis for the processing of this data, is that such processing is necessary for the fulfilment of a contract or for the implementation of pre-contractual measures.

5.2. Google Maps

If you join GoTo Malta and use our services, we collect information about your searches for vehicles and your location. To display interactive maps on the Sites we use Google Maps API applications. This application is essential for the functionality and complete provision of our content and services. You can view Google's Terms of Use here: https://policies.google.com/terms?hl=en. You can find Google's privacy policy here: https://policies.google.com/privacy?hl=en. We use Google Maps to determine the current location of our vehicles and to show you the nearest available vehicle, the estimated walking distance to the selected vehicle, your planned arrival location and the remaining arrival time. We do not share this information with Google. This data will only be transmitted to Google anonymously. It cannot, therefore, be traced back to you.

The legal basis for the processing of this data, is that such processing is necessary for the fulfilment of a contract or for the implementation of pre-contractual measures.

5.3. GPS data

GoTo Malta cars are equipped with vehicle tracking and anti-theft technology that uses Global Positioning System (GPS). GPS is a network of satellites that allow us to determine the location (latitude and longitude) of GoTo Malta cars during your reservation. Additionally, our cars also have an on-board device that may monitor the state of the vehicle from moment to moment whether or not in a reservation, and the information may include its location and driver behaviour monitoring such as crash detection factors or rate of braking or acceleration. This information is transmitted to GoTo Malta and stored. We use this information for a variety of important purposes. For example, we may monitor or store vehicle or GPS data to help you find a car you have reserved, to assist with roadside assistance, to assist in making a car available at the place and time you have reserved, to improve our service, to assist us in enforcing our legal rights, or to locate lost or stolen GoTo Malta cars.

The legal basis for the processing of this data, is that such processing is necessary for the fulfilment of a contract or for the implementation of pre-contractual measures.

5.4. Advertising via personalised newsletters

You have the option to subscribe to a free newsletter on our Sites. This is done on the basis of your consent. When registering for the newsletter, the data is transmitted to us. In the dispatch of the newsletter, we will inform you about current products, services and offerings, which correspond to your personal interests.

We collect your email address and your mobile phone number for this purpose. The identification of your email address and your mobile phone number is carried out by the double opt-in procedure. This means that after processing your data you will receive a separate confirmation email. You will only receive advertising emails after clicking on the link contained in the email confirming your subscription. In addition, we store your IP addresses and the time of registration and confirmation. The purpose of the procedure is to be able to prove your registration and, if necessary, to clarify possible misuses of your personal data.

In order to send you only interest-related information, we must personalise your data. For this purpose, we evaluate your master data (name, address, date of birth), your travel data (time of your last trip, your selected vehicle), your selected product or offer, rental frequency (frequency of completed individual rental agreements).

The data will be deleted as soon as it is no longer needed for achieving this purpose of its collection. To unsubscribe, use the link at the bottom of the newsletter. No data is passed on to third parties in connection with data processing for the dispatch of newsletters. The data will be used exclusively for sending the newsletter.

The legal basis for the processing of data after registration for the newsletter by the user is that such processing is conducted with the user's consent.

5.5. Market and survey research

We process your personal data for market and survey research. Your data will be made anonymous, only used by us for statistical purposes and cannot be traced back to you at any time. You can object to this data processing at any time and without giving reasons with effect for the future by contacting us at privacy@goto.com.mt.

The legal basis of this data processing is based on our legitimate interest and serves the improvement of our purposes mentioned here in the privacy policy, in particular, a more effective organisation of advertising, regarding our offers and services. We comply with the protection of our customers by conducting market research with anonymised data.

5.6. Other

We process the information you provide to us via an email, text or similar message, telephone call, or by other means. Your telephone calls and other communications with us are usually recorded or monitored for quality control, training and similar purposes. The data is not used for any other purposes and passed on to third parties. By using these communication methods you are consenting to receive information via these methods and the recording or monitoring of your calls and communications with GoTo Malta.

  1. Where do we hold your personal information?

We use service providers to provide services and to process your data relating to our services and products. The service providers process the data exclusively in accordance with our instructions and have been obliged to comply with the applicable data protection regulations. All contractors have been carefully selected and will only have access to your data to the extent and for the time required to provide the services or to the extent to which you have consented to the processing and use of your data.

GoTo Malta maintains servers within the European Union and the European Economic Area. By joining GoTo Malta and using our services, you accept the transfer of your personal and financial information outside of the European Economic Area or your home country, as applicable, for the purposes described in this privacy policy. GoTo Malta is committed to ensuring that all its servers act and operate in compliance with applicable data protection laws and if we transfer your personal data outside the European Economic Area we will ensure that appropriate safeguards are in place so that such personal data will be processed in line with such laws.

