Data Protection & GDPR Compliance, Version 1.1, Effective February 2026
Avant Drive / LUXLINE RESERVE LTD, 301 PT 3rd Floor, Castlemead, Lower Castle Street, Bristol, Company Registration 16442367
Data protection enquiries: Bookings@AvantDrive.co.uk, +44 7300 512515, ICO: ico.org.uk / 0303 123 1113
1.1 This Privacy Policy explains how Avant Drive / LUXLINE RESERVE LTD (company registration number 16442367), registered in England and Wales at 301 PT 3rd Floor, Castlemead, Lower Castle Street, Bristol ("Company", "we", "us", "our"), collects, uses, stores, shares and protects your personal data in connection with our vehicle rental services.
1.2 We are the data controller for the purposes of the UK GDPR, the Data Protection Act 2018, and the Data (Use and Access) Act 2025. We handle your personal data lawfully, fairly and transparently.
1.3 Data Protection Enquiries. For all data protection enquiries, contact Bookings@AvantDrive.co.uk or write to the registered office above.
1.4 Supervisory Authority. The Information Commissioner’s Office (ICO) is the UK supervisory authority. You may contact the ICO at ico.org.uk or 0303 123 1113.
1.5 Related Documents. This Privacy Policy should be read alongside our Terms and Conditions, which incorporate it by reference. Together these documents govern your relationship with us.
2.1 Identity Data. Full name, date of birth, nationality, gender, signature, and photographic ID (passport, driving licence).
2.2 Contact Data. Postal address, email, telephone numbers, emergency contact details, and delivery/collection address where that service is used.
2.3 Driving Data. Driving licence number, issuing authority, categories, endorsements, penalty points, driving history and DVLA check code results.
2.4 Financial Data. Payment card details processed securely via our payment processor (including reservation fees and card-on-file for post-rental charges), bank account details for deposit returns, billing address and transaction records. We do not store full card details on our own systems.
2.5 Vehicle Telematics Data. GPS location (real-time and historical), speed, acceleration/braking, engine diagnostics, mileage, route history, ignition status and geofence alerts, collected continuously during the rental via on-board devices.
2.6 Camera Footage. All vehicles have at least a forward-facing dashcam recording continuously (video only, no audio). Some vehicles may have cabin cameras where disclosed at handover and legally permitted. Footage may incidentally include other road users.
2.7 Communication Data. Records of correspondence including emails, call recordings (where notified), WhatsApp messages and notes from in-person interactions.
2.8 Document Data. Copies of uploaded documents including proof of address, proof of identity, insurance certificates and supplementary documentation.
2.9 Technical Data. IP address, browser type, device information and website usage data collected when you use our website or booking systems.
2.10 Delivery and Collection Data. Where you use our optional delivery or collection service, the address and access/logistical details necessary to fulfil it, used solely for that purpose.
We rely on the following lawful bases under Article 6 of the UK GDPR:
| Lawful basis | Processing activity |
|---|---|
| Contract (Art. 6(1)(b)) | Processing your booking, verifying identity and credentials, administering the rental agreement, processing payments (reservation fees and card-on-file charges), managing collection and return, and communicating with you including 24-hour pre-charge notifications. |
| Legitimate Interest (Art. 6(1)(f)) | GPS and telemetry monitoring for security and theft prevention, speed monitoring for insurance compliance, camera recording for accident evidence, fraud prevention, debt recovery, delivery/collection logistics, and improving our services. |
| Legal Obligation (Art. 6(1)(c)) | Road traffic legislation, law enforcement requests, DVLA checks, insurance requirements, financial record-keeping and court orders. |
| Consent (Art. 6(1)(a)) | Marketing communications, optional cookies, and any processing not covered by another basis. You may withdraw consent at any time. |
3.2 Legitimate Interest Assessments. Where we rely on legitimate interests, we have conducted a balancing test to ensure our interests do not override your rights and freedoms.
4.1 GPS Tracking. All vehicles are fitted with GPS devices recording location, speed, direction and engine status in real time, continuously from when the vehicle leaves our premises until return.
4.2 Purpose of GPS Tracking. Vehicle security and theft recovery, ensuring the vehicle stays within permitted territories, monitoring speed/insurance compliance, calculating mileage and excess charges, verifying collection/return times, and providing roadside assistance.
4.3 Camera Recording. A forward-facing dashcam records continuously (video only). Some vehicles may also have cabin cameras, disclosed at handover. Footage is used for establishing liability, evidencing condition, deterring reckless driving and supporting insurance claims.
4.4 Speed Monitoring and Immobilisation. Telemetry monitors speed in real time. Where fitted, we may activate speed-limiting or immobilisation in circumstances set out in the Rental Agreement. Speed data may be shared with our insurer.
4.5 Data Protection Impact Assessment. We have conducted a DPIA in relation to our vehicle monitoring systems, as required under Article 35 of the UK GDPR.
5.1 Booking Administration. Processing and confirming reservations, verifying identity and eligibility, preparing rental agreements and managing your account.
5.2 Payment Processing. Taking rental and reservation payments, processing deposits, issuing refunds, sending pre-charge notifications, processing post-rental charges to your card on file, and recovering outstanding charges.
5.3 Vehicle Protection. Monitoring location and condition, preventing theft and unauthorised use, enforcing territorial restrictions and recovering vehicles where the agreement is terminated.
5.4 Insurance Compliance. Sharing relevant data with our insurer to maintain cover, providing evidence for claims, and monitoring driving behaviour for policy compliance.
5.5 Legal and Regulatory. Responding to lawful requests from law enforcement, complying with court orders and motoring legislation, and responding to Notices of Intended Prosecution.
