TwendeCar Privacy Policy

Last updated: [Insert date]

TwendeCar respects your privacy and is committed to protecting your personal data.

This Privacy Policy explains how we collect, use, store, share, and protect information about you when you use the TwendeCar website, mobile application, services, and related features.

It also explains your rights under UK data protection law, including the UK General Data Protection Regulation and the Data Protection Act 2018.

For the purposes of data protection law, the data controller is:

1. Who This Policy Applies To

This Privacy Policy applies to people who use or interact with TwendeCar, including:

• passengers;
• drivers;
• people offering or looking for rides;
• event attendees;
• event organisers;
• website visitors;
• mobile app users;
• people contacting customer support;
• people involved in complaints, disputes, or safety reports.

It applies whether you use TwendeCar through the mobile app, website, or another supported interface.

2. What TwendeCar Does

TwendeCar is a ride-sharing platform that helps people connect with others who are already planning similar journeys.

Users may use TwendeCar to:

• search for journeys;
• search for event-related transport;
• offer spare seats;
• request seats;
• arrange pickup points;
• make or receive payments;
• communicate through the platform;
• manage journeys;
• verify identity, vehicle, or driving information;
• rate and review other users;
• report safety or behavioural concerns.

TwendeCar is intended to facilitate shared journeys and cost contributions rather than operate as an on-demand taxi service for ordinary private drivers.

3. Personal Data We Collect

We may collect different types of personal data depending on how you use TwendeCar.

3.1 Account and Profile Information

When you create or manage an account, we may collect:

• first name;
• last name;
• email address;
• telephone number;
• password or authentication credentials;
• profile photograph;
• date of birth where required;
• general home area or location;
• biography or profile description;
• account creation date;
• account status;
• verification status.

We do not intend to display your private email address, phone number, or exact home address publicly unless a feature clearly requires it and you are informed.

3.2 Identity and Verification Information

Where identity or driver verification is required, we may collect:

• identity document details;
• passport or driving licence information;
• document images;
• selfie or identity verification images;
• date of birth;
• verification outcome;
• verification provider reference;
• verification dates;
• expiry dates;
• fraud or authenticity check results.

Where practical, TwendeCar may use third-party verification providers rather than store complete identity documents itself.

We will aim to retain only the information reasonably necessary to prove that verification took place.

3.3 Driver and Vehicle Information

If you offer rides, we may collect:

• driving licence information;
• driving licence verification status;
• vehicle registration number;
• vehicle make;
• model;
• colour;
• passenger capacity;
• vehicle image;
• MOT status;
• vehicle tax information;
• insurance information;
• vehicle verification status;
• relevant expiry dates;
• vehicle-related reports.

We may obtain some vehicle information from official or authorised third-party sources, including DVLA or DVSA services where permitted.

3.4 Journey and Ride Information

When you create, request, join, or manage a journey, we may collect:

• journey origin;
• destination;
• date;
• departure time;
• pickup point;
• drop-off point;
• number of seats;
• ride contribution amount;
• event linked to the journey;
• passenger details;
• driver details;
• ride status;
• booking status;
• cancellation information;
• no-show information;
• pickup confirmation data;
• journey completion information;
• timestamps associated with journey actions.

We may also record whether a driver has:

• started travelling to a pickup point;
• arrived at a pickup point;
• confirmed a passenger pickup;
• started a journey;
• completed a journey.

3.5 Location Data

TwendeCar may process location-related information. This can include:

• approximate location;
• pickup and drop-off locations;
• selected addresses;
• map coordinates;
• route information;
• device location where permission is granted;
• journey location data if live tracking is introduced.

Precise device location will only be collected where the feature requires it and appropriate permission has been granted.

You may be able to disable device location through your phone settings, although some location-based features may then work less effectively.

TwendeCar should avoid displaying precise private residential locations publicly.

3.6 Payment Information

When payments are enabled, we may collect information such as:

• payment amount;
• currency;
• booking reference;
• payment status;
• refund information;
• payout status;
• service fee;
• transaction reference;
• payment provider identifier;
• payment date and time.

TwendeCar should not directly store full debit or credit card numbers where payments are processed by a payment provider such as Stripe.

The payment provider may process your payment details under its own privacy policy.

3.7 Messages and Communications

If you use TwendeCar messaging, we may process:

• messages sent between users;
• message timestamps;
• sender and recipient;
• conversation status;
• read status;
• attachments where supported.

