CTLF PRIVACY POLICY - Twelve Transfers Privacy Policy

Respecting your privacy is one of our fundamental commitments and therefore we pay the utmost attention to processing your personal data in accordance with applicable law. We are aware of the importance of maintaining the confidentiality, integrity and security of your personal data (“Personal Data”) and have drafted this privacy and cookie policy (“Privacy Policy”) to explain how your Personal Data Personal Personal are collected, stored, used and disclosed to CTLF Ltd, as operator, in connection with access to and provision of our services through our CTLF App (“Application”) and website- the of www.twelvetransfers.co.uk (“Website”). Whenever we are required by applicable law, we will request your free, informed, specific and unequivocal consent to the processing of your Personal Data. By expressing your consent, you agree that we may collect, use, disclose, process and transfer your Personal Data in accordance with this Privacy Policy.

We reserve the right to change the provisions of this Privacy Policy at any time. If we make changes to this privacy policy, we will make the updated version available in the Application and on the Website and we will update the data mentioned in “Last Updated”. We will also notify you of the change to ensure that you are informed of how your Personal Data will be used. Any change to the Privacy Policy will apply from the date it was made, except for changes that require your prior consent and which will apply at the time you can experience this consent.

The Personal Data processed and the purposes of the processing

1.1. Application and Website usage data

The computer systems and software applications used for the operation of the Application and the Website generally obtain some Personal Data (so-called “log files”), the transmission of which is implicit in the use of Internet communication protocols.

This information is not collected to be associated with identified persons, but due to its nature, it may allow, through processing and integration with certain data stored by third parties, the identification of users. This information includes IP addresses, time of request, method used to send the request to the server, device ID, phone model, version of the Application, as well as other parameters related to the user’s operating system.

We use this data only to obtain anonymous statistical information on the use of the Application and the Website and to check their correct functioning.

The legal grounds for processing browsing data are our legitimate interest in improving our App and Website, managing server capacity and keeping our App error-free, as well as enabling us to comply with legal obligations regarding security of our systems.

1.2. Provision of services through the Application and the Website

1.2.1. Drivers’ Personal Data

1. a) Registering and creating an account

To register and create an account we will need the following Personal Data: name and surname, contact data (e-mail, phone number/numbers), gender, date and place of birth, nationality, CNP, other data included in the identity card, bank details such as the bank account (IBAN) and the name of the bank, data from the driver’s license, data from the professional certificate, data from the registration certificate, data from the minicab / private transfer authorization and from the minicab / private transfer badge, data from the transport authorization and your profile picture. The purpose of this processing consists in signing the contract, creating and managing the account in the Application, providing our services through the Application, issuing invoices and registering payments related to the contract.

1. b) Benefiting from CTLF services and Using the Application

When you use the Application, as a driver, your name and surname, phone number, profile picture, car number, minicab / private transfer company, bank account will be processed. We will also process your geo-location data. These data, with the exception of the bank account, will be transmitted to the Application Client only after you have accepted an order from him. The purpose of this processing is to provide our services through the Application.

The legal basis of this processing is the execution of the contract and the provision of our services through the Application. The refusal to provide this data determines the impossibility of registering and creating an account in our Application and the impossibility of benefiting from the services provided through the Application. Also, in some situations the basis for processing this data is also our legitimate interest to defend our commercial activity, it being understood that we ensure that all the measures we take guarantee a balance between our interests and your fundamental rights and freedoms. Thus, our legitimate interest may consist in taking measures to prevent and detect fraud attempts,

We will process your profile picture only on the basis of your freely expressed consent and until the withdrawal of consent, without affecting the legality of the processing based on consent before its withdrawal.

1.2.2. Personal Data of Customers

1. a) Registering and creating an account
2. i) Registration directly in the Application

In our Application you have the possibility to register and create an account. In this case, we will need your first and last name, your email address, your phone number and your country of residence. Also, once the account is created, you have the possibility to add your profile picture and to allow access to the location, not being an obligation and only at your free choice. Your profile picture will only be stored locally on your device and will never reach CTLF’s servers.

We will not collect or store any other information other than that detailed above. Thus, we will not process your personal data related to bank cards, your profile picture or any other details that you have shared with our business partners through their websites/applications.

1. ii) Service Providers

CTLF Ltd and companies using our system may shares personal information with companies who provide services such as information processing, extending credit, fulfilling customer orders, delivering products to you, managing and enhancing customer data, providing customer service, assessing your interest in our products and services, and conducting customer research or satisfaction surveys. These companies are obligated to protect your information in the same manner as CTLF Ltd and companies using our system.

