25 May 2018
1.1 Who we are
Argyle Satellite (“Us”, “Our” or “We”), formed of Argyle Satellite Limited (company number 10755797) and Argyle Satellite Contract Services Limited (company number 10755970), is the Wirral’s largest private hire and taxi company.
Explained simply, our core product involves us providing a booking service to passengers enabling them to connect with hundreds of self-employed drivers across Wirral, Liverpool and Cheshire. The self-employed drivers offer transportation services to passengers who have booked through Argyle Satellite, and we facilitate connecting the two parties.
To enable us to provide this service we process personal and other data about passengers, drivers, customers, visitors and users of our services and products.
We understand how important this information is and are committed to protecting your information and respecting your privacy. Argyle Satellite is a registered ‘data controller’ with the Information Commissioner’s Office (registration number ZA293310), as we are responsible for deciding how and why your data is used; ensuring your data is kept safe and that it is handled securely.
1.2 What this policy is about
In the context of this policy: ‘process’ and ‘processing’ means the collection, storage, transfer, use or action otherwise on information; and, ‘personal data’ means any information that could identify, directly or indirectly, a natural person (‘data subject’ as defined by the General Data Protection Regulation).
It is important that if you do not agree with this policy, in general or any part of it, you should not access the Website, the Web-Booker, the Apps or use our services.
In the event that you wish to make a complaint about how we process your personal data, please contact us in the first instance at email@example.com and we will endeavour to deal with your request as soon as possible. This is without prejudice to your right to launch a claim with the Information Commissioner’s Office or the data protection supervisory authority in the EU country in which you live or work where you think we have infringed data protection laws.
- What information do we collect and where does it come from?
2.1 Information that you give us
This may include:
- Booking records: We collect information when you, or a third-party on your behalf, create or update a booking. This may include your name, email, phone number, address or location information, destination, payment or banking information, vehicle access requirements and company account details (corporate accounts).
- User profiles: We collect additional information (to booking records) when you create or update a user account on the Web-Booker or App. This includes specific location information (if using the applicable feature), card and payment details (if using the applicable feature) and also includes the preferences and settings that you enable for your Argyle Satellite user account.
- Account profiles: We also collect additional information when you open or update an Argyle Satellite corporate or pre-payment account. This includes departmental contacts, cost centre/purchase orders, authorised personnel and invoice records.
- Driver/PA profiles: We collect information when a driver or passenger assistant signs up to use our services or updates their profile. This may include name, email, phone number, address, payment or banking information as well as DBS, license, vehicle and insurance information. For drivers applying for access to our fleet insurance policy we also collect accident and conviction history (used when proposing to the policy broker). For passenger assistants we only collect name, email, phone number, address, payment or banking information as well as DBS and license information.
- Learner records: As an accredited training centre we collect information from you when you enquire about our courses, attend inductions or engage on a course with us. This may include your name, email, phone number, address, employment status (for funding assessments), query information and previous education information. If a learner is applying for a taxi qualification and they are comfortable to provide it, we may also collect driving experience, accident history and criminal record information as these may affect their ability to obtain a license after completing a course.
- User content: We may collect information that you submit when you contact Argyle Satellite to leave feedback or otherwise contact us. This may include through social media, when signing up for our newsletters or marketing initiatives and correspondence (letters, emails, phone calls).
2.2 Information created when using our services
This may include:
- Location information: Depending on the services you use, your App settings and device permissions we may collect precise or approximate location information as determined through data such as GPS, IP address and WiFi. We also frequently collect location information from drivers when the Driver App is running (in the foreground or background of the device) to assist with booking allocation, tracking and auditing. Passengers and users (excluding drivers) may use our services without enabling us to collect their location information – however this may effect the functionality available to you on the Web-Booker and App.
- Booking Records: We collect information relating to your use of our services. This includes the type and frequency of services requested and/or provided, your booking details, date and time the service was provided, amount charged on the Driver App, distance travelled and route tracking Additionally, we also collect account details and booker information when processing account profile bookings.
- Usage information: We collect information on how you interact with us and how you interact with our services. This may include access dates and times, app features or pages viewed, app crashes and other system activity, type of browser, and third-party sites or service you were using before interacting with our services. In some cases, we collect this information through cookies, pixel tags, and similar technologies that create and maintain unique identifiers.
- Device information: We may collect information about the devices you use to access our services, including the hardware models, device IP address, operating systems and versions, software, file names and versions, preferred languages, unique device identifiers, advertising identifiers, serial numbers, device motion information, and mobile network information.
- Communications data: We communicate directly with users and enable users and drivers to communicate with each other through our systems. To provide this service, we receive and record information regarding the calls or texts, including the date/time of the call/text and the content of the communications. Argyle Satellite may use this information to investigate complaints and resolve disputes (between ourselves and users, or between users), for safety and security purposes, to improve our products and services and for analytics.
