PP.1  Data We Collect

PP.1.1  We collect and process the following categories of personal data:

• Identity data: name, title, company name;

• Contact data: email address, telephone number, billing address;

• Booking data: journey details, collection and delivery addresses, flight numbers, passenger numbers, vehicle preferences, special instructions;

• Financial data: payment card details, billing records, invoice history;

• Technical data: IP address, browser type, website usage data and cookies; and

• Special category data (only where strictly necessary and with explicit consent): health information relevant to the provision of safe transport, such as mobility requirements.

 

PP.2  Lawful Basis for Processing

PP.2.1  We process personal data on the following lawful bases:

• Contract performance: to fulfil our obligations under the contract with you, including providing the Services and issuing invoices;

• Legitimate interests: to operate our business efficiently, manage subcontractors, prevent fraud and improve our Services;

• Legal obligation: to comply with our obligations under applicable law, including tax law and private hire licensing requirements; and

• Consent: where we ask for your consent to process data for a specific purpose, such as marketing communications. You may withdraw consent at any time.

 

PP.3  Data Sharing

PP.3.1  We share personal data with the following categories of recipient:

• Our drivers and subcontractors, to the extent necessary to perform your Booking;

• Our booking management and dispatch technology providers;

• Payment processors and banking institutions;

• Regulatory bodies, including Transport for London and HMRC, where required by law; and

• Legal advisers and debt recovery agents where necessary to enforce our rights.

PP.3.2  We do not sell, trade or rent personal data to any third party for their own commercial purposes.

 

PP.4  Data Retention

PP.4.1  We retain personal data for the following periods:

• Booking and journey records: 6 years (to comply with tax and accounting obligations);

• Financial records: 7 years;

• Marketing preferences: until consent is withdrawn or you opt out;

• Correspondence: 3 years from the date of last communication; and

• Website technical data: 13 months.

 

PP.5  Your Rights

PP.5.1  You have the following rights in respect of your personal data:

• Right of access: to request a copy of personal data we hold about you;

• Right to rectification: to request correction of inaccurate personal data;

• Right to erasure: to request deletion of personal data in certain circumstances;

• Right to restrict processing: to request that we limit how we use your data;

• Right to data portability: to receive your data in a structured, machine-readable format;

• Right to object: to object to our processing of your data based on legitimate interests; and

• Rights relating to automated decision-making: to not be subject to solely automated decisions that have legal or similarly significant effects.

PP.5.2  To exercise any of these rights, please contact us at: info@harringtons-of-london.com. We will respond to all requests within one month of receipt.

PP.5.3  You have the right to lodge a complaint with the Information Commissioner's Office (ICO) at any time if you believe that we have not handled your personal data in accordance with applicable law. The ICO's contact details can be found at ico.org.uk.

 

PP.6  Data Security

PP.6.1  We implement appropriate technical and organisational security measures to protect personal data against unauthorised access, disclosure, alteration and destruction. However, no transmission over the internet is completely secure and we cannot guarantee absolute security.

 

 PP.7  Changes to This Policy

PP.7.1  We may update this Privacy Policy from time to time. Material changes will be communicated via our website or, where appropriate, by direct communication to affected individuals.