This is a draft BKT Executive Travels Privacy Policy, directly taking direction from the structure and key clauses of the provided Addison Lee policy.

BKT EXECUTIVE TRAVELS LIMITED: PRIVACY POLICY

Notice Disclaimer

BKT Executive Travels Limited (“we”, “our”, “us”) are committed to protecting and respecting your privacy. Our group of companies for the purposes of Data Protection are:

BKT Executive Travels Limited: No. [Insert BKT Registration Number] [Insert Subsidiary/Partner Company Name (if applicable)]: No. [Insert Registration Number (if applicable)]

All with Registered Office at: [Insert BKT Registered Office Address]

BKT Executive Travels is a premium private hire and chauffeur company with [Insert Number] years of experience. This privacy policy explains how we use any personal information we collect about you, as a past or present employee, a service user, Driver, or when you use our website or applications.

Please read this notice carefully so that you understand your rights in relation to your personal data, and how we will collect, use, and process your personal data. If you do not agree with this Privacy Notice in general or any part of it, you should not access the Websites, the Apps, or use our services.

Controllers Contact Information

BKT Executive Travels Limited is the controller for the personal information we process, unless otherwise stated via contracts. BKT is the data controller for the purposes of the General Data Protection Regulation (GDPR) and any relevant local legislation (“Data Protection Laws”).

You can contact our Data Protection Officer via: Address: [Insert BKT Registered Office Address] Email: privacy@bkt-executive.com

What Types Of Information Do We Collect About You?

Information You Provide

You may provide information by contacting us via our Websites, Apps or by email, telephone, social media or otherwise, or by signing up for our newsletters or alerts, or by creating an account and then using our services. This personal information always requires the user’s confirmation before it is submitted, and the user can refuse to provide this. However, in this case, they will be unable to engage in the website activity as we would not have the contact details to send the requested information.

B2B Data Collection: If you use our services through your company, information provided to us by your employer. In the case of our corporate customers only, your employer may provide us with information about you when it signs up to use our services, for example your name, contact number, and business email address.

Job applicants, current and former BKT Executive Travels employees When individuals apply to work at BKT Executive Travels, we will only use the information you supply to us to process your application. Once a person has taken up employment with BKT, we will compile a file relating to their employment. The information contained in this will be kept secure and will only be used for purposes directly relevant to that person’s employment. Once their employment with us has ended, we will retain the file in accordance with the requirements of our retention schedule and then delete it.

Drivers for BKT Executive Travels BKT will collect the following personal data about you while you provide services to us:

Identity information such as title, full name, date of birth, photograph, private hire licence with Transport for London (TfL) or such other relevant regulator or authority (the “Transport Regulator”), driver’s licence details, or proof of eligibility to enter into the driver contract.

Contact details such as home and work address, phone number(s), email address(es), emergency contacts, and next of kin.

Contract data, including commencement date, background checks (including criminal records and credit checks), and data relating to complaints.

Vehicle Data, including the location of the vehicle, rate of travel and other similar information transmitted from GPS trackers, telematics devices, and similar devices which are fitted to the vehicle, whether the vehicle is being used for the provision of passenger services or for personal use.

Financial data, including payments for bookings, your bank or building society account details, and tax numbers.

Special category data, including information about your physical or mental health or condition, and information relating to any criminal proceedings in which you have been involved, for insurance or safety purposes, or to comply with legal requirements.

For further details, please check the [Insert BKT Driver Portal Link] for your Driver Type.

We receive information about you directly from you, as well as from other sources including from our group companies, the relevant Transport Regulator, local authorities, law enforcement, government bodies, and certain private companies (such as those responsible for managing parking, speeding, toll, or other traffic-related incidents).

CCTV information. Our vehicles may be fitted with in-bound and out-bound dashboard cameras. The purpose of the cameras is to provide a safe environment for the benefit of our passengers.

Site Visits Closed-circuit television (CCTV) operates at our building for security purposes. The lawful basis we rely on to process this personal data is Article 6(1)(f) of the UK GDPR, which allows us to process personal data when it is necessary for the purposes of our legitimate interests.

Criminal Activity Information provided to us by a third party and/or collected from public records in the case of fraud or suspected fraud.

Technical usage information. When you visit our websites or use our Apps, we automatically collect the information sent to us by your device. This information includes:

your IP address;

device information including, but not limited to, identifier, name, and type of operating system;

standard web information, such as your browser type and the pages you access on our Websites.

The Lawful Basis We Use To Process Your Data

We will only ever process your information if we have a lawful basis to do so. The lawful bases we rely on are:

Contract: This is where we process your information to fulfil a contractual arrangement we have made with you.

Consent: This is where we have asked you to provide explicit permission to process your data for a particular purpose.

Legitimate Interests: This is where we rely on our interests as a reason for processing, generally this is to provide you with the best service in the most secure and appropriate way.

Legal Obligation: This is where we have a statutory or other legal obligation to process the information.

How We Use Your Information

We take your privacy very seriously. The Privacy Policy details what to expect when BKT collects your personal information. In most cases, any personal information provided, for example Contact Form submissions, are stored on servers in our UK Data Centres.

