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TRADERCARS PLATFORM

PRIVACY POLICY

 

1.    GENERAL PROVISIONS

1.1.       We care about your privacy and the security of your personal data, which is why we have prepared this privacy policy (“Privacy Policy”), which explains how we process your personal data, which of your rights we ensure, and provides other information about the processing of your personal data.

1.2.       This Privacy Policy applies when you use the Tradercars Platform - an auction-based vehicles sales engine, available at https://www.tradercars.eu/ (the “Platform”), visit our social networking site LinkedIn (hereinafter - “Social Accounts”), and contact us by email, telephone, or other electronic communication channels.

1.3.       In this Privacy Policy “personal data” (“Personal Data”) means any information or set of information from which we can directly or indirectly identify you, such as your name, surname, email address, telephone number, etc. As used in this Privacy Policy, “You” means a user of the Platform and its services, a visitor to the Social Accounts or a person who communicates with us.

1.4.       In processing Personal Data, we comply with the requirements of the General Data Protection Regulation 2016/679 (EU) (“GDPR”) and the legislation of the Republic of Lithuania, as well as the instructions of the controlling authorities.

1.5.       If you use the Platform, its services, visit our Social Accounts, contact us, you have consented to receive direct marketing communications, we consider that you have read and understood the Privacy Policy.

1.6.       The Platform and Social Accounts may contain links to, for example, our partners’ websites, websites of our other projects. This Privacy Policy does not apply to such websites. We encourage you to review the privacy policies of any third-party sites or platforms before providing any personal information or engaging further.

1.7.       This Privacy Policy is subject to change, so please visit the Platform from time to time to read the latest version of the Privacy Policy posted.

2.    WHO ARE WE?

2.1.       The controller of your Personal Data is Exleasingcar, UAB, a private limited liability company incorporated in the Republic of Lithuania, legal entity code 302837280, address Parodų g. 2, LT-04133 Vilnius, Lithuania, the data is collected and processed in the Register of Legal Entities of the State Enterprise “Registrų Centras” (hereinafter referred to as “Tradercars” or “We”).

3.    HOW DO WE RECEIVE YOUR PERSONAL DATA?

3.1.       We receive your Personal Data:

3.1.1.         directly from You when You provide your Personal Data to us. For example, when You register Your company on the Platform and indicate Yourself as the contact person or representative, use the Platform and its services, participate in the auction(s) organized on the Platform, make a payment, communicate with us by email or telephone, etc.;

3.1.2.         when We collect Personal Data when You use the Platform or Social Accounts. For example, We may record Your participation history in auction(s) organized on the Platform, purchases or sales of vehicles, visits to the Platform, IP address, service preferences, opened URL links, etc.

3.1.3.         when We receive Personal Data from other persons, such as your employer, service provider who identifies You as a contact person, payment institutions about payments made, etc.

3.2.       When You provide Personal Data about yourself or others (e.g., about your employees, agents), You are responsible for the accuracy, completeness, and timeliness of such Personal Data, as well as for informing or consenting of the person whose Personal Data is being provided to us. In certain cases, We may ask You to confirm that You have the right to provide us with Personal Data (for example, by completing registration forms).

4.    WHAT PERSONAL DATA DO WE PROCESS ABOUT YOU?

4.1.       We process your Personal Data for the following purposes and under the following conditions:

Purposes of personal data processing 
Processed personal data
Personal data retention periods 
Legal grounds for personal data processing
Creating and using an account on the Platform, placing a vehicle for the auction(s) organized via Platform, bidding in the auction(s) organized via Platform, and receiving other services provided via Platform.

Name, surname, username, email address, phone number;

Job title, person that you represent (when you represent a company or another person), relationship with the person represented;

Encrypted account passwords;

Account usage history, information on interactions with the Platform;

Information on the services received via Platform, service-related communications and notifications.

Account data is stored for the duration of the account’s use and for 5 years after the last login;

Service related data shall be stored for the duration of the account’s use and for a period of 5 years from the last login;

When processing data based on your consent, we will do so for the duration of your consent. Should you withdraw your consent, we will retain the data until the originally agreed upon period of consent expires.

Consent of the data subject (Article 6(1)(a) of the GDPR).

The processing is necessary for the conclusion and performance of the contract (Article 6(1)(b) of the GDPR);

The legitimate interests of the controller to ensure the quality of the operation of the account, the provision of services, and the proper administration of orders (Article 6(1)(f) of the GDPR).

