This policy sets out how Season Car Rental Limited (“Season Cars”) carries out marketing by email, SMS and other channels, and how we comply with the Privacy and Electronic Communications Regulations 2003 (PECR), UK GDPR, and the CAP/BCAP advertising codes enforced by the Advertising Standards Authority. It applies to all marketing sent using our platforms, currently Mailchimp (email marketing), Mandrill (transactional email) and Fast SMS (SMS).
• PECR — governs unsolicited electronic marketing (email, SMS, and similar). Marketing messages generally require the recipient’s specific consent, subject to the “soft opt-in” exception for existing customers (Section 5).
• UK GDPR / Data Protection Act 2018 — governs how we collect, use, store and secure the personal data (e.g. name, email, phone number, booking history) that supports our marketing.
• CAP Code (non-broadcast advertising) — requires marketing to be legal, decent, honest and truthful, and enforced by the Advertising Standards Authority.
• Consumer Protection from Unfair Trading Regulations 2008 — prohibits misleading or aggressive marketing practices.
| Channel | Platform | Typical use |
|---|---|---|
| Email marketing | Mailchimp (Intuit Inc.) | Newsletters, offers, seasonal campaigns, fleet updates |
| Transactional email | Mandrill (Mailchimp Transactional) | Booking confirmations, deposit release notices, aftercare check-in emails — not marketing |
| SMS | Fast SMS | Marketing texts (offers, campaigns) and operational texts (collection reminders, deposit release confirmation) |
| Website / cookies | Our own Website + any analytics/ad tools enabled | On-site retargeting and analytics (subject to cookie consent) |
| Social media | Facebook, Instagram, LinkedIn, X, YouTube (as listed on the Website) | Organic and, where used, paid social promotion |
4.1 Messages that are strictly necessary to fulfil a booking — e.g. a booking confirmation, a collection/return reminder, or a deposit-release notice sent via Mandrill or Fast SMS — are transactional/service communications, not marketing. They may be sent to anyone with an active or recent booking regardless of marketing consent, because they are necessary for the performance of the hire contract.
4.2 Any message that primarily promotes our services, offers, discounts, or invites further custom is marketing, regardless of the platform it is sent from, and must comply with Sections 5–7 below.
5.1 For anyone who is not yet a customer (e.g. a website visitor who has only requested a quote), we only send marketing email or SMS where they have given clear, specific, opt-in consent — for example, by ticking an unticked checkbox at the point of enquiry that clearly states what they are signing up for.
5.2 For existing customers, PECR’s “soft opt-in” allows us to send marketing by email or SMS about similar products or services, without a separate opt-in, provided that: (a) we collected their details in the course of a sale or negotiation for a sale (e.g. a completed booking); (b) we only market similar products/services to those they hired; and (c) we gave them a simple opportunity to refuse marketing when we first collected their details, and in every message since.
5.3 We do not buy, rent or use third-party marketing lists for email or SMS marketing without confirming that valid consent was obtained for Season Cars specifically to contact that individual.
For every marketing consent (or soft opt-in reliance), we keep a record of: who consented, when, how (e.g. website form, in branch, verbally confirmed and logged), and the exact wording they saw. This record is kept for as long as we hold and act on that consent, so we can demonstrate compliance if challenged by the ICO or an individual.
7.1 Every marketing email includes a clear, working unsubscribe link, and every marketing SMS includes a clear way to opt out (e.g. replying STOP), in each case processed automatically or within 24 hours.
7.2 Once someone opts out or objects to marketing, we stop sending them marketing messages and add their details to a suppression list, so we don’t accidentally re-add them from a future data import.
7.3 Opting out of marketing does not affect transactional/service messages relating to an active or completed booking (Section 4).
We may group contacts (e.g. by vehicle preference, past hire type, or engagement with previous campaigns) within Mailchimp to send more relevant marketing content. This is a form of profiling under UK GDPR. It is used only to decide what marketing content to send, not to make decisions that produce legal or similarly significant effects, and is covered by the same consent/soft opt-in basis described above.
We use the following platforms to deliver marketing and related messages. Each is subject to a data processing agreement, and we only share the personal data (typically name, email address and/or mobile number, and relevant booking/marketing-preference data) needed for them to perform that function.
| Platform | Role | Data location / safeguard |
|---|---|---|
| Mailchimp (Intuit Inc.) | Email marketing — building, sending and reporting on campaigns | United States — transferred under UK IDTA / UK–US Data Bridge safeguards |
| Mandrill (Mailchimp Transactional) | Transactional email delivery only (not used for marketing content) | United States — transferred under UK IDTA / UK–US Data Bridge safeguards |
| Fast SMS | SMS delivery for both marketing texts and operational reminders | United Kingdom |
Where we market to corporate account contacts (e.g. a travel/concierge partner or a corporate booker) in their business capacity, PECR’s rules on “corporate subscribers” are less restrictive than for individual consumers. As a matter of good practice, we still seek a clear opt-in or rely on the soft opt-in, provide an easy opt-out, and never market to a named individual’s personal email/mobile without an appropriate basis.
All marketing content — email, SMS, social media and paid advertising — must be accurate, must not mislead as to price, availability, vehicle specification or terms (including cancellation charges and excess), and must comply with the CAP Code. Any discount, “from” price, or promotional offer must state clearly what it includes and any conditions that apply.
We periodically review our Mailchimp, Mandrill and Fast SMS contact lists to remove consent records that are no longer valid (e.g. stale, more than the retention period referenced in our Data Protection Policy), and to confirm suppression lists are being respected. We keep records of any complaint received about marketing and how it was resolved.
Breach of PECR can result in ICO enforcement action, including fines. Complaints about our marketing can be made to us at info@seasoncars.com, to the ICO (ico.org.uk), or, for advertising content specifically, to the Advertising Standards Authority (asa.org.uk).
This policy is reviewed at least annually, and sooner if we change marketing platform, add a new marketing channel, or if PECR/UK GDPR guidance changes materially.
Season Car Rental Limited, Arch 56, Ingate Place, Battersea, London SW8 3AG.
Email: info@seasoncars.com | Telephone: 0207 046 0048.