We ask that you read this privacy notice carefully as it contains important information on who we are, how and why we collect, store, use and share personal information, your rights in relation to your personal information and on how to contact us and supervisory authorities in the event you have a complaint.
We use your data to provide the Smart Servicing Centre marketplace platform service to you and for the purposes of running our marketplace platform business.
We delete your data when it is no longer needed for these things.
Generally, we do not give your information to third parties other than mechanics / Garage (if you are looking for auto services) or your customer and potential customers looking for auto services (if you are a mechanic/ Garage), but there are some exceptions where we use external service providers to power our operations – some of these are outside Europe.
We are happy to answer your questions about any of this – email us at email@example.com
WHO WE ARE
Smart Servicing Centre Ltd collects, uses and is responsible for certain personal information about you. When we do so we are regulated under the General Data Protection Regulation which applies across the European Union (including in the United Kingdom) and we are responsible as ‘controller’ of that personal information for the purposes of those laws.
This Privacy Notice is directed to you if you are either someone who works for a business that has enquired about or been contacted about registration as a Garage / mechanic on the platform (referred to as a “mechanic / Garage” in this notice), or someone looking to connect with a mechanic / Garage for the provision of auto services (referred to as a “vehicle owner” in this notice).
THE PERSONAL INFORMATION WE COLLECT FROM YOU
We collect the following personal information when you provide it to us.
- Registration Information (mechanics / Garage): If you are a mechanic / Garage, we collect information provided when your business applies to register as a mechanic / Garage on the platform, or enquires about registering, and further information you provide to us in ‘on-boarding’ emails and phone calls with you following your business having submitted its application. This includes your name, full address of your business, telephone number, email address, and further details of your business.
- Registration Information (vehicle owners): If you are a vehicle owner, we collect information provided when you register on the platform or make a booking request for services to be provided by a mechanic / Garage registered on our platform. This includes your name and address, details about your vehicle, and payment card information.
- Usage Data: Details of your usage of the Smart Servicing Centre platform, including auto services bookings you have placed or accepted by means of the platform, auto services you have searched for, and quotes you have received.
- Technical Data: Technical data obtained from your use of our platform, including your IP address, browser or device information.
- Marketing and Communication Preferences: Your preferences as to whether we contact you with briefs, or promotional with information about Smart Servicing Centre. We use this to make sure we don’t send you anything you have asked not to receive. Legal basis: Consent; Legitimate Interest
- Communications: If you choose to communicate with us (for example, through the Platform, email, telephone, SMS, or social media) we will record the fact that you have contacted us and may retain the content of your communication, together with your contact details and our responses.
We may also need to process your data for compliance with a legal obligation to which we are subject.
INFORMATION COLLECTED FROM OTHER SOURCES
We also obtain personal information from other sources as follows:
Feedback: We receive feedback from users of our platform on their experiences in working with you.
HOW WE USE THAT INFORMATION
We use your personal information as follows. References to the basis of processing (e.g. "Basis: Legitimate Interest”) are a reference to a basis specified in General Data Protection Regulation under which we undertake the processing in question.
To allow us to operate the Smart Servicing Centre platform, and the business operations we engage in to that end, including facilitating bookings, facilitating payments, communicating with you about bookings, and related tax and accounting purposes. Data used: Registration Data; Usage Data. Basis: Performance of Contract; Legitimate Interests; Legal Obligation.
To manage our relationship with you, which will include notifying you about changes to our terms or privacy notice, or asking you to leave a review or take a survey. Data used: Technical Data; Usage Data; Registration Information; Marketing and Communication Preferences. Basis: Legitimate Interests, Legal Obligation
To use data analytics to improve our website, products/services, marketing, user relationships and experiences. Basis: Legitimate Interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy).
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data). Data used: Registration Data; Technical Data; Feedback. Basis: Legitimate Interest (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise).
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you. Data used: Registration Data; Technical Data. Basis: Legitimate Interests to study how Garages / mechanics and vehicle owners use our platform services, to develop them, to grow our business and to inform our marketing strategy.
We use your Marketing and Communication Preferences to make sure we don’t send you anything you have asked not to receive. Legal basis: Consent; Legitimate Interest
We may also need to process your data for compliance with a legal obligation to which we are subject. Data used: All data. Basis: Legal Obligation
If you get in touch with us, we will record the fact that you have contacted us and may retain the content of your communication, together with your contact details and our responses. We use this to help us to deliver the Smart Servicing Centre service to you and answer your questions. Data used: Communications. Basis: Legitimate Interest.
USE OF PROFILING AND AUTOMATED DECISION MAKING
Our profiling and automated decision making process works as follows:
- Information (including personal information) is processed by third party service providers to assess whether a user or provided credit card is fraudulent.
