We are committed to protecting your privacy and take the security of customer information seriously. This Privacy Policy explains how AZFO LTD trading as LockCAR (“LockCAR”, “we”, “us” or “our”) collects, uses and protects personal data when you use lockcar.co.uk, buy LockCAR products and services, have a product fitted by one of our approved installers, or use the LockCAR, LockCAR Fleet, LockCAR IMMO and LockCAR CAN-IMMO mobile applications.

Please read this policy carefully. Where required, we will ask for your express agreement, for example by ticking a box on our website or in an app.

1. Who We Are

1.1The website lockcar.co.uk (the “Site”) and the LockCAR, LockCAR Fleet, LockCAR IMMO and LockCAR CAN-IMMO mobile applications (together, the “Apps”) are operated by AZFO LTD, a company registered in England and Wales under company number 14346129, trading as LockCAR, of 49 Hough Road, Birmingham, B14 6HL, United Kingdom.

1.2We are the controller of the personal data described in this policy, except where we act on behalf of a business customer as described in clause 9.6.

1.3You can contact us about this policy or your personal data:

(a) by email, at hello@lockcar.co.uk;

(b) by post, to the address in clause 1.1; or

2. Changes to This Policy

2.1We may update this policy from time to time by publishing a new version on the Site. The date at the top of this page shows when it was last updated.

2.2Please check this page occasionally to make sure you are happy with any changes.

2.3We may notify you of significant changes by email or through the Apps.

3. Personal Data We Collect and Why

3.1This section explains, for each type of personal data, what we collect, why we use it, and the legal basis for using it under UK data protection law.

3.2 Website usage data

We collect data about how you use the Site, including:

• IP address and approximate location derived from it;
• browser type and version, and operating system;
• referral source, visit duration, page views and navigation paths; and
• how you interact with Site features, such as the Vehicle CHECK tool and product quiz.

We use this data to keep the Site secure, analyse its performance and improve your experience.

Legal basis: our legitimate interests in running a secure and effective website. Where this data is collected through non-essential cookies, we rely on your consent (see section 12).

3.3 Account data

If you create an account on the Site or in an App, we collect your name, email address, login details and order history. We use this data to operate your account, keep it secure and communicate with you about it.

Legal basis: performance of a contract with you, and our legitimate interests in keeping accounts and systems secure.

3.4 Order, delivery and fitting data

When you buy a product or service, we collect your name, billing and delivery address, telephone number, email address, the products ordered, your preferred fitting address and time, and the vehicle details needed for fitting and service activation (such as make, model, year and registration number). We use this data to process and deliver your order, arrange fitting (see section 4), activate services, provide warranty and support, and send you service notifications about your order and products.

Legal basis: performance of a contract with you.

3.5 Payment and transaction data

We keep records of your purchases, payments, refunds and invoices, including any business name and VAT number you supply. Card, Google Pay and PayPal payments are processed by our payment providers, under their own privacy policies.

Legal basis: performance of a contract with you, and compliance with our legal obligations to keep financial and tax records.

3.6 Enquiries, compatibility checks and quotes

When you contact us through the Site’s contact form, by email, telephone or WhatsApp, or ask for a compatibility check or Fleet quote, we collect the details you give us, such as your name, mobile number, email address, vehicle details and your message. When you use the Vehicle CHECK tool or product quiz, we process the registration number and answers you enter. We use this data to reply to you, check vehicle compatibility, prepare quotes and recommend suitable LockCAR products.

Legal basis: taking steps at your request before entering into a contract, and our legitimate interests in responding to enquiries.

3.7 Cancellations, returns and warranty claims

When you cancel an order, return a product or report a fault, we process your cancellation notice (including any signed cancellation form), our correspondence with you, product serial numbers, vehicle details and any photographs of the installation you send us.

Legal basis: performance of a contract with you, compliance with our legal obligations under consumer law, and our legitimate interests in handling and defending claims.

3.8 Professional Installer Accounts

When an installer or business applies for a Professional Installer Account, we collect the trading name, company number or sole-trader details, VAT number, trading address, business email and telephone number, website or social media profile, and a description of installation work and experience. We use this data to assess the application, verify business details (for example against Companies House or the VAT register), manage the account and supply trade products.

Legal basis: taking steps before entering into a contract and performance of that contract, and our legitimate interests in making sure trade accounts and pricing are used only by genuine businesses.

