COOKIE AND SIMILAR TECHNOLOGIES POLICY

1. Who we are and the scope of this Policy

Chauffeur International Ltd (company number 11233870), trading as Classy Chauffeur, is responsible for deciding how the technologies covered by this Policy are used on our services. In this Policy, “we”, “us” and “our” mean Chauffeur International Ltd.

Registered office: 450 Bath Road, West Drayton, England, UB7 0EB

Website: www.classychauffeur.co.uk

Email: office@classy-chauffeur.com

This Policy covers our public website and the Classy Chauffeur customer app for iOS and Android. It should be read with our Privacy Policy, which explains how and why we process personal information, retention periods, data sharing and your data-protection rights.

Privacy Policy: www.classychauffeur.co.uk/privacy-policy

2. What cookies and similar technologies are

Cookies are small data files that a website stores on a browser or device. First-party cookies are set for our service; third-party cookies are provided by another organisation. Session cookies usually expire when the browser session ends. Persistent cookies remain for a stated period unless deleted earlier.

The same legal rules can apply to other storage and access technologies, including web or app local storage, software development kits (SDKs), tracking pixels, tags, scripts, device identifiers and similar tools. We therefore use “technologies” in this Policy to cover all of them, not only traditional browser cookies.

3. The legal rules and your choices

Our use of these technologies is governed principally by the Privacy and Electronic Communications Regulations 2003 (PECR), as amended, and—where personal information is processed—the UK GDPR and Data Protection Act 2018.

We may use technologies without consent where they are required solely to transmit a communication, are strictly necessary to provide a service you request, or fall within another applicable statutory exception. Examples may include secure login, fraud prevention, technical security, keeping a booking session active and remembering your privacy selection.

For all other technologies, we request a specific choice before they are activated. Non-essential technologies remain off unless you consent. Rejecting them must not prevent you from creating an account or making a booking, although a feature that depends on an optional technology may remain unavailable until you choose to enable it.

The law may permit limited statistical or appearance/functionality technologies without consent where every condition for the relevant exception is met. If we rely on such an exception, we will explain the purpose, limit use to that purpose, provide a simple means of objecting where required and will not use the information for advertising or individual profiling. Until that assessment has been completed, optional analytics must remain consent-based.

4. Categories of technology we may use

5. The live technology list

The Cookie Settings panel forms part of this Policy. Once the production website and app are available, it must display the technologies actually active on the service, including the exact identifier, provider, purpose, category, first- or third-party status and duration. We will keep that list accurate when the service or providers change.

Our pre-launch design anticipates that the service may require session, authentication, security and privacy-preference technologies. Google Analytics, Google Ads, Meta technologies, maps, payment security, fraud prevention, crash reporting, push-notification or similar provider tools must be listed only if the final technical audit confirms that they are active. A provider named during development is not automatically an active provider.

If a technology is not included in the live list, it must not be activated unless it is added to the list and the required information and choice are provided first.

6. Managing or withdrawing your choices

On your first visit, the website must provide equally accessible options to Accept all, Reject non-essential and Manage preferences. Optional controls must be off by default and must not use pre-ticked boxes or misleading design. The customer app must provide equivalent choices where it uses non-exempt app technologies.

You can change your choices at any time by:

• selecting Cookie Settings in the website footer;
• using the Privacy or Cookie Settings control in the customer app, where applicable;
• changing relevant browser, device or app permissions; or
• contacting us if the control is unavailable or does not work as expected.

Withdrawing consent does not affect the lawfulness of activity that occurred before withdrawal. After withdrawal, we will stop the relevant technology from future use where technically possible. Existing server-side records remain subject to the retention periods and rights explained in our Privacy Policy.

We normally remember a consent or refusal for up to six months, unless you clear the preference, our purposes or providers change, or an earlier refresh is appropriate. We will not repeatedly ask you to reverse a refusal.

7. Third-party services and international transfers

Some features may be supplied by third parties. Depending on the final configuration, these could include analytics, advertising, mapping, payment, authentication, security, customer-support, crash-reporting or push-notification providers. We are responsible for understanding technologies placed through our service and for configuring them consistently with this Policy.

Where a provider processes personal information outside the United Kingdom, we will use an appropriate transfer safeguard or other lawful mechanism as explained in our Privacy Policy. The live technology list will identify the relevant provider and link to further provider information where appropriate.

A simple external link does not itself mean the linked provider sets technologies on our service. If you leave our service or actively open third-party content, that provider's own privacy and technology rules may apply.

8. Browser, device and app controls

Most browsers allow you to view, block or delete cookies. Mobile operating systems also provide controls for permissions, advertising identifiers, notifications and background activity. Blocking strictly necessary technology may prevent login, booking, payment-security or other requested functions from working correctly.

Private or incognito browsing normally permits temporary technologies during the session but removes some local information when the private session closes. It does not necessarily prevent all tracking or server-side processing. Browser settings alone do not replace our duty to provide a valid consent mechanism where consent is required.

9. Retention and changes to this Policy

Each live technology must have a duration proportionate to its purpose. Session technologies normally expire when the relevant session ends. Persistent technologies expire after the period shown in Cookie Settings unless you delete them earlier. A local technology's expiry is not necessarily the same as the retention period for related server-side information; those periods are explained in our Privacy Policy.

We may update this Policy when our service, providers, purposes or the law changes. We will publish the revised effective date. Continued use does not replace consent. If a change materially affects an optional purpose, we will request a new choice before activating the changed technology where required.

10. Contact and complaints

Questions or concerns about this Policy or our privacy controls can be sent to:

Email: office@classy-chauffeur.com

Post: Chauffeur International Ltd, 450 Bath Road, West Drayton, England, UB7 0EB

We will investigate concerns and try to resolve them promptly. You may also complain to the Information Commissioner's Office (ICO), although we encourage you to contact us first so that we have an opportunity to address the issue.

ICO: ico.org.uk/make-a-complaint

APPENDIX A — DEVELOPER LAUNCH VERIFICATION

INTERNAL IMPLEMENTATION SCHEDULE — Complete this appendix before launch. Do not publish it to customers. After completion, populate the live Cookie Settings list, remove the pre-launch note and this appendix, and perform a clean-device test of every consent choice.

The earlier draft named the following technologies. Their inclusion below records a development claim only; it does not confirm that they exist or that their stated purpose or duration is correct.

The final audit must record:

• the exact identifier or storage key, domain, provider, category, purpose and lifespan;
• whether it operates on the website, iOS app, Android app or more than one service;
• whether it loads before any choice and the specific exception relied upon, if any;
• all analytics, advertising, payment, mapping, authentication, security, chat, push-notification and crash-reporting providers;
• whether a third party receives personal information and whether an international transfer occurs;
• that Accept all, Reject non-essential and Manage preferences work and are equally accessible;
• that rejecting or withdrawing consent prevents future optional storage and access; and
• that the final live list and Privacy Policy accurately reflect the production configuration.

Test on a clean browser and fresh app installation, then repeat after Accept all, Reject non-essential, category-level selection and withdrawal. Retain the audit record, consent configuration and policy version for compliance evidence.