Noir Executive – Privacy Policy

Last updated: September 8, 2025

This Privacy Policy explains how Noir Executive (“Noir Executive,” “we,” “us,” or “our”) collects, uses, shares, and protects personal information when you visit our website, contact us by phone/WhatsApp/email/chat, or use our chauffeur and concierge services (collectively, the “Services”). By using the Services, you agree to this Policy.

If you are a resident of California, Virginia, Colorado, Connecticut, Utah (or other US states with privacy laws), or located in the EEA/UK, please see the sections titled State Privacy Rights and EEA/UK Privacy Rights for additional disclosures.

1) Information We Collect

We collect the following categories of information:

A. Identity & Contact – name, email, phone/WhatsApp number, company, billing address, job title, emergency contact.

B. Trip & Service Details – pickup/drop‑off addresses, dates/times, flight number, number of passengers, luggage, special requests (e.g., child seats), notes for chauffeur.

C. Payment & Billing – payment method, partial card details (tokenized by processor), invoice and transaction history. We do not store full card numbers; payments are processed by third‑party providers.

D. Communications & Support – messages sent via forms, chat, WhatsApp/SMS, email, and call notes (and, if disclosed, call recordings for quality and training if applicable).

E. Technical & Usage – IP address, device/browser type, pages viewed, referring pages, time on page, and general location (city/region) via cookies or similar technologies.

F. Marketing Preferences – your opt‑in/opt‑out choices for email, SMS, or WhatsApp updates.

G. Partner & Driver Data – for affiliates and chauffeurs only: onboarding information, compliance documents, and trip assignments (handled under separate agreements).

We collect information directly from you, from your organization (if booking on someone’s behalf), from publicly available sources (e.g., flight status), and from service providers (analytics, payment processors, anti‑fraud tools).

2) How We Use Information

We use personal information to:

• Provide, schedule, and manage trips and concierge requests
• Confirm bookings, send updates, and coordinate with you and your passengers
• Process payments, issue invoices, handle refunds, and prevent fraud
• Operate, maintain, and improve our website and Services (including analytics)
• Provide customer support and respond to inquiries
• Send service announcements and, with consent where required, limited marketing updates
• Comply with legal obligations and enforce our Terms & Conditions

3) Legal Bases (EEA/UK)

Where GDPR/UK GDPR applies, our processing relies on:

• Contract – to perform our agreement with you (e.g., provide the trip)
• Legitimate interests – to ensure safety, prevent fraud, improve the Services, and market similar services (balanced against your rights)
• Consent – for optional cookies/analytics or marketing where required
• Legal obligation – to maintain records and comply with law

4) How We Share Information

We share information with:

• Service Providers/Vendors – payment processors, dispatch systems, cloud hosting, email/SMS/WhatsApp delivery, analytics, and customer support tools
• Affiliates/Chauffeur Partners – to fulfill your trip in locations we serve via partners; we disclose only what is necessary for the assignment
• Corporate Clients – if your organization books or pays for your travel, certain details may be shared for billing and reporting per that relationship
• Professional Advisors – lawyers, accountants, insurers, where necessary
• Authorities – when required by law, subpoena, or to protect safety, rights, or property
• Business Transfers – in connection with a merger, asset sale, financing, or acquisition

We do not sell personal information and do not share it for cross‑context behavioral advertising as defined by the California Consumer Privacy Act (CCPA/CPRA).

5) Cookies & Similar Technologies

We use cookies, pixels, and similar tools to operate the site and understand usage. You can manage cookie preferences via your browser settings. Where required, we will honor your choices through a cookie banner.

Typical cookies:

• Strictly necessary – security, session management, form submission
• Functional – remember preferences
• Analytics – understand site performance and improve content
• Marketing (limited) – measure effectiveness of our campaigns, if enabled

Do Not Track: Our site does not currently respond to Do Not Track signals.

6) Retention

We keep personal information only as long as necessary for the purposes described above, including to meet legal, accounting, or reporting requirements. Typical retention periods: trip and invoice records up to 7 years; routine inquiries up to 24 months, unless a longer period is required by law or to establish/defend legal claims.

7) Security

We use administrative, technical, and physical safeguards designed to protect personal information, including encryption in transit, access controls, and least‑privilege practices with our vendors. No method of transmission or storage is 100% secure; we cannot guarantee absolute security.

8) Children’s Privacy

Our Services are not directed to children under 16. We do not knowingly collect personal information from children under 16. If you believe a child has provided us information, contact us and we will delete it where required by law.

9) Your Choices

• Marketing – You can opt out of email, SMS, or WhatsApp marketing at any time via the message itself or by contacting us. Service/transactional messages are still required for active bookings.
• Cookies – Manage via browser settings or our cookie banner (where available).
• Accurate Info – You may update your contact details by emailing us.

10) State Privacy Rights (US)

Depending on your state, you may have rights to request:

• Access to and a copy of your personal information
• Deletion of personal information
• Correction of inaccuracies
• Information about our data practices
• Opt out of targeted advertising, sales, or profiling (we do not sell or share for targeted advertising under CPRA definitions)

How to exercise your rights: Contact us with “Privacy Request” in the subject. We will verify your request (e.g., by confirming control of your email/phone). You may use an authorized agent as permitted by law.

California Notice at Collection: We collect the categories listed in Section 1 for the purposes in Section 2. We retain information as described in Section 6. We do not sell or share personal information as defined by the CPRA. Sensitive personal information (e.g., precise geolocation in trip context) is used only to provide services and is not used to infer characteristics.

11) EEA/UK Privacy Rights

If GDPR/UK GDPR applies, you have the right to request access, rectification, erasure, restriction of processing, portability, and to object to processing based on legitimate interests or direct marketing. Where processing is based on consent, you may withdraw consent at any time without affecting prior processing.

International transfers: We may transfer personal information to the United States and other countries. Where required, we rely on Standard Contractual Clauses or other approved safeguards.

To exercise rights, contact us. You may also lodge a complaint with a supervisory authority (e.g., the ICO in the UK or your local DPA).

12) Third‑Party Links & Services

Our site may link to third‑party websites or embed third‑party tools (e.g., payment processors, chat, analytics). This Policy does not apply to those parties. We encourage you to review their privacy policies.

13) WhatsApp/SMS and Calls

By providing your number, you agree that we may send service‑related SMS/WhatsApp messages about bookings, driver arrivals, and support. Message and data rates may apply. For marketing messages, we obtain consent where required. You can opt out at any time by replying STOP. For quality assurance, calls may be recorded where lawful and with notice.

14) Changes to This Policy

We may update this Policy from time to time. Changes take effect when posted with the “Last updated” date above. Your continued use of the Services after an update means you accept the revised Policy.