Privacy Policy

The Fan Cars Ltd Group (“we”,“our”, “us”) are committed to protecting and respecting your privacy. Our group of companies are:

Fan Cars Ltd Limited trading name LavishChauffeurs.co.uk No. 14316918 Registered Office: 6. St Peters Street, Censeo House, St. Albans, England, AL1 3LF

Fan Cars Ltd and the group of companies are a private hire car company. This privacy policy explains how we use any personal information we collect about you, as a past, present employee, a service user, Driver or when you use our website or applications.

Please read this notice carefully so that you understand your rights in relation to your personal data, and how we will collect, use, and process your personal data. If you do not agree with this Privacy Notice in general or any part of it, you should not access the Websites, the Apps or use our services.

CONTROLLERS’ CONTACT INFORMATION

Fan Cars Ltd is the controller for the personal information we process, unless otherwise stated via contracts. Fan Cars Ltd is the data controller for the purposes of the General Data Protection Regulation and any relevant local legislation (“Data Protection Laws”).

You can contact our Data Protection Officer via:

Address: 6. St Peters Street, Censeo House, St. Albans, England, AL1 3LF

Email: booking@lavishchauffeurs.co.uk

WHAT TYPES OF INFORMATION DO WE COLLECT ABOUT YOU?

Web Collection

You may provide information by contacting us via our Websites, Apps or by email, telephone, social media or otherwise, or by signing up for our newsletters or alerts, or by creating an account and then using our services. This personal information always requires the user’s confirmation before it is submitted, and the user can refuse to provide this. However, in this case they will be unable to engage in the website activity as we would not have the contact details to send the requested information.

B2B Data Collection:

If you use our services through your company, information provided to us by your employer. In the case of our corporate customers only, your employer may provide us with information about you when it signs up to use our services, for example your name, contact number and business email address.

Job applicants, current and former Fan Cars Ltd employees

When individuals apply to work at Fan Cars Ltd, we will only use the information you supply to us to process your application. Where we want to disclose information to a third party, for example where we want to take up a reference or obtain a ‘disclosure’ from the Disclosure and Barring Service we will not do so without informing you beforehand unless the disclosure is required by law. Once a person has taken up employment with Fan Cars Ltd, we will compile a file relating to their employment. The information contained in this will be kept secure and will only be used for purposes directly relevant to that person’s employment. Once their employment with us has ended, we will retain the file in accordance with the requirements of our retention schedule and then delete it.

Drivers

Fan Cars Ltd will collect the following personal data about you while you provide services to us:

  • identity information such as title, full name, date of birth, photograph, private hire licence with Transport for London (for drivers in London) or such other relevant regulator or authority (the “Transport Regulator”), drivers licence details, or proof of eligibility to enter into the driver contract.

  • contact details such as home and work address, phone number(s), email address(es), emergency contacts and next of kin;

  • data with respect to the driver contract, including commencement date, participation in driver training programmes, background checks (including criminal records, directorship and credit checks), membership of professional bodies and data relating to complaints.

  • data regarding the location of the vehicle, rate of travel and other similar information transmitted from GPS trackers, telematics devices, Wi-Fi routers, forward-facing cameras, the Fan Cars Ltd-provided communications device if so, and similar devices which are fitted to the vehicle, whether the vehicle is being used for the provision of passenger services or for personal

  • financial data, including payments for bookings, your bank or building society account details and tax numbers.

  • information about your physical or mental health or condition.

  • your racial or ethnic origin or religious or similar beliefs in order to monitor compliance with equal opportunities legislation; and

  • information relating to any background check, any criminal proceedings in which you have been involved or the commission of any potential criminal or civil offence for insurance or trust purposes, or when we have been notified of any relevant potential vehicle or driving offences or where there is an allegation of parking, speeding, toll or other traffic-related

  • data with respect to the vehicle hire contract;

  • data regarding the location of the vehicle, rate of travel and other similar information transmitted from GPS trackers, telematics devices, Wi-Fi routers, forward-facing cameras, the provided communications device, and similar devices which are fitted to the vehicle, whether the vehicle is being used for the provision of passenger services or for personal use;

  • financial data, including payments for vehicle hire;

    CCTV information.

    Some of our vehicles are fitted with outward-looking dashboard cameras. These dashboard cameras do not film inside the vehicles, and they do not record audio, but your image may be picked up by them when you enter or exit the vehicle.

    Criminal Activity

    Information provided to us by a third party and/or collected from public records in the case of fraud or suspected fraud. In the case of fraud or suspected fraud, we may obtain information from third parties and from public records to prevent and detect fraud.

