Privacy Policy

This notice sets out how we will process any personal data we collect from you, or that you provide to us. Please read the following carefully to understand our views, practices and processes regarding your personal data and how we will treat this information.

For the purposes of the Data Protection Act, the data controller is FG Virginia Water Cars, Platform-1 Virginia Water Railway Station, Station Parade, Virginia Water, Surrey, GU25 4AA.

Virginia Water Cars is committed to, and fully compliant with all our statutory and legislative regulations (and our supporting in-house best practice guidelines) to ensure the security and confidentiality of the data relating to that of our customers, our staff and all associated third parties. Our processes and systems, both computer-based and paper-based, adhere to the standards set by the Data Protection Act.

We ensure that our company servers, personal computers (PCs), laptops and company mobile devices are suitably secure for the purposes of our work with our customers and suppliers.

We have rigorous systems and safeguards in place which we underpin with in-house training and regular auditing of our IT systems to ensure that all sensitive commercial data and individual level information is shared only on a need-to-know basis, and to ensure that cyber threats are managed, mitigated, and eliminated.

Virginia Water Cars has proactively sought external guidance in order to ascertain how we as a business can implement the stipulations of the General Data Protection Regulation (GDPR) in order to best serve our customers.

The information we collect

Collection of personal information

We will use your personal and non-personal information only for the purposes for which it was collected or agreed with you, such as:

• To carry out our obligations arising from any agreement reached between you and us;
• To notify you about changes to our service;
• For the detection and prevention of fraud, crime, or other malpractice;
• To conduct market or customer satisfaction research or for statistical analysis;
• For audit and record keeping purposes;
• In connection with legal proceedings;
• We will also use your personal information to comply with legal and regulatory requirements or industry codes to which we subscribe, or which apply to us, or when it is otherwise allowed by law;
• Collect information about the device you are using to view our website, such as your IP address or the type of internet browser or operating system you are using with the purpose of offering a better user experience;
• To respond to your queries or comments.

Depending upon the nature of our relationship with you, we may collect different information and these differences are outlined below.

Customers

We collect and process your personal information mainly to provide you with access to our services and products, to help us improve our offerings to you and for certain other purposes explained below. We do not knowingly set out to collect personal data, it is only provided to us by you by contacting us via our website www.virginiawatercars.com (“our website”) or through our mobile application (“our app”), by phone or by email.

Once collected, this data is only used to deliver the service and to respond to you and answer any questions you have. We do not collect sensitive data – financial, health or information about children. This does however include name, phone number, email etc. We collect and process the following information relating to our customers:

• Information collected includes details provided at the time of booking. Examples of information we collect from you are: name, telephone number, email address and the relevant information relating to the booking in cause (address, date/time of travel etc.). This is also done when creating an account with Twelve Transfers;
• If you contact us by email or chat, we will keep a record of that correspondence. If you contact us by telephone, we will not keep a record of that correspondence;
• We may also ask you to complete surveys that we use for research purposes, although you do not have to respond to them;
• To confirm and verify your identity or to verify that you are an authorised customer for security and compliance purposes;
• Additionally, we may collect non-personal information such as geographical location. This is collected as part of the services we provide and are not held for any other purpose. You cannot be identified from this information and it is only used to assist us in providing an effective service.

Employees and Drivers

We will collect information relevant to our legal obligations as an employer or as a contracted party for drivers and may include your name, telephone number and email address, in addition to address, bank account details, licencing information and details relating to criminal convictions and other info as part of our screening and vetting processes.

Suppliers

We will collect information relevant to our status as a customer of yours and may include your name, telephone number and email address, in addition to address, bank account details, licencing information and information relating to the services and products you provide us.

Why we need your details

The reason we require your personal data is to ensure that we are able to fully assist you with any enquiries or requested services. We will not collect any personal data from you if not required to provide or oversee the requested services to you. The lawful basis for processing data identified by Virginia Water Cars includes:

• Legal obligations (for example, as an employer or as part of obligations with regards to HMRC or Transport for London);
• Performance of a contract (especially with regards to our customers and our suppliers);
• Legitimate interest (such as when we ask for your feedback or advice on how to continually improve);
• Consent (only used when sensitive information is required to be processed by us).

