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PRIVACY POLICY

Background

This privacy notice lets you know what happens to any personal data that you give to us, or any that we may collect from or about you. It applies to all products and services, and instances where we collect your personal data. This privacy notice applies to personal information processed by or on behalf of AIR VIP. Changes to this privacy notice. We may change this privacy notice from time to time by updating this page in order to reflect changes in the law and/or our privacy practices. We encourage you to check this privacy notice for changes whenever you visit our website www.AIR VIP.com AIR VIP and our Data Protection Officer. AIR VIP of IBIS Heathrow Airport, 112 Bath Road, Hayes, UB3 5AL. We are a data controller of your personal data. We have a dedicated data protection officer. You can contact the DPO by writing to the above address, marking it for the attention of the DPO or going to “Contact Us” on our website.

What kinds of personal information about you do we process?

Personal information that we process in connection with all of our products and services, if relevant, includes:
- Personal and contact details, such as title, full name, contact details and contact details history
- Your date of birth, gender and/or age
- Your nationality, if needed for the product or service
- Family members (if relevant to the product or service)
- Records of your contact with us such as via the phone number of our phone service and, if you get in touch with us online using our online services or via our smartphone app, details such as your mobile phone number and date of contact.
- Products and services you hold with us, as well as have been interested in and have held and the associated payment methods used
- The usage of our products and services, any call outs and claims and whether those claims were paid out or not (and details related to this)
- Marketing to you, including history of those communications, whether you open them and information about products or services we think you may be interested in. Offers may include our car, meet and assist, connected car, travel and any of our other products and services.
- Information we obtained from third parties, including names and telephone numbers.
- Fraud, debt and theft information, including details of money you owe, suspected instances of fraud or theft, and details of any devices used for fraud
- Information about your health or if you are a vulnerable customer
- Information about your property, such as address, only for the purpose of collection or drop off as part of our limousine service.
- Payment details about you, such as your invoice address and payment method(s)
- Third party transactions; such as where a person other than the account holder uses the service, information about that person and the transaction

What is the source of your personal information?

We collect personal information from the following general sources:
- From you directly, and any information from family members, associates or beneficiaries of products and services
- Information generated about you when you use our products and services
- From a broker or other intermediary (for example, travel agent) who we work with to provide products or services or quote to you
- Business partners (for example, companies with which we have business agreements), account beneficiaries, or others who are a part of providing your products and services.
- From other sources such as Fraud Prevention Agencies, Credit Reference Agencies, other lenders, HMRC, DWP, publicly available directories and information (for example, telephone directory, social media, internet, news articles), debt recovery and/or tracing agents, other organisations to assist in prevention and detection of crime, police and law enforcement agencies

What do we use your personal data for?

We use your personal data, including any of the personal data listed in section 1 above, for the following purposes:
- Assessing an application for a product or service, the price, the risk of doing so, availability of payment method and the terms
- Managing the product or service you have with us
- Updating your records, tracing your whereabouts and recovering debt
- Managing any aspect of the product or service
- To make automated decisions on whether to offer you a product or service, or the price, payment method
- To perform and/or test the performance of, our products, services and internal processes
- To improve the operation of our business and that of our business partners
- To follow guidance and best practice under the change to rules of governmental and regulatory bodies
- For management and auditing of our business operations including accounting
- To monitor and to keep records of our communications with you and our staff (see below)
- To administer our good governance requirements and those of business partners of AIR VIP, such as internal reporting and compliance obligations or administration required for Annual General Meeting (AGM) processes
- For direct marketing communications. We send marketing to you by SMS, email, phone, post, social media and digital channels (for example, using Facebook Custom Audiences and Google Custom Match). Offers may relate to any of our products and services such as transport, meet and assist, travel, as well as to any other offers and advice we think may be of interest
- To provide personalised content and services to you, such as tailoring our products and services
- To develop new products and services and to review and improve current products and services
- To comply with legal and regulatory obligations, requirements and guidance
- To share information, as needed, with business partners (for example, limousine vehicle providers, porter services, insurers), service providers or as part of providing and administering our products and services or operating our business

What are the legal grounds for our processing of your personal information (including when we share it with others)?

