Privacy policy
Privacy Notice
Introduction
Welcome to the Otto Car Limited’s (“Otto Car”/ “We”/ “Us”/ “our”) privacy policy. We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are and how and why we collect, store, use and share your personal data. It also explains your rights in relation to your personal data and how to contact us or supervisory authorities in the event you have a complaint. We collect, use and are responsible for certain personal data about you. When we do so we are subject to the UK General Data Protection Regulation (UK GDPR). We are also subject to the EU General Data Protection Regulation (EU GDPR) in relation to goods and services we offer to individuals and our wider operations in the European Economic Area (EEA). You can also view our Cookie Policy. Please note that this privacy policy is subject to change (see the section ‘Changes to this privacy policy’ below, so please be aware the PDF version you download today may be updated periodically.Important information and who we are
Purpose of this privacy policy This privacy policy aims to give you information on how Otto Car collects and processes your personal data. This privacy policy applies to personal data processing activities we conduct across our business, including personal data:- Which is collected through your use of this website, including any data you may provide through this website when you download any information or documents we offer, purchase a product or service or use this website to apply to become a Hirer or to manage any part of your account with us and/ or communicate with us as a Hirer.
- Any personal data that you provide to us through other means, such as by telephone, by text or in writing and / or which we collect or receive about you in any way, whether through this website or otherwise.
- Any personal data which may be collected by us through use of in-vehicle technologies, as described below.
Controller
Otto Car Limited is the controller and responsible for your personal data (referred to as “Otto Car”, "we", "us" or "our" in this privacy policy). We have appointed a data privacy manager 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, please contact the data privacy manager using the details set out below. This privacy policy does not apply where Otto Car is acting as a processor of personal data (i.e., where we are processing personal data on behalf of another company or entity on the basis of their instructions – for example, any drivers who may have installed CCTV in-vehicle or any third party apps you may use to order private-hire vehicles or to book ride-shares). In this case, you should contact the relevant controller and ask to inspect their privacy policy. Otto Car is not responsible for the privacy policies of third parties.Contact details
If you have any questions about this privacy policy or our privacy practices, please contact our data privacy manager in the following ways: You can contact our data privacy manager by post, email or telephone if you have any questions about this privacy policy or the information we hold about you, to exercise a right under data protection law or to make a complaint. Our contact details are shown below:| Data Privacy Manager: |
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| Contact: Gurinder Dhillon info@ottocar.co.uk Tel: 020 8740 7444 Postal Address: 3 Sussex Place Hammersmith London W3 9EA |
Third-party links
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.The data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). The personal data we collect about you depends on our relationship with us and the services which we are providing you. We will collect and use the following personal data about you:- Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
- Contact Data includes billing address, delivery address, email address and telephone numbers.
- Business Data includes details about your professional activities and registrations, permits, licenses and authorisations and your self-employed status or details of your company.
- Financial Data includes bank account and payment card details and information provided by credit reference agencies.
- Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
- Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
- Telematics Data may include information about vehicle location and GPS, routes taken, monitoring of fuel consumption, driving behaviour, and speed travelled, which is only subject to this privacy policy to the extent that it is personal data.
- Licensing Authority Data may include information from DVLA or TFL in respect of driving licence information and history, registrations, authorisations, licences and permits and information related to the same, passing via congestion charge zones, etc, which is only subject to this privacy policy to the extent that it is personal data.
- Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
- Video Data includes video footage recorded of your movements, person, image and likeness as a passenger or Hirer or driver (or as a road user or pedestrian where you are in-view) via the in-vehicle recording systems supplied by Otto Car which are utilised to monitor and ensure high driving standards and general passenger and public safety.
- Usage Data includes information about how you use our website, products and services.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
- we have your explicit consent;
- the processing is necessary to protect your (or someone else’s) vital interests where you are physically or legally incapable of giving consent; or
- the processing is necessary to establish, exercise or defend legal claims.
How is your personal data collected?
We use different methods to collect data from and about you depending on our relationship with you. We typically collect data in the following ways:- Direct interactions You may give us your Identity, Contact and Financial Data (and if you are a Hirer, Licensing Authority Data) by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- apply for our products or services;
- apply to become a Hirer
- create an account on our website;
- subscribe to our service or publications;
- request marketing to be sent to you;
- enter a competition, promotion or survey; or
- give us feedback or contact us.
