Privacy Policy

1. Who We Are

Startup Coach Limited, trading as PersonalReg (“PersonalReg”, “we”, “us”, or “our”) is the data controller for the personal data collected through our website at personalreg.co.uk and related services.

We are registered in England and Wales as Startup Coach Limited.

Our Data Protection Officer can be contacted at privacy@personalreg.co.uk.

2. Data We Collect

We collect and process the following categories of personal data:

• Identity data: your name, date of birth, and (where required for DVLA transfers) your driving licence number.
• Contact data: your email address, telephone number, and postal address.
• Vehicle data: vehicle registration numbers, V5C reference numbers, and vehicle details as required for plate transfers.
• Financial data: payment card details (processed securely by our PCI-compliant payment provider — we do not store full card numbers), bank details for refunds, and transaction history.
• Technical data: IP address, browser type and version, operating system, referring URLs, and page interactions.
• Usage data: search queries, pages visited, plates viewed, and feature usage patterns.

3. How We Use Your Data

We use your personal data for the following purposes:

• To process and fulfil number plate purchases and transfers, including submitting applications to the DVLA on your behalf.
• To manage your account, provide customer support, and communicate with you about your orders and enquiries.
• To improve our AI-powered search and valuation services by analysing anonymised search patterns and usage data.
• To send you marketing communications about our products and services (only where you have opted in or we have a legitimate interest).
• To detect and prevent fraud, and to comply with our legal and regulatory obligations.
• To maintain the security and performance of our website and services.

4. Legal Basis for Processing

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

• Contract: processing necessary to perform our contract with you (e.g., processing plate purchases and transfers).
• Legitimate interests: processing necessary for our legitimate business interests (e.g., improving our services, fraud prevention), provided these interests are not overridden by your rights.
• Consent: where you have given clear consent for us to process your data for a specific purpose (e.g., marketing emails). You may withdraw consent at any time.
• Legal obligation: processing necessary to comply with our legal obligations (e.g., tax records, DVLA requirements).

5. Data Sharing

We may share your personal data with the following third parties:

• DVLA: to process registration assignments, transfers, and retention applications as required.
• Payment providers: to process payments securely. Our payment provider is PCI DSS Level 1 compliant.
• Sellers/Buyers: limited contact information may be shared between parties to facilitate private plate transactions.
• Service providers: trusted third parties who help us operate our business (e.g., hosting, email, analytics), bound by data processing agreements.
• Legal and regulatory authorities: where required by law, regulation, or court order.

We do not sell your personal data to third parties. We do not transfer your data outside the United Kingdom or European Economic Area without appropriate safeguards in place.

6. Cookies

Our website uses cookies and similar technologies to enhance your experience, analyse site usage, and assist in our marketing efforts.

We use the following types of cookies:

• Strictly necessary cookies: required for the website to function (e.g., session management, shopping basket). These cannot be disabled.
• Performance cookies: help us understand how visitors interact with our website by collecting anonymous statistical information.
• Functional cookies: remember your preferences and settings to provide enhanced features.
• Marketing cookies: used to deliver relevant advertisements and track campaign effectiveness. These are only set with your consent.

You can manage your cookie preferences at any time through our cookie consent banner or your browser settings.

7. Data Retention

We retain your personal data only for as long as necessary to fulfil the purposes for which it was collected, including satisfying legal, accounting, or reporting requirements.

Transaction records are retained for a minimum of 6 years in accordance with HMRC requirements. Account data is retained for the duration of your account and for 2 years after closure.

Anonymous or aggregated data (which cannot identify you) may be retained indefinitely for analytical and research purposes.

8. Your Rights

Under the UK GDPR, you have the following rights regarding 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 where there is no compelling reason for continued processing.
• Right to restrict processing: request that we limit how we use your data in certain circumstances.
• Right to data portability: request your data in a structured, commonly used, machine-readable format.
• Right to object: object to processing based on legitimate interests or for direct marketing purposes.
• Right to withdraw consent: where processing is based on consent, withdraw it at any time without affecting the lawfulness of prior processing.

To exercise any of these rights, please contact us at privacy@personalreg.co.uk. We will respond within 30 days. You also have the right to lodge a complaint with the Information Commissioner’s Office (ICO) at ico.org.uk.

9. Contact Us

If you have any questions about this Privacy Policy or how we handle your personal data, please contact us:

• Email: privacy@personalreg.co.uk
• Post: Data Protection Officer, Startup Coach Limited (trading as PersonalReg)

This Privacy Policy may be updated from time to time. We will notify you of any significant changes by posting the updated policy on our website and, where appropriate, by email.