Privacy Policy

1. Who we are and what this policy covers

Jocks Cabs is a taxi business based in Northern Ireland. For the purposes of this policy, references to “Jocks Cabs”, “we”, “us” or “our” mean the Jocks Cabs business. The data controller and privacy contact details are set out in section 19.

This policy applies to personal data processed in connection with:

• the Jocks Cabs passenger mobile application (the “App”);
• any Jocks Cabs web booking service or website used to make or manage a booking;
• taxi bookings made by telephone, SMS, email or other communication with us; and
• journeys, customer support, complaints, marketing and other communications connected with those services.

Where another licensed taxi operator fulfils a booking through the iCabbi network, that operator may become a separate controller of the passenger information it receives. Section 9 explains this in more detail.

2. Personal data we collect

The information we collect depends on how you use our services and which features are enabled. It may include the following categories.

Account and contact information

Your name, mobile number, email address, username or account identifier, saved addresses and other information you choose to add to your account.

Booking and journey information

Collection point, destination, date and time, via points, booking notes, vehicle requirements, fare or estimate, driver and vehicle allocated, journey status, cancellation/no-show information, tips, ratings/reviews, trip history, flight details for airport bookings, and information connected with collect-and-deliver or bookings made for another person.

Location information

Your device location where you allow the App to access it, including precise location where required for a location-enabled feature such as choosing a pickup point, Passenger Live Location, driver tracking or a trip-sharing feature.

Payment and transaction information

Payment method, payment status, fare charged, refunds, transaction identifiers and other payment information made available to us by the relevant payment service provider. Card or wallet information may be collected directly by the payment service provider rather than by Jocks Cabs.

Device and technical information

Device type, operating system, app version, language/locale, IP address, device or app identifiers, crash information, security logs and similar technical data.

App and service usage information

How you use the App or web booking service, screens/features used, booking activity, notification interactions, promo-code use, campaign or conversion information where enabled, and service diagnostics.

Communications and customer service information

Emails, SMS, push/in-app messages, driver-passenger chat, call or booking notes, enquiries, feedback, ratings, complaints and records of how we responded.

Marketing information

Your marketing preferences, consent or opt-out status, the channel used to contact you, promo-code activity and, where enabled and lawfully permitted, engagement, attribution or conversion information connected with Jocks Cabs promotions.

Accessibility or other sensitive information you choose to provide

For example, information needed to request an accessible vehicle or assistance. Some information may reveal health or disability information and can therefore be special category personal data.

Passenger status, safety and fraud information

No-show/cancellation history, complaints, suspected fraud or misuse, safety incidents, account restrictions, and internal passenger status or “traffic light” information used to manage service, safety and booking access.

Information about other people you ask us to serve or contact

Where you book for another passenger, arrange a collection/delivery, use a business account, or use a trip-sharing feature, you may provide another person’s name, contact details, collection/delivery information or other details needed for the service.

3. How we obtain your information

• Directly from you when you register, make or change a booking, contact us, provide feedback, enter a promotion or choose marketing preferences.
• Automatically from the App, website, device or booking system when you use the service, subject to device permissions and any consent required by law.
• From drivers and our dispatch team in connection with your booking or journey.
• From iCabbi and other service providers that support the App, dispatch, communications, payments or security.
• From another licensed taxi operator where a booking is transferred or received through an authorised booking/networking arrangement.
• If you provide personal data about another person – for example when booking for someone else, arranging a collection or delivery, or sharing a trip – you should only provide information that you are entitled to provide and that is reasonably necessary for the service.

4. How and why we use your personal data

UK data protection law requires us to have a lawful basis for each use of personal data. The main purposes and lawful bases we rely on are set out below.

Legitimate interests. Where we rely on legitimate interests, we consider whether our interests are necessary and balanced against your rights and interests. You can object to processing based on legitimate interests in the circumstances described in section 14.

5. Location information and app permissions

If you allow the App to access your device location, we may use that information to identify or suggest a collection point, support location-based booking features and assist with your pickup. Depending on the feature enabled and the permission you grant, this may involve precise location information.

Where iCabbi Passenger Live Location is enabled, the App may share your current location with the driver allocated to your booking so the driver can find you more accurately. Driver-tracking features may also show you the driver/vehicle location and journey progress. Location permissions can be changed in your device settings. If location access is refused, you may still be able to enter a collection address manually, although some location-enabled features may not work.

If you choose to use a Share Trip or similar feature, the App may create a live journey/tracking link that you can send to a person you choose. That recipient may be able to see information such as the vehicle or journey status and live or recent journey location for the duration of the shared trip. You control who receives the link and should only share it with people you trust.

The App may also request permission for notifications and other device functions that are needed for features you choose to use. Your device settings control these permissions.

