Privacy Policy
Wave Airport Transfer Ltd, trading as e-Wave Green Airport Transfers
Last updated: 18 August 2026 · Version 1.0
1. Who we are
Wave Airport Transfer Ltd (“e-Wave”, “we”, “us”) provides private hire and chauffeur airport transfer services in Cambridgeshire and the surrounding area. We are the data controller for the personal data described in this notice.
| Registered company | Wave Airport Transfer Ltd, incorporated in England and Wales, company no. 14003651 |
| Registered office | 30 Barleyfield Way, Huntingdon, England, PE29 1DD (as recorded at Companies House) |
| Operating address | 1010 Cambourne Business Park, Cambourne, Cambridge, Cambridgeshire, CB23 6DP — please write to us here |
| VAT number | 471 5983 58 |
| ICO registration | ZB327008 (Tier 1) |
| info@e-wave.co.uk | |
| Phone | 07983 551994 |
| Licensing authority | South Cambridgeshire District Council — private hire operator licence no. PO259183, valid to 18 May 2028 (held by Iulian Putinelu, operating as Wave Airport Transfer Ltd) |
We are a small business and are not required to appoint a Data Protection Officer. Privacy questions are handled by Iulian Putinelu, company director, at the contact details above.
2. What personal data we collect
Booking and journey data
- Name, email address, mobile number
- Pick-up and drop-off addresses, including home addresses
- Date, time, flight or train number, and arrival/departure airport
- Number of passengers, luggage, child seat requirements
- Special requests, including accessibility or mobility needs
- Notes about the journey (e.g. meeting-point instructions), and messages you send us by email, SMS or WhatsApp
Payment data
- Billing name and address, transaction amounts, dates and reference numbers
- Where we take the payment — advance payments, invoiced bookings and payments handled by the office — card transactions are processed by Lopay Ltd, which operates on the Stripe platform, and in some cases by Stripe directly. Your card details are processed by them, never by us.
- Where the driver takes the payment in the vehicle, they do so through their own card terminal or payment app, held in their own name as a self-employed business. We act only as an intermediary in arranging that payment. The driver chooses their own payment provider, so the company processing your card details in that situation is theirs rather than ours, and the transaction record is held by them and by that provider. We receive only confirmation that the fare was paid and the amount.
- If you want to know who processed a specific in-vehicle payment, or you need a receipt or a refund, contact us and we will obtain it from the driver.
- Neither we nor our drivers see or store your full card number. We hold only the transaction amount, date and reference.
- Account customers are invoiced monthly. For those accounts we hold the billing contact’s name, email address and telephone number, the invoice address, purchase order or cost centre references, and a record of the journeys billed. Payment is by bank transfer, so we hold your bank details only as they appear on a payment we receive.
- Card details are never written down, photographed, stored on a phone, or kept in a booking record.
Corporate account data
- Where your employer or travel booker books on your behalf, we receive your name, contact details and journey details from them, plus a cost centre or booking reference. We also hold contact details for account administrators and finance contacts.
Website data
- IP address, browser and device type, pages viewed and referring site, collected through cookies and similar technologies. See section 10.
Driver and vehicle records (licence conditions)
- As a licensed private hire operator we are required to keep records of every driver we engage — full name, permanent address, date of birth, private hire badge number and the dates their engagement started and ended — and of every vehicle we take bookings for, including the proprietor’s name and address. These records must be produced to an authorised Council officer or a police constable on request.
- If you apply to drive with us, we also collect your CV, DVLA licence details, private hire badge details, right-to-work documents and DBS status.
In-vehicle cameras (CCTV)
- Our vehicles are fitted with a CCTV system to the specification required by South Cambridgeshire District Council, which mandates CCTV in all licensed hackney carriage and private hire vehicles. Recording takes place automatically while the vehicle is in use.
- South Cambridgeshire District Council is the data controller for this footage, not e-Wave. The Council is registered with the ICO and the footage is encrypted and inaccessible to us in normal use. It is released only in the specific circumstances set out in the Council’s own privacy notice and standard operating procedure, published on scambs.gov.uk.
- We cannot view, copy, download or supply this footage. If you want to make a subject access request for footage, or object to the recording, it must go to South Cambridgeshire District Council rather than to us.
