Data protection NOTICE
We, BLISSCARS247 (“we” “our” or “us”) with our
registered office address at [●][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 BLISSCARS247
software application (the “App”);
1.1.2
the BLISSCARS247
website (the "Website");
and
1.1.3
any other
communications (whether over telephone, email, SMS message or otherwise)
between you and BLISSCARS247 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 BLISSCARS247. Our [Data Protection Officer or Privacy Compliance
Manager] is [INSERT
DETAILS]
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 a taxi journey is
cancelled by you.][8]UPON
CANCELLATION THERE SHALL BE A CANCELLATION CHARGE OF £3. ONCE A DRIVER IS
ENROUTE THEN WE SHALL BE DEDUCTED 25% OF THE TOTAL FARE. |
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, BLISSCARS247 , 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 BLISSCARS247, 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. ●
TAXI COMPANY TO
INSERT ADDITIONAL PURPOSES, IF ANY].[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. ●
[TAXI COMPANY TO
INSERT ADDITIONAL LEGAL OBLIGATIONS][11] |
Legal Basis |
Legitimate Interests |
Purposes |
It is In BLISSCARS247'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. ●
[TAXI COMPANY TO INSERT PURPOSES – DELETE IF NONE][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, BLISSCARS24 , 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] |
●
BLISSCARS247 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
BLISSCARS247 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.][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 info@blisscars247.com.[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 admin@blisscars247.com[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, [INSERT CONTACT
DETAILS].[26]
[1] Please insert
address of customer taxi company in each instance.
[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.