Mobile App Privacy Policy

We, Gold Line Car Services Ltd are the controller and are responsible for your personal data (collectively referred to as “Company”, “we”, “us” or “our” in this policy).

Contact details

Our full details are:

• Full name of legal entity: Gold Line Car Services Ltd
• Name or title of: Data Protection Officer
• Email address: [email protected]
• Postal address: 22 Church Lane, Leytonstone, London, E11 1HG
• Telephone number: 020 8555 5555

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues.

Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review.  It may change and if it does, these changes will be posted on this page and, where appropriate, notified to you when you next start the App.

We may collect, use, store and transfer different kinds of personal data about you as follows:

• Identity Data includes name, title, username or similar identifier
• Contact Data includes home address, billing address, IP address, email address and telephone number.
• Financial Data includes payment card details.
• Transaction Data includes details of bookings made, completed or cancelled.
• Device Data includes mobile device, unique download ID and/or mobile device fingerprint.
• Profile Data includes your username, password and preferences.
• Usage Data includes information on how you use the App.
• Marketing and Communications Data includes your marketing and communication preferences.
• Location Data includes your home location and favourite places stored on the App.

We also collect, use and share Aggregated Data such as statistical or geographical data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific App feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We will collect and process the following data about you:

• Information you give us. This is information (including Identity, Contact, Financial, and Marketing and Communications Data) you consent to giving us about you by completing fields on the App, or by corresponding with us (for example, by email or chat). It includes information you provide when you register to use the App, download or register with the App, subscribe to any of our Services, or place bookings on the App, or give a review of a completed transaction or when you report a problem with an App or the Services. If you contact us, we will keep a record of that correspondence.
• Information we collect about you and your device. Each time you use our App we will automatically collect personal data including Device, Content and Usage Data. We collect this data using cookies and other similar technologies.
• Location Data. We also use GPS technology to determine your current location. Some of our location-enabled Services require your personal data for the feature to work. If you wish to use the particular feature, you will be asked to consent to your data being used for this purpose. You can withdraw your consent at any time by disabling Location Data in your settings.
• Information we receive from other sources including third parties and publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:
• Device Data from the following parties:

analytics providers such as Google based outside the EU;

advertising networks such as Google Ads, Facebook and Twitter based outside the EU; and search information providers such as Yell.com based inside the EU.

• Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as Sagepay and Worldpay based inside the EU;
• Identity and Contact Data from agents or aggregators based inside the EU;

Cookies

We use cookies and/or other tracking technologies to distinguish you from other users of the App, and to remember your preferences. This helps us to provide you with a good experience when you use the App and also allows us to improve the App.

We will only use your personal data when the law allows us to do so. Most commonly we will use your personal data in the following circumstances:

• Where you have consented before the processing.
• Where we need to perform a contract we are about to enter or have entered with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal or regulatory obligation.

We will only send you direct marketing communications by email or text if we have your consent. You have the right to withdraw that consent at any time by contacting us.

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

Purposes for which we will use your personal data

When you consent to providing us with your personal data, we will also ask you for your consent to share your personal data with the third parties set out below for the purposes set out in the above table:

• Taxi drivers for the purpose of delivering the Services.
• Other taxi firms for the purpose of delivering the Services if we are unable to do so.
• IT Service Providers (including GPC Computer Software Limited) who support and manage the App and our booking and fleet management platforms.
• Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.
• Our insurance company and claims handling company for the purpose of investigating and settling any insurance claims.
• Enforcement and regulatory bodies where we are legally required to do so or to investigate any alleged criminal offence.
• Analytical and search engine providers to assist in the improvement of the App and the Services.

Some of our external third parties are based outside the EEA so their processing of your personal data will involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
• Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
• Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US.

All information you provide to us is stored on our secure servers. Any payment transactions carried out by us or our chosen third-party provider of payment processing services will be encrypted. Where we have given you (or where you have chosen) a password that enables you to access certain parts of the App, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

Once we have received your information, we will use strict procedures and security features to try to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator when we are legally required to do so.

By law we have to keep basic information about our customers (including Contact, Identity and Transaction Data) for four years after they cease being customers for regulatory purposes.

In some circumstances you can ask us to delete your data: see Your legal rights below for further information.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

You have the right to:

• Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
  • if you want us to establish the data’s accuracy;
  • where our use of the data is unlawful but you do not want us to erase it;
  • where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
  • you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.