Conclusion and execution of purchase and sale agreements for vehicles sold and acquired through the Platform.
Name, surname, email address, job title, person that you represent (when you represent a company or another person), relationship with the person represented, basis of representation, data related to the sold or purchased vehicle.
The data contained in the sale and purchase agreement will be retained for 10 years after the conclusion of the agreement.

The processing is necessary for the conclusion and performance of the contract (Article 6(1)(b) of the GDPR);

The legitimate interests of the controller or third party (Article 6(1)(f) of the GDPR).

Consultation on services available on the Platform and quality assurance.

If provided: name, surname, email address, phone number;

Person represented (if you represent a company or another person), your relationship with the person represented;

Subject and content of the communication (message, reply) and any data necessary to address quality issues;

In the case of communication via social networks, we may collect publicly visible information from your account.

The data is stored for the duration of the communication and for up to 1 year after the end of the communication (last message);

For Social Accounts, data is stored according to their respective settings;

When processing data based on your consent, we will do so for the duration of your consent. Should you withdraw your consent, we will retain the data until the originally agreed upon period of consent expires.

Consent of the data subject (Article 6(1)(a) of the GDPR);

The processing is necessary for the conclusion and performance of the contract (Article 6(1)(b) of the GDPR);

The legitimate interests of the controller to provide information and to ensure the quality of the service (Article 6(1)(f) of the GDPR).

Managing payments, accounting, debt management.

Name of the payer / person for whom the payment is made;

Personal identification number (if applicable);

Person represented (when representing a company or another person), relationship with the person represented;

Address, email address, telephone number;

Amount of the payment, date of the payment, number of the payer’s account, payment institution, confirmation of payment by the collector of the contribution;

Details of the arrears (date, amount, basis of the origin of the arrears, debtor passed on / unpassed to the debtor for collection).

The data shall be kept in accordance with the legislation governing financial transactions and financial accounting and, where this does not specify time limits, for 10 years from the date of payment.

The processing is necessary for the conclusion and performance of the contract (Article 6(1)(b) of the GDPR);

The processing is necessary for compliance with a legal obligation imposed on the controller to ensure proper financial accounting (Article 6(1)(c) of the GDPR);

The legitimate interests of the controller or third party (Article 6(1)(f) of the GDPR).

Platform administration, development, security, fraud prevention.
IP address, device information, data collected by cookies, analytical data (such as visits, page views, searches, links clicked, and the date and time of those clicks), URL links pointing to the Platform, and information about data changes.

Platform data is stored as described in the Privacy Policy section “Cookies and other tracking technologies” and, if not included in the cookie information, for up to 2 years after collection;

When processing data based on your consent, we will do so for the duration of your consent. Should you withdraw your consent, we will retain the data until the originally agreed upon period of consent expires.

Consent of the data subject (Article 6(1)(a) of the GDPR).

The legitimate interests of the controller in ensuring the smooth functioning, development and security of the Platform (Article 6(1)(f) of the GDPR).

Managing Social Accounts.
Username, comments and shares on the post, information about clicks on “like” and “follow”, information about reactions to entries, photo, details of the message and the reply to the message (time of receipt, content, attachments), rating information, and any other information You provide.
Social Accounts store information according to the terms and conditions set by the owners of the social networks.
Consent of the data subject (Article 6(1)(a) of the GDPR).
Conducting direct marketing campaigns for businesses, sending news.
Data used for sending newsletters and marketing: name, surname, email address, telephone number; preferences for news content, service usage data for personalized news; URL links to the Platform, information about the recipients of the newsletters; data collected via advertising cookies.
When processing data based on your consent, we will do so for the duration of your consent. Should you withdraw your consent, we will retain the data until the originally agreed upon period of consent expires.

Consent of the data subject (Article 6(1)(a) of the GDPR).

The legitimate interests of the controller to manage the mailing lists of news recipients, to analyse aggregated marketing results, to resolve problems related to the provision of news (Article 6(1)(f) of the GDPR).

Resolving disputes and claims.

Email address, content of the complaint / claim / proceeding, information related to the dispute / claim;

Other data provided by the person: name, surname, phone number, address, job title, person represented (if You represent a company or another person), relationship with the person represented.

During the resolving of the dispute and for 10 years after the end of the pendency of the dispute (or, in the case of a judicial dispute, after the final judgment has become final);

Requests and correspondence from data subjects shall be kept for 2 (two) years after the end of the processing of the request.

The processing is necessary for compliance with a legal obligation imposed on the controller (Article 6(1)(c) of the GDPR);

Legitimate interests of the controller or of a third party to assert claims or defend their rights (Article 6(1)(f) of the GDPR).


