EUROPCAR PRIVACY POLICY FOR THE ZAMBIAN FRANCHISE OF EUROPCAR

Purpose of this Privacy Policy

We at Europcar recognize the importance of protecting your personally identifiable information (such as your name, telephone number, e-mail address and other contact information, collectively, PII) that you provide to Europcar. This Privacy Policy sets forth our policies regarding the collection, use and disclosure of your PII both through our online and offline operations. This Privacy Policy also explains how you can correct or change the PII we hold about you, or opt out of receiving certain marketing materials.

The purpose of this Privacy Policy is to tell you how Europcar strives to better serve you by keeping you informed of promotions, products and services, while, at the same time, safeguarding your PII. Our intention is to bring you offers and discounts that we believe are relevant to your interests offered by and through Cendant business units, affiliates, and other non-affiliated companies with whom we have business relationships.

This Privacy Policy is incorporated into, and part of, the Terms of Use, which govern Europcar’s web site at http://international.europcar.com

What Personally Identifiable Information Europcar Collects and How it is Collected

When you make a reservation, rent a vehicle and/or join one of Europcar programs, we need to collect certain information about you in order to provide and improve our services. The service that you chose will determine what information we collect from you. This information may include, but is not limited to:

• Name;

• E-mail address;

• Home and/or business address;

• Telephone numbers at which we can contact you;

• Your date of birth;

• Method of payments (credit card and expiration date); and

• Drivers license and province/country of issuance.

When you rent a vehicle, we will also record information that details your rental (e.g. where you rented the vehicle, where and when you returned the vehicle, payment arrangements, cover preferences, gas consumption, mileage and other information related to the vehicle).

We may also need certain information from you when you request any of the following services or equipment:

• Special Needs/Optional Equipment;

• Special Offers/Discounts;

• Partner Member Numbers;

• Use of a Europcar Discount Number and other car preferences. For example, if you wish to use a discount that Europcar provides to members of an association/affiliate to which you belong, we may collect information about your membership to verify and provide you with the correct discount for our services.

How we collect this information will depend on how you use our services. We may collect this information directly from you by telephone, fax, e-mail, at the counter, upon completion of an application or enrollment form, or through your use of our Site or the Internet.

To the extent you use our Site, we may also collect information about your use of our Site, transactional and account information, e-mail and other information related to communications to our Site. We may also collect information about you indirectly through a travel agent, an account program in which you or your employer participates, or through one of our partner programs when you deal with us through those means. Additionally, our affiliates and third parties may provide us with information about you.

You may choose not to provide some of your PII to us, but this may prevent us from providing our services to you, or limit our ability to provide you with the level of service that you would otherwise expect from us.

How Personally Identifiable Information is Used and Disclosed by Europcar

Usage

• We strive to provide you with a stress-free rental experience and are dedicated to building a rewarding and lasting relationship with every customer. In order to provide you with the optimum level of service, we may use your PII for the following purposes:

• To provide the services and offerings that you request, and to communicate with you regarding such services and offerings;

• To do all things necessary to administer those services;

• To research, develop, manage, protect and improve our Site and services;

• To maintain and develop our service-oriented software and other business systems; and

• To analyze data, or to have a third party do so on our behalf.

We also use your PII information, or some discrete part, such as your e-mail address for other purposes. For example, such information may be used to process and track your transactions, or send you information about us and our affiliates and business partners products and services, and other information and materials that may be of interest to you. If you use our Site, information may also be used to evaluate what portions of our Site are visited more often than others, determine where visitors came from, where they go, and how long they stay on a particular page, or on our Site in general.

We may match information collected from you through different means or at different times. For example, we may use information collected online and offline along with information obtained from other sources, including third parties.

Disclosing

We may disclose your PII to affiliated and non-affiliated organizations including, for example:

• Your company or organization if you use our services under a corporate or other commercial account;

• One of our program partners (e.g. if you are a member of a frequent traveler program and you have asked us to send details of your rental agreement with us to obtain your benefits from that program);

• Entities that provide services on our behalf;

• Your credit card issuer;

• Credit reporting and fraud checking agencies;

• Debt collection agencies, if you fail to pay monies owed to us;

• Government or private organizations responsible for the processing or handling of traffic or parking related violations;

• Driver licensing authorities, directly or through intermediary organizations, when needed to verify compliance with Europcar safe driver criteria for qualified drivers and/or to verify license information; and

• Government, regulatory and law enforcement agencies where the disclosure is required or authorized by law, and otherwise as we believe is necessary or appropriate to satisfy any law, regulation or other governmental request, to operate our Site properly. Or, to protect or defend our rights or the rights or well-being of our employees, users or others, or if you are involved (or are suspected by governmental authorities or our security functions to be involved) in any illegal activity, even without a subpoena, warrant or court order.

