Privacy Policy

1. Who we are

For the purposes of UK data protection law, the controller of your personal information is:

Awen AI Ltd, a company registered in England and Wales (company number 11653307), trading as First Car Scout.

Our registered office is 128 City Road, London, EC1V 2NX.

You can contact us about this Privacy Policy or your personal information at:

Email: info@firstcarscout.com

2. What personal information we collect

We may collect personal information when you use our website, contact us, complete a form, request a car shortlist, ask about a personalised First Car Scout report, or otherwise interact with us. The information we collect may include:

• your name;
• your email address;
• your phone number;
• your postcode or general location;
• your car budget;
• your preferred car type, make, model, age or other preferences;
• information about driving status, such as whether the intended driver has a provisional or full licence;
• the age of the intended driver;
• insurance budget or insurance-related preferences;
• parent or guardian details where relevant;
• information about the intended driver's needs, preferences or circumstances;
• messages, enquiries or other information you choose to provide to us;
• payment and transaction information if you buy a paid service from us;
• technical information about how you use our website, including through cookies and analytics tools.

We do not intentionally ask for special category data, such as health information, ethnicity, religion or political opinions. Please do not provide this type of information unless we specifically ask for it and explain why it is needed.

3. Information about young drivers

First Car Scout may be used by young drivers, first-time drivers, parents and families. Where a user is under 18, they should only submit information to First Car Scout with the knowledge and consent of a parent or guardian.

Parents or guardians may also provide information about a young driver, including their age, driving status, location, budget, insurance needs and car preferences.

We use this information only to respond to enquiries, understand the user's needs, provide relevant information, and support the First Car Scout service requested.

4. How we collect personal information

We may collect personal information when:

• you complete a contact form on our website;
• you ask us to help you find or assess suitable first cars;
• you request information about a personalised car scout list or report;
• you contact us by email, phone, website form, SMS, WhatsApp or another communication channel;
• you interact with First Car Scout through a connected third-party AI assistant (such as ChatGPT), where you choose to share details to get a car shortlist or request a report;
• you make a payment for a paid service;
• you agree to receive updates or follow-up information from us;
• you use our website and cookies, analytics tools or tracking technologies collect information automatically.

Where you use First Car Scout through a third-party AI assistant such as ChatGPT, that platform's own provider (for example, OpenAI) also processes your conversation as part of operating their assistant. This is separate from First Car Scout's own processing described in this Privacy Policy, and is governed by that provider's own privacy policy and terms.

If you ask a connected AI assistant to email you your car shortlist or report, we collect the email address, name and driver details you have already discussed with it (such as age, postcode or town, budget and licence details) so that we can prepare and send that shortlist or report. This only happens if you specifically ask for it, and the assistant is not instructed to send us this information without your request. It is then processed, stored and retained on exactly the same basis as if you had asked for the same shortlist or report directly on our website (see sections 5, 9 and 12).

5. How we use your personal information

We may use your personal information to:

• respond to your enquiry;
• understand what type of first car may be suitable for you or the intended driver;
• prepare or provide a personalised car scout list;
• provide information about a personalised First Car Scout report;
• communicate with you about your enquiry or service request;
• provide customer support;
• process payments where paid services are offered;
• improve our website, forms, services and customer experience;
• analyse website performance and user behaviour;
• measure and improve marketing activity, where permitted;
• keep appropriate business and financial records;
• comply with legal, regulatory, tax and accounting obligations;
• protect our website, systems, users and business.

We do not sell your personal information.

6. Our lawful bases for using your information

UK data protection law requires us to have a lawful basis for using personal information. Depending on the circumstances, we may rely on the following lawful bases:

Contract

We may use your personal information where this is necessary to provide a service you have requested or to take steps before entering into a contract with you. For example, this may apply where you ask us to provide a personalised car shortlist or buy a paid report.

Legitimate interests

We may use your personal information where it is necessary for our legitimate business interests, provided those interests are not overridden by your rights and freedoms. This may include:

• responding to enquiries;
• managing customer relationships;
• improving our website and services;
• keeping records of enquiries;
• protecting our business and systems;
• following up with relevant information about your enquiry.

Consent

We may rely on consent where required, including for certain types of marketing, optional cookies, analytics cookies, tracking pixels and partner introductions. You can withdraw consent at any time.

Legal obligation

We may use your personal information where necessary to comply with legal obligations, including tax, accounting, consumer protection and regulatory obligations.