6. Payments

Where you choose to pay by card, Apple Pay, Google Pay, Pair & Pay or another electronic payment method, payment information may be collected and processed by the payment provider made available through the App or booking service. We receive the information we need to confirm, record, reconcile or refund the transaction, such as the payment method, payment status, fare, tip, amount and transaction reference.

Payment providers process information under their own terms and privacy information where they act as separate controllers. Where they process information on our behalf, they are required to protect it in accordance with applicable data protection law and our contractual arrangements.

7. Marketing and promotions

We may use your personal data to send you marketing about Jocks Cabs services, special offers, promotions, discount codes, service launches or similar products and services. Marketing may be sent by email, SMS, in-app message or push notification, depending on the contact details and permissions you have provided.

For electronic marketing to individuals, we will only send messages where the Privacy and Electronic Communications Regulations 2003 (PECR), as amended, allow us to do so. This will normally be because:

• you have given us valid consent for the relevant type of marketing; or
• the “soft opt-in” applies because we obtained your contact details directly while selling or negotiating to sell our services, the marketing is for our own similar services, and you were given a clear opportunity to opt out when we collected the details and in every subsequent marketing message.

You can stop Jocks Cabs marketing at any time by using the unsubscribe or opt-out option in the message, changing any marketing preference available in the App, or contacting our Privacy Compliance Manager using the details in section 19. Stopping marketing will not stop service messages that are necessary for a booking, account, payment, safety issue or important change to our service.

We keep a minimal suppression record where necessary so that we can respect a marketing opt-out and avoid contacting you again by that channel unless you later choose to opt back in.

Where marketing conversion or campaign analytics are enabled, we may use limited app, device, campaign and booking-sign-up information to understand whether Jocks Cabs advertising resulted in an app registration or booking. Where this involves non-essential tracking, device storage/access or similar technology for which consent is required, it will only be used after the required consent has been obtained.

8. Accessibility and special category information

You may choose to tell us about an accessibility requirement or other information needed to arrange a suitable journey. Where that information reveals health or disability information, it may be special category personal data under the UK GDPR.

We will only use such information where it is necessary to deal with your booking or request and where an additional condition for processing special category data applies. Where explicit consent is the appropriate condition, we will rely on the information you have deliberately provided for that purpose and, where required, obtain an explicit indication of consent. You may withdraw consent, although this will not affect processing that was lawful before withdrawal and may affect our ability to meet the relevant accessibility request.

9. Who we share personal data with

We share personal data only where reasonably necessary for the purposes described in this policy, or where we are required or permitted to do so by law. Recipients may include:

• Drivers allocated to your booking, who receive the booking information needed to locate, contact and transport you. This may include your name or passenger identifier, collection point, destination, booking notes and, where enabled, Passenger Live Location.
• iCabbi service providers, including Coolnagour Limited trading as iCabbi and, where applicable, relevant iCabbi group/service entities such as Taxi Alliance Software Limited, which provide booking, dispatch, passenger-app, communications, hosting and support services.
• Payment service providers and financial institutions used to authorise, process, reconcile or refund payments.
• Communications, cloud, hosting, security, analytics and IT support providers used to operate and protect the service.
• Insurers, accountants, solicitors and other professional advisers where reasonably necessary.
• The Department for Infrastructure, Driver & Vehicle Agency, police, courts, tax authorities, regulators or other public bodies where disclosure is required or permitted by law.
• Another licensed taxi operator or network participant where a booking is subcontracted, diverted, received, sent or made through an authorised iCabbi networking, roaming or cross-border arrangement.
• A person you choose to share a trip with, where you actively use a Share Trip or similar feature. We only make the shared-trip information available through the link or mechanism you choose to send.
• A business or corporate account holder/administrator, where your journey is booked on or charged to that account, who may receive or access the booking, receipt, fare and journey information needed to administer that account.

iCabbi networking, roaming and cross-border bookings

Jocks Cabs may use iCabbi Passenger Experience/App Networking, Dispatch Networking, Phone Call Networking, App Roaming and The Exchange. These features can allow a passenger to use the Jocks Cabs App outside our normal service area and can allow Jocks Cabs to send bookings to, or receive bookings from, participating taxi operators. This may include operators in Northern Ireland, Great Britain, the Republic of Ireland, elsewhere in the European Economic Area, or another country where the iCabbi network is available.

Where another operator needs to receive or fulfil a booking, we may share the information reasonably necessary to provide and administer that journey. Depending on the booking and enabled features, this may include your name or passenger identifier, contact details, collection point, destination, booking time, Passenger Live Location where operationally available, vehicle/accessibility requirements, booking notes, fare or payment status, business-account information, flight information, driver-passenger communications needed for the journey, and other essential booking data.

