PASSENGER PRIVACY POLICY
INTRODUCTION
We are Veezu Holdings Limited. If you need
it, our company number is 09378357 and our registered office is Hodge House,
114-116 St. Mary Street, Cardiff, CF10 1DY. Veezu Holdings Limited is the controller
of your personal information and is responsible for your personal information.
All references in this policy to "Veezu", "our",
"us", or "we" refer to Veezu Holdings Limited, and its
holding companies and subsidiaries defined below, who are all committed to
protecting the privacy and security of your personal information
“Veezu Company” means any company which at
the relevant time is a subsidiary or holding company of Veezu Holdings Limited
of Hodge House, 114-116 St. Mary Street, Cardiff, CF10 1DY or any subsidiary of
any such holding company, and “subsidiary” and “holding company” shall have the
meanings given to them by the Companies Act 2006 Section 1159.
This privacy notice sets out how we process
your personal information as a passenger using our booking services.
It is important that you read this privacy
notice so that you are aware of how and why we are using your personal
information.
WHAT THIS POLICY CONTAINS
2. INFORMATION
ABOUT OTHER INDIVIDUALS
3. WHAT
PERSONAL INFORMATION DO WE COLLECT ABOUT YOU?
4. WHEN
DO WE COLLECT YOUR PERSONAL INFORMATION?
5. WHY
DO WE COLLECT YOUR PERSONAL INFORMATION?
6. DISCLOSURE
OF YOUR INFORMATION
7. PAYMENTS
8. TELLING
YOU ABOUT OUR SERVICES
9.
COOKIES AND RELATED SOFTWARE
10. TRANSFERRING
PERSONAL DATA OUTSIDE OF THE UK
11. HOW DO WE KEEP
YOUR PERSONAL INFORMATION SECURE?
12. HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION
FOR?
13. CHANGES TO YOUR PERSONAL INFORMATION
15. YOUR RIGHTS IN
RELATION TO YOUR PERSONAL INFORMATION
16. CONTACT
17. CHANGES TO OUR PRIVACY POLICY
YOUR
RIGHT TO OBJECT
You have various rights in respect of our use
of your personal information as set out in Section 15. Two of the fundamental rights to be aware of are that:
1. you may ask us to stop using your personal
information for direct-marketing purposes. If you exercise this right, we will
stop using your personal information for this purpose.
2. you may ask us to consider any valid
objections which you have to our use of your personal information where we
process your personal information on the basis of our, or another person’s
legitimate interest.
INFORMATION ABOUT OTHER INDIVIDUALS
If you give us information on behalf of a
third party, and we are satisfied that you have demonstrated that you have
sufficient authority to act on behalf of that third party, you confirm that the
third party has appointed you to act on his/her/their behalf and has agreed
that you can: give consent on his/her/their behalf to the processing of
his/her/their Personal Information; that you will make them aware of this data
protection notice; and give consent to the transfer of his/her/their Personal
Information abroad (if applicable).
WHAT PERSONAL INFORMATION DO WE COLLECT ABOUT YOU?
We process
the following categories of personal information about you:
·
personal
information, including your name, current residential address, pickup address,
destination address, email address or your phone number;
·
any payment
related information that you provide, including bank account details, credit
card details, banking address and account name;
·
information
that you provide to us regarding your health so that we can provide you with a
suitable vehicle;
·
your GPS
location;
·
medical
information which you provide to us, only where we need to procure the
provision by a Driver Partner of a vehicle suitable for your needs (where you
have specifically asked us for this) and you have provided details about your
health which are necessary for us to ensure a suitable vehicle; and
·
details of
any enquiries made by you through the website or by phone. We will monitor and
record communications with you (such as telephone conversations and emails) for
the purposes of provision of services, quality assurance, complaint
investigation, training, fraud prevention and compliance purposes. Any
information that we receive through such monitoring and communication will be
added to the information we already hold about you and will also be used for
the purposes listed above.
Please note that in compliance with data protection
legislation, we will process your personal information without your knowledge
or consent where this is required or permitted by law.
WHEN DO WE COLLECT YOUR PERSONAL INFORMATION?
When you use our website, web booking portal, mobile
device booking application, telephone us, sign up to our
newsletters or alerts, or create an account with us when using our services or
those of our Driver Partners.
WHY
DO WE COLLECT YOUR PERSONAL INFORMATION?