1. b) Order

When you place an order through the Application, we will process your name, surname, the place where you want to be picked up by the driver and the desired destination. This data will be transmitted to the Drivers active in the Application at the time of placing the order.

1. c)  Payment by bank card in the Application

If you choose to pay for your ride with a bank card, CTLF will not collect or store your bank card information. Your bank cards will only be stored locally on your device, they never reach the CTLF servers.

After you pay for the trip with a bank card, we will send you an email with the history of the trip and the amount paid.

The purpose of this processing is to provide our services through the Application.

The legal basis of this processing is the execution of the contract and the provision of our services through the Application. The refusal to provide this data determines the impossibility of creating an account in our Application and the impossibility of benefiting from the services provided through the Application. Also, in some situations the basis for processing this data is also our legitimate interest to defend our commercial activity, it being understood that we ensure that all the measures we take guarantee a balance between our interests and your fundamental rights and freedoms. Thus, our legitimate interest may consist in taking measures to prevent and detect fraud attempts,

We will process your profile picture only on the basis of your freely expressed consent and until the withdrawal of consent, without affecting the legality of the processing based on consent before its withdrawal.

1.3. Providing services through the Call Center

CTLF provides customers and drivers with a dedicated Call Center through which you can send us a request or notification or ask for different information such as: how to create a driver account, how to download the CTLF application, how to use the Star application minicab / private transfer as a driver or customer, or other miscellaneous information. You can find the phone numbers for our Call Center in the Help – Contact section of the CTLF application or on our website at https://www.twelvetransfers.co.uk/contact/ .

When you decide to use our services through the CTLF Call Center, we will record the call processing your voice, name and surname, your email address and/or phone number You can refuse to provide us with this data, but in this otherwise you will not be able to benefit from our services. If you do not want us to process your voice by recording telephone conversations made through the CTLF Call Center, please contact us using another method as described in chapter 7. Contact , below.

The purpose of this processing helps us to improve our services and evaluate our operators.

The legal basis for this processing is our legitimate interest in defending our commercial activity, it being understood that we ensure that all the measures we take guarantee a balance between our interests and your fundamental rights and freedoms. Thus, our legitimate interest may consist in taking measures to prevent and detect fraud attempts, including the transmission of information to the competent public authorities or measures to manage various other risks.

1.4. Location-Based Services

To provide location-based services CTLF Ltd and companies using our system may collect, use, and share precise location data, including your real-time geographic location. Where available, location-based services may use GPS, Bluetooth, and your IP Address, along with crowd-sourced Wi-Fi hotspot and cell tower locations, and other technologies to determine your location. Unless you provide consent, as you would in the context of a specific request for transportation service, this location data is collected anonymously in a form that does not personally identify you and is used by CTLF Ltd and companies using our system to provide and improve location-based products and services.

1.5. Commercial communications

In our Application you have the possibility to opt-in to receive commercial communications, opinion polls and marketing analyzes by email, SMS messages, phone calls or push notifications. If you opt to receive such commercial messages, opinion polls and marketing analyses, we will process your name and surname, your e-mail address, telephone number, the ID of the device used to send you commercial messages, opinion polls and marketing analysis regarding CTLF activities and promotions. You can opt out of providing us with this data or receiving commercial communications, opinion polls and marketing analysis from us. The purpose of this processing is to send commercial communications, opinion polls,

You can revoke or modify the prior agreement at any time and without costs, through the Application in the Main Menu – Settings – Privacy Settings or by sending us an email to the address privacy@ctlf.co.uk .

The legal basis for processing your name and surname, e-mail address and telephone number for this purpose is your freely expressed consent.

1.6. Resolving requests or complaints

For those situations where you are the subject of a request/report/complaint, we will process your name, surname, e-mail address and/or telephone number and, if necessary, the details of the race performed. You can contact us in different ways: by email, by phone, through the form on the Website or through social media websites/applications (Facebook, Whatsapp). In this situation, we will only use your Personal Data to contact you to resolve your issue and to provide you with support. The purpose of this processing is to resolve requests, notifications or complaints.

The legal basis for this processing is our legitimate interest in contacting you and resolving your requests, notifications or complaints. Refusal to provide this data makes it impossible to contact you to solve your problem and provide you with support.

1.7. Children

We understand the importance of taking extra precautions to protect the privacy and safety of children. Accordingly, we do not knowingly collect, use or disclose personal information from children under 18, or equivalent minimum age in the relevant jurisdiction, without verifiable parental consent. If we learn that we have collected the personal information of a child under 18, or equivalent minimum age depending on jurisdiction, without first receiving verifiable parental consent we will take steps to delete the information as soon as possible.

