Privacy notice — draft

Who is responsible

Vehicular is operated by Lawrence Gimenez, the personal information controller responsible for deciding how the service uses personal data. The designated privacy representative and contact arrangements still need confirmation. This identification does not appoint a Data Protection Officer.

The currently published support address is support@vehicular.app. Its activation, monitoring and responsible privacy handler still need operational confirmation. No response guarantee is made here.

Data and purposes

The information depends on the features you use. Some features may be unavailable. These categories are supported by the application’s implementation; they are not a verified inventory of every live or offline operation.

• Website feedback: category, message, optional reply email, submission time, review status and private staff notes help us review suggestions and problems. Feedback is not published and does not subscribe you to updates. It is not linked automatically to your account.
• Accounts and access: email, a password hash, optional names and profile photo, verification and recovery records, sessions and request-limit records help create, protect and recover an account. Access-waitlist requests store an email, request time and consent record separately from subscriptions.
• Vehicle journals: vehicle identifiers, ownership dates, history, mileage, costs, notes, corrections and files support your records. Reminders use your dates, mileage and delivery preferences. Transfer invitations use the recipient’s email. Earlier history versions remain traceable.
• Reports and sharing: your selections, report links, saved snapshots and PDFs support sharing selected vehicle history. Adding records or files does not publish them.
• Inquiries and safety: available messaging features use conversation text, participants, read status, blocks and selected report evidence for communication and safety review.
• Reservations and updates: username reservations use an email, requested name and verification records. Optional update subscriptions keep email, consent wording/version/time and delivery state. Reservation messages and access requests do not subscribe you to marketing.
• Operations: security and activity records, measurements, error reports and any enabled browser verification support service operation. Existing commercial records can include purchase references and reconciliation history; their presence does not mean paid features are open.

Data can come from you, an inviting or previous owner, a conversation participant, someone uploading a file, or the service’s activity records. Files and free text may contain other people’s details, government identifiers or sensitive information. Remove unnecessary personal details before uploading or sharing.

Grounds for processing

The purpose-by-purpose legal assessment is pending. Consent is one possible ground, not a requirement for every use. Reading this notice or creating an account does not give blanket consent.

• For requested account, journal, reminder, reservation, inquiry, sharing and transfer services, the proposed ground for necessary ordinary personal information is performance of the requested service or contract under section 12(b). Necessity and scope still require review.
• Access-waitlist requests record your separate permission to save an email for access interest. Optional update emails use a separate opt-in. Consent must be specific, informed and freely given; available unsubscribe controls let you withdraw it. This does not automatically stop processing needed on another applicable ground.
• Security, safety review, measurements, existing transaction records and claim-related retention each need a documented ground. Reliance on legitimate interests under section 12(f) requires necessity and a balancing assessment; a legal obligation under section 12(c) must identify the actual obligation.
• Sensitive or privileged information needs an applicable section 13 exception. A service contract, legitimate interest or another person’s upload alone does not supply that exception. Privileged communications retain their legal protection under section 15.

How data is handled

The application receives forms and uploads, stores records and files, checks access, keeps correction history, prepares reports and queues configured emails. Authorized staff tools support specific reviews. Session and request-verification cookies support sign-in and form protection.

Automated checks can reject invalid forms, limit repeated requests and determine access from account or feature state. Scheduled processes can expire records or perform configured cleanup. Enabled analytics, browser challenges, profiling or any solely automated decisions with significant effects need a confirmed live inventory and explanation before this notice becomes effective. This draft does not assert their absence.

Sharing and providers

Private records are available through authorized account and staff functions. A transfer gives the new owner management of retained vehicle history, not the previous owner’s account details, reminders, uploaded files or report drafts. Available conversations remain subject to participant and safety-review access rules.

When you enable a public report, anyone with its link can see selected content while access remains available. Report fields omit account names and email, plate, VIN/chassis and engine numbers, private notes and costs. Details inside selected files are not automatically covered up. Stopping sharing cannot recall downloaded copies.

Possible service-provider categories include hosting, database and file storage, backups, email, browser verification, telemetry/error handling and payment processing where used. Actual providers, their roles, countries, subprocessors and contractual safeguards remain unverified. No Philippine-only storage or completed transfer assessment is claimed. Outsourcing does not remove the controller’s responsibility under section 14.

Any disclosure for a legal requirement or claim needs its specific authority, scope and safeguards assessed. External links take you to another service whose own notice should be reviewed.

How long data stays

A complete approved schedule is still missing. Each category needs a justified purpose, finite period or clear expiry criteria, responsible owner and evidence of cleanup, including provider copies and backups. Implementation defaults alone are not an approved retention policy.

The account-deletion recovery window is 30 days where the feature is available. It is not a legal retention rule, a privacy-request response period or a promise that every record disappears on day 30. Vehicle provenance, files, saved reports, safety evidence, transaction records and backups have separate rules or unresolved cleanup requirements.

See the category-by-category retention explanation. Revoking access and deleting a stored object are different actions; copies already received by others are outside the service’s direct control.

Your rights

Under Philippine law, rights apply subject to the relevant conditions and exceptions:

• Information and access: ask what personal data is processed, where it came from, why and how it is used, and who receives it, including relevant automated processing.
• Correction: dispute inaccurate data and request correction, with appropriate communication to recipients. Traceable record history does not remove this right.
• Objection and withdrawal: object to processing, including direct marketing, or withdraw consent where relied upon. After a valid objection, continued processing needs another applicable ground beyond consent or legitimate interests, with its reason explained.
• Blocking or erasure: request restriction or removal where the legal grounds apply, such as unlawful processing or data no longer needed. Established unlawful processing, unauthorized purposes or violations of data-subject rights require erasure or blocking under NPC guidance. Other requests may be limited by a specifically justified lawful exception.
• Portability: request a usable electronic copy where the applicable electronic-processing and consent or contract conditions are met. This does not entitle you to someone else’s data or mean an automatic exporter is available.
• Representation and remedies: lawful heirs or assigns may exercise applicable rights after death or incapacity, with authority verified. You may seek damages for qualifying harm and complain to the National Privacy Commission.

Identity and authority must be checked proportionately, and other people’s rights protected. Any research or investigation exception must meet the law’s conditions and be limited to what is necessary; this draft does not claim such an exemption for Vehicular.

Requests and complaints

Start with the public privacy-request guidance, including if you cannot sign in or your details appear in another person’s file. Describe the concern and desired outcome with only enough information to locate it. Do not send passwords, recovery codes or unnecessary identity documents.

You may consult the NPC’s complaint filing instructions for current requirements, forms and exceptions. The complaint rules generally require first notifying the respondent in writing and allowing an opportunity to address the concern, subject to the NPC’s exceptions. A product recovery window does not prevent a complaint.

Read RA 10173, especially sections 11–18, its Implementing Rules and Regulations and NPC data subject rights guidance. This explanation is not a substitute for individual legal advice.

Before effective publication, confirmed operational facts and reviewed wording must replace the unresolved statements above, with an approved version and effective date. This draft sets neither.