- Participation information: We collect information about you when you participate in competitions, such as your name, address, phone number and/or email address. This data is only used for the purposes of the relevant competition and will be subject to the terms and conditions of that competition
2.3 Information from other sources
This may include:
- Aggregators/corporate account customers: We provide and facilitate transport and delivery services for a number of aggregators as well as corporate and pre-payment account customers. To enable us to provide our services, when required, account customers will provide us with booking details for their employees, customers and clients. This information may include their name, email, phone number, address or location information, destination, requirements, amount charged and the customers’ account details (if applicable).
- CCTV recordings: Our offices are fitted with outward and inward-facing CCTV cameras operating 24 hours a day. These cameras do not record audio, but you image or vehicle image may be picked up by them when you pass or enter/exit the offices.
Alternatively, this may also include:
- Information provided to us by a third-party and/or collected from public records in the case of fraud or suspected fraud.
- User and driver feedback, such as ratings or complaints.
- Users requesting services on your behalf.
- Fraud prevention tools.
- Information in connection with referral programs.
- Users or others in connection with claims or disputes.
- Insurance providers (for drivers).
- Licensing and regulatory bodies (for drivers and passenger assistants).
- Telematic analytics.
- Publicly available sources.
- Marketing service providers.
- Third-party data validation tools (e.g. Experian).
Argyle Satellite may combine the information collected from these sources with other information in our possession.
- What do we do with your information?
It is important that you understand how and why we use the information we collect about you. This section sets out the different purposes for which we process personal data and which types of personal data we need for each purpose.
3.1 Is this the only way?
We use your information only after carefully considering:
- Can the same objective be achieved through other means?
- Might it cause you or another harm by processing your data?
If the answer to either of these questions is YES, we do not process the data.
- Would you reasonably expect us to process your data in this way?
- By not processing your data might it cause you or another harm?
- By not processing your data might we be in breach of our legal or regulatory obligations?
If the answer to any of these questions is NO, we do not process the data.
3.2 Why we use your information
Primary we use this information to:
- Enable us to provide convenient ground transportation, delivery and other services and carry out our obligations arising from these services.
- Create records of bookings and to send you booking acknowledgements, confirmation, receipts and invoices (where applicable).
- Communicate with you and facilitate communication between users and drivers.
- Comply with our accreditation, legal and regulatory obligations.
- Improve security the safety and security of you, the driver and the local community as a whole through the detection and prevention of fraud and crime.
We may also collect and use this information to:
- Facilitate features to enhance and improve your overall customer experience, including: card payments for services, IVR, CLI, call-back, text-back, call2customer, call2driver and track-my-driver;
- Manage aspects of your user, account and driver profile account (where applicable);
- Ensure that our content and information about our services can be accessed in the most appropriate and effective manner for you and your device;
- Monitor, assess and improve the quality of our services;
- Investigate or address claims or disputes relating to your use of our services;
- Pass on feedback (ratings, compliments, complaints) about our drivers;
- Pass on feedback (ratings) to our drivers about users;
- Reduce the likelihood of no-shows where possible (for drivers);
- Provide you with information, products or services that you request from us or which we feel may interest you (where you have expressly consented to be contacted for such purposes).
- Allow you to participate in competitions and to carry out any activities in relation to those competitions, for example contacting you to let you know you have won a prize using your contact telephone number to inform you;
- Provide third-parties with anonymised statistical information about our users.
- Respond to queries, complaints or comments that you have and to make sure that these are appropriately dealt with.
- Research and development.
- Measure and understand the effectiveness of the content we serve to you and others
- Notify you about changes to our services or our terms and conditions.
- Establish facts in cases of claims or disputes.
Whenever possible we use aggregated and/or anonymised data for monitoring and analysis purposes. When used, this data does not enable you or any other individual to be identified.
3.3 Who we share your information with
Argyle Satellite does not sell, rent, lease or share personal information to third parties for third party direct marketing purposes. However, you should be aware that we may share your information with selected recipients. Categories of the main recipients of data include:
- Drivers: To facilitate your taxi bookings we may share your name, account details (if applicable), pickup and/or drop-off locations with drivers. If the booking is made on your behalf, by an aggregator or on an account, the booker or company may also receive a copy of these details in addition to journey logs (e.g. booking, collection and competition times) and journey prices.
- Users: If you are a driver, we may share information with your passenger including name, badge number, vehicle make, model colour, licence plate, location and eta. For bookings made by Web-Booker, App and email, the recipient/passenger will also receive a receipt containing information such as a breakdown of amounts charged, and a map of the route taken.
- IT support providers: To process and secure your data we use external providers who support and maintain our booking platform, network, provide SaaS or have access to our secure servers at our premises.
- Cloud storage providers: We use both local and cloud-based storage solutions to store the personal data you provide and for disaster recovery purposes.
- Merchant service providers: We use merchant service providers (such as Judo) to securely process and store your card and payment details.
Other categories of recipients include:
- Analytics and search engine providers, located in the UK and Ireland, that assist us in the improvement and optimisation of our websites and apps.
- Fraud prevention tools, located in the UK, for the purposes of preventing fraud.
- Where you have consented to receive marketing materials from our company, or companies located in the UK, that require the data to select and serve relevant marketing and advert to you and others.
- If you have been referred to us by a third-party and that third-party is entitled to a commission payment.
