General Information
Sufian Gebal LTD Car
Registered Office Adress: 56 Oldham Road, Ashton-under-Lyne, England, OL6 7AP (UK) United Kingdom
Company number: 16619933
VAT Number: GB502164046
Phone: +44 7404841052
Business E-mail: info@sufiangeballtdcar.co.uk
Support E-mail: sufiangeballtdcar@gmail.com
1. Definitions
The terms and expressions used in this Privacy Policy have the meanings defined below:
“National Data Protection Authority or ANPD”: the public administration body responsible for
overseeing, implementing, and enforcing compliance with the LGPD throughout the national
territory.
“Sufian Gebal LTD Car Collaborators”: exclusively for the purposes of this Policy (without
implying an employment relationship) all individuals working with Sufian Gebal LTD Car,
including partners, administrators, directors, employees, managers, interns, apprentices,
internal service providers, and any other person who has a direct relationship with Sufian
Gebal LTD Car.
“Consent”: a free, informed, and unequivocal expression by which the data subject agrees to
the processing of their personal data for a specific purpose.
“Data Controller”: a natural or legal person, whether public or private, responsible for making
decisions regarding the processing of personal data.
“Data”: Personal Data and Sensitive Personal Data, as defined in this Policy, in accordance
with the provisions of the LGPD.
“Anonymized Data”: data related to the data subject that does not allow their identification
using reasonable and available technical means at the time of processing.
“Personal Data”: information related to a natural person that allows them to be identified in
any way.
“Sensitive Personal Data”: personal data concerning racial or ethnic origin, religious belief,
political opinion, membership in a union or an organization of a religious, philosophical, or
political nature, data related to health or sexual life, genetic data, or biometric data.
“Data Protection Officer”: the person designated by the Data Controller and the Data
Processor to act as a communication channel with the data subjects and the National Data
Protection Authority (ANPD).
“LGPD”: General Data Protection Law (Law No. 13.709/18).
“Data Processor” or “Data Processors”: a natural or legal person, whether public or private,
who processes personal data on behalf of the Data Controller.
“GDPR”: General Data Protection Regulation 2016/679 of the European Union.
“Data Subject” or “Subject”: the natural person to whom the personal data being processed
relates.
“Data Processing” or “Processing”: any operation or set of operations performed on personal
data, including sensitive personal data, such as collection, production, reception,
classification, use, access, reproduction, transmission, distribution, processing, archiving,
storage, deletion, evaluation or control of the information, modification, communication,
transfer, dissemination, or extraction of personal data.
2. Purpose
2.1. The purpose of this Privacy Policy is to define the main rules and principles for the
processing of data collected, including but not limited to the personal data of customers,
suppliers and/or their representatives and collaborators, service providers, partners, rental
agencies, as well as any other parties involved in the execution of Sufian Gebal LTD Car’
activities, ensuring an adequate level of security through protective measures in line with the
LGPD and other applicable regulations.
2.2. In this way, we collect personal information that you provide directly, information about
how you use our services, and information from third-party sources, as described in this
document. We use such information to provide you with our services, understand how you
use our services so that we can enhance and personalize your experience, and develop more
relevant applications, technologies, and content for our customers. We also use personal
information to provide personalized advertisements tailored specifically to your interests.
2.3. This Privacy Policy must be observed by all Sufian Gebal LTD Car collaborators,
customers, suppliers, service providers, partners, rental agencies, or any individual or
legal entity that assumes the role of Data Subject and/or Data Processor, in cases where
Sufian Gebal LTD Car acts as the Data Controller.
3. Points of Collection of Personal Data
The collection of personal data by Sufian Gebal LTD Car can occur in various ways,
directly or indirectly, for example, but not exclusively, through:
Receiving e-mails, including through the Sufian Gebal LTD Car
website; In person, by the Data Subject themselves;
Electronic resumes submitted by the Data Subject to Sufian Gebal LTD Car through the
website and corporate social networks;
Internal and third-party management systems, including those used by Data Processors;
Registration and navigation by the Data Subject on the Sufian Gebal LTD Car
website or application;
When you communicate with our Customer Service team or other service teams, your
communications are transmitted through our systems, including the chatbot, WhatsApp, e-
mail, and application, whether for support or sales;
Corporate social networks and communication applications;
Meetings and events, telephone calls, photos, and images from security cameras; and
Contracts, public sources, digitized documents, and documents from customers and
partners.
