This Privacy Policy describes how Coral Service, Comércio, Serviços e Locações Limitada ("we," "our" or "the Company") collects, uses, stores and protects the personal data of renters, website visitors and all others whose data is processed in connection with our car rental without driver activities in Francisco Morato, São Paulo.
As a registered limited company (Limitada), we are fully committed to compliance with the Brazilian General Data Protection Law — LGPD (Lei nº 13.709/2018), the Brazilian Consumer Protection Code — CDC (Lei nº 8.078/1990), applicable CONTRAN and DETRAN-SP requirements for rental fleet operations, and applicable tax legislation in the State of São Paulo.
Introduction and Scope
This Policy applies to all personal data processed by our car rental company — including individuals and companies renting our vehicles, website visitors and anyone whose data is processed in connection with our activities. Car rental without driver requires the collection of legally mandated identification and driving licence data for every rental contract — this Policy explains how we collect, use and protect that data.
Identity of the Controller
Entity type: Sociedade Limitada (Limitada)
CNPJ: 48.272.080/0001-60
Activity (CNAE): Locação de Automóveis Sem Condutor
Address: Rua 21 de Março, 158, Francisco Morato — SP, CEP 07901-040, Brasil
Email: privacidade@coralservice.com.br
Personal Data We Collect
- Renter identification data: Full name, CPF (for individuals) or CNPJ with responsible contact (for companies), date of birth, address and contact phone and email — collected for every rental contract as legally required for vehicle rental agreements.
- CNH (Carteira Nacional de Habilitação) data: CNH number, CNH category, CNH expiry date and CNH issuing state — mandatory for all drivers of rented vehicles without conductor. All drivers who will operate the rented vehicle must present a valid CNH. We verify and record CNH data before releasing any vehicle.
- Journey and destination data: Where indicated in the rental contract — city of use, expected distance or region of use. This data is used for insurance purposes and contractual compliance, not for tracking individual journeys.
- Billing data: Name and CPF or CNPJ for NF-e issuance — in compliance with SEFAZ-SP and ISS/Prefeitura de Francisco Morato requirements.
- Payment data: Processed via secure payment channels — card data never retained by the company.
- Contact and enquiry data: Messages via WhatsApp, telephone or online form.
- Technical website data: IP address, browser type, pages visited and access times.
Purpose and Legal Basis
| Purpose | Legal Basis (LGPD) |
|---|---|
| Rental contract formation and vehicle release | Performance of contract (Art. 7º, V) |
| CNH verification — CONTRAN / DETRAN-SP compliance | Legal obligation (Art. 7º, II) |
| Issuing NF-e; SEFAZ-SP tax compliance | Legal obligation (Art. 7º, II) |
| ISS — Prefeitura de Francisco Morato | Legal obligation (Art. 7º, II) |
| Fleet insurance compliance and accident management | Legal obligation; Legitimate interest (Art. 7º, IX) |
| Consumer rights under CDC — vehicle rental quality | Legal obligation; CDC Arts. 14–26 |
| Pre-rental enquiry and vehicle availability management | Legitimate interest; Pre-contractual measures |
| Website analysis and improvement | Legitimate interest; Consent (cookies) |
Data Sharing
- SEFAZ-SP / Receita Federal: Tax data for NF-e issuance and applicable federal and state tax compliance.
- Prefeitura de Francisco Morato (ISS): For ISS/ISSQN obligations on vehicle rental activities.
- DETRAN-SP / CONTRAN: Where required by vehicle rental regulation — for example, in the event of a traffic infraction (multa) incurred during a rental, renter data is shared with DETRAN-SP as required by law to identify the driver responsible for the infraction.
- Fleet insurance provider: In the event of an accident or incident, renter identification and CNH data is shared with our fleet insurance provider as required for the insurance claim process.
- PROCON-SP: When required in a consumer dispute mediation under the CDC.
- Legal authorities: When required by a competent judicial or administrative order.
