Important notice: If you use our Website or Services, you should read this notice to understand how we will handle your personal data.
1. Who we are
The Website is operated by garady.com Ltd (“We”, “Us” or “Garady”). Garady is a limited company registered in VietNam under company number 08 2672 0263 and has its registered office at 417/4/9 Tan Son Street, Ward 12, Go Vap District, Ho Chi Minh City, Viet Nam.
Please see how to contact us below.
2. How We collect and receive your information
We collect information to provide our Services to all our users and also to improve our Website and Services. The information We collect can range from an email address to information on how you interacted with the Website and used our Services. Further details about how We collect personal data, as well as the types of personal data We collect, are set out below.
We collect information in the following ways:
If you register to use the Website as a Driver or a Mechanic you will be asked to provide certain information about yourself, including your name and contact details, comprising email address, telephone number and/or address information.
If you register as a Mechanic with us, you may be asked for further information regarding your business. This may include supporting evidence which you may provide to Us via email or post.
Posting a Job
If you are a Driver and use the Website to request Quotes from Mechanics, We will collect information contained in your request which will include your telephone number, car registration number, postcode and details of the work you need to be undertaken.
If you post your Job or request a Quote via a third party who uses our Website or Services, your information (including name, email address and contact details) may be stored and processed in our systems to help that third party to provide a Quote to you. The types of third parties that We work with in this respect include:
Garage owners and Mechanics that host our booking technology on their own websites and/or social media pages.
Parts manufacture, distribution and supply businesses that host our booking technology on their own websites and social media pages.
Price comparison websites that use our Website and booking technology to help their customers arrange vehicle servicing and repairs or obtain Quotes for work.
Automotive-related websites that wish to enable their visitors and customers to arrange vehicle servicing and repairs using our Website and booking technology.
Information you input into the Website, or via online forms or surveys
We may also collect any other information you submit via any online forms or other interactive areas that appear on the Website from time to time.
This includes information contained in any Listing, Request, Quotes or Feedback you post on the Website or which is contained in any message/chat you transmit via the Website. This could include information you supply for additional services We offer via our partners. This could include your name, contact details and information relating to the products you are enquiring into or applying for (such as date of birth, which is needed to help identify you for third party applications of credit).
We collect information about telephone interaction between Drivers and Mechanics, as well as between Garady, Mechanics, Drivers and others.
This could include monitoring, recording, transcribing, storing and using communication between Drivers and Mechanics and with Garady. It may also mean that Drivers, Mechanics and others that call Garadyoffices or Garady personnel may have their contact information recorded in our systems or telecommunication devices. This includes any information you may leave in a voicemail when calling Garady offices or personnel.
The reasons for collecting this information are detailed below.
PLEASE NOTE: In operating as a Mechanic on our Website you agree that Garady may at its choosing monitor, record, transcribe, store and use communication between yourself and a Driver in order to check details of any instructions received as a result of using the Website.
Operating as a Mechanic on the Website or using our booking technology
If you are a Mechanic and you purchase membership or other services on the Website or from Garady, We may collect information about your purchases as well as your credit or debit card information and We will collect information concerning the Quotes you have submitted via the Website or using our technology.
Billing and other information
For Drivers and Mechanics that purchases services from Garady including Membership packages, breakdown cover, and other paid for services provided by Garady, We may store your information with our third-party payment processors. We may store other details in third party systems to provide Us with accounting and customer relationship management abilities. This may include payment histories and contact information as well as various notes taken by Garady staff.
When you use our Website and Services We may collect information about how you interacted with our Website, including information that your browser sends when you visit a website. This log data may include your Internet Protocol address, the address of the web page you visited before using our services, and the date and time of use of our services.
We may use third party tools that, whilst they do not identify specific users of our site, aggregate user behaviour in interacting with our Website and services. These tools may provide information including addresses of web pages visited before using our services and the devices and browsers used to access our Website. This data may include geo-location information as provided by these third parties.
One of the tools we use is Google Analytics. Please see click here on how Google Analytics uses your data https://policies.google.com .
Third party data
Garady may also receive information from our partners or others that We use to make our Services more effective, tailored, and more useful to you. This might be aggregate level information such as which post codes go with which city, or it might be more specific information, such as email address, name and profile information passed from Facebook on account registration via Facebook.
Other methods We may use to collect your information
We may collect information about you (name, contact details, etc) if you contact our office via telephone, fax, post or via email. We may also collect your information at trade shows or during other interactions with you in person. This information may then be transcribed and uploaded into our systems or recorded in written format.