What we do with your details

The limited personal data we obtain is only processed in the UK and EU area. Our hosting is exclusively done in the EU area. Third parties will have access to your personal data only when they are under contract and following the signature of a non-disclosure agreement and only in line with the services these third parties are contracted to do so in order for Twelve Transfers to function as a business. These third parties include:

Customers (website and app users)

• Data will be disclosed to the designated driver of your reservation in order to complete the requested service;
• Auditors, consultants and specialist service providers for the purposes of ensuring Twelve Transfers operate legally and safely. These include hosting and IT services providers, critical to the infrastructure of our website and app;
• Twelve Transfers personnel in order to assist with the delivery of the service requested or to respond to any contact from customers;
• Transport for London (upon receipt of a proper and justified request);
• Police and other regulatory authorities (upon receipt of a proper and justified request).

Employees

• Data will be disclosed to drivers in order to assist with the completion of the service purchased by the customer;
• Auditors, consultants and specialist service providers for the purposes of ensuring Twelve Transfers operate legally and safely. These include hosting and IT services providers, critical to the infrastructure of our website and app;
• Other Twelve Transfers personnel;
• Police and other regulatory authorities (upon receipt of a proper and justified request).

Drivers

• Data will be disclosed to drivers in order to complete the requested service;
• Auditors, consultants and specialist service providers for the purposes of ensuring Virginia Water Cars operate legally and safely. These include hosting and IT services providers, critical to the infrastructure of our website and app;
• Virginia Water Cars personnel in order to assist with the delivery of the service requested or to respond to any contact from customers;
• Police and other regulatory authorities (upon receipt of a proper and justified request).

Suppliers

• Auditors, consultants and specialist service providers for the purposes of ensuring Virginia Water Cars operate legally and safely. These include hosting and IT services providers, critical to the infrastructure of our website and app;
• Virginia Water Cars personnel and drivers so as they can assist with the delivery of the service requested or to respond to any contact from customers;
• We may disclose your personal information to any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006 (only where this relates to the services provided to Twelve Transfers and on an exceptional basis);

Police and other regulatory authorities (upon receipt of a proper and justified request).

If there is a duty to disclose or share your personal data in order to comply with any legal obligation, or to enforce or apply our terms and conditions of supply and/or any other agreements; or to protect the rights, property, or safety of Virginia Water Cars, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

How long we keep your details

• Service user personal data will be retained for no more than three years following each use of our service, unless you exercise your rights highlighted below.
• This relates to details of your visits to our app and website app and the resources that you access will be stored, as will details of transactions you carry out through our app or website and of the fulfilment of your bookings. Under Private Hire Regulations stipulated by Runnymede Borough Council, we are obliged to retain journey records for a period of 12 months as a condition of our contract. Similarly, we are required to keep any complaint, lost property and account query records for the same period of time.
• Employee, driver and financial data will be retained for five years from the end of their contract with Twelve Transfers.
• Of course, we will look to retain records for no longer than is necessary.

What are your Data Subject Access Rights

You have the right for the following:

• Right to access – you have the right to request a copy of all data we hold about you;
• Right to rectification – where any data we hold is incorrect you have the right to ensure it is correct;
• Right to be forgotten – if you no longer wish for us to hold your data, we will delete it (should this not interfere with our legal obligations relating to Runnymede Borough Council);
• Right to portability – you can ask us to provide your data to a third party in machine readable format;
• Right to restrict processing – since we only use this to contact you, there is no processing to restrict, we would simply delete the information wherever possible and in keeping with our own obligations.

If at any point you believe the information we process on you is incorrect, you may request to see this information and even have it corrected or deleted (should this not interfere with our legal obligations relating to Transport for London). If you wish to raise a complaint on how we have handled your personal data, you can contact our Data Protection Officer who will investigate the matter.

We do not store credit card details and all information received via email or forms will be deemed private and will never reach any other person outside; we will never share your information with any third party company.

The company is committed to protecting the privacy of its customers. The company will only use the information that it collects about the customers lawfully (in accordance with the Data Protection Act 1998). Information is collected for two reasons: first, to process the reservation, and second, to provide the customer with the best possible service.

Due to the Children’s Online Privacy Protection Act, COPPA, effective April 21, 2000, we are not permitted to collect personal information from children below age thirteen. Do not submit your information to us by any means if you are younger than thirteen.

For us the protection of privacy and personal data has top priority. Our privacy practices are in accordance with the provisions of the relevant national Data Protection Acts and other provisions of data protection on the Internet. To protect your data against accidental or intentional manipulation, loss, destruction or access by unauthorized persons we use technical and organizational security measures that we continuously improve in accordance with the technical development.