- A Council-issued internal vehicle notice is displayed in each vehicle.
- We do not operate any cameras of our own in addition to the Council’s system.
Health and accessibility information
- We do not ask for health or medical information. If you choose to tell us about a mobility requirement or an assistance dog so that we can send a suitable vehicle, we record only what is needed to carry out the journey, use it for that purpose alone, and delete it with the rest of the booking record.
3. Why we use your data, and our lawful basis
| What we do | Lawful basis under UK GDPR |
|---|---|
| Take, confirm and carry out your booking; allocate a driver; contact you about pick-up | Performance of a contract (Art. 6(1)(b)) — or legitimate interests where the contract is with your employer |
| Track flight numbers so we can adjust pick-up times | Performance of a contract |
| Take payment, issue monthly invoices to account customers, and chase unpaid accounts | Contract; legal obligation; legitimate interests |
| Keep booking, driver, vehicle and complaint records, and produce them to the Council or police on request | Legal obligation (Art. 6(1)(c)) — conditions of our private hire operator licence |
| Keep accounting and VAT records | Legal obligation (Art. 6(1)(c)) |
| Respond to enquiries, complaints and lost-property queries | Legitimate interests (Art. 6(1)(f)) — running and improving our service |
| Passenger and driver safety, insurance claims and incident investigation | Legitimate interests — the safety of passengers and drivers; legal obligation where a claim or police request applies. (Licensed-vehicle CCTV is handled by South Cambridgeshire District Council as controller — see section 2.) |
| Invite you to leave a review, or send occasional service updates and offers | Consent, or legitimate interests where you are an existing customer and can opt out at any time (PECR soft opt-in) |
| Analytics and advertising cookies | Consent (PECR reg. 6) |
You can withdraw consent at any time by emailing info@e-wave.co.uk. Withdrawing consent does not affect processing already carried out.
4. Where your data comes from
Directly from you when you book, call, email or use our website; from your employer, travel manager or PA when they book for you; and from booking partners, hotels or agents who pass us a job. We may also receive flight status data from public flight-tracking services, matched to the flight number you gave us.
5. Who we share your data with
We do not sell your personal data. We share it only with:
- Our dispatch and booking platform — Insoftdev Ltd (Smart Car / booking system), which hosts our booking records
- Payment processing — Lopay Ltd (operating on the Stripe platform) and Stripe Payments UK Ltd for payments we take. For payments taken in the vehicle, the driver’s own payment provider, which varies by driver.
- Our drivers, who receive only the details needed for your journey (name, phone number, addresses, time, flight number) and are required to keep it confidential and not to use it for any other purpose.
- Other licensed private hire operators, where we sub-contract a booking at peak times or for overflow work. We remain responsible for the booking, we record that it was sub-contracted, and we keep a record of the checks we made that the other operator is correctly licensed. Only the details needed to carry out the journey are passed on.
- Website and email providers — Hostinger (website hosting), Google Workspace (our info@e-wave.co.uk email), Amazon SES (newsletter delivery), and the analytics and advertising providers listed in our cookie notice
- Our accountant, insurers and professional advisers
- Public authorities — the police, our licensing authority, HMRC or other regulators where we are legally required or permitted to disclose
- A buyer — if the business is sold or reorganised, personal data may transfer to the new owner, who will remain bound by this notice
Where we act on behalf of a corporate client, we may confirm journey details, dates and costs back to that client for billing and duty-of-care purposes.
6. International transfers
We do not transfer your data overseas ourselves. Some of the technology suppliers we rely on — for example our email and analytics providers — are US-based and may store or process data outside the UK. Where that happens, the transfer is covered by the UK Addendum to the EU Standard Contractual Clauses or the UK–US data bridge, so your data receives an equivalent level of protection. You can ask us for details.