4. Purposes of Data Processing
4.1. The entire data processing procedure at Sufian Gebal LTD Car is carried out using only
the data strictly necessary to achieve the specific purposes, such as, but not limited to:
Fulfillment of contractual and legal obligations with customers, including post-sales support,
for which personal data is processed, such as, but not limited to: name, identification
document, passport, banking details, marital status, physical address, nationality,
occupation, phone, e-mail, IP address, and geolocation.
Analysis of user behavior on the website and application and generation of service
recommendations, for which personal data is processed, such as, but not limited to:
geolocation, customer ID, browsing behavior and purchase history.
Lead acquisition and reactivation via the website, e-mail, and WhatsApp, for which personal
data is processed, such as, but not limited to: name, gender, e-mail, phone, address,
identification document, geolocation, and reservation code.
Conducting customer satisfaction surveys, for which personal data is processed, such as, but
not limited to: name, reservation code, e-mail, and phone.
Analysis of customer testimonials and opinions posted on consumer support sites and social
networks, for which personal data is processed, such as, but not limited to: name, gender,
place of residence, social media profile, and testimonial content.
Calculation of the probability of reservation cancellation, for which personal data is
processed, such as, but not limited to: name, gender, age, e-mail, phone, address, reservation
code, reservation details, reservation location, whether a promotion was used, whether the
customer is new or active, cancellation history, and country of residence.
Customer segmentation for marketing, for which personal data is processed, such as, but not
limited to: name, gender, age, e-mail, phone, address, reservation code, reservation details,
and segment.
Management of contracts and fulfillment of contractual obligations with rental agencies,
suppliers, partners, and service providers, for which personal data is processed, such as, but
not limited to: name, date of birth, marital status, identification document, physical address,
e-mail, phone, nationality, occupation, signature, and position.
Prospecting and negotiation with new business partners and rental agencies, for which
personal data is processed, such as, but not limited to: name, e-mail, phone, identification
document, driver’s license, social media profile, position, and occupation.
Management of payments to rental agencies, partners, suppliers, service providers, and other
third parties, for which personal data is processed, such as, but not limited to: name,
identification document, e-mail, and banking details.
Evaluation and handling of cases of fraud in reservations, for which personal data is
processed, such as, but not limited to: name, date of birth, identification document, e-mail,
physical address, phone, banking details, reservation details, and IP address.
Physical and asset security of its headquarters, for which personal data is processed, such
as, but not limited to: name, photo, and ID; and sensitive personal data, such as biometric
data.
4.2. The data mentioned above is processed by Sufian Gebal LTD Car and by companies
contracted by it, and is stored securely under appropriate technical and organizational
measures, for the period necessary to fulfill the purposes.
4.3. Sufian Gebal LTD Car uses tools and assets with global reach; therefore, it conducts
international transfers of personal data, in accordance with the terms of the LGPD and
Resolution CD/ANPD No. 19/2024.
5. Legal Bases for Data Processing
5.1. The legal bases for the processing of personal data by Sufian Gebal LTD Car,
according to Article 7 of the LGPD, are:
Consent of the Data Subject;
Fulfillment of a legal or regulatory obligation by Sufian Gebal LTD Car;
Execution of a contract or preliminary procedures related to a contract to which the Data
Subject is a party, at the request of the Data Subject;
Protection of the life or physical safety of the Data Subject or a third party;
Legitimate interest of Sufian Gebal LTD Car.
5.2. The legal bases for the processing of sensitive personal data by Sufian Gebal LTD
Car, according to Article 11 of the LGPD, are:
Consent of the Data Subject;
Fulfillment of a legal or regulatory obligation by Sufian Gebal LTD Car; and
Protection of the life or physical safety of the Data Subject or a third party.
6. Storage and Disposal of Personal Data
6.1. Any data provided by the Data Subject is collected and stored securely under appropriate
technical and organizational measures. To that end, Sufian Gebal LTD Car adopts various
precautions in accordance with the security standards established by the applicable
legislation.
6.2. In addition to technical measures, Sufian Gebal LTD Car also adopts organizational
measures, such as the implementation of an Information Security Policy for the proper
processing of the data.
6.3. Access to the collected data is restricted to Sufian Gebal LTD Car collaborators and
persons authorized by Sufian Gebal LTD Car, and it is hosted on servers and systems
located in the United Kingdom and in other countries in accordance with the LGPD and
Resolution CD/ANPD No. 19/2024.
