1. Who we are and the scope of this notice
Chauffeur International Ltd (company number 11233870), trading as Classy Chauffeur (“Classy Chauffeur”, “we”, “us” or “our”), is the controller responsible for the personal information described in this Privacy Policy.
Registered office: 450 Bath Road, West Drayton, England, UB7 0EB
Privacy email: office@classy-chauffeur.com
Telephone: +44 (0)7480 218132
ICO registration number: ZA884112
This notice applies to visitors to www.classychauffeur.co.uk, people who contact us or make an enquiry, customers and account holders using our customer app, passengers, people who make a booking for somebody else, and business contacts connected with customer accounts.
This notice does not cover chauffeurs, driver applicants or users of the driver app. Their personal information is covered by a separate Driver Privacy Notice. Third-party websites, apps and services have their own privacy notices, and we are not responsible for their independent processing.
3. Where we obtain personal information
We obtain personal information:
- directly from you when you visit the website, create an account, use the customer app, request a quotation, make or manage a booking, pay, contact us or exercise your rights;
- from a person or organisation making a booking for a passenger, including an employer, corporate travel manager, hotel, travel agent, event organiser, family member or other representative;
- from assigned chauffeurs and service partners, for example journey-status updates, collection information, incident reports and lost-property information;
- from payment, identity, account-login, mapping, flight-information and communication providers where needed to provide the feature you requested; and
- automatically from the website, customer app, device and cookies or similar technologies, subject to applicable consent requirements.
If you provide another person’s information, you should ensure that you are authorised to do so and that the person has been informed about this Privacy Policy. Where we receive information about a passenger from another source, we provide privacy information at the appropriate time unless an applicable legal exception applies.
4. How and why we use personal information
UK data protection law requires us to have a lawful basis for each purpose. The basis depends on the information and the circumstances. Our principal purposes and bases are set out below.
- Enquiries, quotations and pre-booking steps. We respond to requests, calculate quotations and take steps requested before a contract. We rely on steps necessary before entering a contract and, where the enquirer is not the contracting customer, our legitimate interest in responding and developing our business.
- Accounts and authentication. We create and administer accounts, verify logins, maintain account security and process account-closure requests. We rely on performance of the customer contract and our legitimate interests in secure account administration.
- Bookings and service delivery. We confirm bookings, allocate a suitable chauffeur or service partner, provide journey details, monitor relevant flights, manage changes, cancellations and applicable cancellation charges, and complete the service. We rely on performance of a contract with the customer. Where the passenger is not the contracting customer, we rely on our legitimate interests and those of the customer and passenger in arranging and completing the requested journey.
- Payments, refunds, invoices, accounting and debt recovery. We process payments and refunds, issue invoices, maintain transaction records, prevent payment fraud and contact customers about amounts due. Where an amount remains unpaid, we may take proportionate lawful steps to recover it. We rely on performance of the contract, compliance with legal obligations and our legitimate interests in protecting our business and recovering sums properly due.
- Service communications. We send confirmations, verification messages, receipts, journey updates, service notices and responses to customer enquiries. We rely on the contract and our legitimate interests in providing effective customer service.
- Safety, security, fraud prevention and legal claims. We protect customers, staff, chauffeurs, systems and the business; investigate misuse, incidents or complaints; enforce terms; and establish, exercise or defend legal claims. We rely on legal obligations and our legitimate interests in security, fraud prevention and legal protection.
- Service improvement and analytics. We understand how the website and customer app are used, diagnose faults, improve usability and measure performance. For non-essential cookies, analytics or similar app technologies, we rely on consent where required. For essential diagnostics and aggregated operational analysis, we rely on our legitimate interests in maintaining and improving the service.
- Marketing. We may send information about relevant services and offers by email, SMS, app notification or similar electronic message where you have consented or where applicable law permits communications to existing customers. We rely on consent or legitimate interests as permitted by the Privacy and Electronic Communications Regulations. You can opt out at any time.
- Legal and regulatory compliance. We comply with tax, accounting, transport, licensing, law-enforcement, court and regulatory requirements. We rely on legal obligation and, where appropriate, legitimate interests in demonstrating compliance.
- Business administration and corporate transactions. We manage suppliers, advisers, insurance, audits, corporate restructuring, investment, sale or transfer. We rely on our legitimate interests in operating and protecting the business, subject to appropriate safeguards.
Where we rely on legitimate interests, we consider the necessity of the processing, the expected benefits, the impact on individuals and the safeguards available. You may object to processing based on legitimate interests; see section 12.
