Privacy Policy

DATA CONTROLLER

Execborne Limited is registered in England and Wales under company number 10200167 and has its registered office at Unit D3a, 477 - 479 Whippendell Road, Watford, WD18 7PU.  For the purpose of this Privacy Policy, “we”, “us” and “our” refer to Execborne Limited.

We process personal data in compliance with the General Data Protection Regulation (GDPR) and require you to consider this Privacy Policy in conjunction with the Terms and Conditions carefully and review frequently to ensure that you accept any amendments or variations as we reserve the right to modify from time to time in accordance with new changes in applicable law and industry standards which protect your personal data.  We will notify you of these changes by indicating at the bottom of the Privacy Policy, the date that it was last updated.  By accessing and using the website, you are agreeing to be legally bound by the Terms and Conditions in addition to this Privacy Policy which details how, why and the ways in which we use your personal data.

INTRODUCTION

This Privacy Policy sets out the legal basis on how and why we collect, process and protect any personal data that has been provided to us via access to our website (www.execborne.com), our services, any third parties and equally importantly, clarifying your rights and control of it.  Our main purpose for using your personal data is to operate our business effectively and to provide the services that you require.

As part of our core business values, we take a responsible, ethical, transparent and fair processing approach in respect of data protection and are committed to ensuring that the

privacy and security of personal data is protected. Therefore, any personal data which you disclose upon using our website or our services, shall only be used in accordance with this Privacy Policy.

In this Privacy Policy, "personal data or personal information" is that which can be used to directly or indirectly identify you either together or separately with other information. Such information may include but is not limited to your name, gender, occupation, job title, employer information, date of birth, postal addresses, telephone numbers, email addresses or bank account/ payment details.

"Process or processing" of your data refers to the collection and any management of it, including but not limited to the storing, recording or disclosure.

HOW YOUR PERSONAL DATA IS COLLECTED OR RECEIVED

We collect or receive your personal data when you visit or use our website or services via the following methods:

• Direct communications with you, for example, through meetings, telephone, mobile, website, email, mail, mobile app, client surveys (which you will have consented to), applications for any purpose which may include the opening of an account, placing a booking, submitting feedback or an enquiry;
• Your IP address and device type, which may be provided automatically when you are browsing through our website using cookies (please see the Cookies section below for further information) and similar tracking technologies;
• Third parties such as other websites, service review companies, web analytics services, online advertising services, our existing or potential clients, passengers and other companies such as private hire businesses or credit reference agencies.

TYPES OF PERSONAL DATA COLLECTED OR RECEIVED

We may collect or receive the following types of personal data:

• Identity data including your full name, title, gender, occupation, job title, employer details, company details, vat registration details, credit references, postal addresses, email addresses and telephone/ mobile numbers;
• Sensitive data under the “Special Category” including health/ medical details and photos for client/ passenger identification purposes only;
• Children’s identity data including, full names, age, gender, home and school postal addresses, telephone/ mobile numbers as provided by their adult representative;
• Information relevant to client surveys and/ or offers;
• Client feedback or queries;
• Financial and transaction data including bank account and payment details;
• Technical and usage data from your use of our website and services;
• Personal travel information/ itinerary that you provide upon placing a booking or making an enquiry.

HOW YOUR PERSONAL DATA IS USED

Personal data will be managed transparently, fairly and in line with the current applicable law and regulations. Following these principles, we will not sell, lease or distribute your personal data to any third parties for either their own or another third party’s marketing purposes.

However, your personal data enables us to provide you with a private hire service or other such related services and assists us in identifying and understanding your needs.  It may also be used for the following processing purposes:

• Lawful Process: To comply with our legal obligations generally, including the Local Government (Miscellaneous Provisions) Act 1976 which relates to licensed Private Hire Operators or with any other applicable law or regulation. Also, for commencement or defence of legal claims or for resolving of any disputes.  Where information has been requested by the law enforcement bodies, courts, public or local authorities, government bodies including HMRC, we shall respond in order to assist with such requests.
• Legitimate Business Interests: In order to provide you with support in using our services and for logistics planning, management information, confirming your booking with the designated driver, tracking booked journeys, responding to feedback forms, enquiries or complaints, reviewing applications, sending invoices and statements to you for collecting payments, debt management and/ or analysing credit risk;
• Our Contractual Obligations: To fully perform our contractual obligations and provide you with quotations or information as requested in accordance with our services and to contact you in respect of operational communications or your private client/ corporate account with us;
• Strictly subject to your preferences and where we have your consent, we may contact you by email, phone, mail or social media in respect of marketing, changes to our services or request for your feedback/ review on our services. You may be contacted by third party companies following your consent to provide service reviews.  Please note, that you have the right to withdraw your consent at any time by contacting us;
• Website Improvement: We analyse your use of websites so that we can tailor and improve your browsing experience as well as use of our services;
• Corporate Restructuring: Upon re-organisation, purchase, sale, merger or acquisition of our business.

