We collect, use and are responsible for certain personal information about you. When we do so, we are subject to the General Data Protection Regulation and we are responsible as ‘controller’ of that personal information for the purposes of those laws.
It would be helpful to start by explaining some key terms used in this policy:
|We, us, our||Limo Executives London a company incorporated in England and Wales under company number 12137580 and whose registered office is: Ebury Management 1-6 Caxton Court, Bullen Street, London, Wandsworth, United Kingdom, SW11 3ER.|
|Our data protection officer||Mr Filippos Charalampidis who can be contacted via email@example.com|
|Personal information||Any information relating to an identified or identifiable individual|
Personal information we collect about you
We may collect and use the following personal information about you:
- your name and contact information, including email address and telephone number;
- Information to enable us to check and verify your identity, eg your date of birth;
- location data, if you choose to give this to us;
- your billing information, transaction and payment card information; and
- information to enable us to undertake credit or other financial checks on you.
This personal information is required to provide services to you. If you do not provide personal information we ask for, it may delay or prevent us from providing services to you.
How your personal information is collected
We collect most of this personal information directly from you—in person, by telephone, text or email and/or via our website. However, we may also collect information:
- from publicly accessible sources, eg Companies House or HM Land Registry;
- directly from a third party, eg:
– credit reference agencies; and
– customer due diligence providers.
- from a third party with your consent, eg your bank or building society;
How and why we use your personal information
Under data protection law, we can only use your personal information if we have a proper reason for doing so, eg:
- to comply with our legal and regulatory obligations;
- for the performance of our contract with you or to take steps at your request before entering into a contract;
- for our legitimate interests or those of a third party; or
- where you have given consent.
A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.
The table below explains what we use (process) your personal information for and our reasons for doing so:
|What we use your personal information for||Our reasons|
|To provide services to you||For the performance of our contract with you or to take steps at your request before entering into a contract|
|To prevent and detect fraud against you||For our legitimate interests or those of a third party, ie to minimise fraud that could be damaging for us and for you|
|Conducting checks to identify our clients and verify their identity
Screening for financial and other sanctions or embargoes
|To comply with our legal and regulatory obligations|
|Gathering and providing information required by or relating to audits, enquiries or investigations by regulatory bodies||To comply with our legal and regulatory obligations|
|Ensuring business policies are adhered to, eg policies covering security and internet use||For our legitimate interests or those of a third party, ie to make sure we are following our own internal procedures so we can deliver the best service to you|
|Operational reasons, such as improving efficiency, training and quality control||For our legitimate interests or those of a third party, ie to be as efficient as we can so we can deliver the best service for you|
|Ensuring the confidentiality of commercially sensitive information||For our legitimate interests or those of a third party, ie to protect trade secrets and other commercially valuable information
To comply with our legal and regulatory obligations
|Statistical analysis to help us manage our business, eg in relation to our financial performance, customer base or other efficiency measures||For our legitimate interests or those of a third party, ie to be as efficient as we can so we can deliver the best service for you|
|Preventing unauthorised access and modifications to systems||For our legitimate interests or those of a third party, ie to prevent and detect criminal activity that could be damaging for us and for you
To comply with our legal and regulatory obligations
|Updating and enhancing customer records||For the performance of our contract with you or to take steps at your request before entering into a contract
To comply with our legal and regulatory obligations
For our legitimate interests or those of a third party, eg making sure that we can keep in touch with our clients
|Statutory returns||To comply with our legal and regulatory obligations|
|Marketing our services to:
—existing and former customers;
—third parties who have previously expressed an interest in our services;
—third parties with whom we have had no previous dealings.
|For our legitimate interests or those of a third party, ie to promote our business to existing and former customers|
|Credit reference checks via external credit reference agencies||For our legitimate interests or those of a third party, ie to ensure our customers are likely to be able to pay for our products and services|
Data processing during the registered use of LEL Services and booking of rides
LEL processes the following personal data provided by you when you register and use the
LEL Services or when booking rides (hereinafter “Customer Data”):
Personal master data (title, title, first name, surname, company, address, postcode, city, country, password)
Contact details (e.g. telephone number, mobile phone number, e-mail address)
Contract data (e.g. time and type of registration, status)
Ride-related data (e.g. pick-up location, destination, times, flight number, driver’s instructions)
Status (e.g. bonus program), customer history (e.g. previous trips)
Contract billing (e.g. invoices, status, billing address) and payment data (e.g. last 4 digits of the credit card number)
The Customer Data is used for LEL Services
The customer data is used for LEL services which means i.e. for the personalised fulfilment of the registration relationship (creation, storage, administration and support of your account), for the procurement of booked rides and for the fulfilment of the transportation contract with the limousine service provider. LEL passes on Customer Data to third parties, in particular, our limousine service providers, as far as necessary, so that the customer can be transported and the ride can be handled according to the booking. If the customer has indicated a bonus program supported by LEL, the necessary data will be transmitted to the provider of the bonus program. The collected payment data is stored by a payment service provider and transferred to the financial services institutions or banks involved.
We may use your personal information to send you updates (by email, text message, telephone or post) about our services.
We have a legitimate interest in processing your personal information for promotional purposes (see above ‘How and why we use your personal information’). This means we do not usually need your consent to send you promotional communications. However, where consent is needed, we will ask for this consent separately and clearly.
We will always treat your personal information with the utmost respect and never sell it to other organizations for marketing purposes.