International Transfers
Our rental operations are entirely within Brazil. All renter data and rental records are stored in Brazil. Any technology platforms used for communication or management that operate on international servers do so only under the guarantees of Art. 33 of the LGPD or recognised adequacy mechanisms.
Retention Periods
- NF-e and fiscal records: Minimum 5 years under federal and state tax legislation (CTN, Art. 174; SEFAZ-SP).
- Rental contract records (including CNH data): 5 years from the end of the rental — for fiscal documentation and for any traffic infraction, accident or civil liability dispute that may arise from the rental period.
- Traffic infraction (multa) records: Retained until all applicable administrative and judicial procedures are concluded — DETRAN-SP requires rental companies to maintain records of who drove a vehicle at the time of an infraction.
- CNH data for completed rentals with no incidents: Deleted or anonymised at the end of the 5-year contract retention period.
- Pre-rental enquiry data (no rental completed): Up to 1 year from last contact.
- Website analytics: Aggregated and anonymised after 12 months.
Security Measures
- Renter identification and CNH data accessible only to company management and rental staff directly involved in the contract;
- CNH copies and rental contracts stored securely — physical and digital records protected;
- WhatsApp communications handled with discretion — personal identification data not transmitted via insecure channels without renter consent;
- PCI-DSS certified payment terminals — card data never retained;
- Encryption in transit (HTTPS) for website and digital communications;
- As a Limitada, formal internal data handling protocols maintained;
- Incident response procedures and breach notification per LGPD Art. 48.
Your Rights under the LGPD
- Confirmation and Access (Art. 18, I–II): Confirm whether we hold your data and receive a copy — including rental records associated with your CPF.
- Correction (Art. 18, III): Request correction of inaccurate data.
- Anonymisation / Blocking / Deletion (Art. 18, IV): Request restriction or deletion — subject to mandatory DETRAN-SP, fiscal and insurance retention requirements for rental contract data.
- Portability (Art. 18, V): Receive your data in a structured format.
- Deletion of consent-based data (Art. 18, VI): Request deletion of data processed by consent.
- Information on sharing (Art. 18, VII): Find out which entities your data was shared with — including in any traffic infraction or insurance context.
- Withdrawal of Consent (Art. 8º, §5º): Withdraw consent at any time.
- Complaint to the ANPD (Art. 18, §1º): Lodge a complaint at www.gov.br/anpd.
We respond within 15 business days. Deletion of CNH and rental records is subject to mandatory DETRAN-SP, fiscal and insurance retention requirements that may prevent immediate deletion during the applicable retention periods.
Cookies and Tracking
Our website may use cookies for essential functionality and aggregated performance analysis. We do not use behavioural tracking cookies for advertising without prior consent. Preferences can be managed through browser settings.
Protection of Minors
Vehicle rental without driver requires a valid CNH. In Brazil, CNH may be obtained from age 18. We do not rent vehicles to individuals under 18 years of age. We do not collect personal data from children or adolescents under 18 in the context of our rental service. All rental contracts are signed by adults of legal capacity.
Sensitive Data — CNH and Journey Data
CNH data and driving record information is not classified as sensitive personal data under LGPD Art. 5º, II, but it is legally and practically significant — it identifies an individual as a licensed driver and is required by law for vehicle rental. We treat it with the care appropriate to its significance.
Journey destination data, where collected, is used only for insurance and contractual compliance — to confirm that the vehicle was used within the agreed region or usage parameters. We do not track the real-time location of rented vehicles.
Updates to this Policy
This Policy may be updated to reflect changes in our activities, the LGPD, ANPD guidance, CONTRAN regulations or applicable tax legislation. Material changes will be communicated via our website or directly to active renters by WhatsApp or email.
Contact & Data Protection Officer
All privacy requests, questions and complaints should be directed to our Data Protection Officer (Encarregado — LGPD Art. 41):
PRIVACY CONTACT — CORAL SERVICE LOCAÇÕES LIMITADA
ANPD — Autoridade Nacional de Proteção de Dados
www.gov.br/anpd