3. How We use your information and legal basis for doing so
Information is used in the following ways:
We use the information We collect from you when you use our Website or Services, to provide, maintain, protect and to improve our Website and Services, to develop new ones and to protect Garady and our users. Further information about the purposes for which we use your information and the legal basis for doing so are detailed below.
To provide our Website and Services and an enhanced user experience
Your information will be used to provide you with access to our Website and to supply you with Services you request. In particular:
If you are a Driver and request quotes on our Website, We will use your postcode to select Mechanics who are best placed to respond and We will send details of the request, together with your first name, to these selected Mechanics so they can respond. The car registration number will be provided to the Mechanics and may be shared with our Third Party partners to help identify the make and model of the vehicle, and help provide services to our Mechanics in relation to parts data and parts information so that the Mechanics can provide you a quote on your service or repair request.
Please see how to manage your telephone communication with Mechanics below.
The Website allows the Mechanic to communicate via messaging/chat to Drivers once a Job is quoted on, and likewise a Driver can communicate via message/chat to a Mechanic. This functionality allows you to ask questions and transmit information between each other that might be useful to either party in assessing and understanding a quote. The chat system allows this flow of information to be exchanged in a controlled manner. However, if you provide personal contact or other personal information (e.g. credit card information) via the messaging/chat functionality of the Website, you do so you do at your own risk.
Garady may also review the messaging/chat system from time to time, and may use any or all of the information for various purposes including assisting us in contacting you, assisting us in any legal proceedings or dispute, assisting us in our analysis of completed bookings, assisting us in the development of various enhancements of our systems or Website or in any other manner that we may be required under law to provide such information.
This is often necessary in order to be able to fulfil our obligations under the contract between us.
In other cases this is necessary for our legitimate interests (including managing our relationship with Drivers and Mechanics, enforcing our contractual rights and resolving disputes, keeping records, studying how customers use our Website and Services and improving our Website and Services).
To communicate with you by Email
We send a variety of emails to you, both as Drivers and Mechanics and as other consumers of services in our Website. These include other services you may have subscribed to or purchased, such as breakdown cover, or repair finance.
Some of the emails We send you are part of the functionality of how the Website and our Services work, for instance We inform you if you have received a Quote if you’re a driver. If you are registered as a Mechanic, We may send you renewal notices etc. We categorise emails of this nature as “transactional emails”. They are intended to give you information in relation to the requests you are making in the system and prompt a response from you to those requests.
Other types of emails that We may send you may be marketing-related emails. If you register with us as a Driver or Mechanic or via another service we offer (breakdown cover etc.) and have consented to receive such information, We may use your details to provide you with, or permit selected third parties to provide you with, information about goods, services and offers that We feel may interest you.
For details on how to change your consent to receive these emails, refer to the Your Rights and Choices section of this policy.
The other type of emails we may send to you is regarding interaction with Garady staff and may result in our requesting more information from you about certain matters, or providing you with an update on your account etc.
In the case of transactional emails, this is necessary in order to be able to fulfil our obligations under the contract between us.
Transactional emails (and emails responding to queries or requesting information) are also necessary for our legitimate interests (including to manage our relationship with you and to resolve queries and disputes).
Drivers and Mechanics who registered to use our Website and Service prior to 24th May 2018 will have been given the opportunity to decline to receive marketing emails when they first registered with us and with each marketing email. So we consider the marketing emails we send to these customers are necessary for our legitimate interests (including to grow our business).
Drivers and Mechanics who registered to use our Website and Service after 24th May 2018 will be asked if they want to opt in to receive marketing emails and so we will only send marketing emails to these customers if the have consented to receive them.
To enable our users to communicate with us and each other by Telephone
As disclosed above, Mechanics who respond to a request for a Quote will also be given access to the telephone number a Driver provided so that they can contact the Driver to discuss their requirements and their quotation. Likewise, Drivers are able to access Mechanic telephone numbers in order to call them and enquire about the quotes they have received.
Please see the section below on how Drivers can manage your telephone communication with Mechanics.
Drivers may also be called in connection to other services they actively purchase from Garady. These calls will be for functional purposes related to those purchases, such as liaising with the Driver on their breakdown, or service plan booking.
Garady staff may also use both the Mechanic and/or Driver telephone numbers to transfer calls to either party, to assist us in our analysis of completed bookings, to make enquiries on behalf of Drivers to Mechanics and to assist us in any dispute investigations We may conduct. Additionally, We will use Mechanic telephone numbers to conduct account management calls, sales calls, and other calls to Mechanics on behalf of Garady or our partners.
Garady may monitor, record, transcribe, store and use communication between Drivers and Mechanics and their communications with Us. We will only use this information for the following:
to help us in our analysis of completed bookings;
for training purposes; and
for legal reasons, including regulatory requirements.