5. Accessibility and other sensitive information
You may voluntarily tell us about accessibility or assistance requirements so that we can arrange an appropriate service. This information may reveal health or disability information, which is special category personal information. In addition to an Article 6 lawful basis, we rely on your explicit consent where required under Article 9 of the UK GDPR. We use only the minimum information necessary and share it only with people who need it to provide the requested assistance.
You may withdraw this consent by contacting us. Withdrawal does not affect earlier lawful processing, but it may mean that we cannot provide the particular assistance requested. If somebody provides this information for a passenger, they must be authorised to do so and, where required, have the passenger’s explicit consent.
6. Information required to provide the service
To provide a quotation or booking, we normally require the customer’s or booker’s contact information, the necessary passenger and journey details and, for paid bookings, payment or billing information. Without this information, we may be unable to provide a quotation, enter into the booking contract, collect payment or complete the journey. Location permission, marketing preferences and most optional service preferences are not required, although disabling a feature may prevent that feature from working.
7. Who we share personal information with
We disclose personal information only where necessary and proportionate, including to:
- Assigned chauffeurs, fleet providers and partner operators. We provide the minimum passenger, contact, journey and assistance information needed to deliver the booked service. Depending on the arrangement, a partner operator may act as an independent controller and may provide its own privacy notice.
- The customer, booker or business-account administrator. Where a booking is created, managed or paid for through a business account, authorised account administrators can create and manage bookings and may view information associated with that account, including booking references, assigned chauffeurs, dates, pick-up and drop-off locations, amounts due, payment status and booking history. Where a booking is made for another passenger, relevant booking, journey and payment information may be visible to the person or organisation responsible for the booking.
- Payment and financial-service providers. They process payments, refunds, fraud checks and transaction records under their own legal and security obligations.
- Technology and communications providers. These may include website and app hosting, cloud storage, customer support, email, SMS or OTP delivery, push notifications, account sign-in, mapping, flight information, analytics, security and technical-support providers.
- Professional advisers and insurers. Accountants, auditors, solicitors, claims handlers, insurers and other advisers may receive information where necessary for professional services, claims or risk management.
- Authorities and other lawful recipients. Courts, police, regulators, licensing bodies, tax authorities, emergency services or other recipients may receive information where required or permitted by law, or to protect vital or legal interests.
- Corporate transaction recipients. Prospective purchasers, investors or advisers may receive appropriately protected information during a proposed merger, restructuring, investment or sale. Any new controller must handle information in accordance with applicable law.
We do not sell or rent personal information to third parties.
8. International transfers
Our overseas development or support personnel do not have access to customer, passenger or booking information. Some technology suppliers are international organisations and may process personal information outside the United Kingdom. Where this results in a restricted transfer, we use an appropriate legal mechanism, such as UK adequacy regulations or contractual safeguards approved for UK transfers, and complete any required transfer-risk assessment.
You may contact us for further information about the relevant destination and safeguard, including how to obtain a copy where legally available.
9. How long we keep personal information
We keep personal information only for as long as reasonably necessary for the purpose for which it was collected, including legal, accounting, regulatory, safety and claims requirements. Our normal retention approach is:
- Enquiries that do not become bookings: normally 12 months after the enquiry is closed.
- Customer accounts and deletion requests: for as long as the account remains active. When you request deletion, login access and login credentials are removed immediately and standalone profile information is deleted. Identity and contact information contained within retained past-booking records remains subject to the booking-record period below.
- Past bookings and operational journey information following account deletion: booking references, assigned-chauffeur information, journey dates, pick-up and drop-off locations, charges and the customer information contained in those booking records are normally retained for up to 12 months after account deletion. The system is configured to delete or anonymise this operational information automatically at the end of that period, unless it is still required for an unpaid amount, complaint, incident, fraud investigation, legal claim or legal obligation.
- Invoices, payment, accounting and tax records: an operational customer-linked copy may remain in the booking system for up to 12 months after account deletion. Records that form part of our statutory accounting or tax records are retained separately for the applicable legal period, normally six years, or longer where law or an active enquiry requires.
- Complaints, incidents and legal claims: for as long as necessary to investigate and resolve the matter and normally up to six years after closure, subject to the circumstances and applicable limitation periods.
- Accessibility information: normally until the journey is completed, unless you choose to save the preference to your account or it is required for an incident or claim. Saved preferences remain until you remove them or the account is deleted.