    We also receive information from other sources, such as from our group companies, from fraud prevention tools in the case of fraud or suspected fraud, from analytics companies in the case of in car wifi data usage and in the case of telematics data (including crash/impact detection, GPS location data, vehicle usage/driving style data and odometer readings), from third party data validation tools such as Experian and from publicly accessible data such as Companies House, the Land Registry, the Electoral Register and information you post online.

    Technical usage information.

    When you visit our Websites or use our Apps, we automatically collect the information sent to us by your device, which includes your computer, mobile phone and tablets. This information includes:

     

  • your IP address;

  • device information including, but not limited to, identifier, name, and type of operating system (including versions);

  • mobile network information.

  • standard web information, such as your browser type and the pages you access on our Websites;

  • mobile device UUID (Unique Download ID) and/or mobile device fingerprint; and

  • hardware models, software, file names and versions, preferred languages, unique device identifiers, advertising identifiers, serial numbers, and device motion information.

    THE LAWFUL BASIS WE USE TO PROCESS YOUR DATA

    We will only ever process your information if we have a lawful basis to do so. The lawful bases we rely on are;

     

  • Contract – This is where we process your information to fulfil a contractual arrangement, we have made with you.

  • Consent – This is where we have asked you to provide explicit permission to process your data for a particular purpose.

  • Legitimate Interests – This is where we rely on our interests as a reason for processing, generally this is to provide you with the best service in the most secure and appropriate way.

  • Legal Obligation – This is where we have a statutory or other legal obligation to process the information.

    HOW WE USE YOUR INFORMATION

    We take your privacy very seriously. The Privacy Policy details what to expect when Fan Cars Ltd collects your personal information. In most cases, any personal information provided, for example Contact Form submissions, are stored on servers in our UK Data Centres. We use a third party provider to help manage and maintain the security and performance of our corporate websites.

    To perform our contract with you, we will use your information:

     

  • to communicate with you;

  • to provide you with ground transportation

  • to create records of bookings and to send you booking acknowledgments, confirmations, receipts and invoices; and

  • to maintain records of lost property.

    As it is in our legitimate interests to be responsive to you and to ensure the proper functioning of our services and organisation, we will use your information:

  • to detect and prevent fraud and crime;

  • for reporting and data analysis purposes;

  • to administer our membership and loyalty scheme(s);

  • for insurance purposes;

  • to comply with our legal and regulatory obligations imposed by Transport for London and any other licensing authority where we provide services;

  • to meet customer service requirements and for complaint handling and feedback;

  • to monitor and assess the quality of our service;

  • to host events for our customers;

  • to pass on feedback such as ratings or compliments about our drivers;

  • to sign you up for our newsletters or alerts;

  • to contact you via telephone, email, SMS or via our Apps;

  • to identify our users;

  • to personalise our services for you, for example, to provide you with an accessible vehicle where you request such a vehicle and if you have opted in to marketing, to send you promotions and offers tailored to your use of the services, for example, discounts on airport bookings where you frequently make airport bookings;

  • to enforce our terms and conditions;

  • if you have opted in to marketing, to communicate with you about products, services, promotions, events and other news and information we think will be of interest to you; or

  • to provide third parties with statistical information about our users (but those third parties will not be able to identify any individual user from that information).

    PROFILING

     

  • Fraud prevention: We use a combination of risk screening tools and manual intervention to ensure that customer profiles are not fraudulent. To do this, we match the personal data provided by customers against data fields such as name, email address, mobile phone number, and we use this to accept or decline bookings.

  • Marketing: We manually carry out customer segmentation for marketing purposes based on journey history. We use this to make our advertisements more relevant for market segments, such as promoting relevant journey types.

    SHARING YOUR INFORMATION?

    We do not sell, rent or lease your personal information to others except as described in this Privacy Notice. We share your information with selected recipients. These categories of recipients include:

     

  • cloud storage providers located in the UK or EU, which store your personal data in and for disaster recovery services, as well as for the performance of any contract we enter into with you;

  • provided you have consented, advertisers and e-marketing companies located in the UK and the USA and which store your personal data in the UK and the USA that require the data to select and serve relevant marketing and adverts to you and others.

  • IT Services providers that provide us with SaaS services, including Salesforce, who we use to store our customer relationship management information.

  • analytics and search engine providers located in the UK and the USA that assist us in the improvement and optimisation of the Websites and Apps; merchant acquirers located in the UK and USA and which store your personal data in the UK and the USA for the purpose of processing payments.

  • fraud prevention tools located in the UK and the USA for the purposes of preventing fraud;

  • Partner drivers based in the territory in which you request services.

  • IT support service providers who support and maintain our booking platform and have access at our premises working on a secure server; and

  • Our insurance company and claims handling companies, for the purpose of investigating and settling any insurance claims.

    We will share your information with law enforcement agencies, public authorities or other organisations if legally required to do so, or if we have a good faith belief that such use is reasonably necessary to:

     

  • comply with a legal obligation, process or request.