6.4. After fulfilling the purposes for which the data was collected, the data is disposed of
within the scope and technical limits of the activities, with retention permitted for the
following purposes:
Fulfillment of a legal or regulatory obligation by Sufian Gebal LTD Car;
Transfer to a third party, provided that the data processing requirements set forth in the LGPD
are respected; and
Exclusive use by Sufian Gebal LTD Car, with third-party access prohibited, provided that the
data is anonymized.
7. Geographical Scope
This Privacy Policy applies to cases in which data processing occurs or the data is collected
within the Uniter Kingdom’s territory.
8. Rights of Data Subjects
8.1. The Data Subject, whenever possible, receives information about the processing of their
personal data at the time of collection.
8.2. The Data Subject may exercise rights regarding the processing of their data, such as:
access to information; objection to processing, automated decision-making, and profiling;
restriction of processing; data portability; rectification and deletion of data; and revocation of
consent, as applicable in each case, via the e-mail address indicated in item 13.2 of this
Privacy Policy.
8.3. Sufian Gebal LTD Car has implemented procedures to ensure responses to data
subjects within the legally established deadlines and reserves, under the terms of the
LGPD, the right to evaluate data subjects’ requests and to fulfill them when technically
feasible and legally required. In any case, the outcome of the evaluation will be
communicated to the data subject.
8.4. The Data Subject is aware that exercising some of their rights may prevent the
continuation of their relationship with Sufian Gebal LTD Car.
9. Obligations of the Data Subjects
9.1. The Data Subject is responsible for the truthfulness, accuracy, and confirmation of the
data they provide, whether on the Sufian Gebal LTD Car website or by any other
means.
9.2. The Data Subject is prohibited from sharing logins, passwords, or any type of credentials
with other people or third-party companies, including coworkers, family, and friends. The Data
Subject must use strong and unique passwords for Sufian Gebal LTD Car assets and tools.
Sufian Gebal LTD Car is not responsible for any breaches of privacy or personal data
protection resulting from the actions or omissions of the Data Subject.
9.3. The Data Subject is responsible for implementing all necessary security measures on
their devices used to access Sufian Gebal LTD Car assets and tools, so that Sufian Gebal
LTD Car is not liable for any breaches of privacy or data protection resulting from this lack
of diligence.
10. Obligations of Sufian Gebal LTD Car’ Data Processors
10.1. Sufian Gebal LTD Car seeks to engage with data processors committed to privacy and
data protection.
10.2. Sufian Gebal LTD Car’ data processors must comply with this Privacy Policy as well as
the relevant legislation. In case of non-compliance with either, Sufian Gebal LTD Car reserves
the right to immediate contractual cancellation, without any liability to Sufian Gebal LTD Car,
as well as to apply the appropriate legal and contractual sanctions.
10.3. Sufian Gebal LTD Car reserves the right to verify that its data processors follow
the processes, operational instructions, and procedures defined by Sufian Gebal LTD
Car, through routine or extraordinary audits.
11. Cooperation with the ANPD and Other Authorities
11.1. Sufian Gebal LTD Car, in its capacity as Data Controller, will cooperate with the ANPD
and other data protection authorities on matters related to the protection and privacy of
personal data under its processing, within the limits of the LGPD and GDPR, without waiving
any rights to defense and appeals as guaranteed to it.
11.2. Sufian Gebal LTD Car collaborators, as well as service providers and/or suppliers
potentially involved in the questioned processing or procedure, will provide support on matters
related to the protection and privacy of personal data.
12. Data Sharing
We may share your information internally within our company, as well as with the following
entities, for the purposes described above:
Affiliates and subsidiaries: other Sufian Gebal LTD Car companies over which we have
control or that belong to us.
Business Partners: partners with whom we work to provide you with the requested or
purchased services. For example, we may work with shipping company agencies to facilitate
goods transportation. These partners are responsible for managing your personal information.
Other parties when required by law or for the protection of Sufian Gebal LTD Car, our
services, collaborators, and our customers: we may disclose your information when required
by law, in legal proceedings, or by court order. Additionally, governmental authorities may
request your data for purposes related to law enforcement, national security, counter-
terrorism, and other public safety issues.
Other parties with your consent or upon your request: in addition to the situations outlined in
this Privacy Policy, we may share your information with third parties if you expressly authorize
or request it.
13. Communication Channel
13.1. Sufian Gebal LTD Car
provides the Data Subject, Data Processors, and any other
individual or legal entity with a free communication channel and exclusive service for matters
related to privacy and data protection.
13.2. All matters related to privacy and data protection should be directed to Sufian Gebal
LTD Car’
Data Protection Officer, Sufian Gebal, at the e-mail:
info@sufiangeballtdcar.co.uk