- Marketing records: until you withdraw consent or opt out. We may keep a minimal suppression record for as long as necessary to ensure that we respect your choice.
- Security and technical logs: normally up to 12 months, unless a longer period is needed to investigate a security incident, fraud or misuse.
- Cookie and analytics information: for the periods stated in our Cookie Policy and the relevant consent tool.
When information is no longer required, we delete it securely or anonymise it. Information in protected backups is removed through the normal backup cycle and is not restored for ordinary business use.
10. Cookies, app permissions and similar technologies
The website and customer app use cookies, software development kits, local storage and similar technologies. Technologies that are strictly necessary for security, account access, booking functions or a service you request may operate without consent where the law permits. Non-essential analytics, advertising or preference technologies operate only after the required consent has been obtained.
Our Cookie Policy identifies the technologies used, their providers, purposes and duration. You can change non-essential cookie choices through the cookie-settings tool. App permissions, including device location and notifications, can also be controlled through the app and your device settings. Withdrawing permission may stop the related feature from working.
11. How we protect personal information
We use appropriate technical and organisational measures designed to protect personal information against accidental or unlawful loss, alteration, disclosure, access or destruction. Measures include role-based access controls, authentication, encryption in transit where appropriate, system monitoring, secure payment processing, supplier due diligence, confidentiality obligations, backup and recovery arrangements and incident-response procedures.
No internet or electronic-storage system can be guaranteed completely secure. If a personal-data breach is likely to result in a risk to individuals, we will notify the ICO without undue delay and, where feasible, within 72 hours. If it is likely to result in a high risk, we will also inform affected individuals without undue delay, unless an applicable exception applies.
12. Your data-protection rights
Depending on the circumstances and applicable law, you may have the right to:
- Access. Request confirmation of whether we use your information and obtain a copy together with supporting information.
- Rectification. Ask us to correct inaccurate information and complete incomplete information.
- Erasure. Ask us to delete information where the right applies. This right is not absolute, and we may retain information required by law or for legal claims.
- Restriction. Ask us to restrict processing in specified circumstances.
- Data portability. Receive certain information you provided in a structured, commonly used and machine-readable format, or ask us to transmit it to another controller where technically feasible.
- Object. Object to processing based on legitimate interests. You have an absolute right to object to the use of your information for direct marketing.
- Withdraw consent. Withdraw consent at any time where processing relies on consent, without affecting processing that was lawful before withdrawal.
- Automated decisions. Receive safeguards where a solely automated decision with legal or similarly significant effects is made, where applicable.
- Complain. Raise a concern with us or lodge a complaint with the Information Commissioner’s Office.
To exercise a right, email office@classy-chauffeur.com. We may request information reasonably needed to confirm identity and authority. We normally respond within one month after receiving a valid request and any necessary identification, but the period may be extended where the law permits, for example for a complex request.
Closing or deleting your account. If you have created a customer account, you can initiate account deletion in the customer app by selecting Account → Help & Support → Delete my Account. Login access and login credentials are removed immediately, and other information is deleted, anonymised or retained as described in section 9. You may also contact office@classy-chauffeur.com for assistance.
Active bookings and outstanding amounts. If you delete your account while a booking is still active but has not yet been performed, that booking will be cancelled and the applicable Cancellation Policy will apply. Deleting an account does not remove an outstanding payment obligation. We may contact you about the amount due and, where necessary, take proportionate lawful steps to recover it. We may retain the minimum booking, payment and contact information necessary for those purposes and for our legal obligations.
13. Children
The website and customer app are not directed at children, and a person under 18 should not create an account or make a booking. A child may travel as a passenger where a booking is made and managed by a parent, guardian or other responsible adult. We collect only the child-related information reasonably necessary to provide the journey safely and lawfully.
14. Automated processing
We may use automated tools to help calculate quotations or routes using factors such as distance, time, vehicle category, availability, tolls and airport charges. We do not currently use solely automated processing of personal characteristics to make decisions that produce legal or similarly significant effects on customers or passengers. If this changes, we will update this notice and provide the information and safeguards required by law.
15. Changes to this Privacy Policy
We may update this Privacy Policy to reflect changes in our services, technology, suppliers or legal obligations. The latest version will be published on the website and made available through the customer app. We will update the effective date and, where a change is material, provide an additional notice by an appropriate method.
Need Assistance?
Our team is available 24/7 for bookings, enquiries, or data protection requests.
