We use your personal data to arrange your journey, take payment and look after you on the road. This policy explains what we collect, why, who receives it, how long we keep it and the choices you have.
- We collect what we need to run your booking: contact details, journey details, payment status and messages.
- We do not sell your personal data.
- Card details are entered on Airwallex and are never stored by us.
- Advertising measurement and session recording run only if you allow them, and you can change your mind at any time from the Cookie settings link in the footer.
- You can ask to see, correct or delete your data by emailing concierge@chinachauffeurs.com.
- 1. Who is responsible for your data
- 2. What we collect and why
- 3. Who we share it with
- 4. Artificial intelligence tools
- 5. Advertising measurement and session recording
- 6. International transfers
- 7. How long we keep data
- 8. Your rights
- 9. Security
- 10. Children
- 11. Marketing messages
- 12. Mainland China (PIPL)
- 13. US state privacy rights
- 14. Changes to this policy
- 15. Contact and complaints
1. Who is responsible for your data
Sterling Axis Ltd, trading as China Chauffeurs (“we”, “us”), is the controller of the personal data described here. We work in mainland China through our registered operator, Shanghai Nianyao Automobile Service Co., Ltd, which handles personal data in China on our behalf and in connection with delivering your service. Contact: concierge@chinachauffeurs.com.
2. What we collect and why
| Data | Where it comes from | Why we use it | Legal basis (UK and EU GDPR) |
|---|---|---|---|
| Name, email, phone or WhatsApp number, country | You | To quote, book, contact you and issue invoices | Contract; legitimate interests in running our business |
| Journey details: dates, flight or train numbers, addresses, passengers, luggage, requests such as a child seat | You | To deliver and coordinate your service | Contract |
| Health or mobility information you choose to tell us | You | To arrange suitable assistance | Your explicit consent, given when you tell us |
| Travel document details where a service needs them, such as your name as shown on your passport and your nationality | You | Airport assistance and cross-border arrangements. We ask only for what the service requires | Contract |
| Payment and billing data: amount, currency, reference, status, method and country. Not full card numbers | You and Airwallex | To take payment, keep accounts and prevent fraud | Contract; legal obligation; legitimate interests in preventing fraud |
| Messages and attachments sent by WhatsApp, email or phone | You | To support you and keep a record of what was agreed | Contract; legitimate interests in customer service and record keeping |
| Service records: assigned driver, pickup confirmations and proof-of-service files, notes and incidents | Us and our suppliers | To deliver, check quality, and resolve disputes and safety issues | Contract; legitimate interests |
| Recordings from vehicle cameras, where fitted | Vehicle devices | Safety and resolving disputes | Legitimate interests |
| Website and device data: pages visited, language, approximate location, device and browser, and advertising click identifiers | Your browser | To make the site work, remember your choices, and, only if you allow it, measure advertising and improve pages | Legitimate interests for essential storage; your consent for advertising measurement and session recording |
If you do not give us the information we need to arrange a service, we may not be able to provide it.
3. Who we share it with
- Suppliers who deliver your service: drivers, local operators, airport assistants and guides receive only what they need, such as your name, phone number, pickup details, flight number and passenger count.
- Airwallex processes payments. It receives the amount, your name and email, and the service summary, and it collects your card details itself.
- Meta (WhatsApp Business) carries our WhatsApp messages with you.
- Google provides advertising measurement if you allow it, calendar services that we use to schedule bookings, and AI drafting tools (section 4). Apple provides an iCloud calendar we use to schedule bookings.
- Hosting and technology providers store and process our systems and records, including Railway.
- Lucky Orange provides session recording, only if you allow it (section 5).
- Professional advisers, banks, insurers and authorities where we need advice or must comply with the law, and a buyer if our business is sold.
We do not sell your personal data.
4. Artificial intelligence tools
Our staff use Google’s Gemini AI service from within our internal operations system to help draft invoice wording and client messages. Only the details needed for a draft, such as a client’s name, a summary of the journey and the message wording, are sent. Our staff review every result before anything is used or sent, and AI is not used to make decisions about you.
