LUXURY LIFESTYLE INTERNATIONAL is a licensed private hire operator inviting and accepting private hire bookings for transportation services from individuals, local government and corporate organizations. Whilst providing these services LUXURY LIFESTYLE INTERNATIONAL collects and manages customer and non- customer data. Throughout this process LUXURY LIFESTYLE INTERNATIONAL is committed to complying with applicable data protection and privacy laws. This includes, in its capacity as a “Data Controller”, respecting and maintaining the privacy and rights of customers and non-customers. We have provided this Privacy Notice statement (pursuant to the General Data Protection Regulations (GDPR) (EU) 2016/679 (as incorporated by the Data Protection Act 2018)) to help you understand how we collect, process, store and share your information when you make an enquiry, become a customer or visit our website. We wish to help you make informed decisions on, amongst others, how you can control the use of your information. Collection of Information We typically collect information to enable LUXURY LIFESTYLE INTERNATIONAL to facilitate the following tasks:
• Respond to your enquiry (incl. private hire bookings).
• Supply, or otherwise, provide your services.
• Submit, and manage, financial transactions (incl. billing).
• Offer you service updates or offers.
• Meet statutory, or regulatory, requirements (incl. Private Hire Vehicles (London) Act 1998). In respect of the above, LUXURY LIFESTYLE INTERNATIONAL collects “personal information” (or “personal data”). This means any information relating to an identified, or identifiable individual in particular by reference to an identifier. These may be obtained, or otherwise provided to us, by telephone, video, email, or letter. Such identifiers we need, amongst others, may include:
• Name.
• Postal address.
• Email address
• Telephone number.
• Fax number.
• Photographs.
• Video Recordings.
• Audio Recordings.
In respect of the above, LUXURY LIFESTYLE INTERNATIONAL also collects “sensitive personal information” (or “special categories”). This means any information, such as biometric data, which requires a higher level of protection. Such details we may need, amongst others, include: • Criminal Convictions or Offences.
• Medical or Health Status.
• Professional Memberships.
• Racial or Ethnic Origin. In addition to the above, LUXURY LIFESTYLE INTERNATIONAL’s website collects “cookies”. This means small amounts of data, which includes anonymous unique identifiers, which are sent to your browser from a website’s computer and stored on your computer or mobile device. Such details may be used to improve online functionality and thereby shared with third party organizations (i.e., internet service providers). These can be controlled by you within the preferences of your chosen browser. Processing Personal Information We will only administer personal information in accordance with a lawful basis. When we process personal information at least one of the following must be applicable:
• Consent: The processing follows your giving of clear consent for us to process your personal information.
• Contract: The processing is necessary for a contract we have with you or because we have asked you to take specific steps before entering into a contract.
• Legal Obligation: The processing is necessary for us to comply with the law (not including contractual obligations).
• Vital Interests: The processing is necessary to protect someone’s life.
• Public Task: The processing is necessary to for us to perform a task in the public interest or for
our official functions and the task or function has a clear basis in law.
• Legitimate Interests: The processing is necessary for our legitimate interests or the legitimate interests of a third party unless there is good reason to protect your personal information which overrides those legitimate interests. Lawful Basis for Processing Personal Information We consider the basis for which we will process personal information, referenced in the above ‘Collection of Information’ section, as necessary for the performance of a contract (for enquiry responses, service supply, etc.) we have with you and to enable us to comply with our legal obligations (for statutory requirements, etc.). Occasionally, LUXURY LIFESTYLE INTERNATIONAL may also process personal information for a legitimate interest (for online functionality, service offers, etc.). One or more basis may validate the processing of personal information. Processing Sensitive Personal Information We will only administer sensitive personal information, which require a higher level of protection, in accordance with a lawful basis. When we process sensitive personal information at least one of the following may be applicable:
• Consent: The processing follows your giving of clear consent for us to process your personal information.
• Contract: The processing is necessary for a contract we have with you or because we have asked you to take specific steps before entering into a contract.