- Indirect interactions. We may collect Video Data to the extent that you are a Hirer, driver or passenger in a vehicle in which Otto Car is controller of any video footage which is filmed or recorded in-vehicle or where you may be a road user or pedestrian and you are picked up by the recording device in the limited vicinity of the vehicle. We always ensure that such Video Data is obtained in a lawful manner and in accordance with the Transport for London Guidelines for CCTV Systems in Licensed London Taxis and Private Hire Vehicles and the Joint Surveillance Camera Commissioner /ICO guidance on Data protection impact assessments for surveillance camera systems which includes limitations on when recordings take place and ensuring no sound recordings (such as conversations) are included in such Video Data. If you are a Hirer we may also obtain Licensing Data from the relevant authorities directly, including via APIs with these authorities which link up to our systems.
- Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. If you are a Hirer, we may also obtain Telematics Data from the in-vehicle technologies included in your vehicle and/or as subscribed to by you or via APIs from Government or local authorities which are plugged into our systems. We collect this personal data by using cookies, server logs and other similar technologies as well as from any black-box/CCTV technologies placed in-vehicle. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy for further details.
How we use your personal data
. We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:- Where we need to perform the contract we are about to enter into or have entered into with you.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal obligation.
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 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. Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.| What we use your personal data for | Type of Data | Our reasons |
| To register you as a new customer |
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Performance of a contract with you |
To process and deliver your order including:
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To manage our relationship with you which will include:
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| To enable you to partake in a prize draw, competition or complete a survey |
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| To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data |
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| To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you |
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On the basis of your consent |
| To use data analytics to improve our website, products/services, marketing, customer relationships and experiences |
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On the basis of your consent and of you are a driver or Hirer - Necessary for the performance of a contract and necessary for the purposes of the legitimate interests pursued by Otto Car (i.e., to ensure that vehicles are being driven in a safe and compliant manner). |
| To make suggestions and recommendations to you about goods or services that may be of interest to you and to send marketing to you |
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Necessary for our legitimate interests (to promote our business to existing and former customers) or on the basis of your consent where you are a new contact |
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Marketing
We will use your personal data to send you updates about our products and services, including exclusive offers, promotions or new products and services. Where we have a legitimate interest in using your personal data for marketing purposes (see above ‘How and why we use your personal data’), we do not usually need your consent to send you marketing information. If consent is needed, we will ask for this separately and clearly.Promotional offers from us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing). You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving that marketing.Third-party marketing
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.Opting out
You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service application and or purchase, warranty registration, product/service experience or other transactions.Cookies
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy.Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.Disclosures of your personal data
We may share your personal data with the parties set out below for the purposes set out in the table ‘Purposes for which we will use your personal data above’:- Members of the Otto Car Group or other associated or affiliated companies or shareholders and directors.
- Specific third parties such as insurers, claims handlers and assessors, the Police (where a valid and legally enforceable request has been made), owners of any Charging Station that you may use from time to time and any police, parking, licensing and/ or other authority that is relevant to the any Vehicle which you hire or have hired from us.
- Contractors, subcontractors, suppliers and vendors who we engage to help us run our business.
- Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.
- our and their external auditors, eg in relation to the audit of our or their accounts, in which case the recipient of the information will be bound by confidentiality obligations;
- our and their professional advisors (such as lawyers and other advisors), in which case the recipient of the information will be bound by confidentiality obligations;
- law enforcement agencies, courts, tribunals and regulatory bodies to comply with our legal and regulatory obligations;
- other parties that have or may acquire control or ownership of our business (and our or their professional advisers) in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency—usually, information will be anonymised but this may not always be possible. The recipient of any of your personal data will be bound by confidentiality obligations.