5. Advertising measurement and session recording
With your permission, and outside Europe, the United Kingdom and Switzerland until you choose otherwise, we use the Google tag to learn which advertisement led to an enquiry. When a Google advertisement includes a click identifier, we keep it for up to 90 days so that a confirmed paid booking can be attributed to that advertisement. If you tick the box beside the booking button, we may also send Google a one-way SHA-256 hash of the email address or phone number used for the booking. We do not send the plain contact detail for this purpose.
Session recording (Lucky Orange) runs only if you choose “Accept all” or switch it on in Customise. It records clicks, mouse movement and scrolling on some pages so that we can find confusing steps. You can choose “Essential only” or change your choice at any time using the Cookie settings link in the footer. We honour the Global Privacy Control signal from your browser as a choice not to allow these. See our Cookie Policy.
6. International transfers
We and our suppliers work in mainland China, Hong Kong, the United Kingdom and elsewhere, and some of our providers process data in other countries including the United States. Where UK or EU data protection law requires it, we rely on adequacy decisions, standard contractual clauses or the UK international data transfer agreement or addendum, or, where it applies, on the transfer being necessary to perform your contract with us.
7. How long we keep data
| Data | How long |
|---|---|
| Booking, invoice and payment records | 6 years after the end of the tax year they relate to, as accounting and tax law requires |
| Enquiries that do not become bookings, and WhatsApp conversations | Up to 24 months after the last message |
| Proof-of-service files uploaded by suppliers | Up to 24 months after the service |
| Advertising click identifiers | Up to 90 days |
| Backups of our booking system | Up to about a year |
| Records of your privacy choices | As long as needed to show what you chose |
We may keep data for longer where needed for legal claims, disputes or legal obligations, and we delete or anonymise data when it is no longer needed.
8. Your rights
Depending on where you live, you may have the right to access your data, have it corrected or deleted, restrict or object to our use of it, receive it in a portable format, and withdraw consent at any time. To use a right, email concierge@chinachauffeurs.com. We will reply within one month. We may need to verify your identity. We do not make decisions about you using only automated processing.
9. Security
We protect data with measures that suit its sensitivity, including encrypted connections (HTTPS), restricted sign-in for our operations systems, and cryptographic protection of payment links. Payment card details are handled by Airwallex and are not stored by us. No online system is completely secure, so please be careful about what you send in messages, and tell us at once if you think your data has been misused.
10. Children
Our services are for adults. Children may travel with an adult who makes the booking. We do not knowingly collect personal data from children through this website, other than the names and ages of children travelling that an adult gives us.
11. Marketing messages
We use WhatsApp, email and phone mainly to deal with your booking. We send marketing only where the law allows, for example with your consent or to existing clients about similar services. Every marketing message tells you how to opt out, and you can also ask us to stop at any time.
12. Mainland China (PIPL)
If you are in mainland China, or your personal information is handled in mainland China, we handle it in line with the Personal Information Protection Law. We process it to perform your contract, comply with the law and, where required, with your consent. Where your information is sent outside mainland China for your booking, for example to our UK company or providers, we do so where necessary for your service and, where required, with your separate consent. You may exercise your rights under that law by contacting us at the address below.
13. US state privacy rights
Residents of some US states have rights to know, correct and delete their personal information and to opt out of its sale or sharing for targeted advertising. We do not sell personal information. Advertising measurement is optional and controlled from the Cookie settings link in the footer, and we honour the Global Privacy Control signal. You may make a request by emailing us. We will not treat you unfairly for exercising your rights.
14. Changes to this policy
We may update this policy. The date above shows the current version, and we will make important changes easy to see.
15. Contact and complaints
Email concierge@chinachauffeurs.com or message us on WhatsApp at +86 195 4022 0601. If you are not satisfied with our response you may complain to your data protection authority. In the United Kingdom this is the Information Commissioner’s Office (ico.org.uk).