Privacy Notice Information

I. Introduction

When you use London Blackbook Ltd ("Blackbook"), you trust us with your personal data. We’re committed to keeping that trust. That starts with helping you understand our privacy practices.

This notice describes the personal data (“data”) we collect, how it’s used and shared, and your choices regarding this data.

II. Overview

A. Scope

This notice applies to users of Blackbook’s services anywhere in the world, including users of Blackbook’s app, websites or features.

This notice describes how Blackbook and its affiliates collect and use data. This notice applies to all Blackbook users. This notice specifically applies to:

Riders: individuals who request or receive transportation
Drivers: individuals who provide transportation to Riders individually or through partner transportation companies.
Guest Users: individuals who receive ride services ordered by other Blackbook users

All those subject to this notice are referred to as “users” in this notice.

Our privacy practices are subject to applicable laws in the places in which we operate. This means that we engage in the practices described in this notice in a particular country or region only if permitted under the laws of those places.

B. Data controller

London Blackbook Ltd. is the data controller for the data collected in connection with use of Blackbook’s service in the United Kingdom.

In addition, for drivers in the UK, Blackbook (1) holding the relevant private hire vehicle operator license is the data controller for the data required to comply with licensing requirements; and (2) with whom the driver has entered into a contract, is the data controller for the data required to comply with worker rights. Blackbook respects your data protection rights.

III. Data collections and uses

A. The data we collect

Blackbook collects data:

provided by Blackbook users
created during use of our services, such as location, app usage, and device data

Blackbook collects the following data:

1. Data provided by users. This includes:

We collect data when users place orders via guest checkout features. This may include their name, email, phone number, address, payment or banking information (including related payment verification information), driver’s license and other government issued documents (which may include identification numbers as well as birth date, gender, and photo). This also includes vehicle or insurance information of drivers and delivery persons, emergency contact information, and evidence of health or fitness to provide services using the Blackbook app.
Background check information (drivers): This includes information submitted during the driver application process, such as driver history or criminal record (where permitted by law), license status, known aliases, prior addresses, and right to work. This information may be collected by an authorized vendor on Blackbook’s behalf.
Identity verification photos: This includes photos of drivers (such as, selfies) and/or their government issued identifications (such as, driver’s license or passports). Such photos may be used to verify a user’s identity, such as through facial verification technologies.
User content: We collect the data submitted by users when they contact Blackbook customer support and provide ratings or feedback for other users. This may include photographs, or audio or video recordings submitted by users in connection with a customer support request. This also includes metadata relating to the method you use to communicate with Blackbook.
Travel information: We collect travel itinerary information. We collect such information when users manually input their information into their Blackbook booking forms; or (2) if authorized by users through the Blackbook app.

2. Data created during use of our services. This includes:

Location data (driver): We collect precise or approximate location data from drivers’ mobile devices when the Blackbook app is running in the foreground (app open and on-screen) or background (app open but not on-screen).
Location data (riders): We collect precise or approximate location information from riders’ mobile devices if they enable us to do so via their device settings or when they submit a booking request via online form.

Blackbook collects such data from the time a ride is requested until it is finished, and any time the app is running in the foreground (app open and on-screen).

Riders and order recipients may use the Blackbook app without enabling collection of location data from their mobile devices. However, this may affect certain features in the Blackbook app. For example, a rider who has not enabled precise location data will have to manually enter their pickup address or use the Blackbook website booking form.

In addition, precise location data collected from a driver’s device during a trip is linked to the rider’s account, even if the rider has not enabled precise location data to be collected from their device. This data is used for purposes such as receipt generation, customer support, fraud detection, insurance, and litigation.
Transaction information: We collect transaction information related to the use of our services, including the type of services requested or provided; trip or order details (such as date and time, requested pick-up and drop off addresses, distance traveled and items ordered); and payment transaction information.
Usage data: We collect data about how users interact with our services. This includes access dates and times, app features or pages viewed, browser type, and app crashes and other system activity.
Device data: We collect data about the devices used to access our services, including the hardware models, device IP address or other unique device identifiers, operating systems and versions, software, advertising identifiers and mobile network data.
Communications data: We collect data regarding phone, text or in-app communications between users and drivers that are enabled through the Blackbook’s app. This includes date and time, as well as the content of text or in-app messages. We may also collect the content of phone calls solely where users are notified in advance that the call may be recorded.

3. Data from other sources. These include:

users or others providing information in connection with claims or disputes.
Blackbook business partners such as payment providers, social media services, or apps or websites whose APIs Blackbook uses.
vendors who help us verify users’ identity, background information, and eligibility to work, or who screen users in connection with sanctions, anti-money laundering, or know-your-customer requirements.
insurance, vehicle, or financial services providers for drivers.
publicly available sources.
law enforcement officials, public health officials, and other government authorities.