- When a booking is placed, a third party service provider returns a score indicating to what extent the user’s behaviour suggests fraudulent behaviour. If the score exceeds our internally set threshold, a booking will be held for review before being offered to mechanics. This review is conducted by a human and may result in either further evidence of legitimacy being requested or being rejected entirely without being offered to Garage / mechanics.
- At the point of authorising a payment, a third-party service provider will assess the payment authorisation for likely fraud and may automatically block the card. In this case, the Garage / mechanic and our team will be informed that the payment authorisation did not succeed and agree an appropriate action.
WHO WE SHARE YOUR PERSONAL INFORMATION WITH
We routinely share your personal information with a range of third-party service providers who help us provide, analyse and promote the Smart Servicing Centre services and engage with vehicle owners and mechanics / Garage. Some of those third-party recipients may be based outside the European Economic Area for further information including on how we safeguard your personal data when this occurs, see ‘Transfer of your information out of the EEA’ section below.
If you are a mechanic / Garage, we will share information (including your name, email address, address and telephone number) with a vehicle owner in respect of a booking they wish to make.
If you are a vehicle owner, we will share relevant information about you and your booking (including your name, address, telephone number, vehicle registration number, and the nature of the auto services you require) with mechanics / Garages we consider suitable for your booking.
We will share personal information with law enforcement or other authorities if required by applicable law.
We will not share your personal information with any other third party.
HOW LONG YOUR PERSONAL INFORMATION WILL BE KEPT
- Data about vehicle owners: we will keep this for the duration of your relationship with us, then:
i). if you have made a request for a mechanic / Garage to provide auto services for 6 years after that; or
ii). Otherwise, for 6 months after that.
- Data about mechanics / Garage: we will keep this for the duration of your relationship with us, then for 6 years after that
- Data about Garage / mechanics whose business has not registered and been approved to use Smart Servicing Centre: 3 years.
TRANSFER OF YOUR INFORMATION OUT OF THE EEA
We may transfer your personal information to the following third party service providers, which are located outside the European Economic Area (EEA). We do this to help us provide and promote the Smart Servicing Centre service and to help us engage with vehicle owners and mechanics / Garages:
Data Stored outside of EU Such countries do not have the same data protection laws as the United Kingdom and EEA. Whilst the European Commission has not given a formal decision that those countries provide an adequate level of data protection similar to those which apply in the United Kingdom and EEA, any transfer of your personal information will be subject to appropriate safeguards as permitted under the General Data Protection Regulation that are designed to help safeguard your privacy rights and give you remedies in the unlikely event of a misuse of your personal information. To obtain a copy of the relevant safeguards please contact us at firstname.lastname@example.org
We will not otherwise transfer your personal data outside of the United Kingdom or EEA.
Under the General Data Protection Regulation you have a number of important rights free of charge. In summary, those include rights to:
- access to your personal information and to certain other supplementary information that this Privacy Notice is already designed to address
- require us to correct any mistakes in your information which we hold
- require the erasure of personal information concerning you in certain situations
- receive the personal information concerning you which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to a third party in certain situations
- object at any time to processing of personal information concerning you for direct marketing
- object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you
- object in certain other situations to our continued processing of your personal information
otherwise restrict our processing of your personal information in certain circumstances
- For further information on each of those rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner’s Office (ICO) on individual rights under the General Data Protection Regulation.
If you would like to exercise any of those rights, please:
email us at email@example.com
- let us have enough information to identify you,
- Let us know the information to which your request relates, including any account or reference numbers, if you have them.
If you would like to unsubscribe from any promotional material we send you, you can also click on the ‘unsubscribe’ button at the bottom of the email.
KEEPING YOUR PERSONAL INFORMATION SECURE
We have appropriate security measures in place to prevent personal information from being accidentally lost, or used or accessed in an unauthorised way. We limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit https://www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.
HOW TO COMPLAIN
We hope that we can resolve any query or concern you raise about our use of your information.
The?General Data Protection Regulation?also gives you the right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner's Office who may be contacted at https://ico.org.uk/concerns or telephone: 0303 123 1113.
Please contact us if you have any questions about this privacy notice or the information we hold about you. If you wish to contact us please send an email to firstname.lastname@example.org or write to us at 19 Hollydale Close, Reading, Berkshire, RG28LL.
LEGAL BASES FOR PROCESSING
In the section of this notice which sets out what data we collect and how we use it, we refer to different legal bases for processing. Further details on each of those are set out here.
Legitimate Interest: means the interest of our business in conducting and managing our business to enable us to give you the best service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract: means processing your data where it is necessary for the performance of a contract between us and you or to take steps at your request before entering into such a contract.
Legal Obligation: means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
Consent: To keep you updated with information and news about Smart Servicing Centre we provide you with means to give your consent at the point at which we collect your information.
Last Updated: 2019-09-26