Privacy Statement

Last updated: June 2026

Octobere Limited respects the privacy of clients, partners, suppliers, website visitors and portal users. This Privacy Statement explains how we collect, use, share and protect personal information when we provide airport support, travel logistics, operational support, partner services, private client support and access to the Octobere client portal.

This statement applies to www.octobere.com, the Octobere client portal, email, WhatsApp, telephone, enquiry forms, partner workflows and any other channel used to request or manage Octobere services.

1. Who we are

Octobere Limited is the data controller for the personal information we collect and use for our own business purposes. For some partner arrangements, we may also act as a data processor where we handle personal information strictly on behalf of a business partner. Where this applies, the partner agreement or data processing agreement will set out each party's responsibilities.

Registered company: Octobere Limited
Company number: 16112129
Registered office: 86-90 Paul Street, 3rd Floor, London, England, EC2A 4NE
Email: hello@octobere.com
Data protection contact: hello@octobere.com

2. Personal information we collect

The information we collect depends on the service requested. It may include:

Identity details — name, title, date of birth where needed for travel services, passenger names and traveller details.
Contact details — email address, phone number, WhatsApp number, company name, job title and billing contact details.
Travel and service details — flight numbers, airport, terminal, arrival and departure times, accommodation details, driver details, meeting points, passenger preferences and baggage requirements.
Portal data — login details, request history, messages, chat content, timestamps, status updates and files uploaded to support a request.
Payment and billing details — invoices, payment status and transaction references. We do not ask users to send full card details by email or WhatsApp.
Supplier and partner information — supplier contacts, service reports, performance information, compliance details and account records.
Technical data — IP address, browser type, device information, cookie preferences, website usage and security logs.
Marketing preferences — whether someone has agreed to receive updates from Octobere.

3. Sensitive information

Some requests may involve sensitive information. For example, wellness access, medical coordination, mobility assistance, disability access needs, dietary requirements, religious requirements, security concerns or information about children and family members.

We only collect sensitive information where it is needed to provide the requested service, where the individual has provided it to us, where we have explicit consent where required, or where another lawful condition applies. We only share sensitive information with suppliers or partners where this is necessary to deliver the service or protect the safety of the traveller or client.

4. How we collect information

Directly from clients, partners, travellers or authorised representatives.
Through the Octobere website, enquiry forms and client portal.
Through email, telephone, WhatsApp or other agreed communication channels.
From business partners who ask us to support their clients.
From suppliers and service providers who provide service updates or reports.
From publicly available sources where needed to verify business information or manage risk.

5. How we use personal information

To respond to enquiries and assess whether we can support a request.
To provide airport meet and greet, fast track, travel logistics, ground transport, accommodation support, private client services and operational coordination.
To manage partner relationships, white-label support and business membership services.
To create and manage portal accounts.
To communicate with clients, partners, suppliers, travellers and authorised representatives.
To provide updates, service confirmations, invoices, receipts and service reports.
To manage supplier performance, service quality, complaints and service recovery.
To prevent fraud, protect the security of our systems and ensure appropriate use of the portal.
To comply with legal, tax, accounting and regulatory obligations.
To send marketing communications where permitted by law and where consent has been given.

6. Lawful bases for processing

Under UK data protection law, we must have a lawful basis for using personal information. Depending on the situation, we may rely on:

Contract: to provide requested services, manage bookings, support partner agreements and communicate about active requests.
Legitimate interests: to operate our business, manage service quality, work with suppliers, improve our portal, protect security, prevent misuse and support clients effectively, where these interests are not overridden by individual rights.
Consent: for optional marketing, certain cookies and any sensitive information where explicit consent is required.
Legal obligation: to comply with tax, accounting, company law, fraud prevention and other legal requirements.
Vital interests: in rare urgent situations where processing information is necessary to protect someone's life or physical safety.

7. Who we share information with

We only share information where needed for the purposes described in this statement. This may include:

Airport meet and greet providers, fast track providers, porters and local airport agents.
Chauffeur companies, ground transport providers and security providers.
Hotels, accommodation providers, restaurants, venues and experience providers.
Travel providers, private aviation contacts and logistics partners.
Technology providers, including website hosting, portal hosting, cloud storage, communications and security tools.
Payment processors, accountants, insurers, professional advisers and legal advisers.
Business partners where we provide support under a partner or white-label arrangement.
Regulators, law enforcement or public authorities where required by law.

We do not sell personal information to third parties.

8. International transfers

Octobere provides global support, which means personal information may need to be shared with suppliers or partners outside the UK. For example, an airport agent in Dubai, New York, Paris, Doha, Singapore or another location may need passenger information to deliver a meet and greet service.

Where we transfer personal information outside the UK, we will take steps designed to protect that information. This may include using UK adequacy regulations, standard contractual clauses, the UK International Data Transfer Agreement, transfer risk assessments, contractual controls, supplier due diligence and limiting the information shared to what is necessary for the service.

9. How long we keep information

We keep personal information only for as long as necessary for the purpose it was collected, including to provide services, manage complaints, comply with accounting and tax obligations and protect our legal rights.

Enquiry records: normally up to 24 months after the last contact, unless a longer period is needed.
Client and partner account records: for the duration of the relationship and normally up to 6 years after the relationship ends.
Request and service records: normally up to 6 years after completion, to support contractual, financial and complaint handling records.
Marketing preferences: until consent is withdrawn or the contact unsubscribes.
Cookie preferences and website analytics: according to the relevant cookie duration shown in the cookie tool.
Supplier records: for the duration of the supplier relationship and normally up to 6 years after the relationship ends.

10. Security

We use appropriate technical and organisational measures to protect personal information. These may include access controls, password protection, role-based portal access, secure hosting, supplier confidentiality requirements, account monitoring and internal procedures for handling sensitive requests.

No website, portal or communication channel can be guaranteed as completely secure. Users should avoid sending full card details, passport images or sensitive information through unsecured channels unless specifically requested through an approved method.

11. User rights

Individuals have rights under UK data protection law. These may include the right to access personal information, correct inaccurate information, request deletion, restrict processing, object to processing, request portability and withdraw consent where consent is the lawful basis.

To exercise these rights, contact hello@octobere.com with the subject line "Data protection request". We may need to verify identity before responding.

12. Complaints

We encourage individuals to contact us first so we can try to resolve any concern. Individuals also have the right to complain to the UK Information Commissioner's Office if they are unhappy with how we handle personal information.

ICO website: www.ico.org.uk

13. Children and family requests

Octobere may support family travel, education, childcare-related logistics or requests involving children. We do not knowingly allow children to create portal accounts directly. Where information about children is needed, it should be provided by a parent, guardian or authorised adult, and we will only use it for the relevant request.

14. Changes to this statement

We may update this Privacy Statement from time to time. The latest version will be available on the website and will show the date it was last updated.