5.6 Dispute Resolution. Using telematics, camera footage and communication records to resolve disputes over condition, accidents, mileage, charges or alleged breaches.
5.7 Delivery and Collection. Where arranged, using your contact and location data to coordinate and fulfil delivery or collection at the agreed location and time.
6.1 We may share your data with the following recipients, only to the extent necessary and with appropriate safeguards:
6.2 Insurance Providers. Our motor insurer, for maintaining cover, processing claims and policy compliance, including identity, driving, telematics and camera data where relevant.
6.3 Law Enforcement and Regulatory Bodies. Police, DVLA, local authorities and courts where required by law or where we have a lawful basis, including responding to NIPs and reporting suspected theft.
6.4 Payment Processors. Our payment processor handles card transactions and card-on-file retention. We do not store full card details ourselves. Processing is under written agreements with appropriate security.
6.5 Fleet Management and Telematics Providers. Third-party platforms hosting GPS and telemetry data on our behalf, acting as processors under written agreements.
6.6 Professional Advisors. Solicitors, accountants, auditors and debt recovery agents where necessary for legal, financial or collection purposes.
6.7 Vehicle Recovery Agents. Professional recovery services where a vehicle must be recovered following termination or suspected theft.
6.8 We do not sell your personal data, and do not share it with marketing companies or advertisers without your explicit consent.
7.1 We retain personal data only as long as necessary or as required by law. Standard retention periods:
| Data category | Retention period |
|---|---|
| Booking and rental records | 6 years from end of rental |
| Identity documents (copies) | 6 years from end of rental |
| Financial and payment records | 6 years from end of rental |
| Payment card details (card on file) | Until all charges resolved and deposit released, then deleted promptly, max 90 days unless a charge or dispute extends it |
| GPS and telemetry data | 12 months from end of rental (unless needed for a dispute or claim) |
| Dashcam and camera footage | 90 days from end of rental (unless needed for a dispute, claim or proceedings) |
| Communication records | 6 years from end of rental |
| Technical and website data | 12 months from collection |
| Delivery and collection location data | 6 years from end of rental (as part of the booking record) |
| Marketing consent records | Until consent is withdrawn, plus 12 months |
7.2 Where data is subject to an ongoing dispute, claim or legal proceedings, we retain it until the matter is fully resolved.
7.3 At the end of the retention period, data is securely deleted or anonymised.
8.1 We implement appropriate technical and organisational measures to protect your data against unauthorised access, alteration, disclosure or destruction, in line with Article 32 of the UK GDPR.
8.2 Measures include encryption, access controls and secure hosting, plus staff training and written data processing agreements with processors.
8.3 Breach Notification. In the event of a breach posing a risk to your rights, we will notify the ICO within 72 hours and inform you directly without undue delay where the breach is likely to result in a high risk to you.
9.1 You have the following rights, which are not absolute and may be subject to exemptions:
9.2 Right of Access (Art. 15). Request a copy of the data we hold about you (a Subject Access Request). We respond within one calendar month; no fee for standard requests.
9.3 Right to Rectification (Art. 16). Request correction of inaccurate or incomplete data.
9.4 Right to Erasure (Art. 17). Request deletion where data is no longer necessary, consent is withdrawn, you object with no overriding grounds, or data was unlawfully processed, except where we must retain it for legal or contractual obligations.
9.5 Right to Restrict Processing (Art. 18). Request restriction in certain circumstances, such as where you contest accuracy.
9.6 Right to Data Portability (Art. 20). Where processing is by consent or contract and automated, receive your data in a structured, machine-readable format.
9.7 Right to Object (Art. 21). Object to processing based on legitimate interests; we will stop unless we show compelling grounds or need it for legal claims.
9.8 Automated Decision-Making (Art. 22). Our speed monitoring uses automated thresholds that may trigger alerts or immobilisation. You may request human review of any significant automated decision.
9.9 Right to Withdraw Consent. Where we rely on consent, you may withdraw it at any time; this does not affect prior lawful processing.
9.10 Exercising Your Rights. Contact Bookings@AvantDrive.co.uk or write to our registered office. We respond within one calendar month and may request proof of identity.
10.1 Your data is primarily stored and processed within the United Kingdom. Where transferred outside the UK, we ensure appropriate safeguards in accordance with the UK GDPR.
11.1 Our website uses cookies in accordance with PECR 2003 as amended by the Data (Use and Access) Act 2025. Strictly necessary cookies do not require consent; non-essential cookies (analytics, marketing) are only placed with your consent.
11.2 You can manage cookie preferences via our cookie tool or your browser settings. Disabling some cookies may affect website functionality.
12.1 Our services are not directed at persons under 18, and we do not knowingly collect children’s data. If we become aware we have, we will delete it promptly.
12.2 Camera footage may incidentally capture minors as pedestrians or road users; this is retained and processed under Section 7 only for the purposes set out here.
13.1 We may update this Policy to reflect changes in our processing, legal requirements or guidance. The latest version is always available on our website.
13.2 Where changes are material, we will notify you by reasonable means before they take effect.
14.1 If you are dissatisfied with how we have handled your data, contact Bookings@AvantDrive.co.uk and we will try to resolve it.
14.2 You may also complain to the ICO at any time, ico.org.uk, 0303 123 1113, or Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.
15.1 For any questions or requests relating to this Privacy Policy or your data: Bookings@AvantDrive.co.uk, +44 7300 512515, or by post to LUXLINE RESERVE LTD, 301 PT 3rd Floor, Castlemead, Lower Castle Street, Bristol.
GPS tracking active, Telemetry monitoring, Dash cameras recording
© 2026 Avant Drive, LUXLINE RESERVE LTD, Registered in England & Wales, Co. No. 16442367
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