We may also disclose your information to our affiliates and non-affiliated business partners for their use, both on our behalf and for their own business purposes. For example, our affiliates and business partners may use such information to send you information about their products and services, and other information and materials that may be of interest to you. You may opt-out of us disclosing your PII for these purposes through one of the methods described in this policy.

We may also share your information with other non-affiliated third parties, such as entities that provide services for, or through, our Site or for our business (e.g., advertisers, ad servers, content providers, services providers, credit card processors, fulfillment services providers, e-mail list hosting companies and distribution companies) that use such information on our behalf consistent with this Privacy Policy.

We may also transfer or assign your information to third parties as a result of, or in connection with, a sale, merger, consolidation, and change in control, transfer of assets, reorganization or liquidation.

Licensees

Some Europcar locations are owned and operated by an independent licensee. Each licensee collects PII and uses the PII for its own purposes. Europcar does not control the use of this information or access to the information by the licensee and its associates. The licensee is the merchant who collects and processes credit card information and receives payment for the car rental services. The licensee is subject to the merchant rules of the credit card processors it selects which establish its card security rules and procedures.

This policy does not apply to a licensees web site. Licensees may also use email campaigns and other methods of telephonic, electronic, and direct mail solicitation without our consent or knowledge, and are solely responsible for their content and methods of identifying and contacting addressees.

Web Site and Internet Privacy

If you use our Site or otherwise interact with us via the Internet, the following privacy-related policies also apply:

Web Site Tracking and the Use of Cookies and Other Technologies

If you use our Site, certain PII may be collected in the course of your use of our Site. As with many websites, we may use cookies and/or other technology (e.g., web bugs, e-mail bugs, clear GIFs, web beacons, tracker GIFs and clickstream data logs) in our Site and other websites, or in our electronic communications with you. We do so to enhance the functionality of our Site and services and to make your transactions and other activities more convenient and efficient. These technologies may vary, but in many cases may involve a small file stored locally on the computer used to access our Site (commonly referred to as a cookie), and may be used to store and collect information relating to your viewing and use of our Site and our correspondence with you. We use cookies to track web site trends and patterns. This helps us to understand our users needs better and to improve areas of our Site. We store information we collect through cookies to create a profile of our users. A profile is stored information we keep on individual users that details their travel preferences, rental history and behavioral activity, and to minimize the need for you to re-enter information on our Site. Consequently, collected information is tied to a users PII to provide offers and improve our services and content within our Site.

Most cookies expire after a defined period of time, or you can delete your cookie file at any time. Most web browser software is initially set up to accept cookies. You can reset your web browser software to refuse cookies or to indicate when a cookie is being sent. However, some parts of our Site will not function properly or may be considerably slower if you refuse cookies. For example, without cookies, you will not be able to set personalized preferences, and/or may have difficulty completing transactions.

We may collect your computers IP (Internet Protocol) address and domain name address, the identity of your Internet service or access provider, the type of web browsing software you use, your computers operating system, the URL of the web page from which you came to visit our Site and the language you selected for your web browsing software (collectively referred to herein as clickstream data). We use these technologies to identify our users, to help diagnose problems with our server, and to administer and promote our and our affiliates and business partners web sites and services.

Third parties (including, but not limited to, software vendors, advertisers, ad servers, content providers and services providers) may also use similar technologies by, or through, our Site or third party web sites. In connection therewith, such entities may collect information about you and your usage activity on this and other web sites. We have no responsibility with respect to what information such third parties track or collect, or for any tracking, data collection or other activities of such third parties. Please check their terms of use and privacy policies for such information.

We use third party ad serving technology, to serve ads when you visit our Site. The third party may have access to, and use, non-personalized information about your online usage activity. This technology uses information about your visits to our Site and to our affiliates and business partners web sites to serve ads to you. In the course of delivering our advertisements to you, a unique third party cookie may be placed on your computer used to access our Site. You may occasionally get cookies from our affiliates and business partners if you use the links on our Site to reach their respective web sites. The use of advertising cookies sent by such third party web servers is standard in the Internet industry. Europcar does not control these cookies.

We also share web site usage information about visitors to our Site with a reputable third party, currently DoubleClickInc, for the purpose of targeting our Internet banner advertisements on our Site and other web sites. To do this, we use web beacons and cookies provided by our third-party ad server on our Site. In connection therewith, such third party may have access to, and use, non-personalized information about your online usage activity. The use of advertising cookies and web beacons sent by such third-party Web servers is standard for commercial activity in the Internet industry.

Links to Other Web Sites

Our Site may contain links or references to other web sites outside of our control, and the privacy policies of these sites may differ from our own. Please be aware that we have no control over such web sites and our privacy policy does not apply to such websites. We advise you to check the privacy policies of such sites before disclosing any PII via such sites.

