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1. Introduction

CarMate ("we", "our", "us") operates the CarMate progressive web application (the "App"), accessible via web browsers on mobile and tablet devices. CarMate is a swipe-based, AI-powered car discovery platform that helps users find vehicles matched to their preferences, lifestyle, and budget.

This Privacy Policy explains how we collect, use, store, share, and protect your personal data when you use the App. It applies to all users of CarMate in the United Kingdom and, where applicable, users in other jurisdictions.

We are committed to protecting your privacy and processing your data in accordance with the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018, and the Privacy and Electronic Communications Regulations 2003 (PECR).

2. Data Controller

The data controller responsible for your personal data is:

CarMate
Email: privacy.carmate@gmail.com

If you have any questions about this Privacy Policy or our data practices, please contact us at the email address above.

3. Information We Collect

3.1 Information You Provide Directly

• Account information: name, mobile number, email address, and password when you create an account
• Onboarding questionnaire responses: your budget range, vehicle preferences, driving experience and lifestyle needs
• Feedback and communications: any messages, feedback, or support requests you send to us

3.2 Information Generated Through Your Use of the App

• Swipe data: your swipe interactions (right/like, left/pass, up/favourites) on vehicle cards
• AI preference profile: the preference model our AI builds based on your swipe patterns, questionnaire answers, and browsing behaviour
• Dream Garage / Wishlist data: vehicles you save to your Wishlist
• Match scores: the personalised compatibility scores generated for each vehicle
• Search and filter activity: any filters, searches, or sorting preferences you apply
• Session data: session duration, pages viewed, features used, and interaction timestamps

3.3 Information Collected Automatically

• Device information: device type, operating system, browser type and version, screen resolution
• Usage analytics: anonymised usage patterns, session frequency, feature engagement metrics
• IP address: used for approximate location (city-level) to show relevant local vehicle listings
• Cookies and similar technologies: as described in Section 9 below

3.4 Information We Do Not Collect

We do not collect precise GPS location data, financial or payment information (at this stage), driving licence details, or any special category data (racial or ethnic origin, political opinions, religious beliefs, health data, sexual orientation, or biometric data).

4. How We Use Your Information

4.1 Core Service Delivery

• To create and manage your account
• To generate personalised vehicle recommendations using our AI matching algorithm
• To build and refine your preference profile based on swipe behaviour
• To display match scores and curate your vehicle feed
• To maintain your Dream Garage / Wishlist

4.2 Service Improvement

• To analyse usage patterns and improve the App's functionality, design, and user experience
• To train and improve our AI recommendation engine using aggregated, anonymised swipe data
• To identify and fix technical issues, bugs, and performance problems

4.3 Communications

• To respond to your enquiries and support requests
• To send service-related notifications (e.g., account security, feature updates)
• To send marketing communications, only where you have provided explicit consent (you can opt out at any time)

4.4 Legal and Safety

• To comply with legal obligations and regulatory requirements
• To detect, prevent, and address fraud, abuse, security risks, or technical issues
• To enforce our Terms and Conditions

5. Legal Basis for Processing

Under the UK GDPR, we rely on the following legal bases for processing your personal data:

• Contract: processing necessary to provide the CarMate service to you (Article 6(1)(b))
• Legitimate interests: processing necessary for our legitimate interests in improving the App, understanding user behaviour, and ensuring security, provided these interests are not overridden by your rights (Article 6(1)(f))
• Consent: where we process data based on your explicit consent, such as for marketing communications or non-essential cookies (Article 6(1)(a))
• Legal obligation: where processing is necessary to comply with applicable law (Article 6(1)(c))

6. AI and Automated Decision-Making

CarMate uses artificial intelligence and machine learning algorithms to provide personalised vehicle recommendations. This section explains how this works and your rights in relation to it.

