Privacy Policy
This privacy policy sets out how EET Group t/a Edinburgh Executive Travel uses and protects your personal data. This privacy policy is provided in a layered format so you can click through to the specific areas set out below.
1. IMPORTANT INFORMATION AND WHO WE ARE >>>
2. TYPES OF PERSONAL DATA WE COLLECT ABOUT YOU >>>
3. HOW IS YOUR PERSONAL DATA COLLECTED? >>>
4. HOW WE USE YOUR PERSONAL DATA >>>
5. DISCLOSURES OF YOUR PERSONAL DATA >>>
6. INTERNATIONAL TRANSFERS >>>
12. CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES >>>
1. Important information and who we are
1.1 Privacy policy
This privacy policy gives you information about how EET Group Ltd t/a Edinburgh Executive Travel collects and uses your personal data when you interact with our website, our services and any other sites or services that link to this Privacy Policy. This Privacy Notice applies to you if you are:
- a visitor to our website;
- make an enquiry with us and/ or request a quote from us (either online or by another means);
- make a booking (either online or by telephone) or create an account with us;
- are an end user of our services (for example a passenger), or an employee of our client, where our client uses or requests our services (for example if your employer uses our services and you are a passenger);
- an employee of a supplier who provides a service to us; or
- an individual whose data has been collected by us in line with para 1.3 and paragraph 3 (Third parties or publicly available sources) including for marketing purposes (“Prospects”).
Our website and our services are not intended for children, and we do not knowingly collect data relating to children
1.2 Controller
EET Group Ltd t/a Edinburgh Executive Travel is the controller and responsible for your personal data (collectively referred to as “EET”, "we", "us" or "our" in this privacy policy).
We have appointed a data protection expert who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights (paragraph 9), please contact us using the information set out in the contact details section (paragraph 10).
1.3 Where you provide us with personal data about someone else.
If you provide us with personal data about someone else, you are responsible for ensuring that you are permitted to share that personal data and comply with any applicable legal obligation. This may include explaining to that individual why you are collecting their personal data, what you are doing with it and obtaining their consent, if relevant under applicable law. We also recommend that you direct them to read this privacy notice.
2. The types of personal data we collect about you
Personal data means any information about an individual from which that person can be identified.
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- Identity Data includes first name, last name, any previous names you may have given us, username or similar identifier, title.
- Contact Data includes billing address (personal or business), pick-up address (personal or business), email address (personal or business) and telephone numbers (personal or business) and organisational details including job titles and place of work.
- Financial Data includes payment card details.
- Transaction Data includes details about payments to and from you and other details of services you have purchased from us.
- Technical Data includes internet protocol (IP) address, your account login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, device ID and other technology on the devices you use to access this website.
- Profile Data includes your account data, orders made by you, your communications with us, your interests, preferences, and feedback responses.
- Usage Data includes information about how you interact with and use our website and services.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We also collect, use and share aggregated data such as statistical or demographic data which is not personal data as it does not directly (or indirectly) reveal your identity. For example, we may aggregate individuals' Usage Data to calculate the percentage of users accessing a specific website feature in order to analyse general trends in how users are interacting with our website to help improve the website and our service offering.
3. How is your personal data collected?
We use different methods to collect data from and about you including through:
- Your interactions with us. You may give us your personal data by filling in online forms or by corresponding with us by phone, email or otherwise. This includes personal data you provide when you:
- enquire about our services;
- make a booking with us;
- communicate with us via our website, telephone, text message, email or social media.
- create an account with us;
- subscribe to our service or publications;
- request marketing to be sent to you;
- enter a competition, promotion or survey;
- give us feedback or contact us; or
- provide us with a service, for example if you are a supplier or contractor.
- Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see our cookie policy for further details.
- Third parties or publicly available sources. We will receive personal data about you from various third parties as set out below:
- Identity and Contact data is collected by our clients or customers and shared with us where you are an end user of our services which have been booked by a them.
- Identity and Contact data is collected by our Suppliers and shared with us where we are acting as their sub-contractor.
- Identity and contact data is collected by your employer and shared with us where they provide services to us.
- Technical Data is collected from analytics providers such as Google based outside the UK.
- Contact, Financial and Transaction Data is collected from providers of technical, payment and delivery services.
- Identity and Contact Data is collected from data brokers or aggregators.
- Identity and Contact Data is collected from publicly available sources.
4. How we use your personal data
Legal basis
The law requires us to have a legal basis for collecting and using your personal data. We rely on one or more of the following legal bases:
- Performance of a contract with you: Where we need to perform the contract we are about to enter into or have entered into with you.