B. How we use personal data

Blackbook uses data to enable reliable and convenient transportation services. We also use such data:

to enhance the safety and security of our users and service
for customer support
for research and development
to enable communications between users and drivers
for marketing and advertising
Non-marketing communications
in connection with legal proceedings

We use the data we collect:

1. To provide our services. Blackbook uses data to provide, maintain, and improve our services.
This includes using data to:

enable transportation services/features, such as:
- using location data to navigate rider pick-ups and order drop-offs, calculate ETAs, and track the progress of rides or deliveries.
- features that involve data sharing, such as sharing driver first name and vehicle information with riders to facilitate pick-ups, user profile and trip details for ETA sharing and fare splitting, and user ratings and compliments.
- match available drivers to users requesting services. Users can be matched based on availability, location/proximity, user settings/preferences and other factors such as likelihood to accept a trip based on their past behavior or preferences.
- features that facilitate use of our services by those with disabilities.
enable dynamic pricing, in which ride prices are determined based on factors such as estimated time and distance, predicted route, estimated traffic, and the current number of users requesting or providing services.
process payments.
facilitate insurance, vehicle, invoicing, or financing solutions.
provide users with trip or delivery updates, generate receipts, and inform them of changes to our terms, services, or policies.
perform necessary operations to maintain our services, including to troubleshoot software bugs and operational problems.

Blackbook performs the above activities on the grounds that they are necessary to fulfill the terms of our agreements with users, are compatible with such uses, or on the grounds that they are necessary for purposes of Blackbook’s and its users’ legitimate interests.

2. Safety and security. We use data to help maintain the safety, security, and integrity of our services and users. This includes:

verifying users' identity and eligibility to provide transportation, including through reviews of background checks, to help prevent use of our services by unsafe drivers and/or riders..
In addition, we may use facial recognition technology to process user profile photographs, identification photographs, or other user-submitted photographs to prevent identity-borrowing or use of our services by unauthorized drivers or delivery people.
using data from drivers’ devices to detect unsafe driving behavior such as speeding or harsh braking and acceleration, and to inform them of safer driving practices.
using user ratings, reported incidents, and other feedback as grounds for deactivating users with low ratings.
using driver data (such as past trip information and reported incident rates) and rider data (such as past trip information, cancellation and reported incident rates, account information, ratings information, and current pick-up and drop-off location) to predict and help avoid pairings of users that may result in increased risk of conflict (for instance, because one user previously gave the other a one-star rating).
Blackbook performs the above activities on the grounds that they are necessary to fulfill the terms of our agreements with users, and/or for purposes of the legitimate safety and security interests of Blackbook, our users and members of the general public.

3. Customer support. Blackbook uses the information we collect (which may include call recordings) to provide customer support, including to investigate and address user concerns and to monitor and improve our customer support responses and processes.

4. Research and development. We use data for testing, research, analysis, product development, and machine learning to improve the user experience. This helps us make our service more convenient and easy-to-use, enhance the safety and security of our service, and develop new services and features.
Blackbook performs the above activities on the grounds that they are necessary for purposes of Blackbook’s legitimate interests in improving and developing new services and features.

5. Enabling communications between users. For example, a driver may message or call a rider to confirm a pick-up location, a rider may call a driver to retrieve a lost item.

6. Marketing and Advertising. Blackbook uses data to market its services. This may include sending emails, text messages, push notification, and in-app messages or other communications marketing or advertising Blackbook's service.

7. Non-marketing communications. Blackbook may use data to send surveys and other communications that are not for the purpose of marketing the services or products of Blackbook.

Blackbook performs the above activities on the grounds that they are necessary to fulfill the terms of our agreements with users, or for purposes of Blackbook’s and its users’ legitimate interests in informing users about events that may have an impact on their use of Blackbook's service.

8. Legal proceedings and requirements. We use data to investigate or address claims or disputes relating to use of Blackbook’s service, to satisfy requirements under applicable laws, regulations, or operating licenses or agreements, or pursuant to legal process or governmental request, including from law enforcement.

C. Cookies and third-party technologies

Blackbook and its partners use cookies and other identification technologies on our app, websites, emails, and online ads for purposes described in this notice..

Cookies are small text files that are stored on browsers or devices by websites, apps, online media, and advertisements. Blackbook uses cookies and similar technologies for purposes such as:

authenticating users
remembering user preferences and settings
determining the popularity of content
delivering and measuring the effectiveness of advertising campaigns
analyzing site traffic and trends, and generally understanding the online behaviors and interests of people who interact with our services

We may also allow others to provide audience measurement and analytics services for us, to serve advertisements on our behalf across the internet, and to track and report on the performance of those advertisements. These entities may use cookies, web beacons, SDKs, and other technologies to identify the devices used by visitors to our websites, as well as when they visit other online sites and services.

