Privacy Policy

1. Who we are

1.1 This Privacy Policy explains how Plate Circle Ltd (company number 16736844), registered at Unit 82a James Carter Road, Mildenhall, Bury St. Edmunds, England, IP28 7DE ("Plate Circle", "we", "us"), collects and uses personal data when you use the Plate Circle website and app (the "Platform").

1.2 For the purposes of UK data protection law (the UK GDPR and the Data Protection Act 2018), Plate Circle is the controller of the personal data described in this policy.

1.3 If you have any questions, or wish to exercise your rights, contact us at support@platecircle.com.

2. The personal data we collect

We collect the following categories of personal data:

2.1 Account data, your name, email address, phone number, password (stored in hashed form), and account settings.

2.2 Identity verification data, where you are a Seller and a sale is agreed, we use Stripe Identity to verify your identity. This may include images of an identity document, a selfie image, and the results of verification checks. Stripe processes this on our behalf; we receive the verification outcome and limited associated data.

2.3 Listing and ownership data, details of Registrations you list, and the proof of entitlement you provide (for example DVLA documentation references).

2.4 Transaction data, offers, counter-offers, accepted prices, buyer's premium and fee payments. Payments are processed by Stripe; we do not store full card details.

2.5 Spotted content, photographs, registration marks and any captions or information you submit to the Spotted feature. A registration mark can itself be personal data where it identifies an individual (see section 9).

2.6 Communications, messages you send through the Platform, and support requests.

2.7 Technical and usage data, IP address, device and browser information, and how you interact with the Platform, collected via cookies and similar technologies (see section 10).

2.8 Marketing preferences, your choices about receiving marketing.

3. How we collect personal data

3.1 Directly from you, when you register, list, make or accept offers, submit Spotted content, or contact us.

3.2 Automatically, through cookies and similar technologies when you use the Platform.

3.3 From third parties, our processors (for example Stripe and Stripe Identity for payment and verification outcomes), and other Users where a transaction involves you.

4. Why we use your data, and our lawful bases

4.1 Where we rely on legitimate interests, we have considered whether those interests are overridden by your rights, and you may object (section 8).

4.2 Where verification involves special category data (for example biometric data via identity checks), we will rely on an appropriate condition under Article 9 and the Data Protection Act 2018.

5. Who we share data with

5.1 Other Users, to complete a transaction, limited information is shared between Buyer and Seller (for example the information needed to make and accept offers and to effect the DVLA transfer). Do not share more personal data with another User than is necessary.

5.2 Processors and service providers, including:

• (a) Supabase, hosting, database and authentication;
• (b) Stripe, payment processing;
• (c) Stripe Identity, seller identity verification;
• (d) email, SMS and analytics providers used to operate the Platform.

5.3 Authorities and advisers, where required by law, to enforce our Terms, to prevent fraud or harm, or to obtain professional advice.

5.4 Business transfers, if our business is sold or reorganised, data may transfer to the successor under this policy.

5.5 We do not sell your personal data.

6. International transfers

6.1 Some of our processors (for example Stripe) may process data outside the UK. Where data is transferred outside the UK, we rely on appropriate safeguards, an adequacy decision, the UK International Data Transfer Agreement, or the UK Addendum to the EU Standard Contractual Clauses, as applicable.

7. How long we keep data

7.1 We keep personal data only as long as necessary for the purposes set out above, including to meet legal, accounting and dispute-resolution requirements.

7.2 Indicative periods: account data, for the life of your account and a reasonable period after closure; transaction records, 6 years for accounting/legal purposes; identity verification outcomes, for the period required by law and for fraud-prevention purposes; Spotted content, until removed by you or us, subject to takedown requests.

8. Your rights

8.1 Under UK data protection law you have the right to: access your data; have it corrected; have it erased; restrict or object to processing; data portability; and withdraw consent where we rely on it. These rights have conditions and exceptions.

8.2 To exercise a right, contact support@platecircle.com. We will respond within the statutory time limit (usually one month).

8.3 You have the right to complain to the Information Commissioner's Office (ICO) at ico.org.uk, though we ask that you contact us first so we can try to resolve the matter.

9. Spotted, privacy specifics

9.1 The Spotted feature publishes user-submitted images and registration marks. A registration mark may be personal data where it can be linked to an identifiable individual, so we treat Spotted content with particular care.

9.2 We rely on legitimate interests to operate Spotted, providing an informational and community feature about vehicles seen in public, having weighed this against the privacy interests of individuals. We require Users to follow the restrictions in clause 14 of our Terms, including not posting personal information about others, not identifying vehicle keepers, and not using the feature to harass or target anyone.

9.3 Objections and takedown. If you believe Spotted content identifies you or breaches your rights, contact support@platecircle.com. We will review the content and, where appropriate, remove it. You may also object to processing under section 8.

10. Cookies and similar technologies

10.1 We use cookies and similar technologies to operate the Platform, remember your preferences, keep you signed in, and (with your consent) for analytics and marketing.

10.2 You can manage non-essential cookies through our cookie banner / settings.

11. Marketing

11.1 We send marketing only where you have consented or where permitted by law. You can opt out at any time using the unsubscribe link or by contacting us.

12. Children

12.1 The Platform is for users aged 18 and over. We do not knowingly collect data from children.

13. Security

13.1 We use appropriate technical and organisational measures to protect personal data, including access controls and encryption in transit. No system is completely secure; you are responsible for keeping your login credentials confidential.

14. Changes to this policy

14.1 We may update this policy from time to time. We will publish the updated version with a new effective date and, for material changes, provide reasonable notice.

15. Contact

support@platecircle.com · Plate Circle Ltd · Unit 82a James Carter Road, Mildenhall, Bury St. Edmunds, England, IP28 7DE · 16736844

Information Commissioner's Office, ico.org.uk