Private messages should not be routinely viewed by TwendeCar staff.

However, authorised staff may access messages where reasonably necessary for purposes such as:

• investigating a safety report;
• resolving a dispute;
• investigating suspected fraud;
• complying with law;
• responding to a complaint.

Access to private communications should be limited and logged where appropriate.

3.8 Ratings and Reviews

We may collect:

• star ratings;
• written reviews;
• driver ratings;
• passenger ratings;
• review timestamps;
• reports about reviews;
• moderation outcomes.

Reviews may be visible to other users depending on the product design.

3.9 Reports, Complaints, and Safety Information

If you report another user, journey, event, message, or incident, we may collect:

• details of the report;
• category of concern;
• description;
• evidence submitted;
• related messages;
• related booking or journey;
• photographs or screenshots;
• witness information;
• admin notes;
• investigation outcome;
• account action taken.

This information may be sensitive and will be accessible only to staff who need it.

3.10 Technical and Device Information

When you use TwendeCar, we may automatically collect:

• IP address;
• device type;
• browser type;
• operating system;
• app version;
• device identifiers;
• language;
• login timestamps;
• session information;
• error logs;
• crash logs;
• security logs.

This information helps us operate, secure, and improve the service.

3.11 Website and App Usage Information

We may collect information about how you use TwendeCar, such as:

• pages or screens viewed;
• search activity;
• clicks;
• feature usage;
• journeys viewed;
• events viewed;
• session duration;
• referral source;
• app interactions.

Where analytics cookies or similar technologies require consent, we will request it where required.

4. How We Collect Your Data

We may collect personal data:

Directly from you

For example when you:

• register;
• create a profile;
• add a vehicle;
• submit verification documents;
• offer a ride;
• request a seat;
• send a message;
• make a payment;
• submit a complaint;
• contact support.

Automatically

Through:

• website logs;
• app logs;
• cookies;
• analytics tools;
• security monitoring;
• device information.

From other TwendeCar users

For example when:

• a driver names you in a report;
• a passenger reports a journey;
• another user leaves a review;
• a user identifies you in a safety complaint.

From third parties

This may include:

• payment providers;
• identity verification providers;
• mapping providers;
• vehicle verification services;
• DVLA or DVSA-authorised services;
• fraud prevention providers;
• email or notification providers.

5. Why We Use Your Personal Data

We use your personal data only where we have a lawful basis. Our purposes may include the following.

5.1 Providing the TwendeCar Service

We use your information to:

• create and manage your account;
• display your profile;
• allow you to search for rides;
• allow drivers to offer rides;
• match passengers and drivers;
• manage ride requests;
• confirm bookings;
• manage journeys;
• provide messaging;
• process payments;
• provide notifications.

The lawful basis will often be performance of a contract with you.

5.2 Safety and Trust

We may use information to:

• verify users;
• verify drivers;
• verify vehicles;
• prevent fraud;
• investigate reports;
• suspend unsafe users;
• detect misuse;
• enforce platform rules;
• protect passengers and drivers.

The lawful basis may be: legitimate interests; legal obligation; contractual necessity.

5.3 Payments and Financial Administration

We may use information to:

• process payments;
• calculate service fees;
• issue refunds;
• manage payouts;
• investigate disputed transactions;
• maintain financial records.

The lawful basis may be: performance of a contract; legal obligation.

5.4 Customer Support

We may use your information to:

• respond to support requests;
• investigate problems;
• resolve disputes;
• communicate about your account or booking.

The lawful basis may be: performance of a contract; legitimate interests.

5.5 Legal and Regulatory Compliance

We may process information where necessary to:

• comply with legal obligations;
• respond to lawful government requests;
• maintain tax or accounting records;
• investigate fraud;
• respond to court orders;
• protect legal rights.

The lawful basis is generally legal obligation.

5.6 Improving TwendeCar

We may analyse usage to:

• understand which features are popular;
• improve user experience;
• diagnose bugs;
• improve ride discovery;
• improve safety systems;
• improve performance.

The lawful basis may be legitimate interests. Where required, we will obtain consent for optional analytics technologies.

5.7 Marketing

Where permitted, we may use your contact details to tell you about:

• TwendeCar updates;
• new features;
• promotions;
• referral programmes;
• events;
• relevant journeys.

Where required, marketing communications will be based on consent. You can unsubscribe from marketing communications at any time.

Service-related messages such as booking confirmations or safety notices are not marketing and may still be sent.

