Privacy Policy

1. Introduction

Blackstone Executive Transfers is committed to protecting and respecting your privacy. We aim to handle personal information responsibly, transparently and in accordance with applicable UK data protection legislation, including the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

This Privacy Policy explains how we collect, use, store, share and protect personal information when you visit our website, contact us or use our services once they become available.

Blackstone Executive Transfers is currently preparing its private hire operator service for planned executive travel across Surrey, Sussex and London.

We are not currently taking or confirming private hire journey bookings.

At present, personal information may be collected when you submit a general enquiry, contact us or interact with our website.

The additional booking-related processing described in this policy will apply once our private hire operator service is licensed and active.

2. Who We Are

Blackstone Executive Transfers is preparing to provide pre-booked executive private hire services.

Our contact details are:

Blackstone Executive Transfers

Address: Hamilton House, 87–89 Bell Street, Reigate, Surrey, RH2 7AN

Email: info@blackstoneexecutivetransfers.co.uk

Telephone: +447377173456

Website: www.blackstoneexecutivetransfers.co.uk

Planned service areas: Surrey, Sussex and London.

Blackstone Executive Transfers is responsible for determining how and why personal information is processed for its business activities.

For the purposes of UK data protection legislation, the relevant legal business entity operating under the Blackstone Executive Transfers name is the data controller.

3. Information We Collect

The personal information we collect depends on how you interact with us and whether our private hire operator service is active.

3.1 General Enquiry Information

When you contact us through our website, telephone, email or WhatsApp, we may collect:

  • Your name.

  • Email address.

  • Telephone number.

  • Business name, where applicable.

  • Information included in your enquiry.

  • Communication records and relevant correspondence.

We use this information to respond to general enquiries and provide information about Blackstone Executive Transfers and its planned services.

Submitting a general enquiry does not constitute a private hire booking or booking confirmation.

3.2 Website and Technical Information

When you visit our website, certain technical information may be processed, depending on the website features and technologies in use.

This may include your IP address, browser type, device information, operating system, website interaction information and cookie preferences.

Details of cookies and similar technologies actually installed on our website are provided in our separate Cookie Policy.

3.3 Future Booking Information

Once our private hire operator service is licensed and active, we may collect additional information when a customer requests or confirms a journey.

This may include:

  • Booking or enquiry reference.

  • Booking request date and time.

  • Journey date and time.

  • Hirer and passenger names, where applicable.

  • Telephone number and email address.

  • Collection point and destination.

  • Additional stops and journey instructions.

  • Flight details, where relevant.

  • Passenger and luggage requirements.

  • Accessibility or assistance requirements, where necessary.

  • Agreed fares and applicable charges.

  • Payment and transaction information.

  • Booking amendments and cancellations.

  • Relevant communication records.

We will collect only the information reasonably necessary for arranging and administering the relevant journey and meeting applicable legal obligations.

Where information about a disability or health-related assistance requirement is needed, we will handle it in accordance with the additional protections applicable to special category personal data.

3.4 Driver and Vehicle Information

Once our operator service is licensed and active, we will maintain the driver and vehicle information necessary for our private hire operations.

This may include driver identification and contact details, licensing information, vehicle registration details, insurance information, vehicle licence details, and records of driver and vehicle availability.

These records will be used to manage compliant private hire operations and meet applicable licensing requirements.

4. How We Collect Personal Information

We may receive personal information directly from you when you submit a general enquiry, contact us by telephone, email or WhatsApp, communicate with our business or use our website.

Once the operator service is licensed and active, we may also collect information when you request a journey, make a confirmed booking, apply for a corporate account or report lost property or a complaint.

Where necessary, relevant information may also be received from authorised corporate account representatives, passengers, drivers or other parties involved in an arranged journey.

If we receive personal information from someone other than the individual concerned, we will provide appropriate privacy information in accordance with applicable data protection requirements.

5. How We Use Your Information and Our Legal Bases

We process personal information only where we have an appropriate lawful basis.

The following table explains the purposes and legal bases intended to apply to our business activities.

