PRIVACY
POLICY
M’s
Chauffeurs LTD (together with its affiliates “M’s Chauffeurs”, “we”, “our”
or “us”) puts
great efforts in making sure that your personal data is kept safe and used
properly.
This
Privacy Policy describes how, with respect to M’s Chauffeurs (the “Services”), we collect, store, use and disclose
the following types of personal data:
1. User
data relating to individuals who are registered to
the Services and use them either independently or on behalf of our corporate
customers, to book, send and receive taxi rides and pre-bookings for private
hire drivers;
2. Driver
data relating to drivers who use the Services,
either individually or as part of a fleet that has integrated into the Services,
to accept and execute rides, pick up rider and carry them to their
destinations, and to receive payments for such activities;
3. Website
visitor, CRM & prospects data relating
to visitors of our website, participants at our events, business customers, partners,
and any prospective customer, partner, user or driver who visits or otherwise
interacts with any of our websites, online ads and content, emails or other
communications under our control (“Sites”).
Specifically,
this Privacy Policy describes our practices regarding –
1. Data
Collection
2. Data
uses
3. Data
Location and Retention
4. Data
Sharing
5. Permissions
6. Cookies
and Tracking Technologies
7. Communications
8. Data
Security
9. Data
Subject Rights
10. Data
Controller/Processor
11. Additional
Notice and Contact
12. Attribution
If you are user, driver, visitor, partner or prospect (“you”) – please
read this Privacy Policy carefully and make sure that you fully understand and
agree to it.
You
are not legally required to provide us with any personal data, and may do so
(or avoid doing so) at your own free will. If you do not wish to provide us
with your personal data, or to have it processed by us or any of our Service
Providers (defined below), please refrain from accessing, using or registering
to our Services. If you are using the Services on behalf of any of our business
customers or partners, we suggest that you contact your organisational account
administrator with any questions or to let them know that you would not like to
be registered by them to the Services.
1. Data
Collection
(i) User Data: Our Services enable M’s Chauffeurs
business customers and their personnel, as well as any other eligible
individuals, to easily book and manage their business or personal ground travel
and deliveries. M’s Chauffeurs collects and generates the following
types of personal data relating to such business or individual users –
M’s
Chauffeurs processes certain limited business user
data on its customers’ behalf, as their ‘data processor’ (namely, such data
which is needed for registering and deregistering users on such customers’
business account); whilst with respect to all other personal data pertaining to
our users and processed by M’s Chauffeurs, M’s Chauffeurs shall
act and be deemed as the ‘data controller’.
(ii) Driver Data: Our Services enable registered taxi
drivers and private hire drivers – either operating independently or as part of
our partner fleets – to easily accept taxi rides and pre-booked rides. M’s
Chauffeurs collects and generates the following types of personal data
relating to such drivers and couriers –
(iii) Sites, CRM & Prospect Data: We
collect and generate the following types of personal data concerning our
website visitors, customers, partners and prospects –
We
collect such data either automatically, through the data subject’s interaction
with us or with our Sites or Services; or through third party services, social
media, analytics tools, events we organize or participate in, and other
business initiatives.
To
the extent that any of the above-mentioned data only pertains to a non-human
entity (e.g., the phone number or bank account of a company or business), we
will not regard it as “personal data” and this Privacy Policy will not apply to
it.
2. Data
Uses
We
use personal data as necessary for the facilitation and performance of our
Services; to comply with our legal and contractual obligations; and to support
our legitimate interests in maintaining and improving our Services; providing
customer service and technical support; and protecting and securing our users,
customers, partners, ourselves and our Services.
If
you reside or are using the Services in a territory governed by privacy laws
under which “consent” is the only or most appropriate legal basis for the
processing of personal data (in general, or specifically with respect to the
types of personal data you expect or elect to process or have processed by or
via the Services, e.g. ‘special categories’ under the GDPR), your acceptance of
our Terms and Conditions and this Privacy Policy will be deemed as your
consent to the processing of your personal data for all purposes detailed in
this Policy. If you wish to revoke such consent, please contact us at info@mschauffeurs.co.uk
Specifically,
we use personal data for the following purposes:
1. To
facilitate, operate, and provide our Services;
2. To
authenticate the identity of our users, drivers and couriers, and to allow them
to access and use our Services;
3. To
provide assistance and support to our customers, users, drivers and couriers;
4. To
gain a better understanding on how you use and interact with our Services, and
how we could improve your and others’ user experience, and continue improving
our products, offerings and the overall performance of our Services;
5. To
contact you with general or personalized service-related messages, as well as
promotional messages that may be of specific interest to you (as further
described in Section 6 below);
6. To
facilitate, sponsor and offer certain events, contests and promotions;
7. To
support and enhance our data security measures, including for the purposes of
preventing and mitigating the risks of fraud, error or any illegal or
prohibited activity;
8. To
create aggregated statistical data, inferred non-personal data or anonymized or
pseudonymized data (rendered non-personal), which we or our business partners
may use to provide and improve our respective services, or for any other
purpose; and
9. To
comply with applicable laws and regulations.