6. Lawful Bases We Rely On

Depending on the activity, TwendeCar may rely on:

Contract

Where processing is necessary to provide the service you requested.

Legal obligation

Where we are required to process information by law.

Legitimate interests

Where processing is reasonably necessary for our business or safety purposes and your rights do not override those interests. Examples may include:

• fraud prevention;
• platform security;
• improving the service;
• investigating misuse;
• enforcing terms.

Consent

Where required, including potentially for:

• certain marketing communications;
• optional analytics;
• device permissions;
• optional precise location features.

You may withdraw consent at any time where consent is the lawful basis.

7. Special Category and Sensitive Data

TwendeCar does not intend to collect special category personal data unless necessary.

Special category data can include information about:

• health;
• race or ethnicity;
• religion;
• political opinions;
• sexual orientation;
• biometric data used for identification.

However, users may sometimes voluntarily include sensitive information in:

• messages;
• safety reports;
• complaints;
• accessibility requests.

We will handle such information carefully and only where there is a lawful basis to do so.

If biometric identity verification is introduced, appropriate notices and lawful bases will be provided.

8. Who We Share Personal Data With

We may share information with trusted service providers where necessary. These may include:

Payment providers

For example Stripe or another payment processor.

Identity and verification providers

To verify identity, documents, vehicles, or drivers.

Mapping and location providers

For address search, routing, distance calculation, or maps.

Hosting and infrastructure providers

For cloud hosting, databases, file storage, monitoring, and backups.

Communication providers

For email, push notifications, SMS, or other communications.

Analytics and performance providers

Where permitted.

Professional advisers

Such as: lawyers; accountants; auditors; insurers.

Law enforcement and regulators

Where required by law or reasonably necessary to protect users or prevent crime.

We do not sell personal data to advertisers.

9. Information Shared With Other TwendeCar Users

Some information must be shared to make ride-sharing work. For example, passengers may see:

• driver's first name;
• profile photo;
• rating;
• vehicle make/model;
• vehicle colour;
• registration number where appropriate;
• verification indicators;
• ride origin;
• pickup information;
• departure time.

Drivers may see:

• passenger name;
• profile photograph;
• rating;
• number of seats requested;
• agreed pickup point;
• messages.

Exact information shown should depend on the booking stage. TwendeCar should follow a minimum necessary disclosure approach.

For example, exact pickup details may only become visible after acceptance or confirmation.

10. Public Profile Information

Some profile information may be visible to other users. This may include:

• first name;
• surname initial;
• profile photograph;
• general area;
• rating;
• completed trip count;
• verification badges;
• reviews.

We should not publicly display:

• private email address;
• private telephone number;
• date of birth;
• identity document number;
• full home address.

11. Vehicle Verification Data

TwendeCar may use government or authorised third-party vehicle information services. Vehicle information may include:

• make;
• colour;
• registration;
• tax status;
• MOT status;
• year of manufacture;
• other permitted vehicle attributes.

A successful vehicle lookup does not necessarily prove: vehicle ownership; insurance; roadworthiness at all times; driving entitlement.

TwendeCar may therefore require additional checks.

12. Location Privacy

Location data requires particular care. TwendeCar should avoid showing a driver's precise home address to strangers.

Before booking, users may see: approximate area; town; postcode area; public meeting point.

After a ride is confirmed, more precise pickup information may be shared where necessary.

If live journey tracking is introduced, users will receive additional information about how it works and who can access it.

13. Retention of Personal Data

We retain personal data only for as long as reasonably necessary. Retention periods may depend on:

• account status;
• legal obligations;
• tax and accounting requirements;
• safety concerns;
• disputes;
• fraud prevention;
• limitation periods.

Example retention approach:

Account data

Retained while the account is active and for a reasonable period after closure.

Booking and journey records

May be retained for several years for legal, financial, safety, and dispute purposes.

Payment records

Retained in accordance with accounting and tax requirements.

Verification records

Retained while required to establish verification status and for appropriate fraud/safety purposes.

Messages

Retained for an appropriate period to support bookings, safety investigations, and disputes.

Safety reports

May be retained longer where necessary to protect users or defend legal claims.

TwendeCar should publish a more detailed retention schedule internally before production launch.

14. Account Deletion

You may request deletion of your TwendeCar account.

Deleting an account does not necessarily mean all information can be erased immediately. We may need to retain certain information where necessary for:

• financial records;
• legal obligations;
• fraud prevention;
• safety investigations;
• disputes;
• legal claims.