4.2.       In some cases, we may use the contacts you have provided to send you messages or call you in connection with our services. For example, to inform you of results of the auctions organized via Platform, changes to the provision of the services, etc. Such communications are necessary for the proper provision of our services and are not considered promotional communications.

4.3.       We process some of your Personal Data only with your consent. We observe the following rules for how data is processed on the basis of consent:

4.3.1.         You are not obliged to provide Personal Data, for example, if You are required to fill in a form, You may not fill in the optional fields, or if consent is given by ticking the relevant box, You may not tick it. In case You provide data in optional fields on your own, provide us with more data than is necessary to answer our questions, communicate with us on our Social Accounts, We consider that the provision of such data constitutes, at the same time, your consent to the processing of such data;

4.3.2.         You have the right to object to or withdraw your consent to the processing of your Personal Data at any time when it is processed on the basis of consent. Where We process your Personal Data on the basis of your consent, We will retain such data until You withdraw your consent. You can withdraw your consent by changing your account settings (if the data is processed in your account), by clicking on the relevant links (if provided) or by emailing us at info@tradercars.eu. We will endeavour to implement your request to withdraw consent as soon as possible after We receive it, but in some cases, this may take a reasonable amount of time due to the operation of our systems. Withdrawing your consent to some processing may result in a reduction in the scope of services available to You;

4.3.3.         even if You withdraw your consent, We may keep a record of when consent was given and withdrawn in order to demonstrate our compliance with the data protection rules where necessary.

4.4.       You have the right to amend and update the information we hold about You. In some cases, it is necessary for us to have accurate up-to-date information relating to You and We may ask You to confirm that the information we hold about You is correct.

5.    NEWS AND DIRECT MARKETING

5.1.       We may send information about our activities, services (direct marketing communications) to your email address and / or telephone number, call You if you have given us your consent to receive such information from us or if You or an organization you represent is a client of ours. We may also ask you to help us assess the quality of our performance and service.

5.2.       To provide you with bespoke newsletters, We may personalize direct marketing communications using information about your use of our services. The personalization solutions We use are only intended to improve your experience and if You do not agree on receiving our newsletters, You will not lose your right to use our services and You will receive the same quality of service.

5.3.       Your contact details may be passed on to our partners / data processors who provide us with newsletters or quality assessment services.

5.4.       If You no longer wish to receive direct marketing, You can cancel them in the manner specified in the electronic communications (for example, by clicking on the “unsubscribe” link in the newsletter, etc.) or by sending us a notification by email to info@tradercars.eu.

5.5.       If You withdraw your consent, We will endeavour to stop sending You newsletters immediately, but this may take some time. As our news campaigns are planned in advance, You may still receive our newsletters one more time even after withdrawing your consent.

5.6.       Withdrawal of consent does not automatically oblige us to destroy your Personal Data or to provide You with information about our processing of your Personal Data, and You should make a separate request for these actions.

6.    SOCIAL ACCOUNTS

6.1.       We post information about our activities, services offered, changes to services, and other news on our Social Accounts.

6.2.       It is important to remember that users of Social Accounts are subject not only to this Privacy Policy, but also to the privacy policies, rules and terms of use of the operators of the social networks on which the Social Accounts are located. When You interact with us on the Social Accounts and provide certain information (for example, by messaging us and commenting on our posts), We may see public information about your profile (name, image, email, etc.) depending on the privacy settings you have chosen. This information (for example, a comment you have made) may also be visible to other visitors to a particular Social Account, depending on the privacy settings You have chosen.

7.    HOW DO WE USE YOUR PERSONAL DATA AND WHAT PRINCIPLES DO WE FOLLOW?

7.1.       We respect Your privacy and only collect as well as process Personal Data that is necessary to achieve our stated purposes for processing Personal Data.

7.2.       In processing your Personal Data, we will:

7.2.1.         comply with the requirements of applicable and valid legislation, including the GDPR;

7.2.2.         process your Personal Data in a lawful, fair and transparent manner;

7.2.3.         We collect your Personal Data for specified, clearly defined and legitimate purposes and We do not process it in a way that is incompatible with those purposes, except to the extent permitted by law;

7.2.4.         We take all reasonable steps to ensure that Personal Data which is not accurate or complete in relation to the purposes for which it is processed is promptly rectified, supplemented, its processing is suspended, or it is destroyed;

7.2.5.         We keep them in a form which permits your identification for no longer than is necessary for the purposes for which the Personal Data is processed;

7.2.6.         We do not provide Personal Data to third parties and will not disclose it other than as set out in the Privacy Policy or applicable law;

7.2.7.         We ensure that your Personal Data is processed securely, by ensuring technical and organizational security measures, and by limiting access to your Personal Data to those of our employees who need such access for the purposes of their job functions.

