Platform to Business (P2B) Regulation

The Online Intermediation Services Regulation (2019/1150), also known as the Platform to Business (P2B) Regulation (“Regulation”), came into effect on 12 July 2020 and imposes obligations on platforms like CarTrawler to promote fairness and transparency for business users, such as car rental suppliers, that use its platform.

The Regulation sets out a number of requirements that must be reflected in our terms and conditions with car rental suppliers. Our supplier Agreement covers the majority of the key provisions required under the Regulation. However, for the purposes of satisfying our obligations under the Regulation, we have set out below further information on how we rank search results, our complaints handling procedures and other information that is included in our supplier Agreements.

Ranking of search results:

Our recommended sort order is based on the simple principle of ordering the Expected Value per car from High to Low.
Expected Value is calculated as: Expected Value = Propensity to Purchase * Value
Propensity to Purchase identifies the customer’s likelihood to purchase each individual car given the full range of cars available to them taking into account trends, the customer’s historic behaviour and CSAT/ NPS.
Value is a monetary amount per car that is made up of a combination of the following revenues and costs: car base rate, car revenue, car commission, rebate revenue, insurance revenue, insurance commission, insurance claims costs, refunds, chargebacks, etc.

Complaints and Mediation:

As per the supplier Agreement with CarTrawler, car rental suppliers can submit a complaint to the CarTrawler account manager or [email protected] regarding the following: technological issues, customer service issues, suspension and termination of account or services, or any alleged breach of contract or the EU Regulation 2019/1150 (the “P2B Regulation”) by CarTrawler. We will acknowledge all complaints and follow-up to address the complaint within a reasonable timeframe. Please provide as much information as possible when contacting us about a complaint, along with contact details in order to discuss and communicate the outcome of our complaint investigation. Any dispute or complaint will be dealt with in accordance with the dispute resolution procedure in the supplier Agreement with CarTrawler.

As set out in the supplier Agreement with CarTrawler, complaints that are not resolved through the CarTrawler internal complaint handling mechanism may be referred to mediation, in accordance with the Centre for Effective Dispute Resolution (CEDR) procedures.

CarTrawler have not received any complaints to date in relation to non-compliance with CarTrawler’s obligations in the P2B Regulation, technological issues or CarTrawler’s behaviour relating to the provision of our online intermediation services to business users. Information in relation to any complaints received will be posted here in accordance with the P2B Regulation.

Rates in contracts:

Under the P2B Regulation, CarTrawler has a requirement to provide car rental suppliers with certain information where there are restrictions on business users in relation to offering the same products to consumers under different conditions through other means. Our Agreements with car rental suppliers can contain restrictions of this nature. Providing CarTrawler with competitive rates and conditions is part of a fair and commercial bargain between us and car rental suppliers, which delivers incremental bookings to the suppliers on attractive terms and allows us to ensure that the rates and conditions posted on our platform are competitive while preventing suppliers ‘free riding’ on the considerable investments made by us.