You have the right to opt out of receiving promotional communications at any time by:
- contacting us at firstname.lastname@example.org
- using the ‘unsubscribe’ link in emails or ‘STOP’ number in texts
We may ask you to confirm or update your marketing preferences if you instruct us to provide further services in the future, or if there are changes in the law, regulation, or the structure of our business.
Who we share your personal information with
We routinely share personal information with:
- other third parties we use to help us run our business, eg marketing agencies or website hosts
- external auditors.
- Social Media / Social Networks
- LEL social media appearances maintains pages on social networks such as Twitter, Google (Google+), Facebook, Instagram, Linked in, Pinterest & You tube. The respective provider of the social network provides detailed information on which personal data are processed and how they are used. Facebook, Instagram, Linked in, Pinterest, twitter & You tube. LEL uses services of the social network Facebook, Instagram, Linked in, Pinterest, twitter & You tube
- Facebook Inc, 1601 Willow Road, Menlo Park, CA 94025, USA (“Facebook”). Facebook Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland is responsible for data processing in Europe. Facebook is certified for the “Privacy Shield” (https://www.privacyshield.gov/) which guarantees compliance with the data protection level applicable in the EU. Facebook’s private information can be viewed here: https://www.facebook.com/about/privacy/
Via Facebook Messenger, Facebook Instagram Linked in, Pinterest, Twitter, and Youtube you can contact us and exchange messages with LEL. LEL also offers the possibility to log in for LEL Services with Facebook-Connect, Instagram, Linked in, Pinterest & You tube. You will be redirected to a Facebook, Instagram, Linked in, Pinterest & You tube page where you can log in with your personalised usage data. When you log in to VLC with Facebook, Instagram, Linked in, Pinterest & You tube Connect, certain personal information is transferred from Facebook, Instagram, Linked in, Pinterest & You tube to LEL. Facebook, Instagram, Linked in, Pinterest & You tube tells you which of your information is being transferred, what you can opt-in to or opt-out of. No personal information will be transferred from Facebook, Instagram, Linked in, Pinterest & Youtube to LEL without your consent.
- Conversely, Facebook can use your Facebook Connect login to determine that and when you log in to us. LEL uses the information provided by Facebook to identify you. If you actively select the log in with Facebook, you agree that LEL processes the data transmitted by Facebook for your identification also in connection with your account on a personal basis. This consent can be revoked at any time with future effect free of charge. You can also stop using Facebook Connect and log in to LEL by different means. The legal basis for the processing of personal data when using Facebook Connect is Art. 6 Para. 1 lit. a GDPR (your-consent).
We only allow our service providers to handle your personal information if we are satisfied they take appropriate measures to protect your personal information.
We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.
We may also need to share some personal information with other parties, such as potential buyers of some or all of our services or during a re-structuring. Usually, information will be anonymised but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.
Where your personal information is held
Information may be held at our offices and those of our third party agencies, service providers, representatives and agents as described above (see above: ‘Who we share your personal information with’).
How long your personal information will be kept
We will keep your personal information while you have an account with us or we are providing services to you. Thereafter, we will keep your personal information for as long as is necessary:
- to respond to any questions, complaints or claims made by you or on your behalf;
- to show that we treated you fairly;
- to keep records required by law.
We will not retain your personal information for longer than necessary for the purposes set out in this policy.
When it is no longer necessary to retain your personal information, we will delete or anonymise it.
Transferring your personal information out of the UK and EEA
To deliver services to you, it is sometimes necessary for us to share your personal information outside the UK and/or European Economic Area (EEA), eg:
- if you are based outside the UK/EEA;
- where there is an international dimension to the services we are providing to you.
These transfers are subject to special rules under European and UK data protection law.
Except for the countries assessed by the European Commission as providing an adequate level of protection for personal information non-UK/EEA countries do not have the same data protection laws as the United Kingdom and EEA. We will, however, ensure the transfer complies with data protection law and all personal information will be secure.
If you would like further information please contact us (see ‘How to contact us’ below).
You have the following rights, which you can exercise free of charge:
|Access||The right to be provided with a copy of your personal information (the right of access)|
|Rectification||The right to require us to correct any mistakes in your personal information|
|To be forgotten||The right to require us to delete your personal information—in certain situations|
|Restriction of processing||The right to require us to restrict processing of your personal information—in certain circumstances, eg if you contest the accuracy of the data|
|Data portability||The right to receive the personal information you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations|
|To object||The right to object:
—at any time to your personal information being processed for direct marketing (including profiling);
—in certain other situations to our continued processing of your personal information, eg processing carried out for the purpose of our legitimate interests.
|Not to be subject to automated individual decision making||The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you|
For further information on each of those rights, including the circumstances in which they apply, please contact us or see the guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights under the General Data Protection Regulation.
If you would like to exercise any of those rights, please:
- email, call or write to us – see below: ‘How to contact us’;
- let us have enough information to identify you;
- let us know what right you want to exercise and the information to which your request relates.
Keeping your personal information secure
We have appropriate security measures to prevent personal information from being accidentally lost, or used or accessed unlawfully. We limit access to your personal information to those who have a genuine business need to access it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
How to complain
We hope that we can resolve any query or concern you may raise about our use of your information.
The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns or telephone: 0303 123 1113.
This privacy notice was last updated on 27 December 2020.
We may change this privacy notice from time to time – when we do we will inform you via email.
How to contact us
Our contact details are shown below:
Post: Limo Executives London
Ebury Management 1-6 Caxton Court, Bullen street
SW11 3ER, London UK
Telephone: +44 2084807801
Copyright © 2020. Limo Executives London. All rights reserved.