Processing activity

Purpose

Lawful basis

General enquiries

Responding to questions and providing company information

Legitimate interests or steps requested before entering a contract

Website administration

Maintaining website functionality, security and technical performance

Legitimate interests, where applicable

Future journey bookings

Arranging and administering confirmed private hire journeys

Performance of a contract

Statutory booking records

Maintaining records required under applicable private hire licensing conditions

Legal obligation

Payments and accounting

Processing payments and maintaining financial records

Contract and legal obligation

Complaints

Investigating complaints and maintaining appropriate records

Legitimate interests and legal obligation, as applicable

Lost property

Recording reports and arranging the return of property

Legitimate interests and applicable legal obligations

Driver and vehicle records

Managing licensed drivers, vehicles and relevant operating records

Contract and legal obligation, as applicable

Non-essential website technologies

Using analytics or similar technologies where consent is required

Consent

Marketing

Sending permitted promotional communications

Consent or another applicable lawful basis, subject to UK marketing rules

Where we rely on legitimate interests, our interests include responding to enquiries, administering our business, maintaining website security, handling complaints, managing lost property and keeping appropriate records.

We will consider the rights and interests of individuals before relying on this lawful basis.

Where required, additional conditions will be established before processing special category information, such as health-related accessibility requirements.

6. Current Enquiries and Future Bookings

Blackstone Executive Transfers is not currently accepting or confirming private hire journey bookings.

Information submitted through our existing website contact facilities is used to respond to general enquiries and provide relevant business information.

Contacting us does not reserve a vehicle, confirm a fare or create a private hire booking.

Once our operator service is licensed and active, we intend to process booking information for arranging, confirming and administering pre-booked private hire journeys.

PRIVATE HIRE – PRE-BOOKED JOURNEYS ONLY

All private hire journeys must be pre-booked through Blackstone Executive Transfers once the operator service is licensed and active. Drivers cannot accept street hails.

7. How We Store and Protect Your Information

We take reasonable technical and organisational measures to protect personal information against unauthorised access, loss, alteration, misuse and unlawful disclosure.

Access to personal information will be restricted to authorised individuals who need it for legitimate business purposes.

Personal information may be stored within our website, business email systems and other systems genuinely used to administer our business.

Once the operator service is active, additional arrangements may be introduced for booking administration, payment processing and statutory record keeping.

We will assess the security and data protection arrangements of relevant service providers before using them to process personal information.

No method of electronic transmission or storage is completely risk-free. However, we aim to maintain appropriate safeguards for the nature of the information we process.

8. How Long We Keep Your Information

We retain personal information only for as long as reasonably necessary for the purpose for which it was collected, unless a longer period is required by law or is necessary for an applicable legal claim.

Once our operator service is licensed and active, the following retention arrangements will apply.

Record type

Retention period

Statutory private hire booking records

12 months from the journey

Complaint records

At least 12 months

Lost and found property records

At least 12 months from the date reported

Driver and vehicle records

12 months after the driver or vehicle ceases to be available to the operator

General enquiries

Only as long as necessary for the enquiry and relevant legal or business purposes

Financial and accounting records

Applicable statutory retention periods

Marketing information

While a valid lawful basis and continuing business need exist

Website and cookie information

According to the actual technology used and its stated retention period

Where a longer retention period is required by law or is reasonably necessary in connection with a dispute, investigation or legal claim, the relevant records may be kept for that additional period.

Information that is no longer required will be securely deleted or anonymised, as appropriate.

9. Sharing Your Information

We do not sell your personal information.

We may share relevant information with authorised service providers, professional advisers or public authorities where necessary for legitimate business activities or legal compliance.

Depending on the systems and services actually used, recipients may include website hosting and maintenance providers, business communication providers, IT support services, accountants, legal advisers and regulatory or law enforcement authorities where legally required.

Once our operator service is licensed and active, information may also be shared with appropriately licensed drivers and relevant service providers to the extent necessary to arrange and complete an accepted journey.

Where an external provider processes personal information on our behalf, we will use appropriate contractual and security arrangements as required by applicable law.

We will not share more personal information than is reasonably necessary for the relevant purpose.

10. International Data Transfers

Some third-party communication, website or technology services may involve processing personal information outside the United Kingdom.

Where international transfers take place, we will assess the applicable data protection requirements and implement appropriate safeguards where required.

These may include reliance on applicable adequacy regulations, appropriate international data transfer agreements or other lawful transfer mechanisms.

Further information about relevant international transfers and applicable safeguards can be requested using our contact details.

11. Cookies and Similar Technologies

Our website may use cookies and similar technologies to support essential website functionality and, where implemented, additional features.

Strictly necessary technologies may be used where an applicable legal exemption permits their operation without prior consent.

Where consent is required, non-essential analytics, advertising or other tracking technologies will not be activated until valid consent has been obtained.

Visitors will be able to accept or reject non-essential cookies and review or change their preferences through the website’s cookie settings.

