1. Important information and who we are

Glasgow Taxis Ltd is committed to protecting yours and your family’s personal information when you are using our services. This Privacy Policy gives your information about how GTL collects and uses your personal data when you choose to book Glasgow Taxis. This Privacy Policy applies to drivers and customers of Glasgow Taxis Ltd.

Glasgow Taxis Ltd is the controller and responsible for your personal data (collectively referred to as “GTL”, “we”, “us” or “our” in this Privacy Policy).

We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the DPO using the information set out in the contact details section below.

2. The types of personal data we collect about you

Personal data means any information about an individual from which that person can be identified.

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data includes first name, last name, any previous names, username or similar identifier, date of birth, national insurance number, driver’s license number and details of registration.
  • Contact Data includes billing address, email address and telephone numbers, including referee contact information for previous employer and, emergency contact information.
  • Financial Data includes bank account and payment card details.
  • Transaction Data includes details about payments to and from you and other details of services you have purchased from us.
  • Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, device ID and other technology on the devices you use to access this website.
  • Profile Data includes your username and password, bookings made by you, your interests, preferences, any feedback and/or survey responses, driver photographs.

• Usage Data includes information about how you interact with and use our website, products and services.
  • Journey information includes details we collect about your journey, including the driver’s name, vehicle registration number, date/time of booking, requested pickup and drop off addresses, and distance travelled.
  • Location Data includes the driver’s location during the journey, linking that to the customer’s account. This allows us to display where you are on your trip. We also determine your approximate location and can determine your precise location if you allow us to do so through the settings on your phone. If you do, we will collect your precise location from the time you book a taxi until the journey is finished. We also collect such data when you have the Glasgow Taxis app open on your phone’s screen.

You can use Glasgow Taxis without letting us collect your precise location. However, it may be less convenient for you, including because you will have to type your location into your phone instead of allowing us to detect it for you.

• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share aggregated data such as statistical or demographic data which is not personal data as it does not directly (or indirectly) reveal your identity. For example, we may aggregate individuals’ Usage Data to calculate the percentage of users accessing a specific website feature in order to analyse general trends in how users are interacting with our website to help improve the website and our service offering.

3. How is your personal data collected?

We use different methods to collect data from and about you including through:

• Your interactions with us. You may give us your personal data by corresponding with us by post, phone, email or on our website. This includes personal data you provide when you book our services or contact us via telephone, text message, by email, through our Glasgow Taxis mobile application, on our website, in letters or through correspondence.
  • Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see our cookie policy in the next section for further details.
  • Third parties. We will receive personal data about you from Taxi Alliance Software Limited and/or Coolnagour Limited t/a iCabbi who provides software support services to us in order to facilitate the provision of the Services to you

4. How we use your personal data

Legal basis

The law requires us to have a legal basis for collecting and using your personal data. We rely on one or more of the following legal bases:

• Performance of a contract with you: where we need to perform our contract with you in relation to your use of the Services and our provision of the Services.
  • Legitimate interests: We may use your personal data where it is necessary to conduct our business and pursue our legitimate interests, for example to prevent fraud and enable us to give you the best and most secure customer experience. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
  • Legal obligation: We may use your personal data where it is necessary for compliance with a legal obligation that we are subject to. We will identify the relevant legal obligation when we rely on this legal basis.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use the various categories of your personal data:

Purpose/Use	Type of data
To register you as a new customer	IdentityContact
Enabling             services             and features. This includes: Enabling navigation to pickups and drop offs, calculating ETAs and tracking the journeyMatching you with available driversEnabling features that involve data sharing, such as ETA sharingEnabling accessibility features	IdentityContactTransactionTechnicalJourney InformationMarketing and Communications
Calculating driver/customer prices and driver/customer fares	LocationJourney Information

To manage our relationship with you which will include: Notifying you about changes to our terms or privacy policyDealing    with    your    requests, complaints and queries	IdentityContactProfileMarketing and Communications
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) and For “service administration purposes”, which means that Glasgow Taxis may contact you for reasons related to the service (e.g. to provide you with password reminders or to notify you that a particular service has been suspended for maintenance);	IdentityContactTechnical
To deliver relevant website content and online advertisements to you and measure or understand the effectiveness of the advertising we serve to you	IdentityContactProfileUsageMarketing and CommunicationsTechnical
To use data analytics to improve our website, services, customer relationships and experiences and to measure  the  effectiveness  of  our communications and marketing	TechnicalUsage
To send you relevant marketing communications and make personalised suggestions and recommendations to you about services that may be of interest to you based on your Profile Data	IdentityContactTechnicalUsageProfileMarketing and Communications

Will i be contacted for marketing purposes?

GTL will only use your information for direct marketing purposes, or to promote new services or activities where you have agreed to this.