7. How long we keep it
| Data | Retention |
|---|---|
| Booking and journey records | 5 years from the date of the booking — this is a condition of our private hire operator licence, which requires a full booking record (hirer’s name, pick-up and destination, times, vehicle and driver) to be kept and produced to the Council or a police officer on request |
| Invoices, payment and accounting records | 6 full financial years plus the current year (HMRC requirement) |
| Enquiries that don’t result in a booking | 12 months |
| Complaints and incident records | 6 years (the limitation period for bringing a claim). Complaint records are also made available to authorised Council officers during an investigation, as our operator licence requires |
| In-vehicle CCTV footage | Held and retained by South Cambridgeshire District Council under its own retention rules — not by us |
| Marketing contacts | Until you unsubscribe, then a suppression record only |
| Driver and vehicle records required by our operator licence | Kept for the period the Council requires, and produced to authorised officers or police on request |
| Unsuccessful driver applications | 6 months |
8. How we keep it safe
Access to booking records is limited to the people who need it. Our systems are password-protected with multi-factor authentication where available, our website uses HTTPS, and devices carrying customer data are encrypted and PIN-locked. Drivers receive job details through the dispatch app rather than by open message wherever possible. If a breach occurs that is likely to risk your rights and freedoms, we will report it to the ICO within 72 hours and tell you where required.
9. Your rights
Under UK data protection law you have the right to: be informed; access a copy of your data; have inaccurate data corrected; have data erased; restrict processing; data portability; object to processing based on legitimate interests, and to direct marketing at any time; and not to be subject to solely automated decisions with legal or similarly significant effects. We do not carry out automated decision-making or profiling of that kind.
To exercise any right, email info@e-wave.co.uk. We will respond within one month and will not charge a fee in normal circumstances. We may ask you to verify your identity.
If you are unhappy with how we have handled your data, please tell us first so we can put it right. You can also complain to the Information Commissioner’s Office: ico.org.uk/make-a-complaint, or 0303 123 1113.
10. Cookies
Our website uses cookies. Some are essential for the site to work — they keep the booking form functioning and remember your session. Others help us understand how the site is used and measure our advertising, including cookies set by Google Analytics and Google Ads.
You can block or delete cookies at any time through your browser settings. Blocking essential cookies may stop parts of the booking form working.
11. Children
Our service is not aimed at children, and we do not knowingly collect data from anyone under 16 except where a parent or guardian books travel that includes a child passenger.
12. Changes to this notice
We review this notice at least annually. The date at the top shows when it was last changed. Material changes will be notified by email to customers with an active booking or account.
1. Who we are
Wave Airport Transfer Ltd (“e-Wave”, “we”, “us”) provides private hire and chauffeur airport transfer services in Cambridgeshire and the surrounding area. We are the data controller for the personal data described in this notice.
| Registered company | Wave Airport Transfer Ltd, incorporated in England and Wales, company no. 14003651 |
| Registered office | 30 Barleyfield Way, Huntingdon, England, PE29 1DD (as recorded at Companies House) |
| Operating address | 1010 Cambourne Business Park, Cambourne, Cambridge, Cambridgeshire, CB23 6DP — please write to us here |
| VAT number | 471 5983 58 |
| ICO registration | ZB327008 (Tier 1) |
| info@e-wave.co.uk | |
| Phone | 07983 551994 |
| Licensing authority | South Cambridgeshire District Council — private hire operator licence no. PO259183, valid to 18 May 2028 (held by Iulian Putinelu, operating as Wave Airport Transfer Ltd) |
We are a small business and are not required to appoint a Data Protection Officer. Privacy questions are handled by Iulian Putinelu, company director, at the contact details above.
2. What personal data we collect
Booking and journey data
- Name, email address, mobile number
- Pick-up and drop-off addresses, including home addresses
- Date, time, flight or train number, and arrival/departure airport
- Number of passengers, luggage, child seat requirements
- Special requests, including accessibility or mobility needs
- Notes about the journey (e.g. meeting-point instructions), and messages you send us by email, SMS, WhatsApp or through our website chat
Payment data
- Billing name and address, transaction amounts, dates and reference numbers
- Where we take the payment — advance payments, invoiced bookings and payments handled by the office — card transactions are processed by Lopay Ltd, which operates on the Stripe platform, and in some cases by Stripe directly. Your card details are processed by them, never by us.
- Where the driver takes the payment in the vehicle, they do so through their own card terminal or payment app, held in their own name as a self-employed business. We act only as an intermediary in arranging that payment. The driver chooses their own payment provider, so the company processing your card details in that situation is theirs rather than ours, and the transaction record is held by them and by that provider. We receive only confirmation that the fare was paid and the amount.
