Privacy Policy

Effective date: 01 May 2025

This Privacy Policy explains how Stroheim Capital Ltd (“we”, “us”, or “our”), trading as [Go Cars], collects, uses, shares and protects your personal data when you use our mobile application and related services to book private hire and taxi journeys (the Services). We are the data controller for the processing described in this policy, unless stated otherwise.

If you have any questions, please contact us:

• Registered company name: [Stroheim Capital Ltd]
  
  
• Company number: [07119023]
  
  
• Registered office: [260-270 Butterfield, Luton, LU2 8DL]
  
  
• Contact email: [admin@goluton.com]
  
  

We may update this policy from time to time. We will post the updated version in the App and change the effective date above. If changes are material, we will notify you in-App or by email.

1. The data we collect

Depending on how you use the Services, we may process the following categories of personal data:

• Identity & contact data – name, title, phone number, email address, and (if you choose to save it) home/work addresses.
• Booking & journey data – pick‑up and drop‑off locations, date/time, route, vehicle class, fare, booking reference, notes to driver, voucher usage, and journey history.
• Location data – precise device location (GPS, Wi‑Fi, cell‑tower) to show nearby vehicles, set your pick‑up, enable live tracking and safety features. You can control location permissions in your device settings. If you disable location, some features may not work.
• Payment & transaction data – payment method token, last four digits of your card, billing address, transaction amounts and timestamps. We do not store full card numbers; payments are processed by our payment provider(s).
• Communications data – your messages to support, in‑app chat with drivers/partner fleets, call recordings where call masking is used (see section 10), and your marketing preferences.
• Device & usage data – device model, operating system, app version, language, unique identifiers, diagnostic and crash data, and interaction data to help us improve performance and security.
• Accessibility & preference data – optional information you provide about assistance needs (e.g. wheelchair access, visual/hearing support) and ride preferences (e.g. quiet mode). Note: where such information reveals health‑related data, we will only use it with your consent to fulfil your booking and to comply with safety obligations.
• Verification data (if applicable) – where required for account security or to comply with licensing/law (e.g. two‑factor authentication, proof of authority for business accounts).

We do not knowingly allow children to use the Services without the involvement of a parent or guardian. If you believe we’ve collected data about a child, please contact us.

2. How we use your data and legal bases

We use your personal data for the purposes and under the legal bases below:

• Provide and manage your account and bookings (create your account, take bookings, allocate a driver/partner fleet, send confirmations, provide live tracking, handle payments): Performance of a contract; Legitimate interests (efficient service and safety).
• Share details for journey fulfilment with assigned drivers and, where needed, partner fleets/subcontracted operators (see section 4): Performance of a contract; Legitimate interests (ensuring coverage and service continuity).
• Customer support and service communications (service updates, delays, receipts): Performance of a contract; Legitimate interests (service quality).
• Safety, security and fraud prevention (identity/account protection, misuse detection, chargeback/risk checks, safeguarding and incident handling): Legitimate interests; Legal obligations.
• Improve, troubleshoot and develop the App (analytics, diagnostics, A/B testing where appropriate): Legitimate interests.
• Marketing (news, offers, surveys): Consent where required under PECR; otherwise Legitimate interests with an opt‑out available at any time.
• Compliance with law and licensing (record‑keeping for local licensing authorities and tax): Legal obligations.
• Automated decision‑making (e.g. driver assignment, fare estimates, fraud signals): Performance of a contract; Legitimate interests. You may request human review of a decision that has legal or similarly significant effects on you.

3. Data needed to use the Services

Some data is required to use core features, for example:

• Location data: to set pick‑up, display ETAs and track your driver. You can disable background location in device settings; we only access precise location while you are using relevant in‑App features.
• Contact details: to send booking confirmations and allow the driver/partner fleet to reach you in relation to your journey (often via masked numbers).
• Payment method: for cashless bookings and to prevent fraud.

4. Sharing your data

We share your data only as necessary for the purposes above, with appropriate contractual and technical safeguards.

Partner fleets (important)

Some bookings may be fulfilled by a trusted partner fleet or subcontracted licensed operator when this is needed to provide coverage or specific vehicle types. In those cases we will share only the details necessary for the fulfilment of your booking, such as:

• first name (or initial),
• pick‑up and drop‑off locations (and waypoints),
• date/time, booking notes and accessibility requirements you have asked us to pass on,
• live tracking information necessary to complete the journey,
• a masked contact number or in‑App chat to communicate about the booking.

