Privacy Policy

1. Who we are

We are Sea & Sky Luxury Transfers Ltd., a licensed private-hire operator in the United Kingdom, and we are the data controller for the personal data described in this notice.

Registered address: Jubilee Enterprise Centre, 15 Jubilee Close, Weymouth, Dorset, DT4 7BS
ICO registration number: ZC133717
Data Protection Officer: Simon A. Craddock
Contact: office@seaskyluxurytransfers.com

2. What data we collect

Name, telephone number and email address
Pick-up and drop-off locations, and journey history
Flight numbers or vessel details where you provide them
Payment information
CCTV or in-car camera footage, where fitted
Website usage data, including IP address, device identifiers and cookies

3. Why we use your data, and our lawful basis

Booking and completing journeys: contract
Customer support and dispute resolution: legitimate interests
Safety, CCTV and fraud prevention: legitimate interests
Legal compliance, including licensing and HMRC: legal obligation
Payment processing: contract
Website and app analytics: legitimate interests, or consent for non-essential cookies

4. Our legitimate interests

Where we rely on legitimate interests we have carried out a balancing assessment in line with ICO guidance. Those interests are: ensuring passenger and driver safety, preventing fraud such as fake bookings and chargebacks, investigating complaints and resolving disputes, optimising dispatch operations, and protecting company assets.

We considered less intrusive alternatives, including manual logs and operating without CCTV, and concluded these were insufficient for safety and dispute resolution. Safeguards include clear signage where CCTV is fitted, restricted access to footage, short retention periods, encryption and access logging. This assessment is reviewed annually or after major operational changes.

5. Who we share your data with

Dispatch software providers
Payment processors
Local authority licensing teams
The police, where legally required
Insurers, in relation to incidents only

We do not sell your personal data to third parties.

6. How long we keep it

Journey records: 12 to 24 months
CCTV footage: 14 to 31 days, unless required for an incident
Financial records: 6 years, as a legal obligation
Website analytics data: 12 to 24 months

7. How we protect it

We use an encrypted dispatch system, role-based access controls and secure mobile devices. Access to CCTV footage is restricted and logged.

8. Your rights

You have the right to access your personal data, to have inaccurate data corrected, and to request erasure, restriction of processing, or to object to processing. Where processing is based on consent, you may withdraw that consent at any time. To exercise any of these rights, contact office@seaskyluxurytransfers.com.

If you are not satisfied with our response, you have the right to complain to the Information Commissioner’s Office at ico.org.uk.

9. Driver and staff data

For drivers and staff we process name, address and contact details, driving licence and right-to-work documents, GPS location during shifts, CCTV footage where fitted, incident and complaint records, and payment and tax information.

Our lawful bases are contract for driver engagement, legal obligation for licensing and HMRC requirements, and legitimate interests for safety monitoring, fraud prevention and complaint investigation. Driver records are retained for 6 years after the contract ends; GPS logs for 3 to 12 months.

10. CCTV in vehicles

Where CCTV is fitted, signage is displayed in the vehicle. Images are recorded by Sea & Sky Luxury Transfers Ltd. under UK GDPR legitimate interests, for the safety of passengers and drivers. For enquiries about footage, contact office@seaskyluxurytransfers.com.

11. Changes to this notice

We may update this notice to reflect changes in our services or legal requirements. The current version is always available on this page.