Children under the age of 18, or equivalent minimum age in the relevant jurisdiction, are not permitted to create their own accounts unless their parent provided consent.

1.8. Integrity and Retention of Personal Information

CTLF Ltd and companies using our system make it easy for you to keep your personal information accurate, complete, and up to date. We will retain your personal information for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law.

• Processing time

As a general rule, the duration of the processing of your personal data is:

• data from the CTLF application will be kept as long as you are registered and have an account in the Application;
• website browsing data will be kept for a period of up to two years, in accordance with the Cookies Policy found in chapter 5 , below;
• data collected in order to provide services for drivers will be kept in accordance with legal requirements;
• data collected for commercial communications, opinion polls and marketing analysis will be kept until you withdraw your consent;
• telephone call records will be kept for a period of up to one year;
• the video recordings from the surveillance cameras will be stored for up to 30 days;
• data collected for the purpose of selection and recruitment for one of our vacancies will be kept in accordance with legal requirements in cases where there has been an employment contract in relation to us, or for up to 6 months after the recruitment process for the position has been completed at which you applied for, in case you were not selected for the respective position.

In certain circumstances, we may retain Personal Data for longer periods of time, for example where we are required to do so in accordance with legal, regulatory, tax or accounting requirements.

We may also retain Personal Data for longer periods of time so that we have an accurate record of your dealings with us in the event of any complaints or if we reasonably believe there is a prospect of litigation relating to the Processing of your Data Personal or transactional.

• Transfer of Personal Data

Personal Data is stored on our servers and on the servers of contractual partners who help us provide our services.

We may transfer Personal Data, to the extent necessary, to the following categories of recipients: contractual partners, subcontractors, companies offering courier services, companies offering archiving services, companies offering IT services, payment processors , suppliers of software or hardware products, market research companies, marketing companies, public authorities, courts of law or arbitration, as well as authorities competent to investigate the commission of criminal acts.

These recipients may be located in the European Union and/or the European Economic Area. If the recipients are located outside the European Union and the European Economic Area, including countries that are not recognized as providing an adequate level of protection, the transfer of Personal Data is only carried out if there are adequate guarantees, in accordance with the applicable law . In this sense, we rely on several guarantees, such as the standard contractual clauses issued by the European Commission. You can receive from us a list of recipients in third countries, as well as a copy of the agreed provisions that ensure an adequate level of protection of Personal Data. For any request in this regard, please contact us at the contact details mentioned in chapter 7. Contact, lower.

• Images Uploaded

To provide UI interface and application usability CTLF Ltd and companies using our system may collect, use images uploaded from the mobile device, taken with the device camera. Unless you provide consent, as you would in the context of a specific request for transportation service, this location data is collected anonymously in a form that does not personally identify you and is used by CTLF Ltd and companies using our system to provide and improve the application and in some cases legal requirements for identity.

• Security of Personal Data

The security of your Personal Data is important to us. Therefore, your Personal Data will be processed by applying reasonable technical and organizational measures to protect Personal Data, such as limiting access to Personal Data, encryption or anonymization of Personal Data, storage on secure media. However, despite our best efforts, we cannot always guarantee the effectiveness of the security measures implemented, and therefore, we cannot guarantee the security of Personal Data at all times.

6. Cookies policy

CTLF Ltd and companies using our system, as well as our online services, interactive applications, email messages, and advertisements may use “cookies” and other technologies such as pixel tags and web beacons. These technologies help us better understand user behavior, tell us which parts of our website people have visited, and facilitate and measure the effectiveness of advertisements and web searches. We treat information collected by cookies and other technologies as non‑personal information. However, to the extent that Internet Protocol (IP) addresses or similar identifiers are considered personal information by local law, we also treat these identifiers as personal information. Similarly, to the extent that non-personal information is combined with personal information, we treat the combined information as personal information for the purposes of this Privacy Policy.

CTLF Ltd and companies using our system use cookies and other technologies in mobile advertising services to control the number of times you see a given ad, deliver ads that relate to your interests, and measure the effectiveness of ad campaigns. If you do not want to receive ads with this level of relevance on your mobile device, you can opt out by accessing the appropriate link on the application on your mobile device.

CTLF Ltd and companies using our system also use cookies and other technologies to remember personal information when you use our website, online services, and applications. Our goal in these cases is to make your experience with CTLF Ltd and companies using our service more convenient and personal. Knowing your contact information, hardware identifiers, and information about your computer or device helps us personalize your operating system and provide you with better customer service.