How We Protect the Security of Personally Identifiable Information

The security of your PII is an important concern to us. We exercise reasonable care in implementing generally accepted standards of technology security in order to protect information collected via our Site. We aim to prevent loss, misuse and unauthorized access, disclosure, alteration or destruction, such as firewalls and Secure Socket Layer (SSL) encryption for some of your more sensitive PII.

Unfortunately, perfect security does not exist on the Internet, and no data transmission over the Internet can be guaranteed to be 100% secure. As a result, while we strive to protect your information, we cannot guarantee that any information stored on our servers, or transmitted to, or from, a user will be free from unauthorized access. For example, unencrypted e-mail is not a secure means of communicating with us, since e-mail may be intercepted by a third party in the course of its delivery. By using our Site and corresponding with us, you acknowledge that you understand and agree to assume these risks.

You are responsible for maintaining the strict confidentiality of your account password, membership numbers and pin numbers, and you shall be responsible for any access to, or use of, our Site by you or any person or entity using a password provided to you, whether or not such access or use has been authorized by or on behalf of you, and whether or not such person or entity is your employee, relative or agent. You agree to (a) immediately notify us of any unauthorized use of your password, account or membership number, or any other breach of security, and (b) ensure that you exit from your account at the end of each session. It is your sole responsibility to control the dissemination and use of your password, control access to, and use of, your account and membership number, and notify us when you desire to cancel your account on our Site. We will not be responsible or liable for any loss or damage arising from your failure to comply with this provision.

We will never request that you send us any sensitive PII, such as your credit card number, password, membership number or pin number in an e-mail or into a web site that is not located at the Europcar.co.za domain name. If you receive an e-mail or other correspondence requesting that you provide any such information via e-mail, or to a web site that is not on such domain name, please do not provide such information, and report such request to our privacy officer at privacy@europcarzambia.com

In the unlikely event that we believe that the security of your PII in our possession or control may have been compromised, we may seek to notify you of that development. If a notification is appropriate, we would endeavor to do so as promptly as possible under the circumstances, and to the extent we have your e-mail address, we may notify you by e-mail.

How to Correct or Update Personally Identifiable Information that Europcar Maintains or Opt Out of Receiving Marketing Materials from Europcar

You can opt-out of our use and disclosure of your PII for marketing purposes and customer satisfaction surveys, and/or withdraw your prior consent for some by the methods provided below. If you do so, your consent will be withdrawn, however, it is possible that you may receive correspondence scheduled prior to our receipt and processing of your opt-out request.

To Opt Out of E-mail Campaigns: You may reply to a promotional or marketing e-mail that you have received from us with the word Unsubscribe in the subject line, or you can e-mail us directly at privacy@europcarzambia.com (If you use more than one e-mail address, then send your opt-out e-mail from each of your e-mail addresses.)

We may also provide additional methods for you to opt-out of having your PII used or disclosed for promotional and marketing purposes, such as by clicking on a checkbox located on the page of our site on which your PII is collected, or otherwise made available when you make reservations.

Your option not to receive promotional and marketing material:

• Shall not preclude us from corresponding with you, by e-mail or otherwise, regarding your relationship with us (e.g. your account status and activity, our responses to questions or inquiries you pose to us, or confirmations for existing reservations);

• Shall not preclude us, including our employees, contractors, agents and other representatives, from accessing and viewing your PII for our internal business purposes; and

• Shall not preclude us from disclosing your PII as described in this Privacy Policy for purposes other than sending you promotional and marketing materials.

If you wish to contact us to:

• Inquire about our privacy practices;

• Provide feedback and comments regarding our privacy practices; or

• Access or correct your PII we have, contact us as detailed above.

Applicable Law and Jurisdiction

This Privacy Policy shall be governed by the laws of Zambia , without regard to conflict of law principals. By providing any PII to us, you fully understand and unambiguously consent to the transfer of such PII to, and the collection and processing of such PII in, Zambia and other countries or territories. You agree that any cause of action that may arise under this Privacy Policy shall be commenced and be heard in the appropriate court in Zambia . You agree to submit to the personal and exclusive jurisdiction of the courts located within Zambia .

Changes to this Privacy Policy

We reserve the right, at our discretion, to change, modify, add, or remove portions from this Privacy Policy at any time so visitors are encouraged to review this Privacy Policy at the inception of each session.

Your Acceptance of this Privacy Policy

By using our Site, or otherwise providing your PII to us, you signify your acceptance of our Privacy Policy. If you do not agree to this policy, please do not use our Site or provide any PII to us.

Privacy Policy Effective Date: September 15th , 2006

If we change the way your personal information will be used, we will notify you. We encourage you to periodically review this Privacy Policy in order to keep apprised of our current privacy practices.