Our separate Cookie Policy provides details of the cookies and similar technologies actually installed on the website, including their purposes, providers and durations.

12. Marketing Communications

Where we carry out direct marketing, we will comply with applicable UK data protection and electronic marketing requirements.

We may send promotional information only where an appropriate lawful basis and any required marketing permission exist.

Submitting a general enquiry does not automatically constitute agreement to receive promotional communications.

You may unsubscribe from marketing communications or object to direct marketing at any time by using an available unsubscribe facility or contacting us directly.

You have the right to object to the processing of your personal information for direct marketing at any time.

13. Your Data Protection Rights

Under applicable UK data protection legislation, you may have the following rights, depending on the circumstances:

  • Right of access: Request a copy of the personal information we hold about you.

  • Right to rectification: Request correction of inaccurate or incomplete information.

  • Right to erasure: Request deletion of personal information in circumstances where the right applies.

  • Right to restriction: Request that we restrict the processing of your information in certain circumstances.

  • Right to object: Object to certain processing activities, including processing based on legitimate interests.

  • Right to data portability: Request certain personal information in a structured, commonly used and machine-readable format where applicable.

  • Right to withdraw consent: Withdraw consent at any time where we rely on consent as our lawful basis.

Withdrawing consent does not affect processing that was lawful before withdrawal.

Certain rights may be subject to legal exceptions, including circumstances where information must be retained to comply with a legal obligation.

To exercise your rights, please contact us using the details provided in this policy.

We may request reasonable information to verify your identity before responding.

14. Accessibility and Sensitive Information

Once our operator service is licensed and active, passengers may inform us about accessibility or assistance requirements relevant to a proposed journey.

We will only collect information reasonably necessary to assess or arrange suitable transport and provide appropriate assistance.

Where this includes health or disability information, we will apply the additional safeguards and lawful processing conditions required under UK data protection law.

Such information will not be used for unrelated purposes.

15. Children’s Personal Information

Our website is not specifically directed towards children.

However, once our operator service is licensed and active, journeys may be arranged for families travelling with children.

Where necessary, a parent, guardian or other authorised person may provide limited information about child passengers.

We will process this information only where an appropriate lawful basis exists and it is necessary for the relevant journey or another lawful purpose.

We will take particular care to protect children’s personal information.

16. Third-Party Websites and Communication Services

Our website may contain links to external websites, including WhatsApp and other relevant services.

Where you choose to access an external website or communication platform, the provider’s own privacy practices may apply.

We encourage visitors to review the privacy information provided by those external services.

Blackstone Executive Transfers is responsible for its own handling of personal information received through its business communication channels.

17. Complaints and Lost Property

Once our operator service is licensed and active, we will maintain procedures for recording and managing customer complaints and lost property.

Complaint records will contain relevant information, including complainant details, the nature of the complaint, relevant driver information and action taken.

Lost property records will include relevant details of reported or found items, storage arrangements, reasonable attempts to contact owners and return or disposal outcomes.

Complaint and lost property records will be retained in accordance with the periods described in Section 8 of this policy.

18. Automated Decision-Making

Blackstone Executive Transfers does not intend to use solely automated decision-making, including profiling, to make decisions that produce legal or similarly significant effects concerning customers.

If such processing is introduced in the future, we will update this Privacy Policy and provide any additional information required by law before implementing it.

19. Changes to This Privacy Policy

We may update this Privacy Policy to reflect changes to our website, business activities, operational systems or applicable legal requirements.

Any updated version will be published on our website with a revised last-updated date.

Where a change materially affects how personal information is processed, we will provide additional information or obtain consent where legally required.

20. Contact Us

If you have any questions about this Privacy Policy, wish to exercise your data protection rights or have concerns about the way we handle personal information, please contact:

Blackstone Executive Transfers

Hamilton House, 87–89 Bell Street Reigate, Surrey RH2 7AN United Kingdom

Email: info@blackstoneexecutivetransfers.co.uk

Telephone: +447377173456

Website: www.blackstoneexecutivetransfers.co.uk

21. Complaints to the Information Commissioner’s Office

If you are dissatisfied with how your personal information has been handled, you can contact us so that we have an opportunity to investigate your concerns.

You also have the right to raise a data protection complaint with the Information Commissioner’s Office (ICO), the UK’s independent data protection regulator.

Information Commissioner’s Office

Wycliffe House Water Lane Wilmslow Cheshire SK9 5AF

Telephone: 0303 123 1113

Website: www.ico.org.uk