Air Cars Privacy Notice : Passengers
Last Updated : 23rd January 2024
Air Cars Ltd trading as “Air Cars” (a company registered in the United Kingdom, with company number 13112753), having its registered office at Rourke House, 3, Watermans Business Park, Kingsbury Crescent, Staines-upon-Thames, TW18 3BA.
“Air Cars” or “we” set out below how we use your personal data. Air Cars collects and processes personal data of: passengers in the course of their installation and use of the Air Cars app in accordance with the relevant terms of use.
The term “driver” in this Privacy Notice refers to an individual that has applied to act as an individual providing driver services via the Air Cars platform (including an individual that has applied to fulfill journeys in association with another driver’s account).
The processing of geographical location data is necessary for use of the Air Cars app.
WHAT TYPES OF PASSENGER PERSONAL DATA WE COLLECT AND PROCESS
Personal data is processed in order to provide the service contracted with passengers. Air Cars collects data about you which may include :
Name, telephone number, e-mail address, as collected during installation of the app;
Where you access and use the app from;
Where you register for an account, your user ID and password;
Where you choose to connect to the service from a third party service, such as LinkedIn, Facebook or Twitter, your information from that service;
Feedback ratings (including information provided to resolve disputes), payment information and payment history;
Information regarding your booking requests, including geographical location of the user, the time of provision of service, details of the route and destination; estimates of fares for your journey and price paid;
Data about the usage of the transportation services: things like data about journey status, times and data about your conduct as assessed by drivers;
Text, images and other user content you provide;
If we ban or suspend you from use of the service, a record of that ban or suspension;
Identification data of the device on which the relevant Air Cars app has been installed;
Details of app support queries you make including record of any reported lost items;
Data related to communication through instant messages directly in the Air Cars app ("Chat with Driver" option): date and time of the communication and its content.
PASSENGER PERSONAL DATA RETENTION
Your personal data will be stored as long as you have an active passenger account. If your account is closed, personal data will be deleted (according to the policies set out in this section) from the databases, unless such data is required to be retained for accounting, dispute resolution or fraud prevention purposes. This follows that :
Booking records will be retained for 12 months as per the PHV Operator license requirements.
Journey history data will be stored for 3 years, after which the data will be anonymized.
Data required for accounting purposes will be stored for 7 years after the last journey.
Financial data regarding transportation services provided to passengers will be stored for 3 years after the last journey.
If the Air Cars app has not been used for 3 years, we will notify you and ask you to confirm whether account is still active. If no reply is received, the account will be closed and personal data will be deleted unless such data is required to be stored for accounting, dispute resolution or fraud prevention purposes.
In the event that there are suspicions of a criminal offence, fraud or false information having been provided, the data will be stored as long as necessary according to the internal, legal, and regulatory requirements. In case of payment disputes, data will be retained until the claim is satisfied or the expiry date of such claims;
The retention period for the data about instant messages directly in the Air Cars app messages is 90 days, except cases where messages are related to a reported incident - in which case we will store them for 6 month..
Please note that the deinstallation of Air Cars app in your device does not cause the deletion of your personal data.
HOW AND WHY WE USE THIS PERSONAL DATA
Air Cars collects and uses personal data for purposes of providing the Air Cars apps and for ensuring the safety of passengers and drivers. This includes the following :
We collect and process personal data for the purpose of accepting your journey request and offer a driver to fulfil your journey request;
We forward the data on geographic location of the passenger to drivers to enable them to decide whether to fulfil the passenger’s requested journey and once the journey has been confirmed, we also collect your telephone number in order for a driver to be able to contact the passenger after the driver has confirmed the journey;
We may use the personal data provided to resolve service quality issues or to improve our apps or for reasons related to security including but not limited to complying with law enforcement information requests when applicable;
We use contact details to notify you of updates to the Air Cars app;
If you have consented, we may contact you with promotional messages regarding the Air Cars app;
We collect data of the routes taken by the Air Cars app users to analyse the geographic coverage in order to make recommendations to the drivers;
Personal data related to instant messages directly in the Air Cars app are processed in order to provide service and customer support (including resolving disputes between driver and passenger), for security purposes as well as to improve our products and services, and for analysis.