- If you want to know who processed a specific in-vehicle payment, or you need a receipt or a refund, contact us and we will obtain it from the driver.
- Neither we nor our drivers see or store your full card number. We hold only the transaction amount, date and reference.
- Account customers are invoiced monthly. For those accounts we hold the billing contact’s name, email address and telephone number, the invoice address, purchase order or cost centre references, and a record of the journeys billed. Payment is by bank transfer, so we hold your bank details only as they appear on a payment we receive.
- Card details are never written down, photographed, stored on a phone, or kept in a booking record.
Corporate account data
- Where your employer or travel booker books on your behalf, we receive your name, contact details and journey details from them, plus a cost centre or booking reference. We also hold contact details for account administrators and finance contacts.
Website data
- IP address, browser and device type, pages viewed and referring site, collected through cookies and similar technologies. See section 10.
Driver and vehicle records (licence conditions)
- As a licensed private hire operator we are required to keep records of every driver we engage — full name, permanent address, date of birth, private hire badge number and the dates their engagement started and ended — and of every vehicle we take bookings for, including the proprietor’s name and address. These records must be produced to an authorised Council officer or a police constable on request.
- If you apply to drive with us, we also collect your CV, DVLA licence details, private hire badge details, right-to-work documents and DBS status.
In-vehicle cameras (CCTV)
- Our vehicles are fitted with a CCTV system to the specification required by South Cambridgeshire District Council, which mandates CCTV in all licensed hackney carriage and private hire vehicles. Recording takes place automatically while the vehicle is in use.
- South Cambridgeshire District Council is the data controller for this footage, not e-Wave. The Council is registered with the ICO and the footage is encrypted and inaccessible to us in normal use. It is released only in the specific circumstances set out in the Council’s own privacy notice and standard operating procedure, published on scambs.gov.uk.
- We cannot view, copy, download or supply this footage. If you want to make a subject access request for footage, or object to the recording, it must go to South Cambridgeshire District Council rather than to us.
- A Council-issued internal vehicle notice is displayed in each vehicle.
- We do not operate any cameras of our own in addition to the Council’s system.
Health and accessibility information
- We do not ask for health or medical information. If you choose to tell us about a mobility requirement or an assistance dog so that we can send a suitable vehicle, we record only what is needed to carry out the journey, use it for that purpose alone, and delete it with the rest of the booking record.
3. Why we use your data, and our lawful basis
| What we do | Lawful basis under UK GDPR |
|---|---|
| Take, confirm and carry out your booking; allocate a driver; contact you about pick-up | Performance of a contract (Art. 6(1)(b)) — or legitimate interests where the contract is with your employer |
| Track flight numbers so we can adjust pick-up times | Performance of a contract |
| Take payment, issue monthly invoices to account customers, and chase unpaid accounts | Contract; legal obligation; legitimate interests |
| Keep booking, driver, vehicle and complaint records, and produce them to the Council or police on request | Legal obligation (Art. 6(1)(c)) — conditions of our private hire operator licence |
| Keep accounting and VAT records | Legal obligation (Art. 6(1)(c)) |
| Respond to enquiries, complaints and lost-property queries | Legitimate interests (Art. 6(1)(f)) — running and improving our service |
| Passenger and driver safety, insurance claims and incident investigation | Legitimate interests — the safety of passengers and drivers; legal obligation where a claim or police request applies. (Licensed-vehicle CCTV is handled by South Cambridgeshire District Council as controller — see section 2.) |
| Invite you to leave a review, or send occasional service updates and offers | Consent, or legitimate interests where you are an existing customer and can opt out at any time (PECR soft opt-in) |
| Analytics and advertising cookies | Consent (PECR reg. 6) |
You can withdraw consent at any time by emailing info@e-wave.co.uk. Withdrawing consent does not affect processing already carried out.
4. Where your data comes from
Directly from you when you book, call, email or use our website; from your employer, travel manager or PA when they book for you; and from booking partners, hotels or agents who pass us a job. We may also receive flight status data from public flight-tracking services, matched to the flight number you gave us.
