Privacy Policy

Motorsync Ltd ("we", "us", "our", or "Mira"), registered in England & Wales (Company No. 12700123), is the data controller for the Mira application and related services. We are committed to protecting your privacy and handling your data in an open and transparent manner.

This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our mobile application and services. Please read this privacy policy carefully. If you do not agree with the terms of this privacy policy, please do not access the application.

1. Information We Collect

Information you provide to us

We collect information you voluntarily provide when using our services, including:

• Account information: Name, email address, and phone number when you create an account
• Vehicle information: Vehicle registration numbers you enter for searches and valuations
• Transaction data: Information about vehicles you view, save, or enquire about
• Communications: Messages and correspondence you send through our platform, including AI chat interactions
• Biometric data: Facial images when you use our identity verification features for secure account access
• Document images: Photos of identification documents (driving licence, passport) and vehicle documents (V5C, insurance) for verification purposes

Information collected automatically

When you use our application, we automatically collect certain information, including:

• Location data: Precise GPS location when you are on or near a dealership, used to enable automatic check-in
• Device information: Device type, operating system, and browser type to ensure compatibility and security
• Usage data: Information about how you interact with our application, including pages visited, features used, and AI chat conversations
• Log data: General access information for security monitoring and troubleshooting
• Scanned information: Vehicle registration numbers captured when you use the camera to scan number plates, and text from documents you upload

Publicly available vehicle data

To provide comprehensive vehicle search results, we collect and aggregate publicly available vehicle listing information from dealer websites. This includes:

• Vehicle details: Make, model, year, mileage, price, specifications, and descriptions that dealers publicly advertise
• Dealer information: Business names, addresses, and contact details that are publicly displayed
• Vehicle images: Publicly displayed photos of vehicles from dealer listings

This publicly available data is collected, classified using AI technology, and aggregated to provide users with a comprehensive search experience across multiple dealerships. We only collect information that dealers have made publicly accessible on their websites.

2. How We Use Your Information

We use the information we collect for the following purposes:

• Provide our services: To deliver the core functionality of the MIRA app, including dealership check-in, vehicle searches, finance applications, and AI-powered assistance
• Personalisation: To automatically configure the app with the correct dealership branding when you visit a participating dealer
• Identity verification: To verify your identity using facial recognition technology (Azure AI Vision) for secure account access and finance applications
• AI-powered features: To provide license plate recognition, document scanning with OCR, intelligent chat assistance, and smart recommendations
• Communications: To send you price-drop alerts, new stock notifications, service reminders, and relevant offers based on your preferences
• Finance facilitation: To route finance applications to our authorised broker partner, Choose My Car Ltd (FRN 829450)
• Service improvement: To analyse usage patterns and improve our services through anonymised analytics
• Security: To protect against fraud using risk-based authentication, device fingerprinting, and behavioural analysis
• Legal compliance: To comply with applicable laws, regulations, and legal processes

3. Legal Basis for Processing

We process your personal data under the following legal bases as defined by the UK GDPR:

• Performance of a contract: Processing necessary to provide you with the Mira app services you have requested
• Legitimate interests: Processing necessary for our legitimate business interests, such as sending you relevant vehicle and service offers based on your activity, provided these interests do not override your fundamental rights
• Consent: Where you have given clear consent for us to process your personal data for specific purposes, such as non-essential marketing communications and cookies. You may withdraw consent at any time
• Legal obligation: Processing necessary to comply with our legal obligations

4. Information Sharing and Disclosure

We may share your information with the following categories of recipients:

• Dealerships: The dealership you are physically visiting receives relevant information to provide you with personalised service
• Finance partners: Choose My Car Ltd (FRN 829450) receives your finance application data directly. We do not store complete finance applications
• Service partners: When you explicitly request a quote, your data is shared directly with our partners including ClickMechanic, GID Ltd, and Motorway
• Service providers: Third-party vendors who perform services on our behalf, such as hosting, analytics, and customer support
• Legal requirements: When required by law, court order, or governmental authority

5. Data Retention

We retain your personal data only for as long as necessary to fulfil the purposes for which it was collected, including to satisfy any legal, accounting, or reporting requirements. This section details our data retention practices for different categories of data.

Retention Periods by Data Type

Inactive Accounts

We automatically delete inactive accounts and associated personal data after 24 months of inactivity. Before deletion, we will:

• Send a reminder email at 18 months of inactivity
• Send a final warning 30 days before deletion
• Provide instructions on how to keep your account active or download your data

Data Deletion

When data reaches the end of its retention period or you request deletion:

• Data is permanently deleted from our active systems within 30 days
• Backup copies are deleted within 90 days of the deletion request
• Some data may be retained in anonymised form for analytics purposes

Your Deletion Rights

You may request deletion of your account and personal data at any time by contacting us at info@motorsync.co.uk or using the in-app settings. Note that some data may need to be retained for legal compliance purposes as detailed above.

6. Your Privacy Rights

Under the UK GDPR, you have the following rights regarding your personal data:

• Right of access: Request a copy of the personal data we hold about you
• Right to rectification: Request correction of inaccurate or incomplete personal data
• Right to erasure: Request deletion of your personal data in certain circumstances
• Right to restriction: Request restriction of processing of your personal data
• Right to object: Object to processing of your personal data for certain purposes
• Right to portability: Request transfer of your personal data to another service provider
• Right to withdraw consent: Withdraw consent at any time where we rely on consent for processing

To exercise any of these rights, please contact us at info@motorsync.co.uk. You can also turn off all notifications instantly in the app settings.

7. Data Security

We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, alteration, disclosure, or destruction. These measures include:

• Encryption of your data both when it is being transmitted and when it is stored
• Secure login systems with optional two-factor authentication for added protection
• Your sensitive information is stored securely on your device using built-in security features
• Intelligent security monitoring to detect and prevent unauthorised access
• Regular security assessments and testing by qualified professionals
• Continuous monitoring of our systems for security events
• Ongoing staff training on data protection and security best practices

8. International Data Transfers

Your personal data may be transferred to and processed in countries outside the United Kingdom. When we transfer data internationally, we ensure appropriate safeguards are in place, such as Standard Contractual Clauses approved by the UK Information Commissioner's Office, to protect your personal data.

9. Children's Privacy

Our services are not intended for individuals under the age of 18. We do not knowingly collect personal data from children. If you are a parent or guardian and believe your child has provided us with personal data, please contact us immediately.

10. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or for other operational, legal, or regulatory reasons. We will notify you of any material changes by posting the new Privacy Policy on this page and updating the "Effective date" at the top. We encourage you to review this Privacy Policy periodically.

11. Contact Us

If you have any questions about this Privacy Policy or our data practices, please contact us:

Right to Complain

You have the right to lodge a complaint with the UK Information Commissioner's Office (ICO) if you believe we have not handled your personal data in accordance with applicable law. Visit ico.org.uk for more information.

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