Where your personal data is held
Personal data may be held at our offices and those of our group companies, third party agencies, service providers, representatives and agents as described above (see above: ‘Who we share your personal data with’).International transfers
We may transfer your personal data outside the United Kingdom (UK) and European Economic Area (EEA). Where do so, we will do so on the basis of an adequacy regulation or decision or (where this is not available, in accordance legally-approved standard data protection clauses recognised or issued by either the UK Government further to Article 46(2) of the UK GDPR or the European Commission issued further to Article 46(2) of the EU GDPR, as applicable. In the event we cannot or choose not to continue to rely on either of those mechanisms at any time, we will not transfer your personal data outside the UK/EEA unless we can do so on the basis of an alternative mechanism or exception provided by UK/EEA data protection law and reflected in an update to this policy. If you would like further information about data transferred outside the UK/EEA, please contact (see ‘How to contact us’ above).Data security
We have 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. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.Data retention
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. Following the end of the of the relevant retention period, we will delete or anonymise your personal data. In some circumstances you can ask us to delete your data: see your legal rights 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.Your legal rights
If you are usually resident in the UK or EEA, you have the following rights:| Access | The right to be provided with a copy of your personal data |
| Rectification | The right to require us to correct any mistakes in your personal data |
| Erasure (also known as the right to be forgotten) | The right to require us to delete your personal data—in certain situations |
| Restriction of processing | The right to require us to restrict processing of your personal data in certain circumstances, eg if you contest the accuracy of the data |
| Data portability | The right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations |
| To object | The right to object: —at any time to your personal data being processed for direct marketing (including profiling); —in certain other situations to our continued processing of your personal data, eg processing carried out for the purpose of our legitimate interests unless there are compelling legitimate grounds for the processing to continue or the processing is required for the establishment, exercise or defence of legal claims |
| Not to be subject to automated individual decision making | The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you |
| The right to withdraw consents | If you have provided us with a consent to use your personal data you have a right to withdraw that consent easily at any time You may withdraw consents by [insert details as relevant depending on consents] Withdrawing a consent will not affect the lawfulness of our use of your personal data in reliance on that consent before it was withdrawn |
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.How to complain
Please contact us if you have any queries or concerns about our use of your personal data (see above ‘How to contact us’). We hope we will be able to resolve any issues you may have. You also have the right to lodge a complaint with:- the Information Commissioner if you are usually resident in the UK
- a relevant data protection supervisory authority in the EEA state of your habitual residence, place of work or of an alleged infringement of data protection laws in the EEA for processing activities which take place in the EEA. A list of the relevant authorities is accessible here - https://edpb.europa.eu/about-edpb/about-edpb/members_en.
Terms
Terms of Supply
Last updated: 6th December 2019.Introduction
These are the terms and conditions of supply for https://ottocar.co.uk (Site), which is operated by Otto Car Limited trading as Otto Car (we, us and our). We are a limited company, registered in England. Our registered company number is 08479726, and our registered office is at 3 Sussex Place, Hammersmith, London, England, W6 9EA. Our VAT registration number is GB 190779859. The packages offered on any of the vehicles offered on this Site (Packages) is subject to these terms and conditions and by placing an order for any Package you agree to be bound by them. You confirm that you have the legal capacity to enter into a contract (Contract) and to subsequently place an order on the Site or in person at one of our sales offices. You should print a copy of these terms and conditions for future reference. In addition to these terms and conditions, the following additional terms also apply to your use of the Site and its associated features:- our Website Terms of Use which govern use of the Site itself;
- our Privacy Policy and our Cookie Policy which govern use of your personal information submitted to or via the Site;
- our Acceptable Use Policy which govern your use of the Otto Car website;
- the terms listed in your physical Contract when you pick up your vehicle, and
Use
You will primarily use the vehicle as a private hire vehicle. You shall pay fines, charges or fees relating to the vehicle and carry all liability for such offences. You will adhere to the mileage cap otherwise will promptly pay the excess mileage fees. Failure to do so will allow us to immediately cancel the contract and require the return of the Vehicle within 48 hours.Prices
The weekly cost of Packages are as quoted on the Site from time to time. We reserve the right to change prices of Packages without notice. We will not enforce any pricing changes on existing Contracts, and the price on your Contract will always remain the same unless your Contract is amended in any way. Packages can have different features (such as Contract length) and additions (such as insurance, and breakdown cover) and are subject to change.Payment
We only accept Visa and MasterCard debit and credit cards. We do not accept American Express, online payment methods like PayPal, or other payment methods unless clearly stated on the website. We take payments on a weekly basis every and will charge your card.Fees & Charges
You are responsible for punctually paying for charges and fees that you incur during your Contract period. This includes any charges from authorities such as penalty charge notices (PCNs) as congestion charges; as well as administrative fees incurred by ourselves. You may be charged an administrative fee in several cases, including but not limited to:- you incur any penalty charge notices, which we have to transfer the liability of from ourselves to you.
- you miss your weekly payments and do not settle your missed payment within 24 hours.
- you enter the congestion charge zone in London or cross the Dartford Bridge.
- you drive more than the 40,000 miles/year (or approx. 800 miles/week) mileage cap.