Privacy Policy

1. Introduction
   1. The term Onward Travel Solutions or 'us' or 'we' refers to the owner of the website whose registered office is 3 Viking House, Cheddar Business Park, Wedmore Road, Cheddar, Somerset, BS27 3EB.
   2. We collect and store the minimum information possible to provide the services you've requested (i.e. to process your order). We may also use this information for auditing, research and analysis to operate and improve our technologies and services.
   3. The term 'you' refers to the user or viewer of our website.
   4. Where required to fulfil your transfer, we may pass selected information to third parties.
   5. We may update this policy from time to time by publishing a new version on our website.
   6. You should check this page occasionally to ensure you are happy with any changes to this policy.
2. How we collect and use your personal data
   1. In this Section we set out:
      1. the categories of personal data that we may process;
      2. the reason why we may process personal data;
      3. the legal basis for processing this data;
      4. when we provide your personal data to others;
      5. the steps we take to protect your personal data.
   2. We may collect and process data about your use of our website ('analytics data'). The analytics data may include any of the following: your IP address; approximate location, internet browser type and version, your PC's operating system, the source of referral, length of your visit, and website navigation paths, your email address, as well as information about the frequency, and pattern of your visits. We gather this data through the Google Analytics service. The legal basis for the processing of this data is our legitimate interests in improving our website and service.
   3. We collect and process data relating to Customer Profiles ('Customer Data'). This data includes: your full name, email address, phone number & billing address). You will be required to provide this data during the process of booking our service. The legal basis for processing this data is for the performance of the contract, in particular for us to be able to reliably communicate with you regarding your bookings as well as organise and provide the service you have requested. Some of this data may be passed to third-party services, either as part of Transaction Information (for more information see section 2.5), or analytics data (see section 2.2).
   4. We may collect and process personal data relating to Journeys or Transfers ('Journey Data'). This data includes: head passenger name, passenger mobile telephone number, the route of your journey, flight / service numbers & the date and time of your travel. The legal basis for processing this data is for the performance of the contract. Some of the journey data, where required to fulfil your transfer, may be passed to third-parties, for example independent taxi drivers. Where possible, without impacting the quality of service, this sharing of data is restricted to un-identifiable information, for example when checking the availability of a third-party only the date, time, waypoint postcodes, number of passengers and type of vehicle are provided.
   5. We may collect and process data relating to the payment of services through our website or customer service agents ('Transaction Data'). Transaction data includes: card number, card expiry date & card security code, as well as some customer data: billing address and card holder's name, we also process some additional data to run background checks in order to reduce fraudulent activity, this data may include: your email address & telephone numbers. Transaction data is handled but not stored by us and is passed to a third-party service, SagePay. The transaction data may be processed for supplying the purchased services and keeping proper records of those transactions. The legal basis for this processing is the performance of a contract between you and us.
   6. We may process information contained in or relating to any communication that you send to or have with us ('correspondence data'). The correspondence data may include: email content, online chat transcripts, call recordings and metadata associated with the communication. The correspondence data may be processed for the purposes of communicating with you. Where possible we avoid collecting transaction data in correspondence data, this is done via warning notices on emails and pausing call recordings during the payment. In the unlikely event transaction data is captured in correspondence data records are deleted and purged from our system. The legal basis for this processing is in the performance of a contract, namely to organize and supply the purchased services.
   7. We may process your personal data where necessary, for use in the defence of legal claims in court or another legal proceeding. The legal basis for this is to protect and assert our legal rights, the rights of our customers or the rights of others.
   8. We may process any of your personal data where such processing is necessary to comply with a legal obligation to which we are subject, or to protect your interests or the interests of another person.
3. Retaining and deleting personal data
   1. This Section sets out our data retention policies, these are designed to ensure that we comply with our legal obligations in relation to the retention and deletion of personal data and are designed so that we maintain the lowest possible level of risk to our customers.
   2. Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary to fulfil the purchased service and our, or a third-parties, legal obligations.
   3. We will retain and delete your personal data as follows:
      1. Analytics Data:
         1. Google Analytics retains data relating to a visit to our website indefinitely, the data collected is non-identifiable.
         2. We collect some identifiable analytics data, this is stored for at most 1 month following a visit to our website, at the end of which period it will be deleted from our systems.
      2. Customer Data will be retained for 6 years from the end of last tax period following the completion of all booked journeys, at the end of which period it will be deleted from our systems. The data retention period will restart should any additional services be purchased during the data retention period, it is retained for this period to ensure compliance with the Finance Act of 1988, Schedule 18, Part 3, Section 21(2) which requires us to preserve relevant transactional information.
      3. Journey Data will be retained for at most 1 year following the completion of the journey in accordance with our legal obligations as a registered Private Hire Operator, at the end of which period it will be deleted from our systems.
      4. Some Transaction Data will be retained for 6 years from the end of the last company financial year they relate to in accordance to our legal obligations as a limited company, at the end of which period it will be deleted from our systems.
      5. Correspondence Data will be retained for at most 18 months following its collection, at the end of which period it will be deleted from our systems. Transactional correspondences issued by us are retained for 6 years from the end of last tax period in order to comply with the Finance Act of 1988, Schedule 18, Part 3, Section 21(2) which requires us to preserve relevant transactional information.
   4. We may retain your personal data where it is vital for use in defence of legal claims in court or another legal proceeding.
   5. We may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
4. Your rights
   1. You have the right to access; rectify or request the removal of any personal information we hold about you. We are legally bound to provide/remove this information free of charge within 30 days. This right however is subject to some limitations:
      1. There may be a legal reason we cannot remove the data.
      2. The data may be integral to providing the service, deleting or removing it would result in the cancellation of service. In this case you would be subject to our normal cancellation fees / procedure.
      3. You will be required to supply proof of your identity, in most circumstances we will accept two forms of ID such as a passport, driving license or a copy of a utility bill showing your address listed. This information must be provided by email or post along with your request.
      4. If the request is complicated the timeframe for rectification can be extended by up to two months.
   2. You have the right to lodge a complaint with a supervisory authority.
   3. You have the right to withdraw consent to our use of this data. In some cases this may result cancellation of your service and any relevant charges.

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