We rely on the following legal bases to use your personal data:
- Where it is needed to provide you with our products or services, such as:
a) Assessing an application for a product or service you hold with us, including consider whether or not to offer you the product, the price, the payment methods available and the conditions to attach
b) Managing products and services you hold with us, or an application for one
c) Updating your records, tracing your whereabouts to contact you about your account and doing this for recovering debt (where appropriate)
d) Sharing your personal information with business partners and services providers when you apply for a product to help manage your product
e) All stages and activities relevant to managing the product or service including enquiry, application, administration and management of accounts
- Where it is in our legitimate interests to do so, such as:
a) Managing your products and services relating to that, updating your records, tracing your whereabouts to contact you about your account and doing this for recovering debt (where appropriate)
b) To perform and/or test the performance of, our products, services and internal processes
c) To follow guidance and recommended best practice of government and regulatory bodies
d) For management and audit of our business operations including accounting
e) To carry out monitoring and to keep records of our communications with you and our staff (see below)
f) To administer our good governance requirements and those of our partner companies, such as internal reporting and compliance obligations or administration required for AGM processes
g) For market research and analysis and developing statistics
h) For direct marketing communications and related profiling to help us to offer you relevant products and services
i) Where we need to share your personal information with people or organisations in order to run our business or comply with any legal and/or regulatory obligations
- To comply with our legal obligations
- With your consent or explicit consent:
a) For some direct marketing communications
b) For some of our processing of special categories of personal data such as about your health, if you are a vulnerable customer
- For a public interest, such as:
a) Processing of your special categories of personal data such as about your health, criminal records information, or if you are a vulnerable customer

When do we share your personal information with other organisations?

We may share information with the following third parties for the purposes listed above:
- AIR VIP and service providers
- Business partners (for example, insurers), account beneficiaries, or others who are a part of providing your products and services or operating our business including the HSBC Bank
- Governmental and regulatory bodies such as HMRC, the Financial Conduct Authority, the Prudential Regulation Authority, the Ombudsman, the Information Commissioners Office and under the Financial Services Compensation Scheme
- Other organisations and businesses who provide services to us such as debt recovery agencies, back up and server hosting providers, IT software and maintenance providers, document storage providers and suppliers of other back office functions
- Credit Reference and Fraud Prevention Agencies (see below)

How and when can you withdraw your consent?

Where we're relying upon your consent to process personal data, you can withdraw this at any time by contacting us using the details below.

Is your personal information transferred outside the UK or the EEA?

We're based in the UK but sometimes your personal information may be transferred outside the European Economic Area. If we do so we'll make sure that suitable safeguards are in place, for example by using approved contractual agreements, unless certain exceptions apply.

What should you do if your personal information changes?

You should tell us so that we can update our records using the details in the Contact Us section of our website. We'll then update your records if we can.

Do you have to provide your personal information to us?

We're unable to provide you with our products or services if you do not provide certain information to us. In cases where providing some personal information is optional, we'll make this clear.

Do we do any monitoring involving processing of your personal information?

In this section monitoring means any: listening to, recording of, viewing of, intercepting of, or taking and keeping records (as the case may be) of calls, email, text messages, social media messages, in person (face to face) meetings and other communications. We may monitor where permitted by law and we'll do this where the law requires it, or to comply with regulatory rules, to prevent or detect crime, in the interests of protecting the security of our communications systems and procedures and for quality control and staff training purposes. This information may be shared for the purposes described above.

What about other automated decision making?

We sometimes make decisions about you using only technology, where none of our employees or any other individuals have been involved. For instance, we may do this to decide: whether to offer you a product or service, to determine the risk of doing so, the price we will offer, whether to offer you credit, what terms and conditions to offer you, assess lending, insurance and business risks, or to assess what payment methods we can offer you. We'll do this where it is necessary for entering into or performing the relevant contract, is authorised by laws that apply to us, or is based on your explicit consent.

For how long is your personal information retained by us?

Unless we explain otherwise to you, we'll hold your personal information based on the following criteria:
- For as long as we have reasonable business needs, such as managing our relationship with you and managing our operations
- For as long as we provide goods and/or services to you and then for as long as someone could bring a claim against us; and/or
- Retention periods in line with legal and regulatory requirements or guidance.

What are your rights under data protection laws?

Here is a list of the rights that all individuals have under data protection laws. They don't apply in all circumstances. If you wish to use any of them, we'll explain at that time if they are engaged or not. The right of data portability was only relevant from May 2018.
- The right to be informed about the processing of your personal information
- The right to have your personal information corrected if it is inaccurate and to have incomplete personal information completed
- The right to object to processing of your personal information
- The right to restrict processing of your personal information
- The right to have your personal information erased (the right to be forgotten)
- The right to request access to your personal information and to obtain information about how we process it
- he right to move, copy or transfer your personal information (data portability)
- Rights in relation to automated decision making which has a legal effect or otherwise significantly affects you
You have the right to complain to the Information Commissioners Office which enforces data protection laws: https://ico.org.uk/. You can contact us using the details below.

Your right to object

You have the right to object to certain purposes for processing, in particular to data processed for direct marketing purposes and to data processed for certain reasons based on our legitimate interests. You can contact us by going to the “Contact Us” section of our website to exercise these rights.

What are your marketing preferences and what do they mean?

We may use your office address, phone numbers and email address to contact you according to your marketing preferences. You can opt out of any email or text marketing. If you receive a marketing call from us, you can ask the person who called you to opt you out. You can also write to us at, marking it for the attention of the DPO. Or go to our Contact Us.

Contact Us

If you have any questions about this privacy notice, or if you wish to exercise your rights or contact the DPO, you can contact us by going to the Contact Us section of our website.