We will hold and process your personal data for at least the time during which your account is activated and then in accordance with our legal obligations;
We collect data about journey statuses, time and passenger ratings from driver feedback to encourage user safety, promote compliance with our terms and conditions, and make sure we’re providing a quality and enjoyable service to everyone. Customer support data and correspondence is collected for the purposes of feedback, and resolving disputes and service quality issues.
Data may be processed on the ground of legitimate interest in investigation detecting and preventing fraud and other malicious activities
Record of any requests for your information made by law enforcement.
Personal data is processed in order to provide the service contracted with passengers. We collect and processes the personal data submitted by the passengers in the course of installation and use of the Air Cars app. The prerequisite for the use of Air Cars services is passengers agreeing to the processing of identification and geolocation data.
DIRECT MARKETING TO USERS
We only use your email address and phone number for sharing our product related marketing messages if you have given your consent on the aircarsuk.com website or in the Air Cars app. If you no longer wish to receive direct marketing messages, please click the “Unsubscribe from direct marketing messages” link in the header of our e-mail or Profile section of Air Cars mobile App.
AUTOMATED DECISION MAKING: PASSENGERS
We may use the help of automated decision-making in case of issuing warnings and implementing service suspensions. Data about your usage of the transportation services (data about journey status incl. cancellations and no-shows and data about your conduct as assessed by drivers) is considered when assessing the need for a warning or suspension. You can read more about automated decision-making here. Suspension will stay in force for 6 months, after which access to service will be restored.
You will always have the right for human review of the decision and to contest the decision, express your point of view and obtain an explanation by contacting our customer support in our app.
DISCLOSURE OF PERSONAL DATA TO LAW ENFORCEMENT
Air Cars is committed to ensuring the safety of all passengers and drivers using our service. We take all reports of misconduct seriously and we reserve the right, at our discretion, to volunteer information to law enforcement when we feel is necessary.
If we are made aware that law enforcement requires information about your personal data for a criminal investigation we will comply, to the extent that their request is reasonable and we are able to supply such information.
Personal data that we may provide includes :
passenger’s name(s)
date of birth (if available)
contact number
home address (if available)
journey details including ie. start and finish time, pickup and drop off point
details of the complaint made by the passenger, driver, or applicable third party
Air Cars may, at our discretion, provide you with notice that we have provided law enforcement with your personal data.
We reserve the right to proactively initiate police reports if we become aware of action or behaviour that may constitute a threat to safety or criminal concern.
DISCLOSURE OF PERSONAL DATA TO THIRD PARTIES
The personal data of users is only disclosed to those drivers who have activated the Air Cars app; in such case, they will see the first name, geographic location, rating and trip count on the platform of the user. The driver will be able to contact the user once they have confirmed the journey, however they will not be able to view the users phone number as we use a process called number masking to keep the users contact information hidden;
After the journey, the name of the user will remain visible to the driver for 24 hours. This is necessary for drivers to resolve any issues associated with the journey, e.g., to contact the customer through selecting to do so in app if something was left behind in the car. At no point will the phone number of a passenger be disclosed to a driver without the passenger’s consent;
Any feedback on the quality of the service is anonymous and drivers do not receive information on the names and telephone numbers of the users who provided feedback;
Air Cars may disclose personal data to our third party service providers, who may be located outside the UK, subject to contracts with those third parties. These may include IT or payment services providers or verification and authentication checks providers, Ondemand Apps OÜ, Stripe Inc.). Our payment provider, Stripe is fully PCI DSS 3.2 compliant as a Level 1 Service Provider;
We may also share personal data with local licensing bodies, law enforcement, for legal reasons or if there is a change in ownership if our business or assets.
YOUR RIGHTS AND DELETION OF DATA
Any personal data collected in the course of providing services is transferred to and stored in the data centres provided by Ondemand Apps OÜ which are located in the territories of Member States of the European Union. Only authorised employees of Air Cars group companies and partners have access to the personal data and they may access the data only for the purpose of resolving issues associated with the use of the services (including disputes regarding transportation services).
If you would like to delete the personal data collected by us, please submit a written request to our customer support via support@aircarsuk.com After receiving the request we will delete the account if there are no outstanding payments or as required for legal reasons. After account deletion the associated personal data will be anonymized.
Please note that the deinstallation of the Air Cars app in your device does not cause the deletion of your personal data. If you want to delete your personal data collected by Air Cars, please send a written request by email as indicated above. You should also bear in mind that the request to delete personal data is possible only if we delete your account and always subject to our legal requirements to retain any personal data. As a result of that you will not be able to use Air Cars services under your existing account. We respond to the request for deleting and transferring of personal data submitted by an e-mail within a month and specify the period of data deletion and transfer.
