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1. Purpose and Scope
This policy governs how Blessed Through Favors, Inc., doing business as Epic Limousine, collects, uses, protects, retains, and discloses personal information in the course of providing charter and ground transportation services.
It applies to all employees and contractors, to all information Epic receives from client organizations, and to all systems Epic uses to conduct business. It is an internal policy; the notice published on Epic’s website governs Epic’s relationship with website visitors.
2. Privacy Contact
Epic designates a Privacy Contact responsible for administering this policy, maintaining the records it requires, and serving as the point of contact for privacy questions, requests, complaints, and incidents.
3. Information Epic Collects
Epic collects only the information necessary to arrange, perform, and bill for transportation services. The categories below constitute Epic’s data inventory.
Client contacts
Name, title, work email, work phone of the booking coordinator or department staff
Client organization
Limo Anywhere; email
On-site trip contacts
Name and mobile number of the chaperone, coach, or staff lead accompanying the group
Client organization
Limo Anywhere; email
Trip information
Dates, times, pickup and drop-off locations, vehicle type, total
passenger count
Client organization
Limo Anywhere; email
Billing information
Billing contact, purchase order and invoice records
Client organization
QuickBooks; Limo Anywhere
Personnel records
Driver license details, CDL and SPAB records, background check results, drug and alcohol testing records, employment records
Employee
System
Website visitors
[Analytics data collected via epiclimosf.com, if any]
Website visitor
System
Epic does not request, require, or retain passenger rosters or lists of individual passenger names. Trips are arranged using a total passenger count and a single designated on-site contact. Epic does not collect demographic information, does not process payment card data, and does not collect information from children.
4. How Epic Uses Information
Personal information is used solely to schedule and dispatch trips, communicate with the client’s designated contacts before and during travel, invoice for services, meet regulatory recordkeeping obligations, and respond to safety or service incidents. Epic does not use client or passenger information for marketing, advertising, profiling, or any purpose unrelated to the service requested.
5. Service Providers
Epic uses Limo Anywhere as its reservation, dispatch, and trip record platform. Limo Anywhere is Epic’s only third-party service provider with access to client trip information. Epic additionally uses [Email/productivity provider] for business correspondence and [Accounting provider] for invoicing.
Epic does not sell, rent, trade, or otherwise disclose client or passenger information to advertisers, data brokers, marketing partners, or any other third party.
6. Access Control
Access to systems containing personal information is granted only to employees whose duties require it, and only at the level required. Accounts are individually assigned. Administrator-level accounts are reviewed on the schedule set out in Epic’s Privileged Access Review Procedure, and access is disabled at separation.
7. Disclosure to Clients and Third Parties
Epic discloses information to a client organization about its own trips, to its insurance carrier or legal counsel where necessary to respond to a claim, and to a regulator where required by law. Any other disclosure requires the client’s authorization.
8. Retention and Deletion
Epic retains personal information only as long as necessary for the purpose it was collected and to satisfy legal, regulatory, tax, and insurance obligations.
At the end of the applicable period, records are deleted or, where deletion is not supported by the system holding them, the personal information within them is redacted. Where a record is subject to a legal hold, litigation, or an open claim, retention is extended until the matter is resolved.
9. Security Safeguards
• Business systems are accessed over encrypted connections and protected by individually assigned credentials.
• Multi-factor authentication is enabled where the system supports it.
• Personal information is not transmitted through personal email accounts or consumer messaging applications.
• Company devices are password-protected and are kept secured in accordance with Epic’s Physical Security Policy.
• Epic operates on a paperless basis and does not maintain physical client records at its premises.
10. Personnel
Before a system account is issued, each employee acknowledges this policy in writing and completes the background and licensing checks required for their role. All staff receive an annual refresher on passenger privacy and confidentiality, and completion is recorded.
At separation, on or before the final day of work, system accounts are disabled, credentials and keys are returned, and company devices are collected. The Privacy Contact records the date accounts were disabled.
11. Incidents and Breach Notification
Any employee who suspects that personal information has been lost, disclosed to an unauthorized person, or accessed without authorization must report it to the Privacy Contact immediately, and no later than the end of that business day.
The Privacy Contact will contain the incident, determine what information was affected, notify the affected client’s designated contact without unreasonable delay, and comply with California Civil Code sections 1798.29 and 1798.82 and any other applicable breach notification law. Epic will cooperate with the client’s own investigation and notification obligations.
Epic maintains a written record of reported incidents, including those that do not require notification.
12. Legal and Law Enforcement Requests
Epic does not disclose client or passenger information to law enforcement or any third party absent a valid warrant, subpoena, court order, or other lawful process.
Any such request must be forwarded to the Privacy Contact immediately and must not be answered by the receiving employee. The Privacy Contact will seek legal review, disclose no more than the request compels, and notify the affected client’s designated contact unless legally prohibited from doing so.
13. Requests and Complaints
Individuals seeking access to, correction of, or deletion of their personal information may contact Epic at [Email] or [Phone].
Because Epic receives contact information from client organizations rather than from individuals directly, such requests will be referred to the client organization, and Epic will assist that organization in responding.
Privacy complaints are directed to the Privacy Contact, who will acknowledge them within [5] business days and, where a complaint concerns a client’s information, report it to that client.
14. Applicable Law
Epic processes personal information of California residents and complies with California Civil Code section 1798.81.5, requiring reasonable security procedures, and sections 1798.29 and 1798.82, governing breach notification. Epic falls below the applicability thresholds of the California Consumer Privacy Act but applies practices aligned with it to the personal information it holds.
Epic does not receive or process student education records subject to FERPA, does not offer services to individuals located in the European Union or China, and accordingly does not process data subject to the GDPR or PIPL.
15. Review
The Privacy Contact reviews this policy at least annually and after any material change to Epic’s systems, service providers, or applicable law. The review date and any revisions are recorded in the version history below.
