Data protection NOTICE

We, A1 TAXIS (HUDDS) LTD (“we” “our” or “us”) with our registered office address at 21 NEWSOME ROAD HD4 6NH are fully committed to respecting your privacy and to protecting any information you provide to us. We treat both privacy and security as a priority and make every effort to ensure that all the information provided by you is protected. This Data Protection Notice (the "Notice") exists to respect and protect the privacy of all users of the services provided by us (the "Services") and is intended to inform you about the way that we treat your personal data.

Scope of Notice

This Notice applies in relation to the provision of the Services and in particular to your use of, or engagement with, any or all of the following (as applicable):

The A1 TAXIS (HUDDS) LTD software application (the “App”);
the A1 TAXIS (HUDDS) LTD website (the "Website"); and
any other communications (whether over telephone, email, SMS message or otherwise) between you and A1 TAXIS (HUDDS) LTD in connection with the provision of the Services.

This Notice sets out the basis on which any personal data we collect from you or that you provide to us, in connection with your use of the Services ("Personal Data"), will be processed by us or our third-party service providers. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

For the purpose of the EU General Data Protection Regulation (the "GDPR"), the controller of your Personal Data is A1 TAXIS (HUDDS) LTD. Our Privacy Compliance Manager is OMAR SHAZAD

YOUR PERSONAL DATA COLLECTED AND PROCESSED

IMPORTANT: Please note that the below list of Personal Data, while intended to be as complete and accurate as reasonably possible, is not exhaustive and may be updated from time to time in accordance with Section 10 of this Notice.

We may collect and process some or all of the following Personal Data about you (as applicable):

Data Collected		Data Source(s)
Information you provide	[You provide us with information when you engage with us to use the Services, create an account with us (either through our App, Website or by contacting us through other means), download or install the App, and when you report a problem with the Services, App or Website or when you correspond with us generally in connection with your use of the Services. The information you provide to us may include but is not limited to your name, address, e-mail address, address, phone number, age, date of birth, username, password and other registration information, financial and credit card information, and gender. We may collect demographic information about you, including through user surveys.]^[1]	App, Website, Other Communications
Device Information	[Technical information including but not limited to the type of device you use, a unique device identifier (for example, network information, your operating system, time zone setting and device locale)]^[2]	App, Website
Log Information	[Details of your use of the Services including, but not limited to weblogs and/or other communication data and the resources that you access]^[3]	App, Website
Location Information	[Depending on how you choose to use the Services (that is, whether through use of our App, Website or by contacting us through other means), we may collect details of your location data to determine your current location.]^[4]	App, Website
Information we receive from other sources	[We work with third parties (including, for example, service providers) and may receive certain information from them about you that they choose to disclose with us. This information may include your name, email, address and location.]^[5]	Other Communications
Transaction Information	[We may collect transaction details related to your use of the Services, including the type of services you requested, your order details, delivery information, date and time the service was provided, amount charged, distance travelled, and payment method. We may also record details as to whether or not a taxi journey is cancelled by you. Please note: All Card payments will incur a 10% service charge to cover payment provider costs and will be added to the fare quoted. If no fare is quoted or requested this fee will still apply.	App, Website, Other Communications
Usage Information	[We collect information about how you interact with the Services. This includes information such as access dates and times, App features or pages viewed, App crashes and other system activity, type of browser, and third-party sites or service you were using before interacting with the Services.]^[6]	App, Website, Other Communications

HOW AND WHY WE PROCESS YOUR PERSONAL DATA

We, A1 TAXIS (HUDDS) LTD, in our capacity as controller, use the information held about you on the following lawful bases and for the following purposes:

Legal Basis

Necessary for the Performance of a Contract

Purposes

It is necessary to process your Personal Data to enter into and perform our contract with you in relation to your use of the Services. We will process your Personal Data for the following purposes:

[To create and maintain your account and profile, and, to facilitate your use of the Services.
To help you efficiently access your information after you sign into your App or Website account.
In the case of phone calls to A1 TAXIS (HUDDS) LTD, to facilitate the Services by communicating to drivers your name, number, location and destination.
To enable and facilitate transportation from your location to your destination.
To process or facilitate payments for the Services.
To track the progress of your journey.
To remember information so you will not have to re-enter it repeatedly when you use the Services.
To facilitate the provision of App or Website support, pop-up notifications and other services.
To improve the features and functionality of the App or Website to enhance your experience.

If you do not wish to provide us with your personal data for these purposes, we will not be able to enter into or perform our contract with you and you will not be able to use the Services.