Under data protection legislation we may only process
your personal information if we have a legal basis (i.e., a legally permitted
reason) for doing so. For the purposes of this Policy, our legal basis for
processing your Information is set out below:
a)
The processing of the information listed
below is necessary for the performance of the contract between us, enabling us
to;
·
provide or procure the provision of services
to you and the administration related to those services such as arranging
billing, taking payments (for more information please see below), chasing
payments, issuing email receipts, sending you alert notifications about the
service you have ordered and received via SMS, push notification or telephone
(see further information below under “Telling you about our services”;
investigate and address any comments, queries or complaints made by you
regarding the website and/or our services, acting as intermediary between you
and our Driver Partners and any similar or related comments, queries;
·
ensure that content from the website is
presented in the most effective manner for you and for your device;
·
monitor the frequency and length of time you
use our services and those of our Driver Partners to ensure the smooth running
of the services we provide to you, in accordance with 'Your Rights as set out
in this Policy'; and
·
allow you to participate in interactive
features of the website and electronic booking applications, including
inputting information and providing feedback.
b)
You have provided your consent to the
processing, enabling us to:
·
process your personal information for
marketing purposes where we are required to obtain your consent by law (which
you may withdraw at any time after giving it, as described in the Telling You About Our Services' section below and
·
process your sensitive personal information
where we need to procure the provision by a Driver
Partner of a vehicle suitable for your needs (where you have specifically asked
us for this) and you have provided details about your health which are
necessary for us to ensure a suitable vehicle.
c)
The processing is necessary for Veezu’s
legitimate interests so that we can:
·
contact you for marketing purposes (and you
are given the option to opt-out at any time) pursuant to our legitimate
interest to promote and develop our business. Please see the ' Telling You About Our Services' section below
for further information;
·
research into usage and behaviour pursuant to
our legitimate interest in improving and changing our services, including
personalisation to your needs, such as listing previously used
addresses/destinations, operating, administering, maintaining, providing,
analysing and improving the website and the services available to you through
the website or by phone; and
·
notify you about changes to the website
pursuant to our legitimate interest in communicating changes which may impact
our users' use of our services.
d)
The processing is necessary to protect vital interests, for example:
·
in the rare instance
where we process personal information to save someone’s life.
e)
The processing is necessary to comply with a legal obligation Veezu is
under, for example:
·
any request or order
from law enforcement agencies and/or HMRC in connection with any investigation
to help prevent unlawful activity.
DISCLOSURE OF YOUR INFORMATION
We will disclose your personal information
to:
·
other
companies within our group of companies (i.e., the subsidiaries outlined in the
'Introduction' section);
·
our
business partners, service providers who are providing services under a
separate contract with you, such as our Driver Partners, or our third-party
contractors and advisors such as DiSC telephony and iCabbi dispatch providers
(and any business partners, service providers or third-party contractors of any
other companies within our group of companies) to enable them to undertake
services for us and/or on our behalf;
·
our
third-party payment providers such as Judo and AirPay (please see the 'Payment'
section in our Passenger Terms and Conditions shown on our website(s) for more
information);
·
any
prospective buyer or seller (and their representatives) in the event that we
sell or buy any business or assets;
·
HMRC,
other government departments and regulators, in order to comply with any legal
obligation;
·
other lawyers, insurers or other advisers in
respect of any claims brought by passengers / driver partners / general public.
This includes sharing information in connection with legal or insurance claims
to protect the rights and safety of others;
·
(in
the case of aggregated/anonymous information i.e., information from which you
cannot be personally identified, or insights based on such anonymous
information), selected third parties, including (without limitation) analytics
and search engine providers to assist us in the improvement and optimisation of
the website. In such circumstances we do not disclose any information which can
identify you personally; and
·
(if
our whole business is sold or integrated with another business) our advisers
and any prospective purchasers and their advisers and will be passed on to the
new owners of the business.
·
the
NHS Test and Trace contact-tracing service.
TELLING
YOU ABOUT OUR SERVICES
Communicating with passengers is an essential part of
providing a reliable and trustworthy licensed taxi/ private hire service. We
will therefore contact you by telephone, text, via the app or by email in
relation to non-marketing, service-related communications to:
·
update you on
the progress of your booking;
·
remind you of
any public health guidance applicable to your journey; and
·
ask for
feedback on your journey.
We send out marketing communications based on our
legitimate interests of running a licensed taxi/ private hire booking service
and keeping people informed about the services we and our Driver Partners and
other service providers offer where:
·
we send you
information via post; or,
·
if you are
dealing with us on behalf of a business and we contact you via your corporate
email address;
We will only contact consumer customers, sole traders and
non-limited liability partnerships by personal email for marketing purposes if:
·
you have
given your consent; or
·
you have
previously bought goods and services from us and we are contacting you to let
you know about similar goods and services that we offer.