We will get your express consent before we share your personal data with any third party for their own direct marketing purposes.

Opting out of marketing

You can ask to stop sending you marketing communications at any time by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences.

If you opt out of receiving marketing communications, you will still receive service-related communications that are essential for administrative or customer service purposes for example relating to updates to our Terms and Conditions and, checking that your contact details are correct.

USE OF COOKIES BY GTL

Cookies are small text files placed on your computer by websites you visit. They are widely used in order to make websites work, or work more efficiently, as well as provide information to the owners of the website.

The table below explains what cookies we use and why:

Cookie	Name	Purpose	More information
Google Analytics	_utma _utmb _utmc _utmz	These cookies are used to collect information about how visitors use our site. We use the information to compile reports and to help us improve the website. The cookies collect information in an anonymous form, including the number of visitors to the website, where visitors have come from and the pages they have visited.	Click here for an overview of privacy at Google Session
Session Cookie		The session ID is a read-only value that uniquely identifies the current clients to the web server. This is used purely to maintain a connected state between you and the website.
site cookie acceptance	civicAllowCookies	This cookie is used to record if a user has accepted the use of cookies on Glasgow Taxis website.

Most web browsers allow some control of most cookies through the browser settings. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.allaboutcookies.org.

To opt out of being tracked by Google Analytics across all websites, visit http://tools.google.com/dlpage/gaoptout.

5.          WILL GTL SHARE MY PERSONAL INFORMATION WITH ANYONE ELSE?

We will keep your information confidential except where disclosure is required or permitted by law (e.g. to government bodies and law enforcement agencies) or as described below. Generally, we will only use your information within GTL. However, sometimes GTL uses third parties to process your information on our behalf as noted in paragraph 3 above. GTL requires these third parties to comply strictly with its instructions and GTL requires that they do not use your personal information for their own business purposes, unless you have explicitly consented to the use of your personal information in this way.

6.          International transfers

If you use our Glasgow Taxis mobile application or website to make a booking, we share your personal data with Taxi Alliance Software Limited AND/OR Coolnagour Limited t/a iCabbi who provides software support services to us in order to facilitate the provision of the Services to you. This will involve transferring your personal data outside the UK to the EU. The EU is deemed by the UK to provide an adequate level of protection for personal data.

7.          Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. This includes, storing customer data in secure local drives, shared folders, locked cabinets and other electronic platforms.

We also have security measures in place to secure such data (e.g. firewalls, virus-checking, security updates, encryption and password protection, regular back-ups, secure removal before disposing of old computers and anti-spyware tools).

In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our

instructions and they are subject to a duty of confidentiality. Training will be provided to any employees working within the group who need access to your personal data to ensure it is secured at all times.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8.          Data retention

How long will GTL keep my personal data?

As a general rule we keep your personal data for the duration of your contract with GTL and for a period of 7 years after the contract ends. However, where we have statutory obligations to keep personal data for a longer period or where we may need your personal data for a longer period in case of a legal claim, then the retention period may be longer.

Having reviewed our data storage requirements we consider that customer data may proportionately be held for a period of 7 years after a contract is concluded at which time it will be deleted unless the customer specifically requests it be retained.

9.          Your legal rights

You have a number of rights under data protection laws in relation to your personal data.

You have the right to:

• Request access to your personal data (commonly known as a “subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
  • Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
  • Request erasure of your personal data in certain circumstances. This enables you to ask us to delete or remove personal data 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 data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
  • Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) as the legal basis for that particular use of your data (including carrying out profiling based on our legitimate interests). In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your right to object.

• You also have the absolute right to object any time to the processing of your personal data for direct marketing purposes (see OPTING OUT OF MARKETING in Error! Bookmark not defined.4 for details of how to object to receiving direct marketing communications).
  • Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
  • Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in one of the following scenarios:
    • If you want us to establish the data’s accuracy;
    • Where our use of the data is unlawful but you do not want us to erase it;
    • Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
    • You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

If you wish to exercise any of the rights set out above, please contact us using our contact details (Error! Bookmark not defined.10).

10.    Contact details

If you have any questions about this privacy policy or about the use of your personal data or you want to exercise your privacy rights, please contact our DPO in the following ways:

• Email address: dataprotectionofficer@glasgowtaxis.co.uk
  • Postal address: Glasgow Taxis, 140 Boden Street, Glasgow G40 3PX

11.    Complaints

You have the right to make a complaint to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). However, before doing so please make sure you have first made your complaint to us or asked us for clarification if there is something you do not understand. The ICO will expect you to have done this before reviewing your complaint. You can make a complaint by emailing office@glasgowtaxis.co.uk

CHANGES TO GTL PRIVACY POLICY

This Privacy Policy may be updated from time to time so you may wish to check it each time you submit personal information to GTL. The date of the most recent revisions will appear on this page.