On The Road Pvt. Ltd. Privacy Policy ("Policy")

1- Who we are

OTR (OnTheRoad Pvt Ltd.) is a premier online automobiles’ marketplace assimilated in an exclusively modernistic socializing platform for automobiles users. The website provides idiosyncratic services to help you interact with automobiles traders, auto parts purveyors and fellow members of the website.

We require to obtain and process information about you in order to deliver you the avantgarde experience of OTR’s products and services. This policy ("Privacy Policy") and our Cookies Policy is applicable to all visitors and users of our website, online services and our customers (both Private and Trade). This circumscribes:
  • The OTR website at www.Carpedia.pk (the "Website")
  • Any OTR website that links to this Privacy Policy and/or our Cookies Policy;
  • Social media or official OTR content on other websites;
  • our mobile devices and Applications ("Apps")
It also applies to our use of any personal information you provide to us by phone, SMS, email, in letters and other correspondence and in person.

For the purposes of this Policy, the data controller is OTR Private Limited (registered in Pakistan under company registration number 03909628) and our registered office address is at OTR Pvt. Ltd, 10 KM, Multan Road, Opposite Adil Zafar Motors, Lahore.

Our Privacy Promise

OTR Pvt. Ltd. ("OTR", "we", "us", "our") is earnest to safeguarding your personal information, maintaining transparency of and about the data and information withheld and extending you control over how we use this information, wherever possible.

It’s significant that you read this policy to comprehend the detailed information we may keep about you, how we use it and how you can access or update your information, amend your preferences or request deletion of your personal data.

This Privacy Policy explains:

  • Your information OTR collects;
  • How your information is collected and used;
  • Whether your information is disclosed to anyone else;
  • Your options regarding the personal information you provide to us;
  • When and how your data may be shared with third-parties
For information on cookies on the OTR website please read our Cookie Policy here.

Emendation and updates to this Policy may be made from time to time. Any revisions will be published on this page. You are advised to review this page regularly to be aware of the collection and usage of your information and any other changes.

Your information is used in line with all applicable laws and regulations pertinent to the protection of personal information including any amendments or updates to all equivalent or successor applicable laws and regulations.

2- Information obtained and how we use it

Information provided when placing an advertisement on the Website

The advert placement process on the Website collects your name, cellphone number, email address and your location as well as details of the vehicle you wish to sell, payment options (mentioned below) and your IP address.
  • We use your name and email address to register your account and your cellphone number to place your advert. Acknowledgement of your successfully published advert and service communications about accessing and managing your account and your advert are emailed and texted to your registered email address and cellphone number. You have access to your OTR account at any time to update your personal details and you have the permission to change your options regarding marketing communications from OTR and/or third parties. Your information will be used for marketing purposes only where you have specifically consented to us.
  • We will use your location area specifically for positioning of the vehicle you advertise within our database to allow potential buyers to locate vehicles for sale within their chosen location.
  • Vehicle Registration Numbers are optional whilst placing an advert on the Website. We will not disclose the Vehicle Registration Number to any visitor looking for vehicles on the Website. The visitors may be able to see the Registration Number of your vehicle if the photographs of your vehicle within your advert display your Vehicle Registration Number.
  • We will contact you via phone or email to give you the option to revamp your advert upon its expiry.
  • We may also use your information for internal business records and purposes, including to analyze and improve our products and services and the Website. Certain features in our advert placement process are used to conserve the privacy of our customers during their communication with potential buyers via phone, email or chat.
  • For customers placing adverts, we also provide a customer to customer chat service that allows Website visitors and potential buyers who view your advert to contact you via a chat button displayed on your personal page as well as on your advert, without disclosing your contact information. This helps disabling any potential harmful links that may expose you to fraudulent activity. The use of the customer to customer chat service is mandatory for us to improve quality and maintain security of our Website. We reserve the right to monitor and retain all communications via the chat service for quality and security monitoring purposes.
    We use the financial services extended by third party payment providers for online card payment transactions. Payment card information is received and collected over a secure online payment gateway provided by:All financial and payment transactions processed are encrypted and your payment card information is used solely to process payment for your advert. We do not retain any record of your payment card details.
    For payment refunds, customers will need to write an email to [email protected] explaining the problem faced, in using our services. Our teams will evaluate the pertinent issue within three business days. Once evaluation is accomplished, the customer will be contacted with the result of the evaluation. If return is validated, a complete refund or an option to exchange for another product will be proffered. In case of an invalid return, the customer will be given detailed explanation of the unsuccessful refund claim.

Information provided when you browse or use services on the Website

You will be required to mention your preferred area location in order to search vehicles in our database. We will use this information to display adverts matching your search criteria from your selected location.