6.1 How Our AI Works

• Our AI analyses your onboarding questionnaire answers and swipe behaviour to build a preference profile
• This profile is used to generate match scores for vehicles, indicating how well each car aligns with your stated and observed preferences
• The AI adapts over time as you interact with more vehicles, refining its understanding of your preferences
• No human reviews or overrides individual match scores; they are generated automatically

6.2 Your Rights Regarding AI

The AI-generated match scores and recommendations are provided as guidance to assist your car discovery process. They do not constitute financial advice, purchasing recommendations, or any form of contractual offer. You are free to ignore any recommendation.

Under Article 22 of the UK GDPR, you have the right not to be subject to decisions based solely on automated processing that produce legal or similarly significant effects.
Our AI recommendations do not produce such effects; they are informational only. However, you may contact us at any time to request human review of how the AI has profiled your preferences, or to object to AI-based profiling.

7. Data Sharing and Third Parties

We do not sell your personal data to any third party. We may share your data in the following limited circumstances:

7.1 Service Providers

We use trusted third-party service providers to help us operate the App, including hosting providers, analytics services eg google analytics, and email delivery services. These providers process data on our behalf under data processing agreements that ensure appropriate safeguards.

7.2 Vehicle Data Providers

We receive vehicle listing data from third-party automotive data providers to populate the App. We do not share your personal data with these providers.

7.3 Dealer Referrals

If you choose to contact a dealer through the App or click through to a dealer's listing, we may share limited information (such as the vehicle you are interested in) with that dealer to facilitate your enquiry. We will always make this clear to you before any data is shared.

7.4 Legal Requirements

We may disclose your data if required by law, regulation, court order, or governmental request, or to protect the rights, property, or safety of CarMate, our users, or the public.

8. Data Retention

We retain your personal data only for as long as necessary to fulfil the purposes described in this Privacy Policy:

• Account data: retained for the duration of your account and for up to 12 months after account deletion, to allow for account recovery and to comply with legal obligations
• Swipe and preference data: retained for the duration of your account; anonymised aggregated data may be retained indefinitely for AI training and service improvement
• Analytics data: retained in anonymised form for up to 24 months
• Support communications: retained for up to 24 months after resolution

You may request deletion of your data at any time by contacting us at privacy.carmate@gmail.com

9. Cookies and Similar Technologies

As a progressive web application, CarMate may use cookies and similar technologies (such as local storage and service workers) to:

• Essential functionality: maintain your logged-in session, remember your preferences, and ensure the App functions correctly
• Analytics: understand how the App is used, which features are popular, and where users encounter issues (using anonymised data)

We do not use advertising or tracking cookies. We do not serve third-party advertisements within the App.

You can manage cookie preferences through your browser settings. Disabling essential cookies may affect the functionality of the App.

10. 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 data in transit (HTTPS/TLS)
• Secure password hashing
• Access controls limiting data access to authorised personnel only
• Regular security reviews and updates

While we take reasonable precautions, no method of electronic storage or transmission is 100% secure. We cannot guarantee absolute security of your data.

11. Your Rights Under UK GDPR

You have the following rights in relation to 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 data
• Right to erasure: request deletion of your personal data ("right to be forgotten")
• Right to restrict processing: request that we limit how we use your data
• Right to data portability: request your data in a structured, machine-readable format
• Right to object: object to processing based on legitimate interests, including AI-based profiling
• Right to withdraw consent: where processing is based on consent, you may withdraw it at any time

To exercise any of these rights, contact us at privacy.carmate@gmail.com. We will respond within one month of receiving your request, as required by law.

12. Children's Privacy

CarMate is not directed at children under the age of 16. We do not knowingly collect personal data from children under 16. If we become aware that we have collected data from a child under 16 without appropriate parental consent, we will take steps to delete that data promptly. If you believe a child under 16 has provided us with personal data, please contact us at privacy.carmate@gmail.com

13. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or the App's features. We will notify you of any material changes by posting a notice within the App or sending you an email. The "Effective Date" at the top of this policy indicates when it was last updated.

We encourage you to review this Privacy Policy periodically.

14. Contact Us

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

CarMate
Email: privacy.carmate@gmail.com
Phone: 07549076532