5. Who we share your data with
We do not sell your personal data. We share it only with:
- Our dispatch and booking platform — Insoftdev Ltd (Smart Car / booking system), which hosts our booking records
- Payment processing — Lopay Ltd (operating on the Stripe platform) and Stripe Payments UK Ltd for payments we take. For payments taken in the vehicle, the driver’s own payment provider, which varies by driver.
- Our drivers, who receive only the details needed for your journey (name, phone number, addresses, time, flight number) and are required to keep it confidential and not to use it for any other purpose.
- Other licensed private hire operators, where we sub-contract a booking at peak times or for overflow work. We remain responsible for the booking, we record that it was sub-contracted, and we keep a record of the checks we made that the other operator is correctly licensed. Only the details needed to carry out the journey are passed on.
- Website and email providers — Hostinger (website hosting), Google Workspace (our info@e-wave.co.uk email), Amazon SES (newsletter delivery), and the analytics and advertising providers listed in our cookie notice
- Our accountant, insurers and professional advisers
- Public authorities — the police, our licensing authority, HMRC or other regulators where we are legally required or permitted to disclose
- A buyer — if the business is sold or reorganised, personal data may transfer to the new owner, who will remain bound by this notice
Where we act on behalf of a corporate client, we may confirm journey details, dates and costs back to that client for billing and duty-of-care purposes.
6. International transfers
We do not transfer your data overseas ourselves. Some of the technology suppliers we rely on — for example our email and analytics providers — are US-based and may store or process data outside the UK. Where that happens, the transfer is covered by the UK Addendum to the EU Standard Contractual Clauses or the UK–US data bridge, so your data receives an equivalent level of protection. You can ask us for details.
7. How long we keep it
| Data | Retention |
|---|---|
| Booking and journey records | 5 years from the date of the booking — this is a condition of our private hire operator licence, which requires a full booking record (hirer’s name, pick-up and destination, times, vehicle and driver) to be kept and produced to the Council or a police officer on request |
| Invoices, payment and accounting records | 6 full financial years plus the current year (HMRC requirement) |
| Enquiries that don’t result in a booking | 12 months |
| Complaints and incident records | 6 years (the limitation period for bringing a claim) |
| In-vehicle CCTV footage | Held and retained by South Cambridgeshire District Council under its own retention rules — not by us |
| Marketing contacts | Until you unsubscribe, then a suppression record only |
| Driver and vehicle records required by our operator licence | Kept for the period the Council requires, and produced to authorised officers or police on request |
| Complaint records | Kept as required by our operator licence and made available to authorised officers during an investigation |
| Unsuccessful driver applications | 6 months |
8. How we keep it safe
Access to booking records is limited to the people who need it. Our systems are password-protected with multi-factor authentication where available, our website uses HTTPS, and devices carrying customer data are encrypted and PIN-locked. Drivers receive job details through the dispatch app rather than by open message wherever possible. If a breach occurs that is likely to risk your rights and freedoms, we will report it to the ICO within 72 hours and tell you where required.
9. Your rights
Under UK data protection law you have the right to: be informed; access a copy of your data; have inaccurate data corrected; have data erased; restrict processing; data portability; object to processing based on legitimate interests, and to direct marketing at any time; and not to be subject to solely automated decisions with legal or similarly significant effects. We do not carry out automated decision-making or profiling of that kind.
To exercise any right, email info@e-wave.co.uk. We will respond within one month and will not charge a fee in normal circumstances. We may ask you to verify your identity.
If you are unhappy with how we have handled your data, please tell us first so we can put it right. You can also complain to the Information Commissioner’s Office: ico.org.uk/make-a-complaint, or 0303 123 1113.
10. Cookies
Our website uses cookies. Some are essential for the site to work — they keep the booking form functioning and remember your session. Others help us understand how the site is used and measure our advertising, including cookies set by Google Analytics and Google Ads.
You can block or delete cookies at any time through your browser settings. Blocking essential cookies may stop parts of the booking form working.
11. Children
Our service is not aimed at children, and we do not knowingly collect data from anyone under 16 except where a parent or guardian books travel that includes a child passenger.
12. Changes to this notice
We review this notice at least annually. The date at the top shows when it was last changed. Material changes will be notified by email to customers with an active booking or account.