To create an account and to use certain additional services on the Website, we will collect your cellphone number, email address and your chosen password. After registering your account on OTR, you will be able to edit your personal details within your account. If you choose to log-in via Facebook or another social media account, we will automatically get access to your limited personal details (such as your account ID and email address) for your account verification. After you are logged-in to our Website, your data will be handled in accordance with this Privacy Policy and the Cookie Policy. We hold no responsibility for any use of your personal data by social media websites.

If you want to book a test drive of any vehicle or request a brochure or a quote, through the Website you will have to provide your name, email address, postal address and telephone number. This information will be extended to the relevant dealer or any other third-party. Your authorization on passing your details to the relevant dealer or other party is clearly evinced in the request form. This helps the dealers or other third-parties to contact you regarding your request.

When you opt for the chat service available on OTR’s dealers’ adverts to communicate with dealerships, you may disclose personal information whilst using the service. All inter-party conversations and email exchanges are recorded. Any personal information that you choose to disclose during a live chat or in any online form will be accessible to and processed by us, the Dealer you communicate with and will be made available to OTR. Additionally, the OTR Chat Service provider may channel computer infrastructure based anywhere in the world, by using which, you acknowledge that any personal data disclosed while using the Chat Service will be processed and stored by OTR chat service provider on its systems, protected by adequate safeguards.

We will also collect your IP address when you use the Website.

Information collected when you use our Mobile Applications

If you download or use our Mobile Applications or access our mobile optimized websites, we will receive information about your location and your mobile device. This includes a unique identifier for your device.

We may use the afore-mentioned information to provide you with location-based services including search results, advertising and other personalized content. The smart mobile devices facilitate you to manage or disable location services within the handheld device’s settings. We recommend you to contact your network service carrier or the device manufacturer in case you have questions about using your device’s location services.

How we use the information we collect

We use the information to:
  • administer the Website and connected and related services and manage organizational operations including data analysis, testing, research, statistical and survey purposes, troubleshooting and to improve the Website and our services and products.
  • formulate an overall audience profile of visitors to the Website. We use this information to succor us in creating relevant content on the Website as well as attracting automotive trade advertisers to place their stock adverts or promotions on the Website.
  • provide members who have opted-in to receive marketing communications and promotional content, with relevant and timely offers and promotions by email and text messages.
  • present a user-friendly and targeted online vehicle search experience. The website analytics tools are used in this regard, as described in details in our Cookie Policy.
  • identify the visitor’s location to hamper disruptive or fraudulent use and to establish the number of visits from different areas and locations.

Lawful grounds we use to process your information

We may process your data or information based on the following lawful grounds depending on the particular purpose we are using it for:
  • Contract: To enter into a formal contract with you and to fulfil our contractual obligations to you such as allowing you to post an advert or search for a vehicle from our database, this processing is mandatory for us to provide you with the requested services including registering, administering and managing your user-account and extending support services and service updates.
  • Consent: To provide you with the information about marketing, promotions etc. in relation to services you have opted-in to receive. This includes where you particularly request us to pass your details onto a third party such as an enquiry regarding test drive or a vehicle for sale made by you or where you opt-in to receive relevant marketing communications such as industry news and offers from us.
  • Legal Obligation: When processing of your information is mandatory for us to conform to any legal or statutory requirements. This may include assisting the law enforcement agencies with regards to their investigations.
  • Legitimate interest: To improve and develop our Website, products and/or services, fathom how visitors and customers use our Website, products and/or services, undertake auto-sector research and apprise our general marketing, to run our business and ensure the security or our Website and services for you, us and other Website visitors and customers.

3- Consent

To process certain types of your personal data and information, your consent must be clearly rendered. You must intelligibly consent to receive our marketing communications and/or to request services provided by dealerships.

Where you have consented to the Website to process your personal information, you reserve the right to withdraw consent at any time by emailing [email protected]. We will discontinue processing your data based on your request to withdraw consent but this does not apply to any prior processing of your data undertaken at any time before your withdrawal request.

If your consent has been given for your details to be passed onto a dealer or other third party, your information may already have been used by them to respond to your request before we can begin processing your consent withdrawal request. In such scenario, you will have to contact them to withdraw your consent to their use of your personal data.