D. Data sharing and disclosure

Blackbook's service requires that we share data with other users or at a user’s request. We may also share such data with our affiliates and partners, for legal reasons or in connection with claims or disputes.

Uber may share data:

1. With other users:

for drivers , we may share data with the rider(s), including name and photo; vehicle make, model, color, license plate, and vehicle photo; location (before and during trip); average rating provided by users; total number of trips; period of time since they signed up to be a driver; contact information; and driver profile, including compliments and other feedback submitted by past users.
We also provide riders and order recipients with receipts containing information such as a breakdown of amounts charged, driver first name, photo, and route map. We also include other information on those receipts if required by law.

2. At the user’s request:

We offer features that enable users to share their data with police, fire, and ambulance services in the event of an emergency or after certain incidents.

5. With Blackbook affiliates

We share data with our affiliates to help us provide our services or conduct data processing on our behalf.

6. With Blackbook service providers and business partners

These include:

payment processors and facilitators
background check and identity verification providers
cloud storage providers
social media companies, including Facebook and Instagram, in connection with Blackbook’s use of their tools in Blackbook’s app and websites
marketing partners and marketing platform providers, including social media advertising services, advertising networks, third-party data providers, and other service providers to reach or better understand our users and measure advertising effectiveness
research partners, including those performing surveys or research projects on Blackbook’s behalf
vendors that assist Blackbook to enhance the safety and security of Blackbook apps and services
consultants, lawyers, accountants, and other professional service providers
insurance and financing partners

7. For legal reasons or in the event of a dispute

Blackbook may share users’ data if we believe it’s required by applicable law, regulation, operating license or agreement, legal process or governmental request, or where the disclosure is otherwise appropriate due to safety or similar concerns.

This includes sharing data with law enforcement officials, public health officials, other government authorities, airports (if required by the airport authorities as a condition of operating on airport property), or other third parties as necessary to enforce our Terms of Service, user agreements, or other policies; to protect Blackbook’s rights or property or the rights, safety, or property of others; or in the event of a claim or dispute relating to the use of our services. In the event of a dispute relating to use of another person’s credit card, we may be required by law to share your data, including trip or order information, with the owner of that credit card.

8. With consent

Blackbook may share a user’s data other than as described in this notice if we notify the user and they consent to the sharing.

E. Data retention and deletion

Blackbook retains user data for as long as necessary for the purposes described above, including to provide its services and comply with legal obligations.

Blackbook retains user data for as long as necessary for the purposes described above. The period for which we retain user data is determined by the type of data, the category of user to whom the data relates, and the purposes for which we collected the data.

The length for which Blackbook retains user data may further be determined by legal and regulatory requirements, purposes of safety, security, and fraud prevention, or by issues relating to the user’s account such as an outstanding credit or an unresolved claim or dispute.

For example, we retain data:

for the life of users’ accounts if such data is necessary to provide our services. E.g., user profile information and credentials.
for 7 years if necessary to comply with tax requirements. E.g., drivers’ trip information.
for defined periods as necessary for purposes of safety or fraud prevention. E.g., we retain incomplete driver applications for 1 year, and rejected driver applications for 7 years.
after requests for account deletion if necessary for purposes of safety, security, fraud prevention or compliance with legal requirements, or because of issues relating to the user’s account (such as an outstanding credit or an unresolved claim or dispute).

Users may request deletion of their accounts at any time. Blackbook may retain user data after a deletion request due to legal or regulatory requirements or for reasons stated in this policy.

Users may request deletion of their account by contacting us at any time.

Following an account deletion request, Blackbook deletes the user’s account and data, unless they must be retained due to legal or regulatory requirements, for purposes of safety, security, and fraud prevention, or because of an issue relating to the user’s account such as an outstanding credit or an unresolved claim or dispute. Because we are subject to legal and regulatory requirements relating to drivers, this generally means that we retain their account and data for the applicable statutory retention period after a deletion request. For riders and order recipients, their data is generally deleted within 90 days of a deletion request, except where retention is necessary for the above reasons.

IV. Choice and transparency

Blackbook enables users to access and/or control data that Blackbook collects, including through:

privacy settings
device permissions
in-app ratings pages
marketing choices

Blackbook also enables users to request access to or copies of their data, make changes or updates to their accounts, request deletion of their accounts, or request that Blackbook restrict its processing of user data.

V. Updates to this notice

We may occasionally update this notice.

We may occasionally update this notice. If we make significant changes, we will notify users in advance of the changes through the Blackbook app or through other means, such as email. We encourage users to periodically review this notice for the latest information on our privacy practices.

Use of our services after an update constitutes consent to the updated notice to the extent permitted by law.