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Legal

Privacy Policy

How we collect, use and protect your personal information.

Ram Naryan Pty Ltd (ABN 76 670 898 094)

Trading as LORQEN, Affordable Chauffeur Services, Affordable Limo Services, and Affordable Wine Tours

South Australia

Version 1.0 · Last updated: 5 September 2026

Introduction

Ram Naryan Pty Ltd ("the Company", "we", "us", "our") provides chauffeur and private passenger transport services in South Australia, including airport transfers, point-to-point transfers, corporate transportation, wine and vineyard tours, weddings and event transfers, private charters, and tailored private tours. We are an accredited passenger transport operator and Centralised Booking Service.

This Privacy Policy applies to all websites operated by the Company under its trading names: LORQEN (lorqen.com.au), Affordable Chauffeur Services (affordablechauffeur.com.au), Affordable Limo Services (affordablelimos.com.au), and Affordable Wine Tours (affordablewinetours.com.au). These are trading names of the same legal entity, and all are governed by this Policy.

We are committed to protecting your personal information and being transparent about how we collect, use, store, and disclose it. Where the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs) apply to us, we comply with them. We also use the APPs to guide our privacy practices in areas where they may not legally apply to us. This Policy is also prepared having regard to the Spam Act 2003 (Cth), the Notifiable Data Breaches scheme, and our obligations as an accredited operator under South Australian passenger transport law.

By using our websites or services, you acknowledge that we will handle your personal information as described in this Policy. Where the law requires your specific consent for a particular collection, use, or disclosure of your personal information, we will request it separately at the relevant time.

Information We Collect

Depending on how you interact with us, we may collect:

  • Your name, email address, and phone number
  • Pickup and drop-off addresses
  • Booking dates, times, and journey notes
  • Payment-related information necessary to process a booking (we do not store full card details ourselves; see section 10)
  • If you request a child or booster seat, the age of the child, so an appropriate restraint can be provided (see section 07 for further detail on how we handle information relating to children)
  • If a booking involves a passenger under 18, the contact details of the parent, guardian, or other responsible adult making or authorising the booking, and of the adult travelling with the child during the trip
  • Technical information collected automatically through our websites, such as your IP address, browser type, device information, and pages visited, generally collected via cookies and similar technologies (see section 11)
  • Information you provide if you contact us directly, including via WhatsApp
  • Photographs or video of you, if you consent to us taking these during your booking for marketing purposes (see section 05 for further detail)

We do not generally collect health, medical, or other sensitive information. Where we do (for example, an accessibility requirement for a booking), we collect it only where reasonably necessary to safely deliver the requested service, with your consent, or where otherwise permitted by law.

How We Collect Your Information

We collect personal information when you:

  • Make a booking enquiry through our website contact or booking forms, by phone, by email, or via WhatsApp
  • Communicate with us about an existing or prospective booking
  • Provide information that we enter into our booking and dispatch platform (currently LimoExpress), for internal booking and dispatch purposes (see section 06)
  • Make a payment through Square (our primary payment provider) or Stripe
  • Interact with our advertising on platforms such as Google, Facebook, Instagram, WhatsApp, TikTok, or LinkedIn (see section 11)
  • Browse our websites (via cookies and similar technologies)

Where practical, we collect personal information directly from you. We may also collect your information from a third party booking on your behalf, such as a corporate client, hotel, travel agent, family member, or another transport operator. Where a booking involves a minor, we collect that minor's information from their parent, guardian, or other responsible adult, not from the minor directly (see section 07).

How We Use Your Information

We use your personal information to:

  • Respond to enquiries and provide quotations
  • Arrange, dispatch, and deliver the transport service you have booked
  • Process payments
  • Communicate with you about your booking, including changes, confirmations, and updates
  • Comply with our legal obligations, including those relating to child safety (see section 07) and our obligations as an accredited passenger transport operator
  • Improve our websites and services, and measure the effectiveness of our advertising (see section 11)

We do not use your personal information for any purpose materially different from those set out in this Policy without your consent, unless required or authorised by law.

Sharing Your Information

Disclosure to drivers and subcontracted operators. To perform a booked transport service, we disclose the passenger and trip information reasonably necessary for that purpose (currently your name and mobile number, and relevant trip details) to the assigned contractor driver or, where a trip is subcontracted, to another transport operator. This information is disclosed only for the purpose of delivering the transport service you have requested, not for any other commercial purpose. Relevant drivers must hold a current Working with Children Check (WWCC), verified through the DHS Screening Unit portal, in accordance with our Child Safe Environment Policy. Further detail on our approach to child safety, including our screening and reporting obligations, is set out in that separate Policy, available on request.

