Privacy Policy

Motorsync Ltd, registered in England & Wales (Company No. 11752015) with registered address at 5 Maltby Court, Leeds, LS15 9BA, acts as the primary data controller for the MIRA mobile application, MIRA Business portal, and associated automotive software platforms.

For finance, Mira is also a trading name of General Insurance Distribution Ltd (company no. 14329876, Key House, Christie Way, Christie Fields, Manchester, M21 7QY), a credit broker authorised by the Financial Conduct Authority (FRN 510212). General Insurance Distribution Ltd and Motorsync Ltd are responsible for the details in a finance application on Mira, and the broker or dealer arranging your finance is responsible for them once it receives your application. See the General Insurance Distribution Ltd privacy policy and our Finance information page for what an application collects and keeps.

1. Information We Collect

Information Provided Directly by You

We collect data voluntarily submitted when creating an account or using MIRA features:

• Account & Contact Details: Name, email address, contact phone number, and physical address.
• Vehicle Information: Registration marks (VRN), valuation inputs, and saved vehicle listings.
• Communications & Enquiries: Messages sent to dealerships, support tickets, and chat interactions.
• Voice Conversations with Mira: When you talk to Mira, our assistant, your voice is used to understand you and reply. We keep a written record of the conversation, like a typed chat, but never the recording.
• Biometric Verification: Facial scan data processed temporarily for identity verification during secure account access and finance onboarding.
• Verification Documents: Government-issued photo identification (driving licence, passport) and proof of address required for identity checks.

Information Collected Automatically

When accessing MIRA web or mobile interfaces, technical metadata is captured automatically:

• Precise Geolocation: GPS coordinates (with explicit device permission) used for location-based showroom check-in.
• Device Identifiers: Operating system, hardware model, browser user-agent, and IP address.
• Application Activity: Feature usage, vehicle page impressions, search filters applied, and navigation flow.
• Camera & Document Scans: Images captured via mobile device camera for licence plate recognition and document processing.

Publicly Displayed Vehicle & Dealer Information

To present a comprehensive marketplace, MIRA aggregates publicly available motor vehicle inventory from authorised dealership websites:

• Listing Information: Make, model, specification, mileage, price, vehicle history, and public vehicle imagery.
• Dealer Commercial Data: Business trading name, showroom location address, opening hours, and contact channels.

2. How We Use Your Information

We process personal data for clearly specified legitimate purposes:

• Service Delivery: Providing vehicle discovery, showroom check-in, test drive booking, and customer enquiry management.
• Identity Verification: Utilising computer vision and automated document recognition systems to prevent identity fraud and fulfil regulatory obligations.
• Automated Assistance: Powering plate recognition, smart vehicle matching recommendations, automated customer support chat, and Mira, our assistant, which answers typed and spoken questions.
• Financial Services Facilitation: Routing customer finance enquiries directly to regulated credit broker partners.
• Platform Security: Detecting suspicious activity through risk-based authentication and behavioural threat prevention.

3. Legal Basis for Processing

Under the UK General Data Protection Regulation (UK GDPR), processing is justified by:

• Contractual Necessity: Fulfilling our end-user agreement and delivering requested services.
• Legitimate Business Interests: Maintaining platform safety, optimising user experience, and personalising search features.
• Consent: Where explicit opt-in consent is provided, such as for location services or marketing communications.
• Legal Obligations: Complying with financial record-keeping, anti-fraud laws, and regulatory directives.

4. Information Sharing and Disclosure

Data is disclosed strictly under controlled safeguards to authorised entities:

• Partner Dealerships: Showrooms receive your contact details only when you submit an enquiry, request a callback, purchase a vehicle, or opt to check in at their location (sharing contact details during showroom check-in is strictly optional and may be opted out by the customer at any time).
• Finance firms: General Insurance Distribution Ltd, the credit broker trading as Mira, and the FCA-authorised broker or dealer named on the car you apply for, which receives your application and shares it with its panel of lenders.
• Sub-Processors & Service Providers: Trusted cloud infrastructure, secure storage, and SMS transactional message providers operating under data processing agreements.
• AI Service Providers: Mira's answers are produced by trusted AI providers working for us under data processing agreements. They use what you say only to answer you.
• Law Enforcement: Mandatory disclosure only when strictly required under court order or statutory requirement.

5. Data Retention Schedule

We retain personal data strictly for as long as required by operational, legal, and tax obligations.

6. Your Privacy Rights

Under UK data protection laws, you retain enforceable rights:

• Right of Access (SAR): Request full copies of your stored personal records.
• Right to Rectification: Correct inaccurate or out-of-date information.
• Right to Erasure ("Right to be Forgotten"): Delete your account and personal data yourself. Your account is paused straight away and deleted after 14 days, during which you can sign in and cancel. Records the law requires us to keep (see Section 5) are no longer linked to you and are removed when their time is up.
• Right to Data Portability: Download a copy of your data yourself, in a structured, machine-readable format (JSON) with the files you uploaded. It is usually ready in minutes and always within 7 days.
• Pausing your account: Take a break without deleting anything. You are signed out, hidden from businesses and sent nothing except emails about your account. Sign in any time to reactivate.
• Right to Withdraw Consent: Revoke marketing or geolocation consent at any time via settings.

You can pause, delete or download your account yourself: in the MIRA app under Settings, Privacy; in MIRA Business under Settings, Privacy (business owners can also pause, close or download the whole business there). Without the app you can still delete your account at motorsync.co.uk/account/delete; downloads are only in the app and MIRA Business. Each of these asks you to confirm it is you first.

For any other request, or if you need help, email info@motorsync.co.uk. Requests are handled free of charge within 30 days.

7. Data Security Measures

We employ defense-in-depth technical measures, including TLS 1.3 in-transit encryption, AES-256 at-rest database encryption, strict access control policies, and continuous security vulnerability monitoring.

8. International Data Transfers

Primary data storage facilities are located within the United Kingdom and European Economic Area (EEA). Any cross-border data transfer relies upon International Data Transfer Agreements (IDTA) or UK Standard Contractual Clauses.

When you talk to Mira, your conversation may be processed outside the UK, including in the United States, with the same safeguards. Recordings of your voice are not kept, and you can always type to Mira instead.

9. Children's Privacy

MIRA platforms are intended strictly for users aged 18 and older. We do not knowingly process personal data belonging to minors.

10. Policy Updates

We periodically review this policy to reflect platform updates or legal amendments. Material changes will be communicated through in-app notices or direct email communications.

11. Data Protection Officer Contact