SHARING OF YOUR PERSONAL DATA

We may be required to share your personal data with the following categories of third parties in the course of our business as necessary to fulfil any legal obligations and for the proper operation of our website and services:

• Law enforcement bodies, courts, public or local authorities, HMRC, central or local government bodies, fraud protection and prevention services;
• Trusted third party service providers, suppliers and partners who provide us support in areas such as IT and website development, web analytics services, hosting, online and other advertising services, transport despatch system, telephone software, service review companies, administrative, payment processing, corporate, accounting/ auditing, legal, debt management, printing, monitoring, credit reference, research and development; other private hire companies (for outsourcing bookings);
• Designated drivers.

WHERE YOUR PERSONAL DATA IS STORED

We securely store personal data electronically on our transport despatch systems, computer network, databases, mobile phones, PDAs, other electronic devices, in hard copy format and in the cloud.

Transfers to Third Countries: In order to provide our services or to perform our contractual obligations, your personal data may be transferred to a “third country” which is a country located outside of the European Economic Area (EEA).  An example of this would be where you provide personal data for any reason including when placing a booking from outside of the EEA or whereby we or third party data processors would manage and process your data for the purposes outlined in this Privacy Policy.  In such circumstances, we will put in place appropriate contractual provisions and safeguards to ensure that the security and confidentiality of your personal data is in line with the GDPR.  Please be advised that the laws and protection for personal data provided by some countries may not necessarily be equivalent to the level of protection in your resident country.

PERSONAL DATA RETENTION

We retain your personal data in line with the purposes for which it was collected/ received as well as for statutory/ regulatory requirements for the duration of your active account with us or as deemed necessary in order to provide you the services. Once the services have concluded, your personal data shall then be retained for a maximum of 6 years from the end of the last company financial year that they relate to, in order to satisfy HMRC requirements for limited companies.  However, you are still entitled to exercise your rights as listed under “Your Rights” section in this Privacy Policy.  

SECURITY

We are committed to safeguarding your information and have put in place electronic and organisational procedures to prevent unauthorised access or disclosure of the personal data collected including encryption wherever possible and periodic reviews of our security measures.  Although we have been advised by the cloud service organisations that provide our hosting, data storage and other related services, that they apply adequate security measures for the protection of the personal data that they hold, we will not be liable for damages (to the fullest extent permitted in law) resulting from their misuse of the personal data or other information.

Please be advised, that no method of electronic storage or transmission over the internet is ever completely secure and subsequently, the Company cannot guarantee its security.

COOKIES

Our website uses cookies, which are small text files that are placed on your computer, laptop or mobile device.  Cookies track information in respect of your browsing, enable web applications to respond to you and help us to provide a more enhanced user experience through review of which pages you do or do not find useful.  The information does not identify you as an individual and nor does it withdraw any personal information which you do not disclose. 

We use third party analytics tool provider, Google Analytics.  In order to measure how users, interact with our website and for the purpose of benchmarking, they place cookies on devices when users visit our website to directly collect and store visit data and such other information including the identities of the device type as well as the country in which it is located, the time zone, operating system, IP address, browser type, domain and referring URLs. 

Please be advised that by using our website, you agree for our cookies (as listed below) to be placed on your device.  However, you have the option to decline the above cookies and prevent your data being used by Google Analytics via downloading and installing the Google Analytics Opt-out Browser Add-on.  For other types of cookies, you can generally modify your web browser settings. 

YOUR RIGHTS

Please see below your rights (subject to conditions as provided under the GDPR) in respect of your personal data: 

• Right of access: You can request a copy of your personal data as well as obtain confirmation on how and why it is being processed.
• Right to rectification: You can request for inaccurate personal data held about you to be amended or incomplete personal data to be completed.
• Right to erasure: You can request to have your personal data erased (also known as ‘the right to be forgotten’).
• Right to restrict processing: You can request to place a restriction on the processing of your personal data and limit the way it is used.
• Right to data portability: You can request to obtain your personal data in a structured, commonly used and machine-readable format and/ or have it transferred to another data controller.
• Right to object: You have the right to object to the processing of your personal data.
• Rights related to automated decision making including profiling: You have the right to not have decisions regarding your personal data to be solely based on automated processing, including profiling which can have legal or other significant effects.
• Rights related to marketing:  You have the right to amend your marketing preferences or opt out of receiving marketing material from us.

Please be advised that limiting or erasing your personal data can affect the way that we provide services to you.

CONTACT US

If you have any questions or complaints in respect of the processing of your personal data, this Privacy Policy, our website, our services or you wish to exercise your rights as above then please contact our Data Protection Officer:

Data Protection

Execborne Limited

477 - 479 Whippendell Road
Watford
WD18 7PU

Telephone number: 01923 510101

Email: hello@execborne.com

You have the right to contact the supervisory authority at the Information Commissioner’s office (ICO) which is the UK authority responsible for data protection at any time.  However, we would appreciate the opportunity to deal with your concerns first so please do not hesitate to contact us initially.