3.9 Marketing

We may send you emails about LockCAR products, services and offers. We will only send marketing emails to individual customers if you have agreed to receive them, or if you have bought from us, the emails are about similar products or services, and you did not opt out when we collected your details. Every marketing email includes an unsubscribe link, and you can opt out at any time by emailing us.

Legal basis: your consent, or our legitimate interests in promoting similar products to existing customers and business contacts.

3.10 Legal claims, business administration and legal compliance

We may process personal data where necessary to establish, exercise or defend legal claims; for insurance, risk management, professional advice and website administration; and to comply with legal obligations that apply to us.

Legal basis: our legitimate interests in protecting and properly administering our business, and compliance with our legal obligations.

3.11Do you have to give us your data? We need the data described in clauses 3.3 to 3.5 to supply your order. If you do not provide it, we cannot complete your purchase or provide the service. Giving us data for marketing, analytics cookies or app location access is optional.

3.12We do not make decisions about you based solely on automated processing that have legal or similarly significant effects on you.

4. Fitting by Approved Installers

4.1When you buy a LockCAR product with fitting, we pass your name, telephone number, fitting address, preferred time and vehicle details to the approved installer who will carry out the fitting. We share only the details the installer needs to contact you, carry out the fitting and deal with related warranty work.

4.2The installer may record installation details in the LockCAR CAN-IMMO app, as described in section 8.

Legal basis: performance of a contract with you.

5. Who We Share Your Data With

5.1We share personal data only where necessary for the purposes in this policy, with:

(a) delivery companies, to deliver your order;

(b) payment providers, including PayPal, to process payments and refunds;

(c) approved installers, to fit your product (see section 4);

(d) providers of IT, hosting, email, website and app services that help us run our business;

(e) providers of the mobile data, tracking platform and cloud storage services we use to deliver connected services (see section 9);

(f) vehicle data providers, where needed to identify a vehicle from its registration number;

(g) analytics and advertising providers, only where you have accepted the relevant cookies (see section 12);

(h) insurers and professional advisers, for risk management and legal purposes;

(i) any company in the same group as AZFO LTD, where there is one and where necessary for these purposes;

(j) the police, courts, regulators or other authorities, where we are required by law to do so, or where it is necessary to prevent or detect crime, including vehicle theft; and

(k) a buyer or successor of our business, if all or part of it is sold or transferred.

5.2We do not sell or rent your personal data, and we do not share it with data brokers.

6. International Transfers

6.1Some of our service providers may process personal data outside the United Kingdom. Where they do, we make sure the transfer is protected, for example because the country is covered by UK adequacy regulations, or by using the UK International Data Transfer Agreement or the UK Addendum to the EU Standard Contractual Clauses.

6.2You can contact us for more information about these safeguards.

7. How Long We Keep Your Data

7.1We do not keep personal data for longer than necessary for the purposes for which it was collected.

7.2In general, we keep personal data:

(a) for as long as we have a contract or account with you;

(b) for up to six years after that, to comply with legal, tax and accounting requirements and to deal with any claims; and

(c) for marketing purposes, until you unsubscribe or withdraw your consent.

7.3Enquiries that do not lead to a purchase are kept for as long as needed to deal with them and any follow-up. Specific retention periods for app and connected-service data are set out in sections 8 and 9.

7.4Retention periods may be longer where we are required by law, or where data is needed for an ongoing claim or investigation.

8. LockCAR CAN-IMMO Mobile Application

8.1This section applies to the LockCAR CAN-IMMO mobile application. Vehicle owners use the application to control the LockCAR CAN-IMMO immobiliser fitted to their vehicle, and authorised LockCAR installers use it to fit and configure the immobiliser. The application does not collect personal data from vehicle owners.

8.2When an authorised installer uses the installer section of the application, the following data is collected and sent to our servers:

(a) Installer account data: username, installer name and installer ID, used to authenticate the installer. Installer accounts are issued by LockCAR.

Legal basis: performance of a contract.

(b) Device data: the Bluetooth identifier and name of the immobiliser being configured and its firmware version, used to link the installation to the correct device and to provide firmware updates.

Legal basis: performance of a contract.

(c) Vehicle and configuration data: vehicle make, model and year, detected inputs, button mappings and combo-PIN sequences, used to configure the immobiliser, to keep an installation record and to maintain our database of button maps for each vehicle model.

Legal basis: performance of a contract, and our legitimate interests in providing warranty, support and installation services.

(d) Location data: with the installer’s permission, the GPS location and time at which an installation report is saved, used for audit and warranty purposes. Providing location is optional. If permission is refused, the report is saved without it. Permission can be withdrawn at any time in the phone’s settings.