- Legitimate interests: We may use your personal data where it is necessary to conduct our business and pursue our legitimate interests, for example to prevent fraud and enable us to give you the best and most secure customer experience. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
- Legal obligation: We may use your personal data where it is necessary for compliance with a legal obligation that we are subject to. We will identify the relevant legal obligation when we rely on this legal basis.
- Consent: We rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose, for example if you subscribe to a newsletter.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use the various categories of your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Direct marketing
You will receive marketing communications from us if you have requested information from us or purchased services from us and you have not opted out of receiving the marketing.
We may also analyse your Identity, Contact, Technical, Usage and Profile Data to form a view which services and offers may be of interest to you so that we can then send you relevant marketing communications.
Profiling
Profiling activities occurs when personal data is used to predict an individual’s interests and likely behaviours. Using behavioural information helps us inform our decisions about marketing audiences. This allows us to send the right message to the right audience.
We may use personal data generated when you use our services to improve them, and give you the best service and experience. This means that we may use personal data (including data collected using cookies and similar technologies) to evaluate and predict your personal preferences and interests.
We may conduct profiling activities to:
support you and personalise the communications we send in relation to our services where permitted by applicable law and in line with your preferences; and
deliver advertising, marketing or information which may be useful to you, based on your use of our services (considering your preferences as required); and
Please be aware that, in connection with the purposes above, we may use the personal data of your client’s, employees, contractors and other individuals, whose personal data you input into our website or booking system.
Third-party marketing
We will not share your personal data with any third party for their own direct marketing purposes.
You can ask us to stop sending you marketing communications at any time by following the opt-out links within any marketing communication sent to you, by emailing optout@edinburghexecutivetravel.co.uk or by contacting our data protection expert: rachel@edinburghexecutivetravel.co.uk.
If you opt out of receiving marketing communications, you will still receive service-related communications that are essential for administrative or customer service purposes for example booking confirmations or service updates.
Cookies
For more information about the cookies we use and how to change your cookie preferences, please see Cookies - Edinburgh Executive Travel.
Automated decision-making
We do not conduct any automated decision-making with a significant or legal effect, or otherwise, about you or any individuals.
5. Disclosures of your personal data
We may share your personal data where necessary with the parties set out below, and for the reasons set out blow, for the purposes set out in the table Purposes for which we will use your personal data above.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
We aim to ensure that your personal data is not transferred outside of the UK, and we will not do this directly.
We do however transfer your personal data to service providers that carry out certain functions on our behalf. On limited occasions this may involve them transferring personal data outside the UK.
Whenever we transfer your personal data out of the UK to service providers, we ensure a similar degree of protection is afforded to it by ensuring that the following safeguards are in place:
- Transfers to the EEA, which offers the same level of data protection as the UK;
- Transfers to countries that have been deemed by the UK to provide an adequate level of protection for personal data; or
- Specific standard contractual terms approved for use in the UK which give the transferred personal data the same protection as it has in the UK, namely the International Data Transfer Agreement or The International Data Transfer Addendum to the European Commission’s standard contractual clauses for international data transfers.
We have adopted a ‘privacy by design’ approach to processing personal data meaning that to the best of our ability, we will employ state of the art means of collecting, storing and transmitting your data with a view to promoting privacy and data protection from the outset. We will put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.
How long will you use my personal data for?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.
In some circumstances you can ask us to delete your data: see [paragraph 9] below for further information.
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
You have a number of rights under data protection laws in relation to your personal data.
You have the right to:
- Request access to your personal data (commonly known as a "subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- Request erasure of your personal data in certain circumstances. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) as the legal basis for that particular use of your data (including carrying out profiling based on our legitimate interests). In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your right to object.
- You also have the absolute right to object any time to the processing of your personal data for direct marketing purposes (see OPTING OUT OF MARKETING) for details of how to object to receiving direct marketing communications).
- Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Withdraw consent at any time where we are relying on consent to process your personal data (see the table in section 4 for details of when we rely on your consent as the legal basis for using your data). However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
- Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in one of the following scenarios:
- If you want us to establish the data's accuracy;
- Where our use of the data is unlawful but you do not want us to erase it;
- Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
- You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
If you wish to exercise any of the rights set out above, please contact our data protection expert at rachel@edinburghexecutivetravel.co.uk.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
If you have any questions about this privacy policy or about the use of your personal data or you want to exercise your privacy rights, please contact us in the following ways:
Email address: rachel@edinburghexecutivetravel.co.uk
Postal address: The Barn, 1c Riccarton Mains Farm, Edinburgh EH14 4AR
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
12. Changes to the privacy policy and your duty to inform us of changes
We keep our privacy policy under regular review. This version was last updated on 17 June 2024. Historic versions can be obtained by contacting us.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us, for example a new address or email address.
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.