Where possible, retained data may be anonymised or restricted.

15. Your Data Protection Rights

Under UK data protection law, you may have rights including:

Right of access

You can ask for a copy of personal data we hold about you.

Right to rectification

You can ask us to correct inaccurate information.

Right to erasure

You can ask us to delete certain personal data. This right is not absolute.

Right to restrict processing

You may ask us to restrict how certain information is used.

Right to object

You may object to certain processing based on legitimate interests.

Right to data portability

You may be entitled to receive certain data in a structured, commonly used format.

Right to withdraw consent

Where processing is based on consent, you may withdraw consent.

Rights relating to automated decision-making

You may have rights where significant decisions are made solely by automated systems.

To exercise your rights, contact: privacy@twendecar.com

We may need to verify your identity before responding.

16. Automated Decision-Making

TwendeCar may use automated systems to assist with things such as:

• fraud detection;
• suspicious activity;
• pricing limits;
• ride recommendations;
• account security;
• content moderation.

We should avoid making significant legal or similarly important decisions solely through automated systems unless lawful and appropriate.

Where required by law, users will be informed and given appropriate rights to challenge such decisions.

17. Children's Privacy

TwendeCar should be intended for adults unless and until a specific youth service is designed.

For launch, the recommended minimum age is 18 years old.

Users under 18 should not independently create driver or passenger accounts.

If you later allow parents to book journeys involving children, that should be covered by a separate safeguarding and privacy design.

18. International Transfers

Some TwendeCar service providers may process personal data outside the United Kingdom.

Where personal data is transferred internationally, TwendeCar will use appropriate safeguards where required, such as:

• UK adequacy regulations;
• approved contractual safeguards;
• the UK International Data Transfer Agreement;
• UK Addendum to standard contractual clauses.

19. Security

We use reasonable technical and organisational measures to protect personal information. These may include:

• encryption in transit;
• access controls;
• role-based permissions;
• secure password hashing;
• audit logs;
• secure cloud infrastructure;
• account monitoring;
• staff access restrictions;
• secure backups;
• secret management;
• vulnerability management.

No internet service can guarantee absolute security. Users are also responsible for keeping passwords and devices secure.

20. Admin Access to User Data

TwendeCar administrators should only access personal data where required for their role. Admin access should be governed by role-based permissions. For example:

• support staff may view booking information;
• finance staff may view payment records;
• safety staff may investigate reports;
• verification staff may review submitted documents.

Access to sensitive information should be logged where appropriate. TwendeCar staff should not browse user information out of curiosity.

21. Data Breaches

If a personal data breach occurs, TwendeCar will:

• investigate the incident;
• take reasonable steps to limit harm;
• document the breach;
• notify the UK Information Commissioner's Office where legally required;
• notify affected users where required.

22. Cookies and Similar Technologies

The TwendeCar website may use cookies and similar technologies. These may include:

Essential cookies

Required for login, security, and core functionality.

Preference cookies

Used to remember settings.

Analytics cookies

Used to understand service usage.

Marketing cookies

Only if introduced and where permitted.

Where legally required, non-essential cookies will not be used until consent is obtained. A separate Cookie Policy may provide further information.

23. Push Notifications

The mobile app may send push notifications relating to:

• ride requests;
• acceptance;
• payment;
• driver arrival;
• pickup;
• journey progress;
• messages;
• cancellations;
• safety;
• account activity.

Users can manage push notification permissions in their device settings.

Some important service information may still appear inside the app even if push notifications are disabled.

24. Marketing Preferences

You can opt out of marketing communications at any time. You can use:

• unsubscribe links;
• account settings;
• privacy settings;
• direct contact with TwendeCar.

Opting out of marketing does not stop essential service messages.

25. Third-Party Links

TwendeCar may contain links to: event ticket sites; venues; payment services; external websites.

TwendeCar is not responsible for the privacy practices of third-party websites. You should review their privacy policies separately.

26. Changes to This Privacy Policy

We may update this Privacy Policy as TwendeCar changes.

If we make material changes, we may notify users through: the app; email; website notice.

The latest version will always display its effective date.

27. Complaints

If you have concerns about how TwendeCar handles personal data, contact:

We will aim to investigate and respond appropriately.

You also have the right to complain to the UK Information Commissioner's Office.

28. Contact Us

For privacy questions, data requests, or concerns: