Privacy Policy

and General Data Protection Regulation (GDPR)

This document defines Vehicle Smart's processes and procedures for handling personal data and contains the following sections:

  • About This Document
  • Data Controller
  • Information We Hold
  • How We Store Personal Data
  • How We Use Personal Data
  • Data Retention
  • Data Deletion
  • ANPR Images
  • Subject Access Requests
  • Data Breaches
  • International Responsibilities
  • Your Legal Rights

Revision History

  • April 2018
    • 1.0 Initial version
  • June 2018
    • 1.1
      • Added GDPR Lawful Basis Definitions
      • Added finance data to the data we process
  • September 2018
    • 1.2
      • Updated information we hold and how we use that data with regards to insurance quotes
  • August 2019
    • 1.3
      • Updated information regarding ANPR image processing
  • April 2020
    • 1.4
      • Added information for processing data on API consumers
      • Updated information regarding ANPR image processing
      • Added information on legal rights
      • Added contact details
  • November 2020
    • 1.5
      • Updated information regarding vehicle data processing

Glossary

References to Vehicle Smart, we, us, our is synonymous with Vehicle Smart Ltd.

References to you, an individual, an external organisation is synonymous with any user of services provided by Vehicle Smart Ltd (either as an individual or as a business).

About This Document

This document has been created in order to define the data we hold along with the processes and procedures Vehicle Smart will follow when dealing with personal data provided to us. This is a living document which will continue to be updated as and when required and each change will be recorded in the revision history at the beginning of this document.

The Vehicle Smart website, mobile app and API service is intended for persons aged 16yrs or over and we do not knowingly collect or process data relating to anyone under 16yrs old.

It is important that you read this Privacy Policy together with any other documents that appear on our website

Data Controller

Vehicle Smart is the data controller and responsible for your personal data.

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Email: info@vehiclesmart.com

Registered Office:
Vehicle Smart Ltd
Knight Accountants
77 Bohemia Road
St Leonards on Sea
TN37 6RJ

Information We Hold

The lawful basis for data processing are set out in Article 6 of the GDPR: Lawful Basis For Data Processing. At least one of these will apply when we process personal data:

  • (a) Consent: the individual has given clear consent for you to process their personal data for a specific purpose.
  • (b) Contract: the processing is necessary for a contract you have with the individual, or because they have asked you to take specific steps before entering into a contract.
  • (c) Legal obligation: the processing is necessary for you to comply with the law (not including contractual obligations).
  • (d) Vital interests: the processing is necessary to protect someone’s life.
  • (e) Public task: the processing is necessary for you to perform a task in the public interest or for your official functions, and the task or function has a clear basis in law.
  • (f) Legitimate interest: the processing is necessary for your legitimate interests or the legitimate interests of a third party unless there is a good reason to protect the individual’s personal data which overrides those legitimate interests. (This cannot apply if you are a public authority processing data to perform your official tasks.)

The personal data we can hold for each individual is the following:

  • IP Address
  • Email Address
  • Account Activity
  • Financial Data
  • Vehicle Data

IP Address
If you have used Vehicle Smart services to search for a vehicle then we will hold a copy of your IP address. Our lawful base for processing this data falls under 'Legitimate Interest'. We have a legitimate interest in protecting our IT infrastructure and our data suppliers from abuse e.g. DDOS attacks / hacking attempts.

Email Address
If you have contacted Vehicle Smart by email then we will hold a copy of your email address. Our lawful base for processing this data falls under 'Legitimate Interest'. We have a legitimate interest in retaining your email address such that we may contact you with regards to a query you may have raised with us and for recording any communications with regards to refunds, purchase restores, product enquiries, beta testing, API services or any other account support you may need.

If you have created an account with Vehicle Smart then we will hold a copy of your email address. Our lawful base for processing this data falls under 'Consent'. By creating an account with Vehicle Smart you are giving us consent to store your email address such that it can be used to identify you when you want use Vehicle Smart services e.g. log in, data back up & data restore.

If you use Vehicle Smart to obtain an insurance quote then we will hold a copy of your email address. Our lawful base for processing this data falls under 'Legitimate Interest'. We have a legitimate interest in processing this data for our own internal metrics and reporting.

If you sign up to trial or if you are a subscriber of the Vehicle Smart API service we will hold a copy of your email address. Our lawful base for processing this data falls under 'Contract' and 'Legitimate Interest'. As part of our API service provision we will require your email address to administer your account.

