Legal
Privacy Policy
How we collect, use and protect your personal data, in line with UK GDPR.
Last reviewed: [Date to be confirmed]
Placeholder policy — this document is a structural draft for the VOYA Luxury demonstration build. It must be reviewed and approved by a qualified solicitor and compliance adviser before launch.
1. Who we are
VOYA Luxury [Registered company details to be confirmed] is the data controller for personal data processed through the platform, unless stated otherwise.
2. Data we collect
We collect the following categories of personal data:
- Identity data — name, date of birth, driving licence details.
- Contact data — postal address, delivery details.
- Financial data — payment card details (processed by a third-party payment provider), finance application data.
- Booking data — rental history, vehicle preferences, mileage and usage information.
- Technical data — IP address, browser type, device identifiers.
- Usage data — how you interact with the platform.
3. Lawful basis for processing
We rely on the following lawful bases under UK GDPR, depending on the processing activity:
- Performance of a contract — to process bookings and manage your account.
- Legal obligation — to meet regulatory, tax and record-keeping requirements.
- Legitimate interests — to prevent fraud, improve the platform and communicate service updates.
- Consent — for optional marketing communications, which you may withdraw at any time.
5. Data retention
Personal data is retained only for as long as necessary to fulfil the purposes for which it was collected, including any statutory retention period. Specific retention periods are to be confirmed by compliance review.
6. Your rights
Under UK GDPR you have the right to access, rectify, erase, restrict or object to processing of your personal data, and the right to data portability. You also have the right to lodge a complaint with the Information Commissioner's Office (ICO).
7. Contact us
To exercise any of your data protection rights, or for any privacy-related query, please get in touch via our Contact page.