- Anyone you authorise us to give information about you to.
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, process or request.
- Enforce our terms and conditions and other agreements, including investigation of any potential violation thereof.
- Detect, prevent or otherwise address security, fraud or technical issues.
- Protect the rights, property or safety of us, our users, a third party or the public as required or permitted by law (exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction).
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 of such business or assets.
- 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.
3.4 Where we store your data
Your personal data is processed primarily by staff operating inside the European Economic Area (EEA) who work for us or for one of our suppliers. It is possible however that your personal data may be processed by staff or systems operating outside the EEA to enable the fulfilment of your booking, the processing of your payment details and the provision of support services. In either case will take all steps reasonably necessary to ensure that your personal data is treated securely and in accordance with this policy.
The information we collect from you is primarily stored locally on our secure servers or on EEA located cloud-based storage solutions. All payment transactions are encrypted, processed and stored securely by a PCI level 1 compliant facilitator (the most stringent level of security certification available for card payment companies). Where data that we collect may be transferred to, and stored at, destinations outside the EEA, we have taken and will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this policy.
3.5 Security of your information
As mentioned earlier, we have taken and will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this policy. 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 Website, Web-booker, App, 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.
We will, from time to time, host links to and from the websites of our affiliates or third parties. If you follow a link to any of these websites, these websites will have their own privacy policies and we do not accept any responsibility or liability for these policies. Please check these policies before you submit any information to those websites.
3.6 How long we store your information for
As a rule of thumb, the following records are kept up to:
- 12 months from the last use or activity – CCTV Recordings.
- 2 years from the last use or activity – Booking Records, Location Information and Communications Data.
- 3 years from the completion of course – Learner Records.
- 6 years from the last use or activity – User Profiles, Driver/PA Records, Account Records and Complaint Records.
- Provide you with the services you have requested.
- Comply with the law and all regulatory requirements.
- Support a claim or defence in court.
- What about marketing?
With your permission we may use your personal details to give you information about products and services available from ourselves, which may be of interest to you. If personal information is passed on, it is only such information as would allow them to contact you, by telephone, email, post, text and other means.
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 may instruct us not to process your personal data for marketing purposes by email to the following address: firstname.lastname@example.org.
We will not share your information with third parties accept where outlined in this policy. If we intend to use your data for any marketing purposes outside of this policy, we will inform you and you will have the right to prevent this by “opting out” through not ticking check boxes.
When using our website, Web-Booker or Apps we may collect information about your computer or device and about your visits. We may obtain information about your general internet usage by using a cookie file which is stored on the hard drive of your computer or mobile device. By using our website, Web-Booker or Apps, you accept we may collect and use this information as outlined below.
5.1 What is a cookie?
A cookie is a small data file which contains information that is transferred to the hard drive of the device from which you access our site. For more comprehensive information about how cookies work, see http://www.allaboutcookies.org. Cookies are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site.
5.2 Types of cookies and consent
In summary, we use the following types of cookies:
- Cookies which are essential for our site to operate, such as those which identify you so you can log into your Judo Account. These cookies will always be activated.
- Cookies which are necessary to assist in meeting our regulatory compliance obligations, such as anti-money laundering and anti-fraud obligations, and prevent your user or driver account from being hijacked. These cookies will always be activated.
- Cookies that help us to improve our site and to deliver a better and more personalised service to you.
- Some cookies are not related to us or our group companies. When you visit a page with content embedded from, for example, YouTube or Twitter, you may be presented with cookies from these websites. We do not control the dissemination of these cookies: you should check the third party websites for more information about these cookies.
5.3 Blocking cookies
- What are your rights?
You have rights in relation to the personal data we hold about you. Some of these only apply in certain circumstances, and we have described these situations below, as well as how you can exercise your rights. To exercise any of your rights, please contact us at email@example.com.
- Access: You have the right to ask us to access the personal data we hold about you and be provided with certain information about how we use your personal data and who we share it with.
- Correction: You also have the right to ask us to correct your personal data where it is inaccurate or incomplete.
- Portability: Where you have provided your personal data to us under contract, you have the right to ask us to share (port) this data to another data controller in a structured, commonly used and machine-readable format.
- 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, the right to restrict or object to our processing of your personal information (e.g. where you request correction or erasure, you also have a right to restrict processing of your applicable data while your request is considered). You can object to our processing of your personal data based on our legitimate interests and we will no longer process your personal data unless we can demonstrate an overriding legitimate ground.
In addition, you have the right to complain to the Information Commissioner’s Office or other applicable data protection supervisory authority.
Please note that these rights are limited, for example, where fulfilling your request would adversely affect other individuals or company trade secrets or intellectual property, where there are overriding public interest reasons or where we are required by law to retain your personal data.
- And lastly…
Any changes we will make to this policy in the future will be posted on this page. Please check back frequently to see any updates or changes.
We welcome questions, comments and requests regarding this policy. Please address any enquires or feedback to firstname.lastname@example.org. Alternatively, you can also write to our Information Security Team at Argyle Satellite Limited, 15 Park Street, Birkenhead, Wirral CH41 1ET.