If you register as a Mechanic with Us you are acknowledging and accepting the following:
you are only being given the access to Driver telephone numbers for the purposes of responding to their enquiry on our Website and not for any other reasons;
you are registering with us as a business and as such you will maintain business-like conduct with our staff and with Drivers who you contact, or who contact you through Garady;
you agree to have your telephone number used in connection to marketing and sales-related activities from WCMFC to your business; and
you understand that Garady may at its choosing monitor, record, transcribe, store and use communication between yourself and a Driver in order to check details of any instructions received as a result of using the Website.
In some cases this is necessary in order to fulfil our obligations under our contract with you.
In other cases this is necessary for our legitimate interests (including managing our relationship with Drivers and Mechanics, enforcing our contractual rights and resolving disputes, keeping records, studying how customers use our Website and Services, improving our Website and Services and growing our business).
In some cases this may also be necessary to ensure compliance with out legal obligation.
For Feedback purposes
If you are a Driver and post Feedback, the content of the Feedback will be published on our Website. Mechanics will also have the right to post replies to any Feedback posted and the content will be published on our Website. All Feedback will be posted at the discretion of Garady in accordance with our Feedback policy.
If you register with Us We may use your information to contact you for feedback on your use or our products, services or the Website.
This is necessary for our legitimate interests (including studying how our customers use our Website and Services, monitoring customer performance in the case of Mechanics and customer satisfaction in the case of Drivers and developing and improving our Website and Services).
To manage Mechanic Listing Information and other information you provide Us as a Mechanic
If you are a Mechanic, We will publish the details of any Listing you create on the Website. As a Mechanic you should not include any contact details for your business within your public profile on the Website, as this will be published at the discretion of Garady.
As a Mechanic you may be asked to provide supporting information in relation to your business and identity. We will only use this information in relation our internal approval process, and for any products you are wishing to purchase from/or via our partners, such as motor trade insurance. We may also use any additional information you provide us for any legal or regulatory obligations We may be under in connection to your business and the services We provide.
We may use any Quotes you provide Us or the Driver in a manner consistent with the Website’s Intellectual Property rights as outlined in the Terms & Conditions of the Website. This could include, but not limited to, analysis of such pricing on a repair/service category on a regional, national level, or by type of business that provided the Quotes.
In some cases this is necessary in order to fulfil our obligations under our contract with you.
In other cases, this is necessary for our legitimate interests (including managing our relationship with you, enforcing our contractual rights and resolving disputes, keeping records, improving our Website and Services and growing our business).
In some cases this may also be necessary to ensure compliance with our legal obligations.
For Billing and Account Management purposes
We use your data to help administer your accounts, both as a Driver and Mechanic.
As a Mechanic We will use your information to inform you about Jobs which have been posted on our Website by Drivers and if you post a Quote for a Job this will be shared with the Driver concerned. We will also use information concerning the Quotes you have submitted and your use of the Website for billing purposes and to ensure that you are complying with your obligations under our Terms and Conditions.
As a Driver we will use your information to process payments for additional services you may purchase from Garady or our partners that use Garady systems to provide you with services you have purchased.
As a Driver your car registration number may be used in conjunction with Mechanic, and other information to identify jobs that may have been completed. In addition, your car registration number may be shared with our Third Party partners to help us identify parts that may have been used in any repair or service for billing purposes. Your car registration may also be contained in reports to Mechanics to help them identify work being sent to them, quoted on by the, and completed by them.
This is necessary in order to fulfil our obligations under our contract with you.
This is also necessary for our legitimate interests (including managing our relationship with you, enforcing our contractual rights and resolving disputes and keeping records).
Website Usage Analysis
This is necessary for our legitimate interests (including studying how customers use our Website and Services, improving our Website and Services and growing our business).
We may use and analyse the information We collect so that We can administer, support, improve, optimise and develop the Website and the products and services We offer. This information could be related to your activity on the Website, types of work listed, quotes, regional data, car make/model data and other patterns that are collected from both Jobs being posted by Drivers and Quotes provided by Mechanics.
Other ways we may use your data
We may use your data to investigate, resolve and transfer complaints between parties.
We may receive, requests from official government/local government bodies and law enforcement authorities and to help Us identify and fix issues with our systems.
This is necessary for our legitimate interests (including resolving complaints and disputes, maintaining and improving our systems).
In some cases this may be necessary to comply with legal obligations which we are subject to.
PLEASE NOTE: This policy is not intended to place any limits on what We do with data that is aggregated and de-identified, so it is no longer associated with an identifiable Driver or Mechanic.
