Privacy Policy

1. Who We Are

UGOO SERVICES ("we", "us", "our") is the data controller responsible for your personal data. We are a licensed private hire vehicle operator based in Tonbridge, Kent.

• Company: UGOO SERVICES
• Address: 3 York Parade, Tonbridge, TN10 3NP
• Email: support@ugoo.co.uk
• Telephone: 01732 800 800
• Website: www.ugoo.co.uk

We are registered with the Information Commissioner's Office (ICO) as required under UK data protection law. If you have any questions about how we use your personal data, please contact us using the details above.

2. Scope of This Policy

This Privacy Policy explains how we collect, use, share, and protect personal data when you use our services, including our mobile app (iOS and Android), website (www.ugoo.co.uk), and telephone booking line. It applies to all customers, passengers, and visitors to our app and website.

This Policy should be read alongside our Terms and Conditions. By using our services, you acknowledge that you have read and understood this Privacy Policy.

3. Personal Data We Collect

3.1 Data You Provide to Us

• Identity and contact data: name, email address, phone number
• Account data: username, password (stored securely and never in plain text)
• Booking data: pickup and drop-off addresses, date and time of travel, passenger count, special requirements
• Payment data: payment method, billing address (we do not store full card numbers)
• Communications: messages, enquiries, complaints, or feedback you send us
• Corporate account data: company name, billing details, authorised bookers

3.2 Data We Collect Automatically

• Location data: real-time GPS location when you use our app, to provide and improve our service (only collected with your permission on your device)
• Device and usage data: IP address, browser type, device type, operating system, app version, pages visited, time spent
• Booking and journey records: routes taken, journey duration, fare paid
• Cookies and tracking technologies: see Section 9 below

3.3 Data We Receive From Third Parties

• Payment processors: confirmation of payment status
• App stores (Apple App Store / Google Play): app download and installation data
• Analytics providers: aggregated and anonymised usage statistics

4. How We Use Your Personal Data

We use your personal data for the following purposes, relying on the legal bases set out in the UK GDPR:

4.1 To Provide Our Services (Contract Performance)

• Processing and managing bookings
• Matching you with available drivers and vehicles
• Communicating with you about your bookings
• Processing payments and issuing receipts
• Operating your customer account

4.2 Legal Obligations

• Maintaining records required by our private hire vehicle licence
• Complying with tax and financial record-keeping requirements
• Responding to requests from licensing authorities or law enforcement
• Safeguarding children and vulnerable adults

4.3 Legitimate Interests

• Investigating complaints, fraud, or misuse of our services
• Improving and developing our app, website, and services
• Ensuring the safety and security of drivers, passengers, and staff
• Sending service-related updates and operational messages
• Conducting internal analytics and business planning

4.4 With Your Consent

• Sending marketing communications by email or SMS (you may withdraw consent at any time)
• Collecting location data via our mobile app
• Using cookies for personalisation and analytics (where required)

5. Sharing Your Personal Data

We do not sell your personal data. We may share your data with the following categories of recipients where necessary:

• Licensed drivers: your name, pickup location, and relevant booking details to facilitate your journey
• Subcontracted operators: where we use third-party licensed operators to fulfil a booking
• Payment processors: to process transactions securely
• IT and technology providers: hosting, app development, and platform support
• Analytics providers: to understand app and website usage (data is aggregated and anonymised where possible)
• Customer communications providers: for email, SMS, and push notification delivery
• Licensing authorities: where required to demonstrate compliance with private hire vehicle regulations
• Law enforcement or regulatory bodies: where required or permitted by law

All third parties we share data with are required to handle it in accordance with UK data protection law and are subject to appropriate data processing agreements.

6. International Data Transfers

We aim to keep your data within the UK and the European Economic Area (EEA). Where we use third-party providers that transfer data outside the UK or EEA, we ensure appropriate safeguards are in place, such as UK International Data Transfer Agreements (IDTAs), standard contractual clauses, or adequacy decisions made by the UK Government.

7. Data Retention

We retain your personal data only for as long as necessary to fulfil the purposes set out in this Policy, including any legal, regulatory, accounting, or reporting obligations.

When data is no longer required, we securely delete or anonymise it.

8. Your Data Protection Rights

Under UK GDPR and the Data Protection Act 2018, you have the following rights:

• Right of access: to request a copy of the personal data we hold about you
• Right to rectification: to request correction of inaccurate or incomplete data
• Right to erasure: to request deletion of your data in certain circumstances
• Right to restrict processing: to ask us to limit how we use your data
• Right to data portability: to receive your data in a structured, machine-readable format
• Right to object: to object to processing based on legitimate interests or for direct marketing
• Right to withdraw consent: where processing is based on consent, you may withdraw it at any time without affecting the lawfulness of prior processing

To exercise any of these rights, please contact us at support@ugoo.co.uk. We will respond within one calendar month. We may ask you to verify your identity before processing your request. There is no charge for most requests; however, we may charge a reasonable fee or refuse requests that are manifestly unfounded or excessive.

If you are not satisfied with how we handle your request or your data, you have the right to lodge a complaint with the Information Commissioner's Office (ICO):

• Website: www.ico.org.uk
• Telephone: 0303 123 1113

9. Cookies and Tracking Technologies

Our website and app use cookies and similar technologies to improve your experience, analyse usage, and support our services.

9.1 Types of Cookies We Use

• Essential cookies: required for the website and app to function correctly
• Functional cookies: remember your preferences and settings
• Analytics cookies: help us understand how visitors use our website and app
• Marketing cookies: used to deliver relevant communications (only where you have consented)

You can manage your cookie preferences through your browser settings or the cookie preference centre on our website. Disabling essential cookies may affect the functionality of our app or website.

10. Children and Young People

Our services are not directed at children under the age of 13. We do not knowingly collect personal data from children under 13 without verifiable parental or guardian consent.

Where our services involve transporting children (for example, school runs), we process only the minimum data necessary and in accordance with our safeguarding obligations under applicable UK law. Parents or guardians responsible for booking transport for children are responsible for the accuracy of the data provided.

11. Data Security

We take the security of your personal data seriously and have implemented appropriate technical and organisational measures to protect it against unauthorised access, loss, destruction, or alteration. These include:

• Encrypted data transmission (TLS/SSL)
• Secure storage of passwords using industry-standard hashing
• Access controls limiting data access to authorised staff and systems only
• Regular review of our security practices

No method of electronic transmission or storage is completely secure. In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, we will notify you and the ICO as required by law.

12. Third-Party Links

Our website or app may contain links to third-party websites or services. This Privacy Policy does not apply to those sites. We recommend that you read the privacy policies of any third-party websites you visit. We are not responsible for the privacy practices or content of third-party websites.

13. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, services, or applicable law. Updated versions will be published on our website and app with a revised effective date. Where changes are material, we will provide reasonable notice before they take effect.

14. Contact Us

For any questions about this Privacy Policy or your personal data, or to exercise your data rights, please contact us:

• Email: support@ugoo.co.uk
• Telephone: 01732 800 800
• Post: UGOO SERVICES, 3 York Parade, Tonbridge, TN10 3NP

You also have the right to complain to the Information Commissioner's Office (ICO) at www.ico.org.uk or by calling 0303 123 1113.