DATA PROTECTION NOTICE
We, THISTLE CABS GROUP (“we” “our” or “us”) with our registered office address at 6/8
BONNYTON ROAD,KILMARNOCK,EAST AYRSHIRE,KA1 2QS 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 THISTLE CABS GROUP software application (the “App”);
1.1.2 the THISTLE CABS GROUP website (the "Website"); and
1.1.3 any other communications (whether over telephone, email, SMS message or
otherwise) between you and THISTLE CABS GROUP 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 THISTLE CABS GROUP. Our [Data Protection Officer or Privacy
Compliance Manager] is GRAEME RUSSELL
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.
App,
Website,
Other
Comm
unicati
ons
● 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
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
Comm
unicati
ons
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.]6
App,
Website,
Other
Communications
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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.]7
App,
Website,
Other
Communications
3. HOW AND WHY WE PROCESS YOUR PERSONAL DATA
We, THISTLE CABS GROUP, 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 THISTLE CABS GROUP, 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.
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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 THISTLE CABS GROUP'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.
4. DISCLOSURE OF YOUR INFORMATION TO THIRD PARTIES
We, THISTLE CABS GROUP, 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
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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.]8
●THISTLE CABS GROUP Group: We may disclose your personal information to other
members of our group, which means our subsidiaries, our ultimate holding company and its
subsidiaries.]9
● 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 THISTLE CABS GROUP 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.]10
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.]11
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]12
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
THISTLE CABS GROUP 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.]13
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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.
Further Information
● 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.
● 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.
● You have the right to request that we amend any inaccurate
personal data that we have about you.
● 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.
● 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.
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● We will inform you before the processing restriction is lifted.
● 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.
● 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.
● 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 THISTLE CABS GROUP-
thistlecabs522222@yahoo.co.uk
You also have the right to lodge a complaint with the [Information Commissioner's Office or Data
Protection Commission]14 with regards to the processing of your personal data by us. For
further information see [https://ico.org.uk/ or www.dataprotection.ie]15
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 thistlecabs522222@yahoo.co.uk
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.]16 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.
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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]17 in writing, thistlecabs522222@yahoo.co.uk
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