Privacy Policy
We, [THAME TAXIS (“we” “our” or “us”) with our registered office address
at [THE SANDERUM CENTRE THAME 30A UPPER HIGH STREET THAME OX9 3EEX●][1]
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.
1.
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):
1.1.1
the [THAME TAXIS] software application (the
“App”);
1.1.2
the [THAME TAXIS] website (the "Website"); and
1.1.3
any other
communications (whether over telephone, email, SMS message or otherwise)
between you and [THAME TAXIS 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 [THAME TAXIS]. Our
[Data Protection Officer or Privacy Compliance
Manager] is [MR CHRISTOPHER]
2.
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.
2.1
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, [photograph][2] and gender. ● We may collect demographic information about
you, including through user surveys.][3] |
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)][4] |
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][5] |
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.][6] |
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.][7] |
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.][8] |
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.][9] |
App, Website, Other Communications |
3.
HOW AND WHY WE PROCESS YOUR PERSONAL DATA
We, [INSERT TAXI
COMPANY NAME], 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 [THAME TAXIS],
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. ●
THAME TAXIS].[10] 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. ●
[THAME
TAXIS][11] |
|
Legal Basis |
Legitimate Interests |
|
Purposes |
It is in [THAME TAXIS]'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. ● [THAME TAXIS][12] 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. |
4.
DISCLOSURE OF YOUR INFORMATION TO THIRD PARTIES
We, [THAME
TAXIS], 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.][13] |
|
●
[[INSERT
TAXI COMPANY NAME] Group: We may disclose your personal information to
other members of our group, which means our subsidiaries, our ultimate
holding company and its subsidiaries.][14] |
|
●
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 [INSERT TAXI COMPANY NAME]
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.][15] |
5.
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.][16]
6.
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 [Data Protection Office OR Privacy Compliance Manager][17]
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.
7.
HOW LONG WE KEEP YOUR PERSONAL DATA FOR
[THAME
TAXIS] 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.][18]
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.
8.
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: (1)
it is no
longer necessary to perform the contract (2)
you
withdraw your consent and there is no other legal basis permitting us to
process your personal data (3)
you
object to the processing and we have no overriding legitimate grounds (4)
your
personal data have been unlawfully processed; or (5)
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: (1) where you contest the accuracy of your
personal data (2) where the processing is unlawful and you do
not want us to delete your personal data (3) where we no longer need your personal data for
the purposes of processing but you require the data in relation to a legal
claim (4) 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: (1)
we
process your personal data on the legal bases of your consent or where it is
necessary to perform our contract with you; and (2) 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 [thameandchinnortaxi@yahoo.co.uk].[19]
You also have the right to lodge a
complaint with the [Information
Commissioner's Office or Data
Protection Commission][20] with
regards to the processing of your personal data by us. For further information
see [https://ico.org.uk/ or www.dataprotection.ie][21]
9.
[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 at [thameandchinnortaxi@yahoo.co.uk][22]
10.
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.][23] 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][24], 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 [Data Protection Office OR Privacy Compliance Manager][25] in
writing, [mr Christopher ].[26]
[1] THE SANDERUM CENTRE THAME
30A UPPER HIGH STREET THAME OX9 3EEX
[2] Taxi Company to confirm whether photographs will be
collected from passengers.
[3] Taxi Company to review list and to confirm whether any
additional personal data is typically provided by App users.
[4] 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.
[5] Taxi Company to review and confirm.
[6] Taxi Company to review and confirm.
[7] Please consider whether this covers all information
received by Taxi Company from third party sources. Please make any necessary
updates.
[8] Taxi Company to confirm.
[9] Taxi Company to confirm.
[10] Taxi Company to list additional purposes (if any) for
processing personal data. Please only include purposes necessary to provide the
services i.e. that fall within the scope of being "necessary to perform
the contract".
[11] Taxi Company to specify whether it processes personal data to comply
with any specific legal obligations (and provide details of any specific
obligations).
[12] Taxi Company to insert purposes if any. Delete if none.
[13] Taxi Company to confirm whether passenger personal data will be shared
with third party advertisers.
[14] Taxi Company to confirm whether passenger personal data will be shred
within the taxi company group.
[15] Taxi Company to confirm whether passenger personal data will be shared
with the buyers/sellers of business assets.
[16] Taxi Company to confirm if this is a feature of the App, Website or
applicable booking platform. Delete if irrelevant.
[17] Taxi Company to amend as appropriate.
[18] 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
[19] Taxi Company to confirm this is the correct email
address.
[20] Taxi Company to select one option based on whether it is a UK or Irish
taxi fleet.
[21] Taxi Company to select one option based on whether it is a UK or Irish
taxi fleet.
[22] Taxi Company to confirm whether this service will be available to
individuals under the age of 18 (i.e. whether persons under the age of 18 will
be able to book though the taxi company platform). Please delete this section
if this is not the case.
[23] Taxi Company to confirm how users will be notified of updates.
[24] Taxi Company to amend as appropriate.
[25] Taxi Company to amend as appropriate.
[26] Taxi Company to insert relevant contact details.