The Addison Lee Group ("we", "our", "us") is committed to protecting and respecting your privacy.
Addison Lee Limited is a limited liability company established in England with a registered office at 35-37 William Road, London, NW1 3ER ("Addison Lee");
Project Tristar Limited is a limited liability company established in England with a registered office at Unit 1, Horton Road, West Drayton, UB7 8BQ ("Tristar UK");
American Limousine LLC is a limited liability corporation established in the United States of America which has its principal place of business at 90 McKee Drive, Mahwah, New Jersey, 07430 and its registered office at 820 Bear Tavern Road, West Trenton, New Jersey, 08628 ("American Limousine"); and
Tristar Services US Inc is a company registered in the United States which has its principal place of business at 100 Cummings Centre, Suite 220-G, Beverly, MA 01915 and its registered office at Corporation Trust Centre, 1209 Orange Street, Wilmington, Delaware, 19801 ("Tristar US"),
and for the purpose of the General Data Protection Regulation (the "GDPR"), if you book services as a passenger in England, the data controller is Addison Lee or Tristar UK (as set out in your booking confirmation) and if you book services in the USA, the data controller is American Limousine or Tristar US (as set out in your booking confirmation).
This policy sets out the basis on which we will process any personal data or usage information we collect from you, or that you provide to us, in connection with your use of our websites at www.addisonlee.com, uk.tristarworldwide.com, and us.addisonlee.com (the "Websites"), our mobile apps (the "Apps") or our services. Please read this notice carefully so that you understand your rights in relation to your personal data, and how we will collect, use and process your personal data. If you do not agree with this Privacy Notice in general or any part of it, you should not access the Websites, the Apps or use our services.
To perform our contract with you, we will use your information:
As it is in our legitimate interests to be responsive to you and to ensure the proper functioning of our services and organisation, we will use your information:
Technical usage information. When you visit our Websites or use our Apps, we automatically collect the information sent to us by your computer, mobile phone, or other access device. This information includes:
As it is in our legitimate interests to process your data to provide effective services and useful content to you we collect this information in order to:
We receive information from other sources, such as from our group companies, from fraud prevention tools in the case of fraud or suspected fraud, from analytics companies in the case of in car wifi data usage and in the case of telematics data (including crash/impact detection, GPS location data, vehicle usage/driving style data and odometer readings), from third party data validation tools such as Experian and from publicly accessible data such as Companies House, the Land Registry, the Electoral Register and information you post online.
If you would like details of the information we used to create your profile, please contact email@example.com. You can request a manual review of our automated processes or object to profiling, including profiling for marketing purposes by contacting firstname.lastname@example.org.
We use Google Analytics, which is a web analytics tool that helps us understand how users engage with our Websites. Like many services, Google Analytics uses first-party cookies to track user interactions, as in our case, where they are used to collect information about how users use our site. This information is used to compile reports and to help us improve our Website. The reports disclose website trends without identifying individual visitors. You can opt out of Google Analytics without affecting how you visit our site - for more information on opting out of being tracked by Google Analytics across all websites you use, visit this Google page: tools.google.com/dlpage/gaoptout.
We do not sell, rent or lease your personal information to others except as described in this Privacy Notice. We share your information with selected recipients. These categories of recipients include:
We will share your information with law enforcement agencies, public authorities or other organisations if legally required to do so, or if we have a good faith belief that such use is reasonably necessary to:
We will also disclose your information to third parties:
The information that we collect from you will be transferred to, and stored at/processed outside of the EEA in the USA, Hong Kong and any other territory where you request that we provide services as set out at www.addisonlee.com/services/global. Your personal data is also processed by staff operating outside the EEA who work for us or for one of our suppliers or partner drivers. Such staff are engaged in, among other things, the fulfilment of your booking, the processing of your payment details and the provision of support services. We will take all steps reasonably necessary to ensure that your personal data is treated securely and in accordance with this policy.
We export your personal data outside of the EEA to whitelisted countries (considered to provide an adequate level of protection for personal data by the European Commission). We will also export your personal data if required by a contract with you (in which case your personal data will be sent to the country where you request that services are provided in order to fulfil your booking). Otherwise, we make sure that the personal data that we collect from you will be transferred to, and stored at/processed outside of the EEA, under the Commission's model contracts for the transfer of personal data to third countries (i.e., the standard contractual clauses), pursuant to Decision 2001/497/EC, 2004/915/EC, and/or 2010/87/EU. Please contact email@example.com, if you would like to see a copy of the Model Clauses.
Unfortunately, the transmission of information via the internet or email is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your information transmitted through the Websites, Apps, over email or via our contact centres; any transmission is at your own risk. Once we have received your information, we will take appropriate technical and organisational measures to safeguard your personal data against loss, theft and unauthorised use, access or modification.
We will, from time to time, host links to and from the websites of our affiliates or third parties. If you follow a link to any of these websites, these websites will have their own privacy policies and we do not accept any responsibility or liability for these policies. Please check these policies before you submit any information to those websites.
To determine the retention period of your personal data, we consider several criteria to make sure that we do not keep your personal data for long than is necessary or appropriate. These criteria include:
We will retain your information as follows:
After you have terminated your use of our services, we will store your information in an aggregated and anonymised format.
You have rights in relation to the personal data we hold about you. Some of these only apply in certain circumstances. We have described these situations below, as well as how you can exercise your rights. To exercise any of your rights, please contact us at firstname.lastname@example.org
In addition, you have the right to complain to the Information Commissioner's Office or other applicable data protection supervisory authority.
Please note that these rights are limited, for example, where fulfilling your request would adversely affect other individuals or company trade secrets or intellectual property, where there are overriding public interest reasons or where we are required by law to retain your personal data.
At any time you have the right to object to our processing of data about you in order to send you marketing communications, including where we build profiles for such purposes, and we will stop processing the data for that purpose. You can change your marketing preferences at any time using the preference centre within your account which can be reached via www.addisonlee.com or via our UK App.
In the event that you wish to make a complaint about how we process your personal data, please contact us in the first instance at email@example.com and we will endeavour to deal with your request as soon as possible. This is without prejudice to your right to launch a claim with the Information Commissioner's Office or the data protection supervisory authority in the EU country in which you live or work where you think we have infringed data protection laws.
Any changes we will make to this policy in the future will be posted on this page. Please check back frequently to see any updates or changes to this policy.
Questions, comments and requests regarding this policy are welcomed and should be addressed to firstname.lastname@example.org. You can also write to our Data Protection Officer at Addison Lee Limited, 35-37 William Road, London, NW1 3ER, email@example.com or by telephoning +44 203 910 3470.