• Legal Obligation: The processing is necessary for us to comply with the law (not including contractual obligations) and satisfies the obligations under our Data Protection Policy.
• Vital Interests: The processing is necessary to protect someone’s life.
• Public Task: The processing is necessary to for us to perform a task in the public interest or for our official functions and the task or function has a clear basis in law and satisfies the obligations under our Data Protection Policy.
• Legitimate Interests: The processing is necessary for our legitimate interests or the legitimate interests of a third party unless there is good reason to protect your personal information which overrides those legitimate interests. Lawful Basis for Processing Sensitive Personal Information We consider the basis for which we will process sensitive personal information, referenced in the above ‘Collection of Information’ section, as necessary for the performance of a contract. Where appropriate, LUXURY LIFESTYLE INTERNATIONAL may seek your clear consent before recording any details (of medical or health status, criminal convictions, etc.). Where consent is sought, please be aware you are under no contractual obligation to comply with the request and you may decline. Data Transfers The information collected, processed and stored may be shared with a third party or third-party service providers within, or outside of the European Union (EU). Information sharing may arise due to a legal obligation, as part of the performance of a contract or in situations where there is a legitimate interest (including a legitimate interest of a third party). Activities which may be carried out by third parties on our behalf include dispatch software, service updates, insurance, financial accounting and billing, customer and non-customer file management and website functionality. If shared, LUXURY LIFESTYLE INTERNATIONAL expects third parties to adhere and comply with GDPR when processing your information. Automated Decisions We do not anticipate any of our decisions will occur without human involvement. Should we use any form of automated decision-making we will advise you in writing of such a change. Data Retention We will generally retain information for a period of 10 years. Once the end of the retention period is reached, and upon conclusion of our contract with you or until we are no longer legally required to retain it, it will be reviewed and deleted (unless there is special reason to keep it). Occasionally, we may continue to use data without further notice. This will only occur where such data is anonymized and you cannot be identified as being associated with that data. Data Security We have implemented security measures to avoid information from being accessed, damaged, stolen or otherwise compromised. Where a breach, or suspected breach, occurs of information security you will be informed, alongside any appropriate regulator, pursuant to our legal obligations. If you would like further information, please write to Mr. FIDA HUSSAIN (Director) at LUXURY LIFESTYLE INTERNATIONAL, Office A, Citi Car Park, Burne House, 5 Bell Street, London, NW1 5BZ. Your Information Rights We are committed to ensuring any information we process is correct and up to date. It is your obligation to make us aware of any changes to your personal information. In accordance with legislation, you now possess the following: • Right To Be Informed: We must tell you how we use your information and this is the purpose of this privacy notice.
• Right to Request Access: You have the right to access the information we hold on you. To do so, you should make a “Subject Access Request”. It may be accessed at no cost and will be provided within 30 days of your request.
• Right To Request Correction: If any information we hold about you is incomplete or inaccurate you are able to require us to correct it.
• Right To Request Erasure: If you would like us to stop processing your information, you possess the right to ask us to delete it from our systems where you believe there is no reason for us to continue processing it.
• Right To Object To The Inclusion Of Any Information: In situations where we are relying on a legitimate interest (or those of a third party) you have the right to object to the way we use your information where we are using it.
• Right To Request The Restriction of Processing: You have the right to ask us to stop the processing of information (whilst still holding it) until we have ensured the information is correct.
• Right To Portability: You may transfer the information we hold on you for your own purposes.
• Right To Request The Transfer: You have the right to request the transfer of your information to
another party. Where consent has been given to use information, an additional unrestricted right to withdraw consent at any time is available. Withdrawing consent means we will cease processing the information consent was given on without any resultant consequence. We may however, in some circumstances, continue using the information where so permitted by having a legitimate reason.
If you wish to exercise any of your above rights, please write to Mr. FIDA HUSSAIN (Director) at LUXURY LIFESTYLE INTERNATIONAL, Office A, Citi Car Park, Burne House, 5 Bell Street, London, NW1 5BZ.