As is true of most internet services, we gather some information automatically and store it in log files. This information includes Internet Protocol (IP) addresses, browser type and language, Internet service provider (ISP), referring and exit websites and applications, operating system, date/time stamp, and clickstream data.

We use this information to understand and analyze trends, to administer the site, to learn about user behavior on the site, to improve our product and services, and to gather demographic information about our user base as a whole. CTLF Ltd and companies using our system may use this information in our marketing and advertising services.

In some of our email messages, we use a “click-through URL” linked to content on the CTLF Ltd website or the websites of companies using our system or advertising partners. When customers click one of these URLs, they pass through a separate web server before arriving at the destination page. We track this click-through data to help us determine interest in particular topics and measure the effectiveness of our customer communications. If you prefer not to be tracked in this way, you should not click text or graphic links in the email messages.

Pixel tags enable us to send email messages in a format customers can read, and they tell us whether mail has been opened. We may use this information to reduce or eliminate messages sent to customers.

6.1. Definition of cookies

Cookies are small text files made up of letters and numbers, which will be stored on a user’s device (computer, mobile terminal or other equipment) when accessing the Internet. Cookies are installed by a request sent by a web server to a browser and is completely passive, in the sense that it does not contain software programs, viruses or spyware and cannot access the information on the user’s hard drive. 

Cookies provide the user with a pleasant experience of accessing and browsing a website by offering functionalities such as: language options, saving registration data, relevant advertising, shopping cart.

The use of cookies does not involve the request for personal data and, in most cases, does not personally identify users.

6.2. Lifetime of cookies

The lifetime of a cookie can vary significantly depending on the purpose for which it is placed. Some cookies are used exclusively for a single session (session cookies) and will be deleted from your hard drive immediately after your browsing session. They are temporarily stored in the cookie file of the web browser so that it remembers them until the user leaves the respective website or closes the browser window (for example when logging in/out of a web account -mail or on social networks).

Other cookies remain saved on your device’s hard drive (persistent cookies) and allow us to recognize your device on a subsequent visit to Website. These are the cookies that allow us to make our Website more user-friendly, efficient and secure. Persistent cookies also include those placed by a website other than the one the user is currently visiting (third-party cookies) that can be used anonymously to remember a user’s interests so that they are delivered advertising as relevant as possible to users.

The persistent cookies we use will expire between 30 minutes and two years after they were downloaded to your device.

You can choose to remove a cookie at any time by adjusting your web browser settings, more details on this are provided in Section 5.5 , below.

6.3. Own cookies and those placed by third parties

CTLF Ltd’s website, the websites of companies using our system, and products, applications, and services we offer may contain links to third-party websites, products, and services. Our products and services may also use or offer products or services from third parties − for example, a third‑party app. Information collected by third parties, which may include such things as location data or contact details, is governed by their privacy practices. We encourage you to learn about the privacy practices of those third parties.

• Own cookies – we use these cookies to estimate the number of unique visitors, to improve our Website and to detect the most searched words in search engines that lead to a page on the Website. These cookies are not used to target you with online marketing. We use these cookies to learn how our Website works, to make relevant improvements and to improve your browsing experience.
• Cookies placed by third parties – we also use Google Analytics and other third party analytics providers to measure how users interact with the content of our Website. These cookies “remember” what our users have done on previous pages and how they interacted with the Website. For more information about Google Analytics, visit the Google information page. For instructions on how to opt out of Google Analytics, see the dedicated section below.

6.4. Restriction and deletion of cookies

If you wish, you can restrict or delete cookies using your browser settings. However, we remind you that if the cookie settings are restricted on your device, you will no longer be able to use all the functions of our website. For example, it is possible that the option to change the language of the website no longer works correctly.

To change your browser settings, you can access the “Help” section of your browser, or you can directly access the following links:

• Microsoft Edge: https://support.microsoft.com/ro-ro/windows/%C8%99tergerea-%C8%99i-gestenarea-modulelor-cookie-168dab11-0753-043d-7c16-ede5947fc64d
• Chrome: https://support.google.com/chrome/answer/95647?hl=ro
• Safari: https://support.apple.com/ro-ro/HT201265
• Firefox: https://support.mozilla.org/ro/kb/activarea-si-deactivarea-cookieurilor
• Opera: https://help.opera.com/en/latest/web-preferences/

You can learn more about changing your settings by visiting the following link: http://www.allaboutcookies.org/manage-cookies/ .