When we receive subcontracted work, a referring operator may provide us with the relevant passenger and journey information needed for us to perform that trip.

Service providers. We share limited personal information with the third-party service providers described in section 06, to the extent necessary for them to provide their services to us (for example, our booking platform, hosting provider, website developer, and payment processors).

Legal disclosures. We may disclose personal information where required or authorised by law, including to law enforcement, regulators, or courts, or to protect the safety of a passenger, including a child (see our Child Safe Environment Policy for our approach to reporting harm or risk of harm to a child).

Photography and marketing. From time to time, we may ask to take photographs or video during a booking for use in our marketing, including on our websites, our Google Business Profile, our Facebook page, Instagram, and tourism website listings. We will only do so with the specific consent of each identifiable adult appearing in the photograph or video, given at the time, which they are free to decline without affecting the transport service provided. If you or another identifiable person later changes their mind, you may ask us to remove any published image by contacting us; we will take reasonable steps to do so within the channels we control. We do not photograph or feature a passenger under 18 for marketing purposes without the express consent of their parent or legal guardian, or another adult who confirms that they have authority from the parent or legal guardian, consistent with our Child Safe Environment Policy.

We do not sell, rent, or trade your personal information to third parties for their own independent marketing or commercial purposes.

Overseas Disclosure of Your Information

We use several service providers, some of which are based overseas or may store or process information overseas. We disclose this to you in accordance with Australian Privacy Principle 8 (cross-border disclosure of personal information).

Website development and maintenance. Our website developer, based in India, may access our website systems and related customer information from India when carrying out development or maintenance work.

Website hosting. Our websites are hosted through Hostinger, which does not operate a data centre within Australia. Our website server is located in Singapore, and website backups are stored in India (Mumbai).

Booking and dispatch platform. We currently use LimoExpress for booking and dispatch purposes. LimoExpress is provided by LimoExpress LLC (Delaware, United States) and, according to its published Data Processing Agreement, is hosted in Switzerland; personal information may also be processed by LimoExpress's subprocessors in other countries. Information passed to a driver through this platform is currently limited to the passenger's name and mobile number, and relevant trip details. LimoExpress offers optional integrations with other third-party platforms (such as Gmail, Zapier, Twilio, and Booking.com); none of these are currently enabled, and we do not enable any such integration without first reviewing whether this Policy needs to be updated. If we change our booking or dispatch provider in the future, this Policy will be updated to reflect the new provider's name and hosting arrangements. Where a new provider involves a materially different arrangement, for example new categories of personal information or materially different processing, we will review and update this section before that provider receives live customer information.

Payment processing. We primarily use Square to process payments and payment links. According to Square's own Buyer Privacy Notice, your information may be disclosed to service providers overseas, including in the United States, Canada, Japan, Ireland, France, Spain, and the United Kingdom. We also hold a fully operational Stripe account, which we have not yet used to process a payment but retain because some third-party platforms we use only integrate with Stripe; Stripe may similarly process payment-related information overseas as part of its standard payment infrastructure. Neither Square nor Stripe are currently integrated directly into our websites; we currently issue invoices or payment links manually (see section 10).

Advertising platforms. Google, Meta (Facebook and Instagram), WhatsApp, TikTok, and LinkedIn are based overseas and may process information collected through their advertising and analytics tools outside Australia, in accordance with their own privacy policies (see section 11).

Where we disclose personal information overseas, we take reasonable steps to ensure the overseas recipient handles it consistently with the APPs, including by reviewing the provider's own privacy and data-handling terms where available. Where Australian Privacy Principle 8 applies, we may remain accountable for how an overseas recipient handles your personal information, even though it is processed outside Australia. You should also be aware that overseas recipients may not always be subject to privacy obligations equivalent to the APPs.

Children's Privacy and Bookings Involving Minors

Our services may include children and young people only when they travel in the vehicle with a parent, guardian, or other responsible adult. We do not offer or accept school-formal transport bookings, and we do not accept bookings for any passenger under 18 to travel without a parent, guardian, or other responsible adult in the vehicle.

Our approach to information relating to children is:

  • A minor's personal information is generally collected from the parent, guardian, or other responsible adult making or authorising the booking.
  • Where a child or booster seat is required, we ask for the child's age, so an appropriate restraint can be provided; we collect only the minimum information about a child reasonably required to safely perform the booked service.
  • Only the information reasonably required to safely perform the service is disclosed to the assigned driver.
  • Our service does not include childcare or supervision beyond what is reasonably involved in providing the booked transport.

