Privacy Policy

1. Who we are

[CONFIRM: exact registered company name] ("Silvar", "we", "us") is the data controller responsible for your personal data collected through the Platform. We are registered with the Information Commissioner's Office (ICO) under registration number [CONFIRM: ICO data protection registration number]. For any privacy question or to exercise your rights, contact [CONFIRM: privacy/DPO contact email].

2. What personal data we collect

Identity and contact data — name, email, phone number, and (for Membership) billing address.

Booking data — pickup and drop-off locations, journey times, vehicle preference, flight details where provided, and special requests.

Payment data — processed by [CONFIRM: payment processor name] on our behalf; we retain only the last four digits and card type, not your full card number.

Communications — messages exchanged with Silvar or an Operator through the Platform, and support correspondence.

Technical data — device, browser, IP address, and app usage data, collected via cookies and similar technologies (see clause 7).

Referral data — where applicable, who referred you (e.g. concierge, PA, hotel, corporate account).

3. How we use your data and our legal basis

Provide and manage Bookings and Membership — necessary to perform our contract with you (UK GDPR Art. 6(1)(b)).

Communicate with you about a Booking, including proactive updates on delays or flight changes — necessary to perform our contract, or our legitimate interest in providing a reliable service (Art. 6(1)(f)).

Process payments and prevent fraud — necessary to perform our contract and our legitimate interest in protecting the Platform (Art. 6(1)(b) and (f)).

Improve the Platform and our service standards — our legitimate interest in operating and improving the business (Art. 6(1)(f)).

Send you marketing communications — only with your consent, which you can withdraw at any time (Art. 6(1)(a)); see clause 8.

Comply with legal and regulatory obligations, including those owed to Transport for London and tax authorities — necessary for compliance with a legal obligation (Art. 6(1)(c)).

4. Who we share your data with

Operators (Fleet Partners and chauffeurs) — your name, contact number, and journey details, so they can fulfil your Booking.

Payment processors — [CONFIRM: payment processor name], to process payment.

Service providers — hosting, communications (including WhatsApp-based messaging where you opt in), and customer support tools, under contracts that require them to protect your data.

Regulators and authorities — where required by law, including TfL, the ICO, or law enforcement.

Corporate or Affiliate accounts — where a Booking is made on your behalf by a corporate account, hotel concierge, or affiliate organisation, relevant booking data is shared back with that organisation as part of fulfilling the booking they made for you.

We do not sell your personal data.

5. International transfers

Where any service provider is located outside the UK, we ensure an appropriate safeguard is in place — such as the UK's International Data Transfer Agreement (IDTA) or a finding of adequacy — before your data is transferred.

6. How long we keep your data

We keep Booking and payment records for as long as required for tax and accounting purposes (currently up to 6 years after the relevant tax year), account data for as long as your account is active plus a reasonable period after closure, and marketing consent records until you withdraw consent. We delete or anonymise data once it is no longer needed for these purposes.

7. Cookies and similar technologies

We use cookies and similar technologies to operate the Platform (strictly necessary), remember your preferences (functional), and understand how the Platform is used (analytics). Non-essential cookies are only set with your consent, given through the cookie banner shown on your first visit, in line with the Privacy and Electronic Communications Regulations (PECR). You can change your cookie preferences at any time via the "Cookie preferences" link shown at the bottom of every page.

8. Marketing communications

We only send you marketing communications (email, SMS, or WhatsApp) where you have opted in. You can withdraw consent at any time by using the unsubscribe link, replying STOP, or contacting [CONFIRM: privacy/DPO contact email]. Withdrawing marketing consent does not affect operational communications about a confirmed Booking.

9. Children's data

The Platform is not directed at, and we do not knowingly collect data from, anyone under 18.

10. Data security

We use appropriate technical and organisational measures — including encryption in transit, access controls, and regular review of our service providers — to protect your data against unauthorised access, loss, or misuse.

11. Your rights

Under UK GDPR, you have the right to access the personal data we hold about you, correct inaccurate or incomplete data, request erasure of your data where applicable, restrict or object to certain processing, receive your data in a portable format, and withdraw consent at any time where processing is based on consent.

To exercise any of these rights, contact [CONFIRM: privacy/DPO contact email]. We will respond within one month. If you are unhappy with how we have handled your data, you have the right to complain to the ICO (ico.org.uk), the UK's data protection regulator.

12. Changes to this policy

We may update this Privacy Policy from time to time. Material changes will be notified through the Platform or by email before they take effect. This policy was last updated on [CONFIRM: effective date].