5.1

Data Controller

For the purposes of the UK GDPR (UK Data Protection Act 2018) and EU GDPR (Regulation 2016/679), the data controller responsible for your personal data is:

CarSpanner

Email: contact@carspanner.com

We do not have a data protection officer because we do not engage in large-scale or systematic processing of personal data. All data protection enquiries should be directed to the email address above.

5.2

Personal Data We Process

CarSpanner is designed to minimise data collection. We collect only what is necessary to provide the service. No registration, account, name, or email address is required.

Data Type What We Collect Why Retention
Conversation content Text messages and uploaded photos sent to the CarSpanner chat To provide AI-powered parts identification and sourcing responses 90 days, then automatically deleted
Aggregate analytics Page views, referrer, country (no PII — processed by Plausible) To understand usage patterns and improve the service Rolling 12 months, aggregated only
Affiliate click events Referral click recorded by affiliate networks on link click-through Affiliate commission attribution Per affiliate network policies (see Cookie Policy)
IP address Logged by hosting infrastructure (Render) and anonymised by Plausible Security, abuse prevention, infrastructure monitoring 30 days (infrastructure logs)
Photos you upload are transmitted to Anthropic's AI service for analysis and are subject to Anthropic's privacy policy as a data processor. Photos are not stored after the conversation expires.
5.3

Legal Basis for Processing

We process personal data under the following legal bases under Article 6 of UK GDPR / EU GDPR:

Processing Activity Legal Basis Justification
Answering parts queries Art. 6(1)(f) — Legitimate interests Necessary to provide the AI service you actively chose to use; no override of your interests
Storing conversation history Art. 6(1)(f) — Legitimate interests Enables session continuity and access to your chat history during a visit
Processing uploaded photos Art. 6(1)(f) — Legitimate interests Required for AI vision-based part identification; photos submitted at your explicit action
Anonymous analytics (Plausible) Art. 6(1)(f) — Legitimate interests No personal data is processed; aggregate counts only; no consent required
Affiliate referral attribution Art. 6(1)(f) — Legitimate interests Attribution of commission-qualifying referrals; disclosed openly in Affiliate Disclosure
Security and abuse prevention logging Art. 6(1)(f) — Legitimate interests Protecting the integrity and availability of the service
Legitimate interests balancing test: For each processing activity above, we have assessed that our legitimate interests are not overridden by your rights and freedoms, taking into account the minimal nature of data collected, the reasonable expectations of users of a free AI tool, and the absence of any high-risk processing.
5.4

Your Rights

Under UK GDPR and EU GDPR, you have the following rights in relation to your personal data. To exercise any of these rights, email contact@carspanner.com. We will respond within one month.

Right of Access

Article 15 UK GDPR / EU GDPR

You have the right to obtain confirmation of whether we process your personal data and, if so, to receive a copy of that data along with information about how it is used.

How to exercise: Email contact@carspanner.com with "Subject Access Request" in the subject line.

Right to Rectification

Article 16 UK GDPR / EU GDPR

You have the right to have inaccurate personal data corrected, or incomplete data completed.

How to exercise: Email contact@carspanner.com specifying what data you believe is inaccurate.

Right to Erasure ("Right to Be Forgotten")

Article 17 UK GDPR / EU GDPR

You have the right to request deletion of your personal data where there is no compelling reason for its continued processing. Note that conversation data is automatically deleted after 90 days.

How to exercise: Email contact@carspanner.com with your conversation session ID if available.

Right to Restriction of Processing

Article 18 UK GDPR / EU GDPR

You have the right to request that we restrict processing of your personal data while a dispute about accuracy, lawfulness, or our legitimate grounds is being resolved.

How to exercise: Email contact@carspanner.com explaining the restriction you require.

Right to Data Portability

Article 20 UK GDPR / EU GDPR

Where processing is based on consent or contract, you have the right to receive your personal data in a structured, commonly used, machine-readable format, and to transmit it to another controller.

How to exercise: Email contact@carspanner.com. We can provide conversation data in JSON format.

Right to Object

Article 21 UK GDPR / EU GDPR

You have the right to object to processing of your personal data where processing is based on legitimate interests. We must stop processing unless we can demonstrate compelling legitimate grounds which override your interests.

How to exercise: Email contact@carspanner.com stating the nature of your objection.

Rights re Automated Decision-Making

Article 22 UK GDPR / EU GDPR

CarSpanner's AI responses are automated. However, they do not constitute legally significant or similarly significant automated decisions about you. If you have concerns, you may request human review of any AI response.

How to exercise: Email contact@carspanner.com.

5.5

Data Minimisation

CarSpanner does not require registration. We do not collect names, email addresses, telephone numbers, physical addresses, payment details, or account credentials. The only personal data processed is what you actively type or upload into the chat interface, plus pseudonymous infrastructure logs.

This design reflects Article 5(1)(c) of UK GDPR / EU GDPR: data must be adequate, relevant, and limited to what is necessary.

5.6

Automated Processing and Profiling

CarSpanner uses Claude (Anthropic) to process your parts queries. This constitutes automated processing of the content you submit. The AI does not produce legal effects or decisions that significantly affect you — it provides informational responses about classic car parts.

The AI does not build profiles of individual users across sessions. Each conversation is processed independently. We do not use your data to make inferences about your characteristics, preferences, or behaviour beyond answering your immediate question.

5.7

International Transfers

Your data may be transferred outside the UK/EEA in the following circumstances:

ProcessorLocationTransfer MechanismPurpose
Anthropic (Claude AI) United States Standard Contractual Clauses (SCCs) AI processing of your queries and photos
Render United States Standard Contractual Clauses (SCCs) Application hosting and database
Plausible Analytics European Union (Germany) No transfer — EU-hosted Anonymous aggregate analytics
5.8

Data Retention

We retain personal data only for as long as necessary for the purpose it was collected:

  • Conversation data (messages and photos): 90 days from creation, then automatically and permanently deleted.
  • Aggregate analytics data (Plausible): Rolling 12-month window; no personal data is retained.
  • Infrastructure logs (including IP addresses): 30 days, then automatically purged by Render.
5.9

Children's Data

CarSpanner is not directed at children under 13 years (under the UK DPA 2018) or under 16 years (under EU GDPR, where applicable). We do not knowingly process personal data from children. If you believe a child has submitted data, please contact us at contact@carspanner.com and we will delete it promptly.

5.10

Supervisory Authorities

You have the right to lodge a complaint with your relevant supervisory authority. You should first contact us to resolve any concerns, but you are not required to do so before lodging a complaint.

🇬🇧 United Kingdom

Information Commissioner's Office (ICO)

ico.org.uk

Tel: 0303 123 1113

Casework intake at: ico.org.uk/make-a-complaint

🇪🇺 European Union

European Data Protection Board (EDPB)

edpb.europa.eu

EU residents may contact their national DPA. The EDPB provides a directory at edpb.europa.eu/about-edpb/board/members.

5.11

Contact & Response Times

For any data protection queries, rights requests, or concerns, please contact us:

Email: contact@carspanner.com

Subject line: "GDPR Request" or "Data Protection Query"

We will acknowledge your request within 5 business days and provide a full response within one calendar month as required by Article 12 UK GDPR / EU GDPR. In complex cases, this may be extended by a further two months, with notice provided.