XTS Group is committed to protecting our customer privacy and takes its responsibilty regarding the security of customer information very seriously. We will be clear and transparent about the information we are collecting and what we will do with that information.
This policy sets out the following:
- What personal data we collect and process about your and/or your business in connection with your relationship with us, both as a customer and through your use of our website and online services;
- Where we obtain data from;
- What we do with that data;
- How we store the data;
- Who we transfer/disclose that data to;
- How we deal with your data protection rights;
- And how we comply with the data protection rules.
All personal data is collected and processed in accordance with UK and EU data protection rules.
WHAT PERSONAL DATA WE COLLECT
Personal data means any information relating to you which allows us to identify you, such as your name, contact details, booking reference number, payment details and information about your access to our website.
We may collect personal data from you when you book a transfer with us, create an account with us, use our website or contact us.
Specifically, we may collect the following categories of information:
- Name, home address, email address, telephone number, credit/debit card or other payment details;
- Medical conditions for passengers who have special medical and/or dietary requirements;
- Travel history, including information related to your flights;
- Information about your use of our website;
- The comminications you exchange with us or direct to us via letters, emails, calls and social media.
Personal details about your physical or mental health, alleged commission or conviction of criminal offences are considered senstive personal data under applicable data protection laws. We will process any such data only if you have given your explicit consent, or it is necessary (for instance if you request special assistance), or you have deliberately made it public.
WHAT DO WE USE YOUR PERSONAL DATA FOR, WHY AND FOR HOW LONG
Your data may be used for the following purposes:
- Providing the service you request: we use the information you give us to perform the services you have asked for in relation to your transfer;
- Contacting you in the event of any change or cancellation: we send you communications about the service you have asked for and any changes to such services. These communications are not made for marketing purposes and cannot be opted-out of;
- Credit or other payment card verification: we use your payment information for accounting, billing and audit purposes;
- Administrative or legal purposes: we use data for statistical and marketing analysis, systems testing or to deal with a dispute or claim;
- Security, health, administrative, crime prevention/detection: we may pass your information to government authorities or enforcement bodies for compliance with legal requirements;
- Customer Services communications: we use your data to manage our relationship with you as our customer and to improve our services and enhance your experience with us;
- Provide tailored services: we use your data to provide information we believe is of interest to you, prior to, during, and after your transfer to personalise the service we offer to you;
- Marketing: from time to time we will contact you with information regarding promotions via e-communications. You will have the choice to opt in or opt out of receiving such communications. You will also be given the opportunity on every e-communication that we send you to indicate that you no longer wish to receive our direct marketing material.
We will only process your personal data where we have a legal basis to do so. The legal basis will depend on the reasons we have collected and need to use your personal data for.
In most cases we will need to process your personal data so we can enter into our contract of carriage for you.
We may also process your personal data forone or more of the following:
- To comply with a legal obligation (e.g. a government body request);
- You have consented to us using your personal data (e.g. for marketing related uses);
- To protect your vital interests or those of another person (e.g. in case of a medical emergency);
- It is in our legitimate interests in operating as a chauffeur ground transportation business (e.g. for administrative purposes).
Only children aged 16 or over can provide their own consent. For children under this age, consent of the children's parents or legal guardian is required.
We will not retain your data for longer than is necessary to fulfil the purpose it is being processed for. To determine the appropriate retention period, we consider the amount, nature and senstivity of the personal data, the puroses for which we process it and whether we can achieve those purposes through other means.
We must also consider periods for which we might need to retain personal data in order to meet our legal obligations or to deal with complaints, queries and to protect our legal rights in the event of a claim being made.
When we no longer need your personal data, we will securely delete or destroy it. We will consider if and how we can minimise over time the personal data that we use, and if we can anonymise your personal data so that it can no longer be associated with you or identify you, in which case we may use that information without further notice to you.
SECURITY OR YOUR PERSONAL DATA
We follow strict security in the storage and disclosure of your personal details, and to protect it against accidental loss, destruction or damage.
All payment details are transmitted over SSL across dedicated network infrastucture and stored in compliance with Payment Card Industry Data Security Standards (PCI DSS).
SHARING YOUR PERSONAL DATA
- Government authorities, law enforcement bodies and regulators for compliance with legal requirements;
- Trusted third partner chauffeur services required to deliver the services you have asked for;
- Credit and debit card companies which facilitate your payments to us, and anti-fraud screening, which may need information about your method of payment and transfer booking to process payment or ensure the security of your payment transaction;
- Legal and other professional advisers, law courts and law enforcement bodies in order to enforce our legal rights in relation to our contract with you;
Cookies are small text files that are transferred to your computer's hard drive through your web browser to enable us to store your email address. Most web browsers automatically accept cookies, but, if you wish, you can change these browser settings by accepting, rejecting and deleting cookies. The "help" portion of the toolbar on most browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. If you choose to change these settings, you may find that certain functions and features will not work as intended. The cookies we use do not detect any information stored on your computers.
For more information about cookies and how to stop cookies being installed visit the following website:
YOUR DATA PROTECTION RIGHTS
Under certain circumstances, by law you have the right to:
Request information about whether we hold personal information about you, and, if so, what that information is and why we are holding/using it.
Request access to your personal information (commonly known as a "data subject access request"). This enables you to receive a copy of the personal information we hold about you and check that we are lawfully processing it.
Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
Object to automated decision-making including profiling, that is not be subject of any automated decision-making by us using your personal information or profiling of you.
Request the restriction of processing of your personal information This enables you to ask us to suspend the processing of personal information about you, for example, if you want us to establish its accuracy or the reason for processing it.
Request transfer of your personal information in an electronic and structured form to you or to another party (commonly known as a right to "data portability"). This enables you to take data from us in an electronically useable format and to be able to transfer your data to another party in an electronically useable format.
Withdraw consent. In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent fot that specific processing at any time. Once we have received notification that you have withdrawn your consent, we will no longer process information for the purpose or puposes you originally agreed to, unless we have another ligitimate basis for doing so in law.
If you want to exercise any of these rights, then please submit a completed online request available at the following link [https://ico.org.uk/for-the-public/personal-information/], or contact us by post at XTS Group, 4 Theatre Court, Warwick, CV34 4DY.
You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alernatively, we may refuse to comply with the request in such circumstances.
We may need to request specific informatuon from you to help us confirm your identity and ensure your right to access the informatuon (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.