The App should, where the feature supports it, identify when a journey is being serviced by another network operator. The receiving taxi operator will normally determine how it uses the passenger information needed to fulfil the journey and may therefore act as a separate controller under its own privacy policy and local law. Where any passenger authorisation or consent is required for a networking feature, we will obtain it in the manner required by applicable law and the relevant service arrangement.

A journey may also physically cross the border between Northern Ireland and the Republic of Ireland. If Jocks Cabs itself accepts and fulfils the journey, the fact that the vehicle crosses the border does not by itself mean that we have disclosed your personal data to a separate organisation abroad. If the booking is instead transferred to, received from or fulfilled by a separate operator in the Republic of Ireland or another country, the relevant booking information may be disclosed to that operator as described above.

Where you use the Jocks Cabs App while in the Republic of Ireland or elsewhere outside the UK, Jocks Cabs may continue to process account, app and booking information in connection with your use of our branded App, while the local network operator processes the information it needs to provide the local taxi service. Different data-protection laws may apply to the receiving operator.

10. International transfers

Because all networking and roaming features may be enabled, personal data may be made available outside the United Kingdom when a booking is sent to or fulfilled by a network operator abroad, or when a technology/service provider processes information outside the UK. This can include the Republic of Ireland and other countries in the European Economic Area, as well as other countries in which iCabbi network participants or relevant service providers operate.

Transfers from the UK to the Republic of Ireland and other EEA countries are currently covered by UK adequacy regulations. For transfers to a country or recipient not covered by UK adequacy regulations, we will use an appropriate lawful transfer mechanism where required, such as the UK International Data Transfer Agreement (IDTA), the UK Addendum to approved EU Standard Contractual Clauses, another approved safeguard, or a valid statutory exception where the law permits it. Where personal data is sent from the EEA to the UK, the UK is currently recognised as adequate by the European Commission. You can contact our Privacy Compliance Manager using the details in section 19 for more information about the transfer safeguards relevant to your data.

If EU GDPR applies to particular processing because Jocks Cabs is offering services to, or monitoring individuals in, the EEA, we will also comply with the applicable EU GDPR requirements. Where EU law requires us to appoint an EEA representative, the representative’s contact details will be made available in this policy or through the App/website.

11. How long we keep personal data

We do not use one retention period for every type of personal data. Our standard retention period for the core booking/journey record is six years from completion or cancellation of the journey. We use a shorter period for information that is more intrusive or is no longer needed for that purpose, such as standalone live-location data, and a longer period only where a specific legal, tax, insurance, regulatory or active-claim reason requires it. We periodically review retention and delete or anonymise information when it is no longer needed.

Core taxi booking and journey records

Normally 6 years from completion or cancellation of the journey. Current Northern Ireland taxi-operator guidance requires booking records to be kept for at least 12 months from the date the booking was accepted; Jocks Cabs keeps the core booking/journey record for longer as a standard business retention period so that we can deal with customer queries and disputes, investigate fraud or misuse, reconcile records, and establish, exercise or defend legal claims. We may retain a particular record beyond 6 years where a complaint, incident, insurance matter, regulatory investigation or legal claim is still active.

Account/profile information

For as long as your passenger account remains active. After closure or prolonged inactivity, profile/preferences that are no longer needed are deleted or anonymised, but limited account/contact information linked to a retained booking may remain with that booking for the applicable booking-record retention period.

Financial and tax records

For the period required by tax and accounting law. Business records relevant to Self Assessment generally need to be kept for at least five years after the 31 January submission deadline for the relevant tax year, and longer in some circumstances.

Complaint records

Normally 6 years after the complaint or incident is closed where the record may reasonably be needed for accountability, insurance, regulatory matters or legal claims. Current Northern Ireland taxi-operator guidance requires complaint records to be kept for at least 12 months from the date of entry. A record may be kept longer while a claim, investigation or legal obligation remains active.

Marketing records

While we are entitled to send the relevant marketing and until you opt out. A minimal suppression record may be kept for as long as needed to ensure we continue to respect your opt-out.

Technical, security and diagnostic logs

For the shortest period reasonably necessary for security, fraud prevention, troubleshooting and service operation, normally no longer than 24 months unless a longer period is necessary for a specific security incident, investigation or legal claim, or a provider applies a shorter retention setting.

Accessibility/special category information

Only for as long as necessary to provide the booking or saved accessibility preference for which it was supplied. It is not retained for six years merely because a booking record is retained, unless the information is necessary for an ongoing complaint, incident or legal claim and we have a lawful basis and special-category condition to keep it.

Passenger Live Location and detailed location telemetry

Used for the operational period needed to provide pickup, tracking and journey features and not intentionally kept as a six-year standalone location history. It may be retained for longer only where it forms part of a specific safety incident, complaint, fraud investigation or legal claim, or where a technology provider must temporarily retain it for security/technical purposes under an applicable retention setting.

