ilha9 rent-a-car

Draft — to be reviewed by a Portuguese lawyer before publication

This text is an internal draft. It has not been reviewed by a lawyer and does not replace legal advice. Before publication, a lawyer admitted to practise in Portugal must confirm its content and wording.

Privacy policy

What data we collect and why

Booking data

Name, contact details, payment details, rental and return dates, selected additional services — to process the booking.

Legal basis: Performance of the contract (Art. 6(1)(b) GDPR)

Driving licence data

Licence number, date of issue, issuing country — to check driving entitlement before handover.

Legal basis: Performance of the contract and legal obligation (Art. 6(1)(b) and (c) GDPR)

Visual check of ID and driving licence (counter rental)

If the rental is recorded at the airport counter, a member of staff looks at your ID card or passport and your driving licence in the original and compares the numbers with the documents. We make NO copy and NO scan of your documents; no image is stored. All that is stored is whether the check took place, when it took place and which member of staff carried it out. The ID and licence numbers read off at that moment are part of the contract data and are described above.

Legal basis: Performance of the contract (Art. 6(1)(b) GDPR): without checking your driving entitlement we may not hand a vehicle over to you. In addition, legitimate interest in evidencing that the check took place (Art. 6(1)(f) GDPR). No consent is required for this — the law asks only for the driving licence number (Article 9(3) of Decreto-Lei n.º 181/2012). Because nothing is reproduced, Article 5(2) of Lei n.º 7/2007 (ban on reproducing the citizen card without consent) does not apply either.

Images of ID and driving licence (online check-in)

If you use the online check-in, you upload images of your ID card or passport and of your driving licence. These images are stored on our own server, are not shared with third parties and can only be viewed by signed-in Ilha 9 staff. Thirty days after the rental ends the image files are deleted automatically; all that remains is the note that a check took place, with time and result — that note is deleted after two years. What is evaluated automatically is the machine-readable zone of your document: we recompute its check digits (the ICAO Doc 9303 method) and compare name, date of birth, document number and expiry date with what you entered. That is a text measurement and NOT artificial intelligence. There is NO face match and NO automatic authenticity check. Nothing is rejected automatically — a human always decides (Art. 22 GDPR). You can remove the images yourself at any time.

Legal basis: Explicit consent (Art. 6(1)(a) GDPR) — required here because Article 5(2) of Lei n.º 7/2007 prohibits reproducing the citizen card without the holder's consent (fine of 250–750 € under Article 43). Without that consent we accept no image; the online check-in then does not apply and you show the original documents at the counter. You can withdraw your consent at any time by removing clearing the consent tick box in the check-in and saving; your images are deleted immediately. Withdrawal takes effect for the future.

Handover photos

Photos of the vehicle at handover and return (condition, mileage, fuel level) — as evidence for both sides in the event of damage.

Legal basis: Performance of the contract and legitimate interest in securing evidence (Art. 6(1)(b) and (f) GDPR)

GPS location data

If theft or unauthorised use outside the agreed conditions is suspected, the vehicle's location is evaluated on a case-by-case basis.

Legal basis: Legitimate interest in theft protection (Art. 6(1)(f) GDPR) — expressly not consent

GPS tracking: case-by-case, not based on consent

The vehicles are fitted with GPS tracking for theft protection. The location data is not evaluated continuously, but only on a case-by-case basis — for example if theft is suspected, if a vehicle is not returned, or if there are indications of use outside the contractually agreed conditions. The legal basis is the lessor's legitimate interest in protecting its property (Art. 6(1)(f) GDPR), expressly not the renter's consent.

Retention period

Booking and contract data is stored for the statutory retention periods under commercial and tax law. Handover photos are kept for as long as they may be needed to clarify damage arising from the respective rental and are deleted afterwards. GPS location data is only evaluated in a specific case and is not retained beyond that. For a rental taken at the airport counter two separate periods apply: your personal access to the customer area expires 30 days after the rental ends, unless you have expressly agreed to it being kept ("keep my account"). Your name, date of birth, ID and driving licence numbers, contact details and the record of the visual check are kept for two years after the rental ends and are deleted after that — unless you chose "keep my account", in which case they are kept until you withdraw that consent, which you can do at any time in your customer area. The reason for those two years: within that period traffic fines can still reach us for which we, as the registered keeper, must name the driver (Article 171 of the Código da Estrada), and within that period we must be able to produce the rental contract for the authorities (Article 14 of Decreto-Lei n.º 181/2012). Your message history and your help requests in the customer area are deleted in any case 30 days after the rental ends — even if you keep the account. The free text of a review is deleted after one year; the star rating remains without a link to you. For a rental taken at the counter no copies and no scans of your identity documents are made; if you voluntarily upload documents during online check-in, the period stated there applies to those.

Rights of the data subject

  • Access to the stored data
  • Rectification of inaccurate data
  • Erasure, provided no retention obligation stands in the way
  • Restriction of processing
  • Objection to processing based on legitimate interest
  • Data portability
  • Complaint to the competent supervisory authority (CNPD, Comissão Nacional de Proteção de Dados)

Contact

For data protection enquiries: info@rentacarilha9.com or +351 295 543 403.