Partner fleets are contractually required to use your data solely to provide the journey and to keep it secure. Depending on local licensing arrangements they may act as our processor (processing on our instructions) or as an independent controller for their own legal and safety obligations. In both cases, they must handle your data lawfully and transparently.

Other recipients

• Assigned drivers – to complete your booking and contact you about pick‑up.
• Payment service providers – to process payments and prevent fraud.
• Communications providers – to send SMS, email, and provide call masking/in‑App voice.
• Cloud hosting, IT and support providers – to operate the App and store data securely.
• Analytics and diagnostics providers – to improve stability and performance (aggregated where possible).
• Regulators, licensing authorities and law enforcement – where we are legally required or to protect vital interests (e.g. safety incidents).
• Corporate account administrators – where you travel on a business account set up by your employer, we may share booking and spend details with them under that arrangement.
• Business transfers – in the context of a merger, acquisition or reorganisation, subject to appropriate safeguards.

We do not sell your personal data.

5. International transfers

We generally store your data in the UK/EEA. Where we transfer personal data outside the UK (for example, to cloud or communications providers), we use appropriate safeguards such as the UK International Data Transfer Agreement (IDTA) or the UK Addendum to the EU Standard Contractual Clauses, together with technical and organisational measures to protect your data.

6. Data retention

We keep your personal data only for as long as necessary for the purposes set out in this policy and to meet legal, accounting and licensing requirements. Typical retention periods are:

• Account profile – while your account remains active and for up to [24 months] after last activity, unless you ask us to delete it sooner (subject to legal holds).
• Booking and transaction records (including invoices/receipts) – up to six (6) years for tax and accounting.
• Journey location/telemetry data – retained for the trip and then for [12 months] for safety, dispute resolution and service quality.
• Customer support records – [24 months].
• Marketing preferences and opt‑outs – maintained until you change your preferences; records of opt‑out may be kept to honour your choice.

Where retention periods are shown in square brackets, we will confirm the exact periods applicable to your operator licence and internal policies.

7. Security

We implement appropriate technical and organisational measures to protect your data, including encryption in transit and at rest where appropriate, access controls, least‑privilege policies, monitoring, staff training and vendor due diligence. While no system is 100% secure, we work to prevent unauthorised access, alteration or loss.

8. Your rights

Under UK data protection law (UK GDPR and Data Protection Act 2018) you have rights including to:

• Access your personal data and receive a copy;
• Rectify inaccurate or incomplete data;
• Erase your data in certain circumstances;
• Restrict or object to processing, including where we rely on legitimate interests;
• Data portability for data you provided to us with consent or under a contract;
• Withdraw consent at any time, where processing is based on consent;
• Complain to the UK Information Commissioner’s Office (ICO) if you are unhappy with how we have handled your data.

To exercise your rights, please contact us using the details above. You can also contact the ICO at ico.org.uk or by post at Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.

9. Cookies, SDKs and analytics in the App

The App uses software development kits (SDKs) and similar technologies for core functionality (e.g. maps, payments, push notifications) and analytics/diagnostics. Where required, we will seek your consent for analytics/marketing technologies and you can change your preferences at any time via in‑App settings or your device settings.

10. Calls, messages and recordings

To protect your privacy we may use number masking or in‑App voice so drivers and partner fleets can contact you without seeing your real number. Support calls may be recorded for training and quality; we will tell you when recording is active. Any recordings are retained only as needed for these purposes and then deleted.

11. In‑App permissions and controls

You can control certain processing via your device and App settings, including:

• Location access (while using the app / allow once / don’t allow)
• Push notifications
• Analytics/marketing preferences
• Saved addresses and payment methods

12. About this policy in relation to partner fleets

Where a journey is fulfilled by a partner fleet, they may provide their own privacy information to you (for example, on a receipt or via a link). Their handling of your data is also governed by local licensing rules and their own policies. We require partner fleets to use your data only for the fulfilment of your booking and to implement appropriate security measures. If you have questions about a journey completed by a partner fleet, you can contact us in the first instance and we will liaise with them as needed.

13. Contact us

Questions or requests about this policy or your personal data:

• Email: [admin@goluton.com]
  
  
• Postal: [Data Protection,Go Cars, 193-197 Marsh Road, LU3 2QQ]

If you would like this policy in another format (large print, audio), please let us know.