Our broader approach to child safety, including driver screening, reporting obligations, and our Code of Conduct, is set out in our separate Child Safe Environment Policy, available on request.

Data Security

We take reasonable steps to protect the personal information we hold from misuse, interference, loss, and unauthorised access, modification, or disclosure. This includes securing our systems with appropriate access controls, and only disclosing personal information to drivers and subcontracted operators to the extent reasonably necessary to deliver a booked service.

We do not currently use in-vehicle security cameras, dashcams, or telephone call recording in connection with our services. This does not include occasional photographs or videos taken with specific consent for marketing purposes, as described in section 05. If we introduce in-vehicle cameras, dashcams, or call recording in future, we will provide appropriate notice and update this Policy before doing so.

No method of electronic storage or transmission is completely secure. While we take reasonable steps to protect your information, we cannot guarantee its absolute security.

How We Hold Your Information

Personal information we collect is generally held in our business email accounts, WhatsApp, our booking and dispatch platform (LimoExpress), payment and invoice records, and secured website or cloud-based systems provided by our service providers described in section 06.

Payments

We currently issue invoices or payment links through Square, our primary payment provider, rather than accepting payments through a direct online payment portal. We also hold a Stripe account, which is fully operational but has not yet been used to process a customer payment; we retain it because some of the third-party platforms we use only integrate with Stripe. We do not store your full payment card details; this is handled directly by Square or Stripe in accordance with their own security standards and privacy policies. At a later stage, our booking platform may be integrated directly with Square or Stripe to process payments; this Policy will be updated if that occurs.

Cookies and Online Advertising

We use online advertising and social media platforms, such as Google, Meta (Facebook and Instagram), WhatsApp, TikTok, and LinkedIn, and may use other similar platforms from time to time, to promote our services. We may also use analytics tools to understand how visitors use our websites. We do not currently conduct email or SMS marketing.

Where we have installed a cookie, pixel, or similar tracking technology from one of these platforms on our websites, it may collect information about your visit and combine it with information the platform already holds about you, in accordance with that platform's own privacy policy. Not every platform listed above necessarily has a tracking technology installed on our websites at a given time. Having a business account or advertising profile with a platform does not by itself mean it is tracking visitors to our websites. Where we do deploy a tracking pixel or similar technology, we configure it to collect only the minimum information reasonably necessary, and to prevent the collection or disclosure of sensitive information (such as health or accessibility information) through that technology:

If you would prefer not to receive targeted advertising based on your browsing activity, you can manage your ad preferences directly through each platform (for example, through Google Ads Settings or Meta's Ad Preferences), or control cookies generally through your browser settings. You can also contact us using the details in section 16 with any concerns about our use of these tools.

Data Retention and Deletion

We retain personal information only for as long as reasonably necessary for the purposes described in this Policy and to meet applicable legal, taxation, accounting, insurance, and passenger transport record-keeping obligations. Different records may be retained for different periods; financial records, such as invoices and payment records, are generally retained for at least 7 years. When personal information is no longer required, we take reasonable steps to destroy or de-identify it.

Your Rights: Access and Correction

You may request access to, or correction of, the personal information we hold about you by contacting us using the details in section 16. We will generally respond within 30 days and may need to verify your identity before providing access. There is generally no charge for making a request, though we may charge a reasonable fee for giving access, if applicable.

Complaints and Data Breaches

If you have a concern about how we have handled your personal information, please contact us using the details in section 16. We will acknowledge your complaint within 7 days and aim to provide a substantive response within 30 days. If you are not satisfied with our response, you may contact the Office of the Australian Information Commissioner.

If a complaint or concern specifically relates to the safety of a child, please refer to the complaints process in our Child Safe Environment Policy.

If we become aware of a data breach that is likely to result in serious harm, we will assess the incident in accordance with the Notifiable Data Breaches scheme and notify affected individuals and the Office of the Australian Information Commissioner where required.

Third-Party Links

Our websites may contain links to third-party websites, such as social media platforms. This Policy does not apply to those third-party websites. We encourage you to review the privacy policies of any third-party website you visit.

Contact Us

For any questions about this Policy, or to make an access, correction, or complaint request, please contact us at:

Privacy Officer, Ram Naryan Pty Ltd

Changes to This Policy

We may update this Policy from time to time to reflect changes in our practices, service providers, or the law. The updated Policy will be posted on our websites with a revised "last updated" date.

Your privacy matters

Questions about this policy, or a request to access or correct your information? Contact us and a person will handle it directly.

privacy@lorqen.com.au or +61 406 135 135

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