If you wish to access or correct your personal data or have any other concerns about the processing of your personal data by Air Cars, please contact us at support@aircarsuk.com.
QUESTIONS AND UPDATES
Personal data can be viewed and corrected in the Air Cars App. If you have any disputes, questions or concerns about this privacy statement or your personal data, please contact us at support@aircarsuk.com.
You have the right to make a complaint at any time to the supervisory authority which is the UK Information Commissioner’s Office (ICO) who can be contacted here: https://ico.org.uk/global/contact-us/
This privacy notice was last updated on 26th November 2023. Any changes we may make to this privacy notice in the future will be posted on this page and, where appropriate, notified by email. Please check back regularly to keep informed of updates or changes to this privacy notice.
Air Cars Privacy Notice : Drivers
Last Updated : 23rd January 2024
This privacy notice lets you know how we promise to look after your personal data as a driver in the United Kingdom. This notice tells you things like what information we collect and process from you when using Air Cars' platform, in the course of your installation and use of the Air Cars driver app, what personal data we use to register and onboard you, and how we use your data to provide you with our platform services, all in accordance with the relevant terms of use. This notice also lets you know how we use your information to keep you and others safe, and the choices and controls available to you. This notice tells you about your privacy rights and how data protection rules work to protect everyone’s interests. And if you need to get in touch, all the details follow below.
The term “you” or “driver” refers to an individual that has applied to act as an individual providing driver services via the Air Cars platform (including where you are a driver that has applied to fulfill journeys in association with another driver’s account, in which case the exceptions stated below will apply).
Who we are
Air Cars Ltd trading as “Air Cars” (a company registered in the United Kingdom, with company number 13112753) having its registered office at Rourke House, 3, Watermans Business Park, Kingsbury Crescent, Staines-Upon-Thames, TW18 3BA - “Air Cars” or “we” set out below how we use your personal data.
1. Personal data we process
We only process information that we need to, so we can provide you with the very best service on our platform.
We process the following types of personal data:
Personal information: things like name and date of birth, and contact details like your address, email, and phone number.
Payment information: things like your bank details and transaction details such as transaction amounts, except where you are a driver that has applied to fulfill journeys in association with another driver’s account.
Information about your driving licence and the information on it, your vehicle, and your insurance details.
Background checks: things like medical certificates, topographical test certificates and English language test certificates, too.
Data regarding criminal convictions and offences.
Law enforcement engagement: things like any record of a police request for your personal data, a record of whether a disclosure was made by us, and the content of that disclosure.
Third party verification: Information collected from third parties about you in order to verify any information you supplied to Air Cars during registration to Air Carsplatform.
Authentication and verification data: Things like the selfies you provide to us, from which identity authentication and verification checks can be undertaken and recorded.
Limited identification data of the device, like the IP address on which the Air Cars app has been installed.
Geolocation: things like where you are, the location of nearby passengers to you, the time, the journey progression and the final destination of a journey.
Feedback and ratings: a score (out of 5) provided by each passenger after a journey.
Data about your platform usage: things about your engagement and interaction with the app, such as details of journeys (date and time, number of confirmed journeys and cancellations), duration of fulfilling journeys on each day, and ratings (including your Driver Score, Confirmation Rate and Preferential Allocation Level where such features are available).
Driver records: things like where we withdraw your right to use the service, issue a notice, or provide a driver with additional guidance or require other actions to be taken, and information relating to any associated reviews or appeals.
Communication and correspondence records: such as when you engage with our in-app chat ("Send a Message" option), or speak with our customer service agents, the date and time of the communication, and its content.
We may receive and collect your data from another driver where you are a driver that has applied to fulfill journeys in association with another driver’s account.
2. Purpose of the processing
Air Cars collects and uses personal data for the purposes of providing its services in accordance with the Air Cars Driver Terms, and for ensuring the safety of passengers and drivers. This includes the following:
We make sure you are who you say you are, and that you are licensed to provide driver services (where applicable): Driver's license, professional qualifications and certifications, identity documents and criminal convictions and offences are processed to determine driver compliance with legal requirements and regulatory conditions that apply to driver services. We use the information on your driving licence data and the selfies you provide to us to verify and authenticate your identity on an ongoing basis for safety and security purposes. When you create a new account on the Air Cars app and prior to taking your first journey, you will be asked to upload a picture of your driving licence and submit a selfie; and then on an ongoing basis at appropriate intervals, you will be asked to submit another selfie. We may use biometric software to achieve this purpose.