  1. Do we share your personal information with third parties?

GoTo Malta shares information with third parties in limited circumstances such as when it is necessary to provide the GoTo Malta service, fulfil a transaction you have requested, offer you personalised services, or in other circumstances that are permitted by law and consistent with the purposes for which we collected the information. For example, we may disclose your personal information, including GPS information from any of our vehicles, within GoTo Malta and to contractors, advisors, consultants and service providers acting on our behalf or under our instructions, including for purposes relating to the provision, operation, maintenance, administration, promotion, improvement, and oversight of our services, Sites and advertising services, or to fulfil your requests for information or service. If you apply for GoTo Malta membership, some of the information you supply may be shared with regulatory bodies and/or service providers we utilise to obtain your driving record or other personal information. In addition, if you are associated or affiliated with another primary account (for example, if you are affiliated with a business's account or discount plan), the primary account holder (such as a business) will generally have access to certain information regarding your account or your use of our services, including specific reservation details.

We may disclose your personal information in connection with a corporate transaction, proceeding, or reorganisation involving the business activities for which the information is maintained. In the event that ownership of GoTo Malta or its business was to change as a result of a merger, acquisition or transfer to another company, your personal information may be shared or transferred.

GoTo Malta may disclose your personal information, including location/GPS data, in response to legal process (for example, a court order, search warrant or subpoena) or requests from law enforcement or regulatory authorities; in other circumstances in which GoTo Malta believes the Sites, the GoTo Malta service or our vehicles are being or have been used in violation of our policies, applicable law or otherwise in the commission of a crime; when we have a good faith belief that there is an emergency that poses a threat to the safety of you or another person; or when necessary to protect the rights or property of GoTo Malta or third parties.

  1. Your rights as an affected person

8.1. Right to information

You have the right to ask us at any time about the data stored concerning you. Upon request, we will provide you with information about whether we hold any of your personal information. Please contact us at privacy@goto.com.mt and we will respond to your request within 30 days.

8.2. Right of revocation

If you have given your consent to the use of data, you can revoke this at any time without giving reasons with effect for the future.

8.3. Right of correction

If you are a member of GoTo Malta, you can review and correct personal information by signing in to the Sites and navigating to Settings. If you would like to access, delete and/or correct other personal information held by GoTo Malta, please contact us at privacy@goto.com.mt and we will respond to your request within 30 days.

8.4. Right of deletion and blocking

You have the right to block and delete your personal data stored by us. As a rule, your personal data will be deleted within a maximum of 30 working days after assertion of this right.

Should the deletion contradict legal, contractual, fiscal or commercial-law storage obligations or other reasons based in law, your data can only be blocked, not deleted. Once your data has been deleted, it is no longer possible to provide information.

8.5. Right to data transmission

Should you request the personal data provided to us, we will release or transmit the data to you or another person responsible, if you so desire, in a structured, current and machine-readable format. The latter, however, shall only be the case if this is technically possible.

8.6. Right of objection

You have the right to object at any time and without giving reasons for data processing for the purpose of direct marketing. In addition, it is pointed out that the execution of the framework contract; as well as the handling of individual contracts, may be restricted or no longer possible due to opposition to all data processing operations.

8.7. Right to file a Complaint

You have the right to lodge a complaint with the with the supervisory authority in Malta.

  1. Terminating your subscription of GoTo Malta services

Please contact us if you wish to cancel your subscription. We generally retain information for the duration of the contract. After you have initiated the termination of the business relationship, the data will be kept for a maximum of 5 years from your last transaction.

  1. What are security measures used to protect my personal information?

GoTo Malta has established safeguards, such as SSL encryption and other security practices to help prevent unauthorised access to or misuse of your personal information, but cannot guarantee that your personal information will never be disclosed in a manner inconsistent with this privacy policy. These security measures are continually updated in line with technological developments. We use a password to help verify your identity before granting access or making corrections to any of your personal information. It is your responsibility to choose a strong password, safeguard it, and never disclose it to a third party. If you contact us by phone, we will ask you to verify certain information related to your account before providing any access to personal information.

  1. How might this privacy policy be changed?

We may change this privacy policy from time to time, so it is advisable to review it frequently. We will advise you of material changes to this privacy policy through our Sites or other means, and all amended terms shall automatically be effective as of the date of the amended policy. Your continued use of the GoTo Malta service or maintenance of a GoTo Malta subscription will be deemed to be acceptance of any revised privacy policy.

  1. Contact information

If you have questions about our handling of personal information, you may write to us at privacy@goto.com.mt or GoTo Malta Privacy, located at 5, Salvatore Psaila Street, Victoria (Gozo) (hereinafter referred to under its brand name "GoTo Malta").

This privacy policy was last revised on September 14, 2018.