To perform our contract with you, we will use your information:

to communicate with you;

to provide you with ground transportation and/or chauffeur services;

to create records of bookings and to send you booking acknowledgments, confirmations, receipts, and invoices; and

to maintain records of lost property.

As it is in our legitimate interests to be responsive to you and to ensure the proper functioning of our services and organisation, we will use your information:

to detect and prevent fraud and crime;

for reporting and data analysis purposes;

for insurance purposes;

to comply with our legal and regulatory obligations imposed by TfL and any other licensing authority where we provide services;

to meet customer service requirements and for complaint handling and feedback;

to monitor and assess the quality of our service;

to pass on feedback such as ratings or compliments about our drivers;

to sign you up for our newsletters or alerts;

to personalise our services for you;

to enforce our terms and conditions;

if you have opted in to marketing, to communicate with you about products, services, promotions, events, and other news and information we think will be of interest to you.

Profiling

Fraud prevention: We use a combination of risk screening tools and manual intervention to ensure that customer profiles are not fraudulent. To do this, we match the personal data provided by customers against data fields such as name, email address, and mobile phone number, and we use this to accept or decline bookings.

Marketing: We manually carry out customer segmentation for marketing purposes based on journey history. We use this to make our advertisements more relevant for market segments, such as promoting relevant journey types (e.g., airport transfers).

Sharing Your Information

We do not sell, rent, or lease your personal information to others except as described in this Privacy Notice. We share your information with selected recipients. These categories of recipients include:

Cloud storage providers located in the UK or EU, which store your personal data.

IT Services providers that provide us with SaaS and IaaS services.

Analytics and search engine providers located in the UK or EU that assist us in the improvement and optimisation of the Websites and Apps.

Merchant acquirers located in the UK or EU for the purpose of processing payments.

Fraud prevention tools for the purposes of preventing fraud.

Partner drivers based in the territory in which you request services.

Our insurance company and claims handling companies, for the purpose of investigating and settling any insurance claims.

Advertisers and e-marketing companies (provided you have consented) that require the data to select and serve relevant marketing and adverts to you and others.

We will share your information with law enforcement agencies, public authorities, or other organisations if legally required to do so, or if we have a good faith belief that such use is reasonably necessary to: comply with a legal obligation, enforce our terms and conditions, detect, prevent, or otherwise address security, fraud or technical issues, or protect the rights, property, or safety of us, our users, a third party or the public.

We will also disclose your information to third parties:

in the event that we sell any business or assets, in which case we will disclose your data to the prospective buyer; or

if we or substantially all of our assets are acquired by a third party, in which case information held by us about our users will be one of the transferred assets.

The Security Of Your Personal Data

Unfortunately, the transmission of information via the internet or email is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your information transmitted through the Websites, Apps, over email or via our contact centres; any transmission is at your own risk. Once we have received your information, we will take appropriate technical and organisational measures to safeguard your personal data against loss, theft and unauthorised use, access, or modification.

How Long Do We Store Your Personal Data?

To determine the retention period of your personal data, we consider several criteria to make sure that we do not keep your personal data for no longer than is necessary or appropriate. These criteria include: the purpose for which we hold your personal data, our legal and regulatory obligations (e.g., financial reporting or obligations to TfL), whether our relationship with you is ongoing, any specific requests from you in relation to the deletion of your personal data, and our legitimate business interests in relation to managing our own rights.

Your Rights As A Data Subject

You have rights in relation to the personal data we hold about you. To exercise any of your rights, please contact us at privacy@bkt-executive.com.
Right Description
Access You have the right to ask us to access the personal data we hold about you.
Correction You have the right to ask us to correct your personal data where it is inaccurate or incomplete.
Portability You have the right to ask us to share (port) your data to another data controller in a structured, commonly used and machine-readable format (where provided under contract).
Erasure In certain circumstances, you have the right to ask us to delete the personal data we hold about you.
Restriction In certain circumstances, you have the right to ask us to restrict (stop any active) processing of your personal data, save for storage.
Objection In certain circumstances, you can object to our processing of your personal data (e.g., where based on our legitimate interests or for direct marketing).

Please note that these rights are limited, for example, where we are required by law to retain your personal data.

Cookies & Marketing

Cookies: Please see our Cookie Policy for full details on the cookies that we use on this website and your consent options.

Marketing: At any time you have the right to object to our processing of data about you in order to send you marketing communications, including where we build profiles for such purposes, and we will stop processing the data for that purpose. You can change your marketing preferences at any time using the preference centre within your account.

Complaints

BKT Executive Travels tries to meet the highest standards when processing and collecting your personal information. In the event that you wish to make a complaint about how we process your personal data, please contact us at privacy@bkt-executive.com and we will endeavour to deal with your request as soon as possible.

If you are not satisfied with the response from BKT Executive Travels or believe we are not processing your data in accordance with the law, you have the right to raise your complaint with the Information Commissioner’s Office (ICO).

Changes To Our Privacy Notice

We keep our privacy notice under regular review, and we will place any updates on this web site. The last update to this privacy policy was [Insert Month Year].