1. Introduction

West One Concierge ("we", "us", "our") operates the West One Concierge mobile application (the "App"). This Privacy Policy explains how we collect, use, disclose, and safeguard your personal information when you use our App and related services.

We are committed to protecting your privacy in accordance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018. By using the App, you agree to the collection and use of information in accordance with this policy.

2. Data Controller

The data controller responsible for your personal data is:

West One Concierge
Email: [email protected]

3. Information We Collect

3.1 Information You Provide

• Account information: Name, email address, phone number
• Trip details: Travel destinations, dates, hotel preferences, flight details
• Emergency contacts: Name and phone number of your emergency contact
• Communications: Messages you send through the in-app chat feature
• Documents: Travel documents you upload (e.g., booking confirmations, insurance documents)
• Feedback: Testimonials and reviews you choose to submit

3.2 Information Collected Automatically

• Device information: Device type, operating system, unique device identifiers
• Push notification tokens: For delivering trip alerts and messages
• Usage data: App interactions, features used, access times

3.3 Information We Do NOT Collect

• Passport numbers or scanned passport images
• Payment card details or banking information
• Precise GPS location data
• Biometric data

4. How We Use Your Information

We use your personal data for the following purposes:

• Trip management: Planning, booking, and managing your travel itineraries
• Communication: Sending trip updates, reminders, countdowns, and responding to your enquiries
• Push notifications: Alerting you about trip updates, messages, packing reminders, and important travel information
• Document storage: Securely storing your uploaded travel documents for easy access during your trip
• Service improvement: Understanding how you use the App to improve our services
• Legal compliance: Meeting our legal and regulatory obligations

5. Legal Basis for Processing

Under UK GDPR, we process your personal data on the following legal bases:

• Contract performance: Processing necessary to fulfil our travel services to you (Article 6(1)(b))
• Legitimate interests: Improving our services and ensuring App security (Article 6(1)(f))
• Consent: Where you have given explicit consent, such as receiving marketing communications or push notifications (Article 6(1)(a))

6. Data Sharing

We may share your information with:

• Travel suppliers: Airlines, hotels, cruise lines, and tour operators to fulfil your bookings
• Our host agency: Janine Loves Travel (JLT) who processes bookings on our behalf
• Cloud service providers: For secure data storage and App hosting (AWS, Abacus AI)

We do NOT sell your personal data to third parties. We do NOT share your data with advertisers or marketing platforms.

7. Data Storage & Security

Your data is stored securely using industry-standard encryption. Documents and files are stored using Amazon Web Services (AWS) S3 with server-side encryption. Access to your data is protected by two-factor authentication (2FA) and JWT tokens.

While we implement robust security measures, no method of electronic storage is 100% secure. We cannot guarantee absolute security.

8. Data Retention

We retain your personal data for as long as your account is active or as needed to provide our services. Trip data is retained for up to 3 years after the trip completion date for reference and rebooking purposes. You may request deletion at any time (see Section 10).

9. International Transfers

Your data may be transferred to and processed in countries outside the UK (e.g., the United States for cloud hosting). Where such transfers occur, we ensure appropriate safeguards are in place, including Standard Contractual Clauses (SCCs) as approved by the UK Information Commissioner's Office (ICO).

10. Your Rights

Under UK GDPR, you have the right to:

• Access: Request a copy of the personal data we hold about you
• Rectification: Request correction of inaccurate data
• Erasure: Request deletion of your personal data ("right to be forgotten")
• Restriction: Request restriction of processing in certain circumstances
• Data portability: Receive your data in a structured, machine-readable format
• Object: Object to processing based on legitimate interests
• Withdraw consent: Where processing is based on consent, withdraw it at any time

To exercise any of these rights, please contact us at [email protected].

11. Children's Privacy

The App is not intended for children under the age of 16. We do not knowingly collect personal data from children under 16. Family trip details that include children's names are provided by their parent or legal guardian.

12. Push Notifications

We use push notifications to keep you informed about your trips, including countdown reminders, packing lists, document reminders, and messages from your travel concierge. You can disable push notifications at any time through your device settings.

13. Third-Party Services

The App may contain links to third-party services (e.g., airline check-in, hotel websites). We are not responsible for the privacy practices of these external services. We encourage you to review their privacy policies independently.

14. Cookies & Tracking

The App does not use cookies. Our admin web panel uses essential cookies only (for session authentication). We do not use analytics tracking cookies or advertising cookies.

15. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of any material changes via the App or by email. The "Last updated" date at the top of this page will be revised accordingly.

16. Complaints

If you are dissatisfied with how we handle your personal data, you have the right to lodge a complaint with the Information Commissioner's Office (ICO):

Website: ico.org.uk
Phone: 0303 123 1113

17. Contact Us

For any questions about this Privacy Policy or your personal data, please contact:

West One Concierge
Email: [email protected]