You have the right at any time to ask us, or any third
party, to stop processing your information for direct marketing purposes,
please see 'Your
Rights in Relation to Your Personal Information' below.
Please see our separate Cookies Policy on any of our
websites for further information about how we use cookies.
TRANSFERRING PERSONAL DATA OUTSIDE OF THE UK
We may transfer your Personal Data to
countries outside of the UK and these countries may have data protection rules
that are different from the UK. To ensure that any of your personal
information that is transferred outside of the UK receives an adequate level of
protection, appropriate measures are in place to ensure that your personal
information is treated by those third parties in a way that is consistent with
and which respects UK law on data protection.
HOW
DO WE KEEP YOUR PERSONAL INFORMATION SECURE?
We have put in place measures to protect the security of
your personal information both in accordance with the requirements of the UK
GDPR, the DPA 2018 and the ISO 27001 Information Security Standard. Third
parties will only process your personal information on our instructions and
where they have agreed to treat the information confidentially and to keep it
secure.
We have put in place appropriate security measures to
prevent your personal information from being accidentally lost, used or
accessed in an unauthorised way, altered or disclosed. In addition, we limit
access to your personal information to those employees, agents, contractors and
other third parties who have a business need to know. They will only process
your personal information on our instructions, and they are subject to a duty
of confidentiality.
We have put in place procedures to deal with any
suspected data security breach and will notify you and any applicable regulator
of a suspected breach where we are legally required to do so.
HOW LONG DO
WE KEEP YOUR PERSONAL INFORMATION FOR?
We will only retain your personal information for as long
we need to. This includes satisfying any regulatory, legal, accounting, or
reporting requirements.
·
we hold your
personal information for up to a maximum of 7 years from when it was last used
to comply with legislation and local authority rules that we are subject to;
and/or
·
where we are
processing on the basis of consent only, we hold the Information until consent
is withdrawn.
CHANGES TO
YOUR PERSONAL INFORMATION
It is important that the personal information we hold
about you is accurate and current. Please keep us informed if the personal
information you have given to us either when you downloaded our App or when you
opened an account, changes during your relationship with us.
Under data protection legislation, we are a Data Controller
and therefore we are responsible for, and control the processing of, your
personal information. Such information must be protected in accordance with
data protection legislation.
In accordance with data protection legislation your
personal information will be;
·
used
lawfully, fairly and in a transparent way;
·
collected
only for valid purposes that we have clearly explained to you and not used in
any way that is incompatible with those purposes;
·
relevant to
the purposes we have told you about and limited only to those purposes;
·
accurate and
kept up to date;
·
kept only as
long as necessary for the purposes we have told you about; and
YOUR
RIGHTS IN RELATION TO YOUR PERSONAL INFORMATION
If you are an individual, you have the right to:
• ask us to provide you with copies of personal information
we hold about you;
• ask us to provide your personal information to a
third-party provider of services. This right only applies where we use your
personal information on the basis of your consent or performance of a contract
and where our use of your information is carried out by automated means;
• ask that we correct any personal information if it is
found to be inaccurate or out of date;
• ask that your personal information is erased where it is
no longer necessary for us to keep it;
• request a restriction to be placed on further processing
of your personal information where there is a dispute in relation to the
accuracy or processing of your personal information;
• object on legitimate grounds to the processing of your
personal information, where applicable i.e., where processing is based on
legitimate interests (or the performance of a task in the public
interest/exercise of official authority) and processing for the purposes of
scientific/historical research and statistics);
• ask us to stop using your personal information for direct
marketing purposes. If you exercise this right, we will stop using your
personal information for this purpose. If you wish to exercise this right, you should complete
our Withdrawal Consent Form available on our website (www.veezu.co.uk) or
contact the relevant third party using their given contact details, giving us
or them enough information to identify you and deal with your request.
Alternatively, you can follow the unsubscribe instructions in emails you
receive from us or them.
There are some exemptions, which may apply, for example,
information collected and processed for the prevention, investigation,
detection or prosecution of criminal offences. If you want to exercise any of
your data subject access rights, please contact: Veezu Compliance at compliance@veezu.co.uk.
If you have any difficulty in reading or understanding
this Policy, or if you would like this Policy in another format (for example
audio, large print or braille), please contact us.
Veezu Compliance will oversee compliance of
this privacy notice. If you have any questions about this privacy notice or how
we handle your personal information, please email compliance@veezu.co.uk
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.
We may update our privacy policy from time to
time. Any changes we make to our privacy policy in the future will be posted on
this page and, where appropriate, notified to you by post or email. Please
check back frequently to see any updates or changes to our privacy policy.