3. Data
Location & Retention
Data Location: Your personal data may be maintained,
processed and stored by us and our authorized Service Providers (defined below)
in multiple locations, including in the United Kingdom, the EU and other
jurisdictions, as reasonably necessary for the proper performance and delivery
of our Services, or as may be required by law.
While
privacy laws may vary between jurisdictions, M’s Chauffeurs and its
Service Providers are each committed to protect personal data in accordance
with this Privacy Policy, customary industry standards, and such appropriate
lawful mechanisms and contractual terms requiring adequate data protection,
regardless of any lesser legal requirements that may apply in the jurisdiction
to which such data is transferred.
Data Retention: We will retain your personal data for
as long as it is reasonably necessary for us to maintain and expand our
relationship and provide you with our Services and offerings; in order to
comply with our legal and contractual obligations; or to protect ourselves from
any potential disputes (i.e. as required by laws applicable to log-keeping,
records and bookkeeping, and in order to have proof and evidence concerning our
relationship, should any legal issues arise following your discontinuance of
use), all in accordance with our contractual terms and data retention policy.
Please
note that except as required by applicable law or our specific agreements with
you, we will not be obligated to retain your personal data for any particular
period, and we are free to securely delete it or restrict access to it for any
reason and at any time, with or without notice to you. If you have any
questions about our data retention policy, please contact us by e-mail at info@mschauffeurs.co.uk.
4. Data
Sharing
Legal Compliance: In exceptional circumstances, we may
disclose or allow government and law enforcement officials access to your
personal data, in response to a subpoena, search warrant or court order (or
similar requirement) and where such disclosure is necessary to comply with
applicable laws and regulations. Such disclosure or access may occur if we
believe in good faith that: (a) we are legally compelled to do so; (b)
disclosure is appropriate in connection with efforts to investigate, prevent,
or take action regarding actual or suspected illegal activity, fraud, or other
wrongdoing; or (c) such disclosure is required to protect the security or
integrity of our Services.
Service Providers: We engage selected third-party
companies and individuals to perform services complementary to our own. Such
service providers hosting and server co-location services, communications and
content delivery networks (CDNs), billing and payment processing services, data
and cyber security services, fraud detection and prevention services, web and
mobile analytics, e-mail, text messages and web/mobile notification
distribution, monitoring and analytics services, data optimization and
marketing services, social and advertising networks, content providers, e-mail,
voicemails, support and customer relation management systems, call and session
recording services, and our legal, financial and compliance advisors (collectively,
“Service Providers“).
These
Service Providers may have access to your personal data, depending on each of
their specific roles and purposes in facilitating and enhancing our Services,
and may only use it for such limited purposes as determined in our agreements
with them. Should you decide to directly engage with any of M’s Chauffeurs’s
Service Providers, please note that such engagement is beyond the scope of M’s
Chauffeurs’s Terms and Conditions and Privacy Policy, and will therefore be
covered by our Service Provider’s terms and policies.
Our
Service Providers shall be deemed as ‘data processors’ in circumstances where M’s
Chauffeurs assumes the role of ‘data controller’; and where M’s
Chauffeurs acts as the ‘data processor’ for our business customer, the
Service Provider shall be deemed our ‘sub-processor’ (as further described in
Section 9 below).
Third Party Websites and Services: Our
Services may also include links to third-party websites, and integrations with
third party services. Such websites and third-party services, and any
information you process, submit, transmit or otherwise use with such websites
and third-party services, are governed by such third party’s terms and privacy
practices and policies, and not by this Privacy Policy. We encourage you to carefully
read the terms and privacy policies of such website and third-party services.
Sharing Personal Data with our Customers and their Users:
We may share your personal data with the business customer owning the account
to which you are subscribed as a user – including data and communications
concerning your use of the Services or other interactions with us, but only in
relation to that business account). In such cases, sharing such data means that
the account’s administrator(s) or other individuals in your organization may
access it on behalf of our business customer, and will be able to monitor and
review data concerning the rides or deliveries you ordered via our Services, as
well as access any personal data that was submitted by you or the individual for
whom you ordered the ride or delivery.
Sharing data between Users and Driving Partners:
in order to provide our Services, we are required to share certain details
about users (name, phone, ride start and end point, pick-up time and ride
related details entered as free text) and our drivers or couriers (name, phone,
user score, current location, time of arrival estimation, car type/brand and
plate number, hobbies and similar information) with each other.