Account Activity
If you have created an account with Vehicle Smart we will record your account metadata e.g. activities which include account log in, log out, performing a data back up or data restore. Our lawful base for processing this data falls under 'Consent'. By creating an account with Vehicle Smart you are giving us consent to monitor your account activities to ensure the security of all accounts held with Vehicle Smart.

If you are a consumer of the Vehicle Smart API service we will record your account metadata and all API service activity. Our lawful base for processing this data falls under 'Contract'. When opting to trial or if you are a subscriber of the Vehicle Smart API service you are giving us consent to monitor all your account activities for account administration purposes.

Financial Data
If you have used Vehicle Smart to make a purchase (e.g. vehicle checks) then we will hold a copy of your payment details and the transaction. This will include your payment details, payment status, transaction summary and any discount codes used. Our lawful base for processing this data falls under 'Legal Obligation'. We are legally obliged to record all financial transactions to comply with UK company law (Companies Act 2006).

Vehicle Data
If you use Vehicle Smart to save vehicles in the garage then we will hold a copy of this data e.g. each individual vehicle and any data associated to it. This data is not linked to any individual unless you have created an account with us at which point, your vehicles will be linked to your email address. Our lawful base for processing this data falls under 'Consent'. By creating an account with Vehicle Smart you are giving us consent to store your vehicle data such that it can be used with Vehicle Smart services e.g. data backup & data restore.

The vehicle data that can be stored by us includes all DVLA data, DVSA data, vehicle check data and any custom added data by you such as photos, nicknames and technical data.

How We Store Personal Data

All data controlled by Vehicle Smart is held within the EU on secure platforms. We use data encryption for password credentials.

How We Use Personal Data

Our priority is to keep your data private and your communications free from spam. We will never share your personal data without your consent and you will always have full control over your personal data.

How we use your personal date is defined by each data type:

IP Address
We will use your IP address for network activity logging and rate limiting.

Email Address
If you have contacted Vehicle Smart by email or if you have created an account with Vehicle Smart we will use your email address to contact you with regards to your account, for communications you have made with us regarding our services and for marketing services you have opted-in for.

If you use Vehicle Smart to obtain an insurance quote we will use your email address for our own internal metrics and reporting.

If you contact us with a query which we cannot answer then we may need to forward your query on to one of our data providers. In this instance, we may share your email address with a data provider so that they can contact you direct with an answer to your query. We will always seek your consent before passing on your contact details.

Account Activity
We use your account activity for account validation, for monitoring account activity patterns and for account administration

Financial Data
We will store your financial data for accountancy purposes to comply with UK business law.

Vehicle Data
We store your vehicle data on our secure platforms so that you can perform backup and restore functions.

Data Retention

We will retain all data for a minimum of 6 years.

Data Deletion

If you want to us delete your personal data please email us at info@vehiclesmart.com

ANPR Images

The ANPR service within the Vehicle Smart app uses a third party to process all images. ANPR images are not retained by Vehicle Smart Ltd or any third party and are deleted once processed after 7-days. ANPR images may be processed on a server hosted outside of the UK (see International Responsibilities below).

Subject Access Requests

You can request to know what data we hold about you. To do this, simply send an email request to: info@vehiclesmart.com with the details you'd like to know. We will aim to respond to all data requests within 28-days.

Please note: we will charge for requests or refuse to honour any requests which are manifestly unfounded or excessive.

Data Breaches

We take privacy and data protection very seriously. We have many protections in place already however we will not be immune to every type of malicious attack, hacking attempt or human error.

As a paid member of the Information Commissioner's Office (ICO) we are obliged to report data breaches to the ICO and to any individuals where it is likely to result in a risk to the rights and freedoms of those individuals.

If we discover a data breach, we will assess the impact and follow ICO and GDPR guidelines on reporting and investigating data breaches. We will attempt to notify any affected individuals (where possible) and inform them of the impact should we be required to do so.

International Responsibilities

Vehicle Smart Ltd and its operations are hosted almost exclusively within the UK and the EU. The only exception to this is the processing of ANPR images for which we use a third party provider hosted outside the UK. We have taken the necessary steps to ensure all personal data transferred outside the UK is protected by GDPR and we have data processing agreements with international suppliers to ensure all personal data is processed in accordance with GDPR.

Your Legal Rights

You have the right to:

Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

  • If you want us to establish the data's accuracy.
  • Where our use of the data is unlawful but you do not want us to erase it.
  • Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
  • You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.