We connect you with a passenger: We collect and process personal data for the purpose of connecting drivers with passengers to fulfill a journey,.
We provide a platform: We collect and use information about a driver’s engagement and interaction on the platform, and their ratings (including Driver Score where this feature is available to you) to encourage user safety, ensure the compliance with the Driver Terms and make sure we’re providing a quality and enjoyable service to everyone. Where your Driver Score (when available) drops below a specified threshold, we may issue you with a notification to digest some further guidance.
We make sure the journey goes smoothly: We use geolocation data to make sure you get to your destination and resolve quality issues related to our services.
We make sure the app is optimal: We use contact details to notify drivers of updates to the Air Cars app so you can keep using our services. We also gather limited data from the device that you use to connect you with our internet, mobile and telephone services, and to help keep your account safe through authentication and verification checks.
We make sure that journeys are quick and convenient: We collect data on the routes taken by drivers to analyse geographic coverage. This lets us do things like improving recommendations to drivers about the most efficient routes.
We process payments: We process payment details to make payments, except where you are a driver that has applied to fulfill journeys in association with another driver’s account.
We maintain and promote standards: We collect data about journey status, time and ratings from passenger feedback to encourage user safety, promote compliance with our terms and conditions, and make sure we’re providing a quality and enjoyable service to everyone. Customer support data and correspondence is collected for the purposes of feedback and resolving disputes and service quality issues.
We talk and keep you informed: Your name, phone number and email address will be used to communicate with you our most important service-related messages. Personal data related to instant messages directly in the Air Cars app are processed in order to provide assistance and customer support, including where we need to resolve any dispute between driver and passengers.
3. Lawful Basis
We are allowed to use personal information in the ways described above if we have a proper reason to do so. We always make sure we have a good reason for doing anything with your data.
We collect and process the personal data of drivers to comply with our legal and regulatory obligations, such as to comply with relevant legislation that applies to us and to meet our own licensing conditions and for verifying a driver’s qualifications for providing driver services.
Personal data is processed to provide the driver services available via the Air Cars platform in accordance with our terms and conditions that apply to drivers in the United Kingdom. This includes, for example, connecting you with a passenger, operating our platform, resolving any service quality issues and monitoring compliance with terms.
We generally in other circumstances process your personal data relying on legitimate interest grounds. Legitimate interests include our interests in providing an innovative, personalised and safe service to you and others. Our legitimate interests include things like investigating, detecting and preventing fraudulent and other malicious activities, maintaining the security of our network and systems, and responding to suspected or actual criminal acts.
We may from time to time rely on alternative lawful bases for processing your data when:
It is necessary to protect your vital interests or those of others, for example in the event of an emergency or an imminent threat to life; or
you have given us clear consent to do so for another specific purpose in which you have been fully informed. Where we rely on consent to process personal data, you can withdraw your consent to such activities at any time.
If you choose not to give us personal information, it may prevent us from fulfilling the contract with you or stop us from doing something expected of us in law. It may also mean that we cannot operate your account. For example, we collect and process the personal data submitted by you in the course of installing and using the Air Cars app; refusing to share geolocation data via the App means we cannot direct you to a passenger location for pick-up. We will not be able to fulfil our obligations to you in other circumstances, for example, should you refuse to undertake an identity verification check to ensure the integrity of your account, then the account may be suspended or terminated to prevent fraud.
4. Recipients
We only work with trusted partners and authorities. We only share when there is a proper reason to do so. We limit sharing to only that which is required. We do not sell your personal information.
Your personal data is disclosed to passengers when:
- You have confirmed the offer to fulfill the journey; in which case they will see your name, vehicle details, photo, geolocation data (e.g. ETA), fare and rating (out of 5 stars).
In some circumstances, we are legally obliged to share information with external recipients. For example, under a Court Order or where we cooperate with a data protection supervisory authority in handling complaints or investigations. We can also respond to requests, such as those from law enforcement agencies when the response is required by law or furthers a public interest task. In any scenario, we’ll always satisfy ourselves that we have a lawful basis on which to share the information and we’ll make sure that we document our decision.