Legal Basis

To Comply With a Legal Obligation

Purposes

We may process your Personal Data as necessary in order for us:

To comply with applicable Irish and European Union laws.
To comply with requests from regulators, government entities and official inquiries.

Legal Basis

Legitimate Interests

Purposes

It is in A1 TAXIS (HUDDS) LTD 's legitimate interests to collect and process the Personal Data for the following purposes:

To facilitate the Services being provided to you through utilisation of third-party software.
To monitor metrics such as total number of visitors, traffic and demographic patterns.
To prevent the corruption and/or loss of your Personal Data, to ensure the security of our systems and to carry out regular testing to ensure the smooth maintenance of our systems.

You have the right to object at any time to the processing of your personal

data carried out on this basis.

When we process your personal data based on our legitimate interests, we make sure to consider and balance any potential impact on you and your data protection rights. We will not process your personal data for

activities where our interests are overridden by the impact on you.

DISCLOSURE OF YOUR INFORMATION TO THIRD PARTIES

We, A1 TAXIS (HUDDS) LTD, may disclose some or all of the data we collect from you in connection with your use of the Services to the following third parties:

RECIPIENT

Service Providers: Service providers who may use this information to assist with the provision and improvement of the Services. In particular, we will share your personal data with Taxi Alliance Software Limited AND / OR Coolnagour Limited t/a iCabbi who provide software support services to us in order to facilitate the provision of the Services to you.

Our Service Provider may log certain information concerning your use of the App or Website in relation to activities connected with the use of the Services. This information is logged for the purpose of providing the Services. The information gathered is then aggregated and anonymised. From the anonymised information collected, statistics may be compiled in the form of percentages and/or figures relating to users’ interaction with the Services. As a service, certain anonymised statistical information may be supplied to third parties in order to help them understand the likes, dislikes, trends, habits and behaviour of Service users.

[Advertisers: We may provide advertisers with anonymous (not individual) aggregate information about our users. We may also use such aggregate information to help advertisers reach the kind of audience they want to target. We do not disclose information about identifiable individuals to our advertisers.]^[7]

A1 TAXIS (HUDDS) LTD Group: We may disclose your personal information to other members of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries.]^[8]

Law Enforcement Agencies: We may disclose your information if we are under a duty to disclose or share your personal data in order to comply with any legal or regulatory obligation or request.

[Buyers and Sellers of Business Assets: If A1 TAXIS (HUDDS) LTD or substantially all of its assets are acquired by a third party, personal data held by it about its customers will be one of the transferred assets.]^[9]

LINKS TO THIRD PARTY WEBSITES

The App or Website may contain links to and from the websites of our partner networks, advertisers and service providers. If you follow a link to any of these websites, please note that these websites and any services that may be accessible through them have their own data protection notices and that we do not accept any responsibility or liability for these notices or for any Personal Data that may be collected through these websites or services, such as contact and location data. Please check these notices before you submit any personal data to these websites or use any such third party services.]^[10]

STORING AND TRANSFERS OF YOUR PERSONAL DATA

We may transfer your Personal Data outside the European Economic Area ("EEA"). Certain of our third party service providers who process your Personal Data on our behalf may transfer your Personal Data outside the EEA to a country that does not provide an adequate level of protection to your Personal Data.

Where such transfers occur, it is our policy that: (i) they do not occur without our prior written authority; and (b) that an appropriate transfer agreement such as the Standard Contractual Clauses or other transfer mechanism approved by the European Commission and supervisory authorities is put in place to protect your Personal Data. If you would like to find out more about any such transfer, please contact our Privacy Compliance Manager

All information you provide to us is stored on our secure servers or the servers of our service providers, contractors or suppliers. Where we have given you (or where you have chosen) a password that enables you to access the App or Website, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

HOW LONG WE KEEP YOUR PERSONAL DATA FOR

A1 TAXIS (HUDDS) LTD will keep your Personal Data for as long as you use the App or Website and for a period of 7 years after you delete your account.]^[11]

Please note that in certain circumstances, we may hold your Personal Data for a longer period, for example, if we are processing an ongoing claim or believe in good faith that the law or a relevant regulator may reasonably in our view expect or require us to preserve your data.

YOUR RIGHTS & HOW TO EXERCISE THEM

You have a number of rights in relation to your Personal Data which are set out in this Section 8. In particular these rights include the right to object to processing of your personal data where that processing is carried out for our legitimate interests. Note that in certain circumstances, these rights might not be absolute.

