This document defines the Vehicle Mark processes and procedures for handling personal data and contains the following sections:
References to Vehicle Mark , we, us, our is synonymous with Vehicle Mark Ltd.
References to you, an individual, an external organisation is synonymous with any user of services provided by Vehicle Mark Ltd (either as an individual or as a business).
This document has been created in order to define the data we hold along with the processes and procedures Vehicle Mark 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 Mark 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 policies and terms on our website
Vehicle Mark 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.
Registered Office:
Vehicle Mark Ltd
20 Wenlock Road
London
England
N1 7GU
ICO Registration Number: ZB970769
The lawful bases for data processing are set out in Article 6 of the UK GDPR: Lawful Basis For Data Processing. At least one of these will apply when we process personal data:
The personal data we can hold for each individual is the following:
If you have used Vehicle Mark services to search for a vehicle then we will hold a copy of your IP address. Our lawful basis 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.
If you have contacted Vehicle Mark by email then we will hold a copy of your email address. Our lawful basis 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 Mark then we will hold a copy of your email address. Our lawful basis for processing this data falls under 'Consent'. By creating an account with Vehicle Mark you are giving us consent to store your email address such that it can be used to identify you when you want use Vehicle Mark services e.g. log in, data back up & data restore.
If you use Vehicle Mark to obtain an insurance quote from one of our affiliate insurance providers then we will hold a copy of your email address. Our lawful basis 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 Mark API service we will hold a copy of your email address. Our lawful basis 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.
If you have created an account with Vehicle Mark 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 basis for processing this data falls under 'Consent'. By creating an account with Vehicle Mark you are giving us consent to monitor your account activities to ensure the security of all accounts held with Vehicle Mark.
If you are a customer of the Vehicle Mark API service we will record your account metadata and all API service activity. To the extent there is personal data, our lawful basis for processing this data falls under 'Contract' and ‘Legitimate Interest’. When opting to trial or if you are a subscriber of the Vehicle Mark API service, we monitor all your account activities for account administration purposes.
If you have used Vehicle Mark 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 basis 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).
If you use Vehicle Mark 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. The Vehicle Data that can be stored by us includes all DVLA data, DVSA data, vehicle check data and any custom data added by you such as photos, nicknames and technical data.
If you have created an account with us, your vehicles will be linked to the email address you have provided. If not, we attach a pseudo-email address to your Vehicle Data. Our lawful basis for processing this data falls under 'Legitimate Interest'. Our legitimate interests are as follows:
All data controlled by Vehicle Mark is held within the EU on secure platforms. We use data encryption for password credentials.
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:
We will use your IP address for network activity, IT security, logging and rate limiting.
If you have contacted Vehicle Mark by email or if you have created an account with Vehicle Mark 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 Mark to obtain an insurance quote from one of our affiliate insurance providers 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.
We use your account activity for account validation, for monitoring account activity patterns and for account administration.
We will store your Financial Data (as described above) for accountancy purposes to comply with UK company laws.
We store your Vehicle Data on our secure platforms so that you can perform backup and restore functions, to gather statistical information around how our services are being used, provide the appropriate support to our users if needed and rate limiting (all as explained in the Information We Hold Section).
Where you have an account with us, we may from time to time, with your permission, send you periodic marketing e-mails about:
Also, If you have an account and allow us to, we may from time to time:
In relation to all of the above, you have control over which types of marketing communications (if any) you wish to receive. You can at any time log in to the Vehicle Mark Car Check app and toggle your privacy settings. Alternatively, If you no longer want to receive any marketing e-mails from us, please contact us at info@vehiclemark.com to let us know or simply click on the instructional link in the relevant email. We will not send you any unsolicited marketing or spam. We will take all reasonable steps to ensure that we fully protect your rights and comply with our obligations under the UK GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, as amended.
We will hold your personal data on our systems only for as long as required to provide you with the services you have requested, including for the purposes of satisfying any legal, regulatory, tax, accounting, reporting or other legitimate requirements. We may retain your personal information for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we have put in place a data retention policy and consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting, reporting or other legitimate requirements.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research, demographic, accounting, analytical or statistical purposes in which case we may use this information indefinitely.
If you want to us delete your personal data please use the contact us section
The ANPR services within the Vehicle Mark platform are all processed internally. ANPR images may be retained to improve the ANPR service within the platform, however, images are typically removed once processed. The service is not a traditional ANPR system whereby it is collecting vehicle data autonomously. You decide whether to use the ANPR service or not and you control the image that is fed to the service.
You can request to know what data we hold about you. To do this, simply contact us 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.
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 high risk to the rights and freedoms of those individuals.
If we discover a data breach, we will assess the impact and follow ICO and UK GDPR guidelines on reporting and investigating data breaches. We will attempt to notify any affected individuals (where appropriate) and inform them of the impact should we be required to do so.
Depending on how and why you provide us with your personal data, we may share it in the following ways where appropriate:
We do not seek to transfer your personal data outside the UK or EU, though it may be necessary from time to time for us to do so, particularly when transferring data to our service providers and business partners located in other countries. Where that is the case, your personal data may be transferred to or accessed from outside the UK or EU, and possibly in countries which are not governed by data protection laws equivalent to the UK GDPR.
Where that is the case, we adopt appropriate safeguards to require that your personal data will remain protected in accordance with this Privacy Policy and your rights are upheld. These may include implementing the relevant standard contractual clauses prescribed by the appropriate regulatory body, anonymisation, or limiting transfers to those countries deemed as providing an adequate level of protection of personal information.
Vehicle Mark Ltd and its operations are hosted almost exclusively within the UK and the EU.
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 lawful 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:
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 may advise you if this is the case at the time you withdraw your consent.