Protecting Rights and Safety: We
may share your personal data with others if we believe in good faith that this
will help protect the rights, property or personal safety of M’s Chauffeurs,
any of our users, partners or customers, or any members of the general public.
M’s
Chauffeurs Subsidiaries
and Affiliated Companies: We may share personal data internally
within our group of companies, for the purposes described in this Privacy
Policy. In addition, should M’s Chauffeurs or any of its subsidiaries or
affiliates undergo any change in control or ownership, including by means of
merger, acquisition or purchase of substantially all or part of its assets,
your personal data may be shared with the parties involved in such an event. If
we believe that such change in control might materially affect your personal
data then stored with us, we will notify you of this event and the choices you
may have via e-mail or prominent notice on our Services.
For
the avoidance of doubt, M’s Chauffeurs may share your personal data in
additional manners, pursuant to your explicit approval, or if we are legally
obligated to do so, or if we have successfully rendered such data non-personal
and anonymous. We may transfer, share or otherwise use non-personal data at our
sole discretion and without the need for further approval.
5. Permissions
Permissions require from the user:
a) Location Permission:
When you use our Chauffeuring App, we may collect and use
information about your precise location through the GPS functionality on your
device. This information is used solely for the purpose of providing you with
location-based services such as finding nearby drivers and estimating arrival
times. We do not store your precise location history unless you explicitly
provide consent.
b)
Camera Usage & Photo Library:
Our Chauffeuring App may request access to your device's camera
and photo library to enable you to upload a profile picture or provide
additional verification information. We will only access your camera or photo
library with your explicit consent and solely for the purpose of enhancing your
user experience within the App. We do not store or have access to your photos
or videos unless you choose to share them within the App.
c)
Media Library:
The App may request access to your device's media library to
enable you to upload media files such as profile pictures or vehicle images. We
will only access your media library with your explicit consent and solely for
the purpose of enhancing your user experience within the App. We do not store
or have access to your media files unless you choose to share them within the
App.
d)
Notification Permission:
Our Chauffeuring App may send you push notifications to provide
you with important updates, such as driver status, trip confirmations, or
promotional offers. We will only send you push notifications with your explicit
consent, and you may opt out of receiving them at any time by adjusting your
device settings.
6. Cookies
and Tracking Technologies
Cookies
are packets of information sent to your web browser and then sent back by the
browser each time it accesses the server that sent the cookie. Some cookies are
removed when you close your browser session. These are the “Session Cookies”.
Some last for longer periods and called “Persistent Cookies”. We use both
types.
We
use Persistent Cookies to remember your log-in details and make it easier for
you to log-in the next time you access the Services. We may use this type of
cookies and Session Cookies for additional purposes, to facilitate the use of
the Services’ features and tools.
Every
browser allows you to manage your cookies preferences. Please bear in mind that
disabling cookies may complicate or even prevent you from using certain parts
of features of the Services.
For
more information, please review our Cookie Policy.
We
also use analytics tools such as Google Analytics. These tools help us
understand your behavior on our Services, including by tracking page content,
and click/touch, movements, scrolls and keystroke activities. Further
information about the privacy practices of our google analytics is available at:
www.google.com/policies/privacy/partners/;
Further
information about your option to opt-out of google analytics services is
available at: https://tools.google.com/dlpage/gaoptout.
Please
note that if you get a new computer or device, install a new browser, erase or
otherwise alter your browser’s cookie file (including upgrading certain
browsers), you may also clear the opt-out cookies installed once you opt-out,
so an additional opt-out will be necessary to prevent additional tracking.
7. Communications
Service Communications: By
creating an account and providing your phone number, you agree to receive text
messages from M’s Chauffeurs. Message and data rates may apply.
Message frequency varies.
Promotional Communications: We
may also notify you about new features, additional offerings, better ways to
use the Services, events and special opportunities or any other information we
think you will find valuable. We may provide such notices through any of the
contact means available to us (e.g. phone, SMS, mobile notifications or
e-mail), through the Services, or through our marketing campaigns on any other
sites or platforms.
If
you do not wish to receive such promotional communications, you may notify M’s
Chauffeurs at any time by filing the
contact form, or by following the “unsubscribe”, “stop”, “opt-out” or
“change e-mail preferences” instructions contained in the promotional
communications you receive.
8. Information
Security
We
and our hosting services implement systems, applications and procedures to
secure your personal data, and to reduce the risks of theft, damage, loss of
data, or unauthorized access or use of personal data. These measures provide
sound industry standard security. However, although we make efforts to protect
your privacy, we cannot guarantee that the Services will be immune from any
wrongdoings, malfunctions, unlawful interceptions or access, or other kinds of
abuse and misuse.