Legal basis: consent.

8.3Data collected by the application is sent only to LockCAR’s servers. It is not sold, and it is not shared with advertising networks or any other third party, except as described in section 5.

8.4Installation records are kept for as long as necessary for warranty, support and audit purposes, in line with section 7.

8.5The rights in section 10 apply to data collected through the application.

9. GPS Tracking, Dashcam and Fleet Services

9.1This section applies if you use a LockCAR GPS tracker, 4G dashcam or Fleet service, including through the LockCAR, LockCAR IMMO and LockCAR Fleet apps.

9.2Depending on the service you use, we process:

(a) Location data: the live position of the vehicle and its journey history;

(b) Alerts and commands: security alerts, immobiliser status and remote commands such as engine cut;

(c) Dashcam recordings: front and cabin video and images, live view sessions and clips stored in the cloud;

(d) Device and authorisation data: identifiers of the tracker, dashcam, SIM and paired tags, smart watches, smart rings or keyfobs, and the authorisation log showing when the immobiliser was disarmed and by which device; and

(e) Fleet data: driver assignments, driver and mileage reports.

9.3We use this data only to provide the service you have subscribed to, including showing you your vehicle’s location, sending alerts, storing your recordings, providing support and protecting the service against misuse. It is not sold, and it is not shared with advertising networks.

Legal basis: performance of a contract with you.

9.4Retention. Journey history is kept for [__] days. Dashcam clips stored in the cloud are kept for [__] days, unless you delete them earlier. When your subscription ends, this data is deleted within [__] days, unless we need to keep it for a legal claim or because the law requires it.

9.5Other drivers and passengers. If anyone else drives or travels in a vehicle fitted with a LockCAR tracker or dashcam, you are responsible for telling them that the vehicle’s location is tracked and, where applicable, that the cabin is recorded.

9.6Fleet customers. When a business uses LockCAR Fleet to monitor its vehicles and drivers, that business is the controller of its drivers’ personal data, and we process that data on its behalf and on its instructions. The business is responsible for having a lawful basis for monitoring and for informing its drivers. Drivers who wish to exercise their data protection rights should contact their employer or the business operating the fleet.

10. Your Rights

10.1Under UK data protection law, you have the right to:

(a) access the personal data we hold about you;

(b) have inaccurate data corrected;

(c) have your data deleted;

(d) restrict how we use your data;

(e) object to our use of your data, including at any time to direct marketing;

(f) receive your data in a portable format; and

(g) withdraw your consent at any time, where we rely on consent. This does not affect processing carried out before you withdraw it.

10.2Some of these rights apply only in certain circumstances. To exercise any of them, email us at hello@lockcar.co.uk. We may ask you to confirm your identity. We will respond within one month, which may be extended in some cases as the law allows.

10.3If you are unhappy with how we have used your personal data, please contact us first so we can try to resolve it. You also have the right to complain to the Information Commissioner’s Office (ICO), the UK data protection regulator, at ico.org.uk/make-a-complaint.

11. Security and Children

11.1We use appropriate technical and organisational measures to protect personal data against loss, misuse and unauthorised access. No transmission over the internet is completely secure, so please contact us straight away if you believe your account or data has been compromised.

11.2You are responsible for keeping your account passwords, app login details and immobiliser PINs confidential.

11.3Our products and services are intended for adults aged 18 or over. We do not knowingly collect personal data from children.

12. Cookies

12.1About cookies. A cookie is a small file containing an identifier that is stored by your browser. Cookies help us recognise users and improve the functionality and security of the Site. Cookies do not usually identify you directly, but they may be linked to information stored in your account. This section applies to the Site only.

12.2Cookies we use. We use:

(a) essential cookies, needed for the Site to work, such as for your basket, checkout, login, account security, fraud prevention and remembering your cookie choices; and

(b) non-essential cookies, for analytics and performance monitoring, personalisation and advertising relevance.

12.3Your consent. Essential cookies are set automatically because the Site cannot work without them. Non-essential cookies are set only if you accept them, and you can withdraw your consent at any time by changing your cookie settings or deleting cookies in your browser.

12.4Third-party cookies. Where you accept them, third-party providers such as Google Analytics and advertising platforms may place cookies when you visit the Site. Third-party websites linked from the Site may also use their own cookies, which we do not control.

12.5Managing cookies. Most browsers allow you to block or delete cookies. Instructions vary depending on your browser. Blocking essential cookies may stop some parts of the Site from working, such as the basket or checkout.

13. Contact Us

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