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Privacy Notice

Last updated: 4 November 2026

This Privacy Notice explains how Luxy collects, uses, stores and protects your personal data when you visit our website, send us an enquiry or travel with us. It is written to meet the requirements of the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

1. Who we are

Luxy is a trading name of TWODOR LTD, a company registered in England and Wales (company number 12391438, VAT number 467380857), registered office 15-17 High Street, Elstree, Hertfordshire, WD6 3BY. We hold Private Hire Operator Licence number 387.

TWODOR LTD is the data controller for the personal data described in this notice. We have not appointed a Data Protection Officer because we are not required to do so; privacy questions are handled directly by our management.

2. The personal data we collect

  • Identity and contact data: your name, telephone number, email address and, if you provide it, your company name.
  • Journey data: pickup and drop-off addresses, dates and times, number of passengers and luggage, flight or train details, and any special requests.
  • Passenger data: names of other passengers you book for, and any accessibility needs you choose to tell us about (for example wheelchair use or travelling with an assistance dog).
  • Documents you upload: itineraries or other files you attach to an enquiry.
  • Booking and payment data: quotes, booking confirmations, invoices and payment status. We do not store full card numbers on our website.
  • Communications: messages you send us by telephone, WhatsApp, email or through our website, and our replies.
  • Technical data: limited information needed to keep the website secure, such as your IP address used briefly to prevent spam and abuse of our forms.

We do not intentionally collect special category data. If you share health information (such as a mobility need) we use it only to provide a suitable vehicle and assistance, with your explicit consent.

3. How and why we use your data, and our lawful basis

  • To reply to your enquiry and prepare a quote - steps taken at your request before entering into a contract (Article 6(1)(b)).
  • To arrange, carry out and invoice your journey - performance of our contract with you (Article 6(1)(b)).
  • To keep booking records required by our private hire operator licence and to meet tax and accounting rules - legal obligation (Article 6(1)(c)).
  • To keep our website and services secure, prevent fraud and handle complaints or legal claims - our legitimate interests (Article 6(1)(f)).
  • To record accessibility needs - your explicit consent (Article 9(2)(a)), which you may withdraw at any time.
  • To send you marketing - only with your consent. We do not currently send marketing messages, and will ask you first if we ever do.

We do not use your data for automated decision-making or profiling that has legal or similar effects on you.

4. Who we share your data with

We never sell your personal data. We share it only where necessary with:

  • The chauffeur assigned to your journey, who receives only the details needed to carry it out.
  • Service providers acting on our behalf, such as our website hosting, secure database and email delivery providers, and our payment provider where you pay online. They may only use your data on our instructions and must keep it secure.
  • WhatsApp (Meta Platforms), if you choose to contact us through WhatsApp. Its use of your data is governed by its own privacy policy.
  • Our professional advisers, such as accountants, insurers and lawyers.
  • The licensing authority, police or other public bodies, where we are required by law or our licence conditions to provide records.

5. International transfers

Some of our service providers may store or process data outside the UK. Where this happens, we make sure appropriate safeguards are in place, such as a UK adequacy decision or the UK International Data Transfer Agreement or Addendum to the EU Standard Contractual Clauses.

6. How long we keep your data

  • Enquiries that do not become bookings: kept for up to 12 months, then deleted.
  • Booking records: kept for at least the period required by our private hire operator licence conditions.
  • Invoices and financial records: kept for six years from the end of the financial year to which they relate, as required by HMRC.
  • Complaints and claims: kept for as long as needed to resolve them and for up to six years afterwards in case of legal claims.

When data is no longer needed, we delete it securely or anonymise it.

7. How we keep your data secure

Your enquiries are stored in a secure, encrypted database that only authorised Luxy staff can access with individual sign-in accounts. Uploaded files are kept in private storage and opened only through short-lived secure links. All data sent to and from our website is encrypted in transit. If a personal data breach occurs that is likely to put you at risk, we will tell you and the Information Commissioner's Office as required by law.

8. Your rights

Under UK data protection law you have the right to:

  • access the personal data we hold about you;
  • ask us to correct inaccurate or incomplete data;
  • ask us to delete your data, where we no longer have a reason to keep it;
  • ask us to restrict how we use your data;
  • object to our use of your data based on legitimate interests, and to any direct marketing at any time;
  • receive your data in a portable format (data portability);
  • withdraw consent at any time, where we rely on consent.

Exercising your rights is free of charge. We will reply within one month, which may be extended by two further months for complex requests; we will tell you if this applies. We may need to confirm your identity before acting on a request.

9. Cookies

Our website does not use advertising or analytics cookies. For details of the strictly necessary storage we do use, please read our Cookie Policy.

10. Children

Our booking services are intended for adults. We do not knowingly collect personal data directly from children. Where a child travels with us, their details are provided by the adult making the booking.

11. Links to other websites

Our website may link to other websites, such as WhatsApp or airport sites. We are not responsible for their privacy practices, so please read their own privacy notices.

12. Contact us and complaints

For any question about this notice or to exercise your rights, contact us by telephone or WhatsApp on +44 7777 488483, or write to TWODOR LTD, 15-17 High Street, Elstree, Hertfordshire, WD6 3BY.

If you are unhappy with how we have handled your data, please contact us first so we can try to put it right. You also have the right to complain to the Information Commissioner's Office (ICO), the UK data protection regulator, at ico.org.uk/make-a-complaint or on 0303 123 1113.

13. Changes to this notice

We may update this notice from time to time. The latest version will always be on this page, with the date it was last updated shown at the top.