9. Data
Subject Rights
If
you wish to exercise your rights under any applicable law, such as the EU
General Data Protection Regulation (GDPR), to request access to, and
rectification or erasure of your personal data held with M’s Chauffeurs,
or to restrict or object to such personal data’s processing, or to port such
personal data – please contact us via info@mschauffeurs.co.uk.
Please
note that when you ask us to exercise any of your rights under this policy or applicable
law, we may need to ask you to provide us certain credentials to make sure that
you are who you claim you are, to avoid disclosure to you of personal data
related to others and to ask you to provide further information to better
understand the nature and scope of the data to which your request pertains.
Such additional information will be then retained by us for legal purposes
(e.g. as proof of the identity of the person submitting the request), in
accordance with Section 3 above.
We
may redact from the data which we will make available to you, any personal data
or confidential information related to others.
10. Data
Controller/Processor
Certain
data protection laws and regulations, such as the GDPR, typically distinguish
between two main roles for parties processing personal data: the “data
controller”, who determines the purposes and means of processing; and the “data
processor”, who processes the data on behalf of the data controller. Below we
explain how these roles apply to our Services, to the extent that such laws and
regulations apply.
M’s
Chauffeurs is
the “data controller” of personal data pertaining to its users, drivers and
couriers, customers, suppliers, visitors and prospects,
and assumes the responsibilities of a data controller (solely to the extent
applicable under law), as set forth in this Privacy Policy. In such instances,
our Service Providers processing such data will assume the role of “data processor”.
M’s
Chauffeurs is
the “data processor” of registration and deregistration data pertaining to
users of business accounts (solely
to the extent that such data is shared by our business customer during the
onboarding process). In such instances, our business customer shall be deemed
the “data controller” of such data, and M’s Chauffeurs will process such
data on the customer’s behalf, as its “data processor”, in accordance with its
reasonable instructions, subject to our Terms and Conditions, this Privacy
Policy, and the commercial and data processing agreements executed between M’s
Chauffeurs and such customers (as applicable). M’s Chauffeurs’s
Service Providers shall then act as designated sub-processors in these
instances. M’s Chauffeurs’s business customer will be responsible for
meeting any legal requirements applicable to data controllers (such as
obtaining their consent or establishing other legal basis for processing).
11. Additional
Notices
Updates and Amendments: We
may update and amend this Privacy Policy from time to time by posting an
amended version on our Services. The amended version will be effective as of
the date it is published. We will provide a 10-day prior notice if we believe
any substantial changes are involved via any of the communication means
available to us or via the Services. After such notice period, all amendments
shall be deemed accepted by you.
External Links: While our Services may contain links
to other websites or services, we are not responsible for their privacy
practices. We encourage you to pay attention when you leave our Services for
the website or application of such third parties, and to read the privacy
policies of each and every website and service you visit. This Privacy Policy
applies only to M’s Chauffeurs’s Services.
Our Services are not designed to attract children under the age of 16: We
do not knowingly collect personal data from children and do not wish to do so.
If we learn that a person under the age of 16 is using the Services, we will
attempt to prohibit and block such use and will make our best efforts to
promptly delete any personal data stored with us with regard to such child. If
you believe that we might have any such data, please contact us by e-mail
at info@mschauffeurs.co.uk
Data Protection Officer: M’s
Chauffeurs has appointed Privacy Team as our
Data Protection Officer (DPO), for monitoring and advising on M’s Chauffeurs’s
ongoing privacy compliance and serving as a point of contact on privacy matters
for data subjects and supervisory authorities. If you have any comments or
questions regarding our Privacy Policy, if you have any concerns regarding your
privacy, or if you wish to make a complaint about how your personal data is
being processed by M’s Chauffeurs, please contact info@mschauffeurs.co.uk.
UK Representative: M’s
Chauffeurs Limited has been designated as M’s Chauffeurs’s
representative in the United Kingdom for data protection matters pursuant to
Article 27 of the UK GDPR. M’s Chauffeurs Limited may be contacted only
on matters related to the processing of personal data. To make such an inquiry,
please send an email to info@mschauffeurs.co.uk, or contact M’s Chauffeurs
Limited by post at Office F07, 1 Marlborough Hill, Harrow, HA1 1UX United
Kingdom. If you are situated in the UK, you also have the right to lodge a
complaint with the Information Commissioner’s Office.
Questions, concerns or complaints: If
you have any comments or questions regarding our Privacy Policy, or if you have
any concerns regarding your personal data held with us, please contact us at: info@mschauffeurs.co.uk
12. Attribution
This
privacy policy was created using a document from Rocket Lawyer (https://www.rocketlawyer.com/gb/en).
12th of May 2024