4- Disclosure of your information

OTR will not share with or pass on your personal data or information to third parties except as elaborated in this policy or with your consent. We may disclose your personal information to third parties for the purpose(s) and in the circumstances as part of our processing activities, as set out below:
  • We will share your personal information with automobiles dealers, automotive manufacturers and relevant third-parties to accredit them to provide you with the requested services and products via the Website or the Apps. In certain circumstances, automotive manufacturers and other relevant third-parties may subsequently process and store your personal data and information for their business and administration purposes, in accordance with their own privacy policies. Please refer to their privacy policies or contact them if you have any queries about how these third-parties use your personal information.
  • We may use international service providers to assist us in running the Website or services available on the Website. Some of our webpages run plugins from third party platforms such as the 'Facebook Recommend' or Facebook Gestures' function. The information about your visit to the Website may be received by these third-party service providers. Logged into your account, if you browse these pages on the third-party platform, information collected and received by the third party may be synchronized to your account on the third-party platform. Please refer to their privacy policies or contact them if you have any queries about how these third-parties use your personal information.
  • We are under an obligation to disclose or share your personal information in order to conform to any legal obligation, or in order to enforce our terms and conditions and any other agreements.
  • If we trade any of our businesses or assets, we may disclose your personal information to the prospective seller or buyer of such businesses or assets.
  • We may share your personal information with our sister concerns and group companies.
  • We may share your information with our legal teams and professional advisors, the police, other public or private sector agencies, governmental or representative bodies including financial organizations, insurance companies, automotive advertising agencies and/or other organizations in accordance with the relevant legislation for the purposes of the prevention or detection of offences, and/or the apprehension or prosecution of offenders.
  • You acknowledge that our legitimate business interest requires us to preclude the use of our platform or services in any way that may aid fraudulent activity or deny consumers of their legal rights. We may share your information or your advertised vehicles on our platform with third parties or their legal representatives to the extent imperative to inhibit fraud or any adverse impact to third-parties consumer rights.
Except for when these parties act as our processor, we are not responsible for the use of your personal data by these parties.

5- Where we store your personal data

OTR will ensure that your data is handled securely and in accordance with this Privacy Policy.

All information you provide to us is securely stashed within Pakistan, and not transferred abroad unless specifically detailed.

Payment card details, information you provide when opting for a dealer or other third-party services through the Website and other information you provide when using the Chat Service is handled in accordance with the relevant service providers’ privacy policies. These information and details may be transferred and stored or processed by the service providers outside Pakistan. Where we transfer your information outside Pakistan, we will ascertain that safeguards are in place and a foolproof protection is available to secure the data.

The parties, we disclose your personal data to, may transfer your data outside Pakistan as part of their business and administration activities (see above, Disclosure of your information). Except for when these parties act as our processor, we are not responsible for the use of your personal data by these parties.

Please refer to their privacy policies or contact them if you have any queries about how these third-parties use your personal information and how your data is transferred outside the country.

We use strict procedures and security features to impede any unauthorized access to your held data.

6- Retention period

To effectuate the purpose behind collection of your information, OTR will process your personal data for as long as necessary, serving the accounting, legal and reporting purposes and requirements, and for the necessary prevention and detection of fraudulent or criminal activity. The storing, processing and retention time period of your information varies depending on the use you make of the Website and the offered products and/or services. We will retain your information, when you register an account or place an advert, for as long as your account and/or advert is active and an unspecified period after your account is closed or advert is ended to allow us to satisfy our legal, accounting and reporting requirements.

In certain cases, you can request us to delete your data: see Right to be forgotten below for further information.

In certain circumstances we may anonymize your personal data for quality, research or statistical purposes. In such case, we may keep using the information indefinitely without further notice to you.

7- Your rights as a data subject

As a data subject, you keep and can exercise any of the following rights at any given time during the period, we are possessing or processing your data and information.
  • Right of access – you can request a copy of the information that we possess about you. In case OTR refuses your request under rights of access, a reason will be extended to you.
  • Right of rectification – you can request us to rectify your data that you reckon as inaccurate or incomplete.
  • Right to be forgotten – in certain circumstances you can request us to erase your data from our records.
  • Right to restriction of processing – in certain conditions you can request us to restrict the processing.
  • Right of portability – in certain circumstances you can request us to have your data transferred to another organization.
  • Right to object – you possess the right to object to certain processing types such as profiling, direct marketing, automated processing.
  • Right to complain to the supervisory authority – in certain circumstances, you can complain to us, as outlined in paragraph 8 below.
If you have any concerns or queries regarding your rights. You can exercise your rights as mentioned above by emailing us at [email protected].

8- Complaints and Contact

If you choose to complain about the processing of your personal data by OTR (or any third- parties as described above), or the way your complaint has been handled, please email your concerns and reservations to [email protected]

If you have any questions about the use of your personal data, please contact us at: [email protected]

or

OTR Private Limited, 10 KM Multan Road, Opposite Adil Zafar Motors, Lahore, 54000.