Chat, ratings, reviews and routine customer-service communications

Normally up to 2 years after the relevant interaction or journey, unless the information forms part of a complaint, incident, fraud matter or legal claim, in which case the longer complaint/claim retention period may apply.

Passenger status, fraud/safety flags and booking restrictions

Kept while reasonably necessary to protect passengers, drivers, staff and the service, and reviewed periodically. Historic supporting records are deleted or anonymised when no longer needed, subject to any active incident, complaint, regulatory or legal-claim requirement.

12. Deleting your passenger account

You can initiate deletion of your Jocks Cabs passenger account from within the App using the account deletion option provided in the account or settings area. If you need help with account deletion or a data protection request, contact our Privacy Compliance Manager using the details in section 19.

When your passenger account is deleted, we will delete or anonymise personal data that is associated solely with the account and is no longer required. Account deletion does not require us to erase information that we are legally required or otherwise lawfully entitled to retain. This can include taxi booking and journey records, transaction and tax records, fraud or safety records, suppression records used to respect marketing opt-outs, and information needed for an ongoing complaint, insurance matter, investigation or legal claim. The retention periods in section 11 continue to apply to such information.

13. Keeping your information secure

We use appropriate technical and organisational measures designed to protect personal data against unauthorised access, loss, misuse, alteration or disclosure. Access to passenger information is limited to people and service providers who need it for legitimate business purposes, and our processors are required to protect information in accordance with their contractual and legal obligations. Where we disclose personal data to service providers or other third parties that process it on our behalf, we require them to provide the same or an equivalent level of protection for that personal data as described in this Privacy Policy and as required by applicable law.

No internet, mobile or information system can be guaranteed to be completely secure. You are responsible for keeping your App credentials and device secure and should not share passwords, authentication codes or account access with anyone who is not authorised to use your account.

14. Your data protection rights

Depending on the circumstances and the lawful basis we rely on, you may have the following rights under UK data protection law:

Access — Ask whether we process your personal data and request a copy of it.

Rectification — Ask us to correct inaccurate or incomplete personal data.

Erasure — Ask us to delete personal data where the legal conditions for erasure are met.

Restriction — Ask us to restrict how we use personal data in certain circumstances.

Data portability — Receive certain personal data you provided to us in a structured, commonly used, machine-readable format, or ask us to transmit it to another controller where the right applies.

Object to legitimate-interests processing — Object to processing based on our legitimate interests. We will stop unless we can demonstrate compelling legitimate grounds that override your interests, rights and freedoms, or the processing is needed for legal claims.

Object to direct marketing — Object at any time to the use of your personal data for direct marketing. If you object, we will stop using your personal data for that marketing.

Withdraw consent — Where we rely on consent, withdraw it at any time. Withdrawal does not affect the lawfulness of processing carried out before consent was withdrawn.

Automated decision-making rights — Where applicable, rights relating to decisions based solely on automated processing that produce legal effects or similarly significantly affect you.

You can exercise these rights by contacting our Privacy Compliance Manager using the details in section 19. We may need to verify your identity before acting on a request. Data protection requests are normally free of charge, although the law permits a reasonable fee or refusal in limited circumstances, for example where a request is manifestly unfounded or excessive.

15. Complaints

If you have a concern about how we use your personal data, please contact our Privacy Compliance Manager using the details in section 19 first so that we can try to resolve it. You also have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection.

ICO website: ico.org.uk

Where the EU GDPR applies to particular processing connected with a booking in the European Economic Area, you may also have the right to complain to the competent EEA supervisory authority. In the Republic of Ireland, this is the Data Protection Commission (DPC): dataprotection.ie

16. Age of passenger accounts

The Jocks Cabs Passenger App is intended for registered account holders aged 18 or over, in line with the applicable passenger-app terms. An adult account holder may be able to make bookings for other people, including members of their household, where the terms of the service allow it. We do not knowingly allow a person under 18 to register their own passenger account.

If you believe that a person under 18 has registered an account or provided personal data directly to us contrary to the App terms, contact our Privacy Compliance Manager using the details in section 19.

17. App technologies, analytics and similar storage/access technologies

The App and web booking services may use software development kits (SDKs), local storage, cookies or similar technologies for essential functions such as authentication, security, payment, location, communications, driver/passenger tracking and service operation. Where enabled, we may also use analytics, diagnostic, advertising-attribution or conversion-measurement tools to understand performance and the effectiveness of Jocks Cabs marketing.

Where UK privacy rules require consent before using a non-essential storage/access technology or similar tracking feature, we will seek that consent before using it. You may also be able to control permissions through the App, browser or device settings.

18. Changes to this privacy policy

We may update this privacy policy when our services, suppliers, legal obligations or data-processing activities change. We will publish the updated policy through the App, website or another appropriate channel. Where a change is material, we will take reasonable steps to bring it to your attention before the new processing begins where required.