We may share your personal data with Air Cars group companies to provide our services and for internal administrative purposes.
Air Cars may provide personal data to our service providers and business partners, which include :
Business partners who offer their partnership or promotional offering in collaboration with Air Cars;
Drivers, where you are a driver that has applied to fulfill journeys in association with another driver’s account;
Payment processors and facilitators;
Background check and identity verification providers;
Cloud service providers and other IT support and infrastructure service providers;
Telecommunication service providers;
Research partners.
5. Security and access
Air Cars may on occasion, need to transfer personal data to its third-party service providers, who may be located in countries outside of the UK and EEA. Whenever we transfer your personal data out of the UK and/or EEA, we ensure the same degree of protection is afforded to your data by ensuring at least one of the following safeguards is implemented:
we will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the UK Government (in the case of transfers out of the UK), and/or the European Commission (in the case of transfers out of the EEA); and/or
where we use certain service providers, we may use specific contracts approved by the UK Government (in the case of transfers out of the UK) and/or the European Commission (in the case of transfers out of the EEA).
6. Your rights and controls
We want you to stay in control of your personal data. Air Cars provides you with controls through the app where you can view and change your personal information.
Your right to access
You have the right to ask us to erase your personal information in certain circumstances. After receiving the request we will delete the account so long as there are no payments due, and no outstanding contractual or legal obligations. Following account deletion, any associated personal data related to you will be anonymised.
Your right to restriction of processing
You have the right to ask us to restrict the processing of your information in certain circumstances. This means that your data can only be used for certain things, such as legal claims or to exercise legal rights.
Your right to object to processing
You may have the right to object to processing if we are processing your information on the basis of legitimate interests.
Your right to data portability
You have the right to ask that we transfer the information you gave us from one organisation to another, or give it to you, in certain circumstances. This only applies to the information you have given us.
7. Retention
Air Cars retains driver personal data for only as long as necessary for the purposes described above. This means that we retain different categories of data for different periods of time depending on the type of data and the purposes for which we collected the data.
Booking records are retained for 12 months in line with PHV Operator license requirements.
Data necessary for accounting purposes is retained for 7 years.
In the event that there are suspicions of a criminal offence, fraud or false information having been provided, the data will be stored as long as necessary according to the internal, legal, and regulatory requirements.
In the event that your account is closed the personal data associated with your driver profile will be stored for 3 years before deletion.
Correspondence data in the Air Cars app instant-messaging service is retained for 90 days, except in cases where messages are related to a reported incident in which case we will store them for 6 months, or in the event, they are related to a dispute.
In the event of disputes, the data shall be retained until the claim is satisfied or until the expiry date of such claims.
Please note that uninstalling the Air Cars app on your device does not cause the deletion of your personal data. If the Air Cars app has not been used for three years, we’ll get in touch and ask you to confirm whether you wish to keep your account active for future use. If no reply is received in a reasonable time, the account will be closed and personal data will be deleted unless the data’s retention is required for any other purpose mentioned earlier in this privacy notice. In the event you wish to have your account deleted, please submit a written request to customer support in the first instance at support@aircarsuk.com
8. Direct marketing
We may send direct marketing messages to your e-mail address and/or phone number when you have given us permission to do so, or under a soft opt-in basis. We may personalise direct marketing messages using the information on how you use Air Cars' services, such as how frequently you use the Air Cars app, and other preferences.
If you no longer wish to receive direct marketing messages, please click the "Unsubscribe" link in the footer of one of our emails, or opt-out in the profile section of the Air Cars app.
9. Dispute resolution
Disputes relating to the processing of personal data are resolved through customer support in the first instance.
We have nominated a Data Protection Officer, and you can contact him at support@aircarsuk.com or at our postal address. Please mark the subject line or envelope ‘UK Data Protection Officer’.
You have the right to make a complaint at any time to the supervisory authority which is the UK Information Commissioner’s Office (ICO), who can be contacted here: https://ico.org.uk/global/contact-us/
10. Our undertaking to you
We hope you have found this privacy notice easy to understand.
Data protection laws are important. They strengthen rules and enhance your information rights. Many of these rules may appear complicated, but most are grounded in common sense. We take our responsibilities with your data seriously. Air Cars will continue to make changes to this privacy notice as part of our commitment to protecting your privacy and affording you even more transparency.