  • enforce our terms and conditions and other agreements, including investigation of any potential violation thereof

  • detect, prevent or otherwise address security, fraud or technical issues; or

  • protect the rights, property or safety of us, our users, a third party or the public as required or permitted by law (exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction).

    We will also disclose your information to third parties:

     

  • in the event that we sell any business or assets, in which case we will disclose your data to the prospective buyer of such business or assets; or

  • if we or substantially all of our assets are acquired by a third party, in which case information held by us about our users will be one of the transferred assets.

    THE SECURITY OF YOUR PERSONAL DATA

    Unfortunately, the transmission of information via the internet or email is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your information transmitted through the Websites, Apps, over email or via our contact centres; any transmission is at your own risk. Once we have received your information, we will take appropriate technical and organisational measures to safeguard your personal data against loss, theft and unauthorised use, access or modification.

    We will, from time to time, host links to and from the websites of our affiliates or third parties. If you follow a link to any of these websites, these websites will have their own privacy policies and we do not accept any responsibility or liability for these policies. Please check these policies before you submit any information to those websites.

    HOW LONG DO WE STORE YOUR PERSONAL DATA?

    To determine the retention period of your personal data, we consider several criteria to make sure that we do not keep your personal data for no longer than is necessary or appropriate. These criteria include:

     

  • the purpose for which we hold your personal data;

  • our legal and regulatory obligations in relation to that personal data, for example any financial reporting obligations and our regulatory obligations to Transport for London and other local licensing authorities.

  • whether our relationship with you is ongoing, for example, you have an active account with one or more of our brands, you continue to receive marketing communications, or you regularly browse or purchase off our Websites/Apps);

  • whether you are no longer actively participating or engaging with our brands, for example, you do not open our emails, visit our Websites, or share user generated content;

  • any specific requests from you in relation to the deletion of your personal data; and

  • our legitimate business interests in relation to managing our own rights, for example the defence of any claims.

    YOUR RIGHTS AS A DATA SUBJECT

    You have rights in relation to the personal data we hold about you. Some of these only apply in certain circumstances. We have described these situations below, as well as how you can exercise your rights. To exercise any of your rights, please contact us at booking@lavishchauffeurs.co.uk

     

  • Access: You have the right to ask us to access the personal data we hold about you and be provided with certain information about how we use your personal data and who we share it with.

  • Correction: You also have the right to ask us to correct your personal data where it is inaccurate or incomplete.

  • Portability: Where you have provided your personal data to us under contract, you have the right to ask us to share (port) this data to another data controller in a structured, commonly used and machine-readable format.

  • Erasure: In certain circumstances, you have the right to ask us to delete the personal data we hold about you.

  • Restriction: In certain circumstances, you have the right to ask us to restrict (stop any active) processing of your personal data, save for storage.

  • Objection: In certain circumstances, the right to restrict or object to our processing of your personal information (e.g. where you request correction or erasure, you also have a right to restrict processing of your applicable data while your request is considered). You can object to our processing of your personal data based on our legitimate interests and we will no longer process your personal data unless we can demonstrate an overriding legitimate ground.

    Please note that these rights are limited, for example, where fulfilling your request would adversely affect other individuals or company trade secrets or intellectual property, where there are overriding public interest reasons or where we are required by law to retain your personal data.

    Other websites

    Our website contains links to other websites. Our privacy policy only applies to this website, we would encourage you to read the privacy statements on the other websites you visit.

    COOKIES & MARKETING

    Cookies are small text files that are stored on your computer or smart device when you access a website. They allow websites to recognise your visit and to store information on your preferences or past actions to improve your experience of using the website. Please see our Cookie Policy on our website.

    Marketing

    At any time you have the right to object to our processing of data about you in order to send you marketing communications, including where we build profiles for such purposes, and we will stop processing the data for that purpose. You can change your marketing preferences at any time using the preference centre within your account which can be reached via LavishChauffeurs.co.uk or via our UK App.

    COMPLAINTS

    Fan Cars Ltd tries to meet the highest standards when processing and collecting your personal information. In the event that you wish to make a complaint about how we process your personal data, please contact us at booking@lavishchauffeurs.co.uk and we will endeavour to deal with your request as soon as possible.

    If you are not satisfied with the response from Fan Cars Ltd or believe we are not processing your data in accordance with the law, you have the right to raise your complaint with the Information Commissioner’s Office (ICO)

     

  • Website: https://ico.org.uk/concerns/

  • Email: casework@ico.org.uk

  • Telephone: +44 (0) 303 123 1113

CHANGES TO OUR PRIVACY NOTICE

We keep our privacy notice under regular review, and we will place any updates on this website. The last update to this privacy policy was November 2022

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