PLEASE NOTE: As we indicate above, some processing of your personal data may be necessary to fulfil our contractual obligations to you. This includes processing your information to provide Services to you. If you do not provide this information, we may not be able to fulfil our contractual obligations to you.
4. How your information may be shared and with whom
Our employees who need to have access to your personal data will have access to it in order to provide Services to you and for the purposes detailed above. We will also share your information with other users of the Website and Services in the ways described in Section 2 (How We Use Your Information). We may also share your information with other third parties in the ways described below.
Third parties for marketing purposes
If you have consented to receiving marketing information from selected third parties, We may share your information with third parties so that they can provide you with information about the products and services they offer.
With our third-party service providers and agents
We may allow third-party providers and contractors who supply services to Us or who process information on our behalf (for example our payment provider and website hosts and third parties who help us to develop and support our Website) access to your information limited to the extent that it is necessary for them to perform their services. We will make sure we have a contract in place with all such suppliers which satisfies the requirements of data protection laws. In particular, we will ensure that they keep your information secure and do not use it for their own purposes, unless you grant them permission to do so.
During changes to our business structure
We may share your information with another organisation which buys our business or our assets or to whom We transfer our agreement with you and in the course of any negotiations which may or may not lead to such a transfer or sale.
To comply with laws
We will disclose your information if We are required to by law. We may disclose your information to enforcement authorities if they ask us to, or to a third party in the context of actual or threatened legal proceedings, provided We can do so without breaching data protection laws.
In working with partners to offer Mechanics enhanced or further services, and to help manage our accounts
If you are a Mechanic registered with Us and you have expressed your interest joining one of the various networks that We are deploying, then your contact information may be passed to the suitable network partner to help onboard you to that network.
As a Driver, your car registration number may be shared with our partners in order to.
Help identify parts and other specific information related to your car make and model.
Help identify jobs that Mechanics may be completed by purchasing parts related to your car registration number.
Help provide reporting to those partners on what work is being done via our Website.
Working with third party referrers of visitors to our website and third-party suppliers to our Mechanics
If you have visited the Website as a result of a referral link or integration with a third-party site with which We hold a commercial relationship, such as another automotive website or price comparison platform, We may share selected elements of your information with that party, such as your vehicle registration number, during the process of regular reporting and verification of our commercial relationships with them. We will only share this information to the extent that it is required to confirm that relationship and only with the partners with which a relationship has been tracked by our system.
Mechanics may choose to take advantage of commercial partnerships We hold with suppliers of vehicle parts, or businesses of a similar nature, to procure supplies for the completion of the servicing or repair of your vehicle. We may share selected elements of your information with those partners, such as your vehicle registration number, during the process of regular reporting and verification of our commercial relationships with those partners. We will only share this information to the extent that it is required to confirm that relationship and transaction.
To enforce our rights, prevent fraud, and for safety
To protect and defend the rights, property, or safety of Garady or third parties, including enforcing contracts or policies, or in connection with investigating and preventing fraud.
PLEASE NOTE: In registering as a mechanic, you agree to the Websites Terms and Conditions and Code of Conduct. In line with this, Garady may disclose your contact details to Drivers (if requested by the Driver) in the event disputes arise between you and the Driver.
PLEASE NOTE: We may disclose or use aggregated and de-identified information for any purpose. For example, we may share aggregated and de-identified information with our partners or others for business or research purposes like telling a prospective Mechanic the number of Jobs available in a certain area, or partnering with a publisher to detail cost of servicing by make and model of car to its readers.
Cookies are small text files which are transferred from the Website and stored on your computer’s hard drive. They enable the Website and analytical software to assign stateful information to visitors at an individual level. Please refer to our Cookies Policy for details of the Cookies use on the Website.
By registering to use the Website you are consenting to Us using cookies in the ways described in our Cookies policy.
You may be able to configure your browser to restrict cookies or block all cookies if you wish. However, if you disable cookies you may find this adversely affects your ability to use certain parts of this Website
6. Our responsibilities
If you are a Driver and request Mechanics to provide Quotes or undertake work for you, you understand and agree that those Mechanics (and not Garady ) are solely responsible for their use of your information. Whilst We ask all Mechanics to act responsibly and to comply with all applicable data protection and privacy laws We cannot accept any responsibility for their use of your information. If you are a Driver and have questions or concerns about any Mechanic’s use of your information, please raise the matter with the Mechanic in question in the first instance.
If you would like to then raise your concern to Garady please contact Us at firstname.lastname@example.org
7. Your rights and choices
We have to hold certain personal data about you, e.g. email addresses and telephone numbers, etc. However, we provide you with certain choices about how your personal data can be used. We will also operate in accordance with data protection laws in maintaining, protecting, and using your personal data and we will respect your rights under data protection laws.