Right	Further Information
Right to be Informed	You have the right to know whether your personal data is being processed by us, how we use your personal data and your rights in relation to your personal data.
Right of Access	You have the right to request a copy of the personal data held by us about you. We will only charge you for making such an access request where we feel your request is unjustified or excessive. You may also access your personal data by logging into your account on the App or Website and viewing your profile.
Right to Rectification	You have the right to request that we amend any inaccurate personal data that we have about you.
Right to Erasure	You have the right to ask us to erase your personal data where: it is no longer necessary to perform the contract you withdraw your consent and there is no other legal basis permitting us to process your personal data you object to the processing and we have no overriding legitimate grounds your personal data have been unlawfully processed; or it must be erased to comply with a legal obligation. Please note that some of your personal data may be required in order for the App to function properly.
Right to Restriction of Processing	You have the right to ask us to restrict processing your personal data in the following situations: where you contest the accuracy of your personal data where the processing is unlawful and you do not want us to delete your personal data where we no longer need your personal data for the purposes of processing but you require the data in relation to a legal claim where you have objected to us processing your personal data pending the verification as to whether or not our legitimate interests override your interests or in connection with legal proceedings. When you exercise this right we may only store your personal data. We may not further process the data unless you consent or the processing is necessary in relation to a legal claim or to protect the rights of another person or legal person or for reasons of important public interest. Please note that it may be necessary for us to process some of your personal data in order to provide the App or Website and in certain instances where you ask us not to process your personal data you may not be able to use the App or Website. We will inform you before the processing restriction is lifted.
Right to Data Portability	You may request us to provide you with your personal data which you have given us in a structured, commonly used and machine-readable format and you may request us to transmit your personal data directly to another data controller where this is technically feasible. This right only arises where: we process your personal data on the legal bases of your consent or where it is necessary to perform our contract with you; and the processing is carried out by automated means.
Right to Object	You have a right to object at any time to the processing of your personal data where we process your personal data on the legal basis of pursuing our legitimate interests.
Right to Object to Automated Decision-Making, including Profiling	You have a right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you. We may not be able to comply with this request where the processing is necessary to enter or perform our contract with you or where you explicitly consent to this. However, you are entitled to have a person from our team to review the decision so that you can query it and set out your point of view to us.

You can exercise any of these rights by submitting a request in writing to info@a1taxishudds.co.uk You also have the right to lodge a complaint with the Data Protection Commission with regards to the processing of your personal data by us. For further information see www.dataprotection.ie

[AGE RESTRICTION

Individuals under the age of 18 are not eligible to use the Services and must not attempt to register and/or submit any personal information to us. We do not knowingly collect personal information from any person who is under the age of 18 or allow them to register. If it comes to our attention that we have collected personal data from a person under the age of 18, we will delete this information as soon as reasonably possible. If you have reason to believe that this has occurred, please contact us a info@a1taxishudds.co.uk

CHANGES TO THIS NOTICE & QUESTIONS

[Any material changes we may make to the Notice in the future will be notified to you by e-mail or pop-up notification when you next start the App or visit the Website.]^[12] The new Notice may be displayed on-screen and you may be required to read and accept them to continue your use of the App or the Website.

If at any time we decide to use your Personal Data in a manner significantly different from that stated in this notice, or otherwise disclosed to you at the time it was collected, we will notify you by e-mail, and you will have a choice as to whether or not we use your Personal Data in the new manner.

Questions, comments and requests regarding this Notice and the way your Personal Data is being used or processed by us are welcomed and should be submitted to our Privacy Compliance Manager in writing, info@a1taxishudds.co.uk or call us on 01484 541111

[1] Taxi Company to review list and to confirm whether any additional personal data is typically provided by App users.

[2] Taxi Company to review to ensure the full extent of "technical" data collected is covered by this list. Please update with any additional technical data collected.

[3] Taxi Company to review and confirm.

[4] Taxi Company to review and confirm.

[5] Please consider whether this covers all information received by Taxi Company from third party sources. Please make any necessary updates.

[6] Taxi Company to confirm.

[7] Taxi Company to confirm whether passenger personal data will be shared with third party advertisers.

[8] Taxi Company to confirm whether passenger personal data will be shred within the taxi company group.

[9] Taxi Company to confirm whether passenger personal data will be shared with the buyers/sellers of business assets.

[10] Taxi Company to confirm if this is a feature of the App, Website or applicable booking platform. Delete if irrelevant.

[11] Taxi Company to confirm period for which it retains user data. We have included the 7 year period by way of example only and based on possible applicable statutory limitation periods. It will be a matter for the taxi company to

[12] Taxi Company to confirm how users will be notified of updates.