7. Marketing and follow-up contact

At launch, First Car Scout does not expect to operate a general newsletter. We may contact you about an enquiry you have made or a service you have requested. This is service-related communication, not general marketing.

We may also contact past enquirers with follow-up car-buying guidance, reminders or related offers where we are legally permitted to do so. Where we send marketing by email, SMS, WhatsApp or similar electronic messages, we will only do this where we have a valid legal basis and, where required, your consent.

You can opt out of marketing at any time by following the unsubscribe instructions in the message or contacting us at info@firstcarscout.com.

8. Cookies, analytics and tracking technologies

Our website may use cookies and similar technologies. Cookies are small files placed on your device when you visit a website. We may use:

• essential cookies needed for the website to work;
• analytics cookies, such as Google Analytics, to understand how visitors use our website;
• cookie-free analytics, such as Vercel Web Analytics, which counts page views, device types and countries in aggregate without setting cookies or building a profile of you;
• marketing cookies or tracking pixels, such as Meta Pixel, to measure and improve advertising;
• security and performance technologies used by our website and server infrastructure.

Non-essential cookies should only be used where legally permitted and, where required, after you have given consent through our cookie banner. You can manage your cookie choices through the cookie banner or your browser settings.

9. Third-party service providers

We may use trusted third-party service providers to operate our website and services. These may include providers of:

• website hosting and secure server infrastructure;
• AI assistant platforms you choose to interact with us through, such as OpenAI's ChatGPT;
• analytics tools, including Google Analytics and Vercel Web Analytics;
• advertising and tracking tools, including Meta Pixel;
• payment processing, including Stripe;
• email, communication and business administration tools;
• database, storage and security services.

These providers may process personal information on our behalf. Where required, we will put appropriate contractual and security protections in place.

10. Partner introductions and data sharing

At launch, First Car Scout does not expect to share customer details with dealers, insurers, finance brokers, inspection companies, breakdown providers, vehicle history providers, garages or affiliate partners.

If First Car Scout later offers introductions to third-party partners, we will only share your personal information with those partners where you have specifically requested or agreed to that introduction.

We may also share information where necessary:

• with professional advisers, such as accountants, lawyers or insurers;
• with payment providers;
• with IT, security or hosting providers;
• where required by law, regulation, court order or a public authority;
• in connection with a business sale, restructuring or investment process.

11. International transfers

Some of the software tools and service providers we use may be based outside the UK or may process information outside the UK. This may include software providers such as Google, Meta, Stripe or other cloud-based service providers. Where personal information is transferred outside the UK, we will take steps designed to protect it in accordance with UK data protection law, including using adequacy regulations, approved contractual clauses or other appropriate safeguards.

12. How long we keep personal information

We will keep personal information only for as long as we need it for the purposes described in this Privacy Policy.

We may anonymise information so that it no longer identifies you. We may keep anonymised information for research, analytics, service improvement or reporting.

13. How we protect your information

We take reasonable steps to protect personal information against loss, misuse, unauthorised access, disclosure, alteration or destruction. These steps may include:

• using secure server infrastructure;
• limiting access to personal information to people who need it;
• using appropriate technical and organisational security measures;
• reviewing the tools and providers we use;
• keeping records only for as long as needed.

No online service can be guaranteed to be completely secure. If you believe your information has been compromised, please contact us.

14. Your rights

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

• ask for access to your personal information;
• ask us to correct inaccurate or incomplete information;
• ask us to delete your information in certain circumstances;
• ask us to restrict how we use your information;
• object to certain uses of your information;
• withdraw consent where we rely on consent;
• ask for a copy of certain information in a portable format;
• complain to the Information Commissioner's Office.

To exercise your rights, contact us at info@firstcarscout.com. We may need to confirm your identity before responding.

15. Complaints

If you have a concern about how we use your personal information, please contact us first so that we can try to resolve it. You can contact us at info@firstcarscout.com.

You also have the right to complain to the UK Information Commissioner's Office at ico.org.uk.

16. Links to other websites

Our website may include links to third-party websites, services or partner sites. We are not responsible for the privacy practices of those third parties. You should read their privacy policies before providing information to them.

17. Changes to this Privacy Policy

We may update this Privacy Policy from time to time. The latest version will be published on this page with a new "last updated" date.

If we make significant changes, we may take additional steps to notify users where appropriate.