We give you the following choices when you use our Website and Services:
Opt-in/out of receiving marketing emails: You have the choice to opt-in or out of receiving any marketing email from Us and any third party at any time. To change your permissions for marketing email please see the attached link
Drivers choices about use of the telephone number: If you are a Driver and wish to remove your telephone number from the system, you can email Us at email@example.com and We can remove your active number from our system records. We may ask you for supporting evidence of your identity, before We remove the telephone number from our main system. Note: This may make it difficult for Mechanic to quote correctly on your job and they may request your telephone number via our messaging/chat systems. If you put contact details into any message you send the Mechanics We may not be able to prevent the Mechanic from holding your details in their own records. Any personal information you supply in our messaging/chat system you do at your own risk.
Your Rights under data protection law:
Under data protection legislation you also have certain rights regarding your personal data. In particular, you have the right to:
Request access to any personal data we hold about you. In order to do this, you can submit a Subject Access Request Form to Us by post, You can request the form and the supporting evidence you will need to provide to prove your identity please email firstname.lastname@example.org;
Have any personal data which we hold about you which is inaccurate rectified or to have incomplete personal data completed. You can do that via updating your profile information, or requesting that changes be made in our systems via email. We might ask you to submit supporting evidence of your identity before We comply with any request.
Have personal data erased;
Have the processing of your personal data restricted (for example, if you think the data we hold about you is inaccurate you can ask us to stop processing it, until we will either correct it or confirm it is accurate);
Be provided with the personal data that you have supplied to us, in a portable format that can be transmitted to another data controller without difficulty;
Object to certain types of processing, including processing based on legitimate interests (see above), automated processing (which includes profiling) and processing for direct-marketing purposes; and
Not be subject to a decision that is based solely on automated processing which produces a legal effect or which has a similar significant effect for you.
For more information on what rights you have please see the Information Commissioners website at http://mic.gov.vn.
In order to exercise any of these rights you can to submit a request to us via email to email@example.com. We might ask you to submit supporting evidence of your identity before We comply with any request.
Please consult the ICO website at http://mic.gov.vn. For further information concerning your rights, and under what conditions Garady may refuse certain requests.
8. Security and Retention of information
We will keep your information secure by taking appropriate technical and organisational measures against its unauthorised or unlawful processing and against its accidental loss, destruction or damage. We will retain your information for as long as We need it for the purposes set out in this policy, or as otherwise required by law. This means that personal data will be destroyed or erased from our systems when it is no longer required. For more information on how long certain types of data is likely to the kept before being destroyed please contact our Data Protection Manager.
10. Links from our website to others
If you follow a link from any part of the Website to another site, this policy will no longer apply. We are not responsible for the information handling practices of third party sites and We encourage you to read the privacy policies appearing on those sites.
11. Transfers of Data Outside the VietNam
We will not transfer your personal data outside the VietNamunless such transfer is compliant with data protection laws. This means that we cannot transfer any of your personal data outside the VietNam unless:
the VietNam Commission has decided that another country or international organisation ensures an adequate level of protection for your personal data;
the transfer of your personal data is subject to appropriate safeguards, which may include binding corporate rules or standard data protection clauses adopted by Asean or the EU Commission or EU-US Privacy Shield framework (see https://www.privacyshield.gov; or
one of the derogations under data protection laws applies (including if you explicitly consent to the proposed transfer).
We currently use a number of suppliers of IT services (including cloud- based services, hosting services and software development, support and maintenance services) who are based outside the EEA. All such suppliers have either entered into an agreement with us containing EU Commission approved data protection clauses, or they are signed up the EU/US Privacy Shield framework.
12. How to Contact Us
Feel free to contact Us if you have any questions about this policy or if you wish to exercise your information rights about any personal data you have shared with Us, or that we might hold.
For general enquires you can contact by email at firstname.lastname@example.org
If you wish to contact Us in regards to a complaint please email us at email@example.com
If you wish to contact Us in regard to exercising your information rights please contact us at firstname.lastname@example.org
You can also write to Us at
Garady.com Ltd, 417/4/9 Tan Son Street, Ward 12, Go Vap District, Ho Chi Minh City, Viet Nam.
13. Right to make a complaint
If you have any issues with our processing of your personal data please contact us in the first instance and we will endeavour to resolve it for you. However, if you wish to make a formal complaint, you can contact the Information Commissioner’s Office on 08 2672 0263 or at 417/4/9 Tan Son Street, Ward 12, Go Vap District, Ho Chi Minh City, Viet Nam.