6.5. The categories of cookies used on the Website

The cookies used on our Website are classified as follows:

• Functional or strictly necessary cookies . These cookies are essential for browsing the website and using its functions, such as moving around the page and accessing secure areas. The website cannot function properly without these cookies.
• Analytical or statistical cookies . These cookies are used to collect and report anonymous aggregate information about the number of visitors and how they use the website. These cookies collect information for statistical purposes only and use only pseudonymous cookie identifiers, which do not directly identify you.
• Targeting or marketing cookies. These cookies are used to track website visitors, to provide more relevant and attractive advertisements to the user. They are also used to limit the number of times a user sees an advertisement, as well as to help measure the effectiveness of an advertising campaign. These cookies remember that a user has visited a website and this information may be shared with other organizations such as third party marketing and advertising agencies. This means that after a user has been to a website, they may see some advertisements about that website elsewhere on the Internet. Although these cookies can track the user’s device visits to websites, they usually cannot personally identify the user.

7. Your rights regarding the processing of Personal Data

In accordance with applicable law, you have the following rights:

The right of access : You have the right to obtain confirmation from us that your Personal Data is processed by us, as well as information regarding the specifics of the processing such as: the purpose, the categories of Personal Data processed, the recipients of the Personal Data, the period for which Personal Data is kept, if we transfer it abroad and how we protect it, your rights, where we obtained the Personal Data.

The right to rectification: You have the possibility to request the rectification of your Personal Data, provided that the applicable legal requirements are respected. In the event of errors, upon notification, we will immediately correct your Personal Data.

The right to erasure: In certain cases, you have the possibility to request the deletion of Personal Data: they are no longer necessary for the purposes for which we collected and process them; you have withdrawn your consent for the processing of Personal Data and we can no longer process the Personal Data on other legal grounds; Personal Data are processed against the law; you exercise a legal right to object. We are not obliged to comply with your deletion request if the processing of Personal Data is necessary to comply with a legal obligation, or to establish, exercise or defend a right in court. There are also other circumstances in which we are not obliged to comply with this request to delete Personal Data.

Restriction of processing : You may request that we restrict the processing of your Personal Data if you dispute the accuracy of the Personal Data, for a period that allows us to verify the accuracy of the Personal Data in question; if the processing is illegal, and you object to the deletion of the Personal Data, requesting instead the restriction of its use; if we no longer need the Personal Data for the purpose of processing, but you request it for a court action; if you have objected to the processing, for the period of time in which it is checked whether our legitimate rights as operators prevail over those of the data subject.

The right to data portability : To the extent that personal data is processed based on your consent or for the execution of the contract and the processing is done by automatic means, you have the right to have your Personal Data provided to you in a structured format, used in a way current and which can be read automatically and you have the right to transmit this Personal Data to another operator. This right does not adversely affect the rights and freedoms of others.

The right to object : In certain situations, such as when we process your Personal Data based on a legitimate interest, you have the right to object to the processing of your Personal Data by us. In case of unjustified opposition, we are entitled to further process the Personal Data.

The right to object to receiving commercial messages : You can also object to the processing of your Personal Data for the purpose of sending commercial messages.

Revocation of consent : To the extent that we process your Personal Data on the basis of your consent, you may revoke or modify your consent at any time, free of charge, without affecting the lawfulness of the consent-based processing prior to its withdrawal. Personal data collected based on consent will be kept until it is withdrawn.

The right not to be subject to individual decisions : If the applicable legal provisions are respected, you have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects about you or affects you in a similar way to a significant extent. 

To exercise the rights mentioned above, please contact us at privacy@ctlf.co.uk .

8. Contact

If you have any questions or concerns regarding this Privacy Policy, which also includes our cookie policy, or its implementation, you can contact us in the following ways:

• Email: privacy@ctlf.co.uk
• Phone: +44 (0)20 3479 5700 or +44 (0)7884 696776
• Website form: https://www.twelvetransfers.co.uk/contact/
• Facebook: https://www.facebook.com/TwelveTransfers/

9. How can I delete my CTLF Account?

If you no longer wish to use the CTLF app and would like to have your account deleted the process is straight forward.You can send an email to our customer support to delete your account by emailing to info@twelve.london your request of directly in the CTLF APP in section "Menu" > "Application" > "Request Delete Account".

IMPORTANT: Due to Transport for London Regulations regarding taxi bookings the account must be not in use for 12 months and there must be not an active booking in the last 12 months in your account in order to be able to request account delete.

We reserve the right to change the provisions of this Privacy Policy without prior notice. Any change to the Privacy Policy will apply from the date it was made.

This Privacy Policy was updated on 06.08.2023.