8.    TO WHOM AND WHEN DO WE TRANSFER YOUR PERSONAL DATA?

8.1.       We may transfer your Personal Data to processors or recipients who assist us in the performance of our activities:

8.1.1.         marketing and advertising service providers;

8.1.2.         providers of financial accounting and financial transaction services;

8.1.3.         IT solution providers;

8.1.4.         cloud and hosting service providers;

8.1.5.         payment administration service providers.

8.2.       To enable us to publish content on Social Accounts, We provide data to the following social networking platform operators:

8.2.1.         LinkedIn Ireland Unlimited Company (Ireland) and LinkedIn Corporation (USA) (data transferred in accordance with the EU Standard Contractual Clauses approved by the European Commission);

Given that Tradercars does not administer LinkedIn, but only its own account on LinkedIn, You are invited to read the information about the storage of your personal data in the privacy documents of LinkedIn.

8.3.       We may provide data to law enforcement and pre-trial investigation authorities, courts and other dispute resolution authorities, other persons performing functions assigned by law, in accordance with the procedure provided by the legislation of the Republic of Lithuania. We provide these entities with information that is required by law or specified by the entities themselves.

8.4.       We may also transfer data, if necessary, to companies that would buy or acquire our business or engage in joint activities or other forms of cooperation with us, as well as to companies established by us.

8.5.       We generally process Personal Data within the EU / EEA, but in some cases your Personal Data may be transferred outside the EU / EEA. The transfer of your Personal Data outside the EU / EEA is based on:

8.5.1.         a data processing or supply agreement that describes such transfer and includes Standard Contractual Clauses for international transfers; or

8.5.2.         an adequacy decision adopted by the European Commission, which means that the European Commission has recognized the country in which the third party is established and / or carries on business as providing an adequate level of protection of personal data; or

8.5.3.         a specific authorization by the data protection supervisory authority to carry out such transfer; or

8.5.4.         your consent to the transfer of your Personal Data outside the EU / EEA.

9.    WHAT RIGHTS DO YOU HAVE?

9.1.       As a data subject, You have the following rights in relation to your Personal Data:

9.1.1.         to have access to your Personal Data, i.e., to receive a notice confirming whether We are processing your Personal Data and, if We are, to request access to the data processed and the information relating to it;

9.1.2.         to ask us to correct inaccurate or incorrect information We use or to supplement information where it is incomplete;

9.1.3.         to ask us to erase information We hold about You where there is a basis for erasure (an exception to this right is provided for in point 9.4.);

9.1.4.         to request us to restrict the processing of the information We hold about You where You contest the accuracy of the data or object to the processing of the data, You object to the erasure of your data which is unlawfully processed, or You need the data in order to assert, exercise, or defend legal claims;

9.1.5.         to object to the use of your data where We process your data for our and / or third parties legitimate interests;

9.1.6.         to request us to transfer / receive data that You have provided to us under a contract or consent and that We process by automated means in a commonly used electronic format;

9.1.7.         to object to the application to You of a fully automated decision, including profiling, where such a decision may have legal consequences or a similar significant effect on You;

9.1.8.         to withdraw the consents, You have given us to use information about You where We are using the data on the basis of your consent;

9.1.9.         lodge a complaint with the relevant data protection supervisory authority.

9.2.       If You wish to exercise any of your rights set out above, You may contact us by email at info@tradercars.eu. In order to better understand your request, We may ask you to fill in the relevant request form, ask You to provide a request signed with an advanced or qualified electronic signature, send the request by post or visit us.

9.3.       For security reasons, in some cases We will only be able to process your request after verifying your identity. We may therefore ask you to prove your identity, for example by providing an identity document or other information.

9.4.       You can exercise some of your rights as a data subject by changing your account settings on the Platform or deleting your account yourself. By changing your settings or deleting your account, You may lose some or all of the information contained in your account. This right cannot be exercised when You are participating in the auction as the seller or the buyer.

9.5.       We reserve the right to suspend or cancel your account privileges and the ability to use the Platform under certain circumstances. If you are not active on the Platform, meaning there are no vehicles listed in an ongoing auction or you haven't placed a bid as a buyer, we may suspend or cancel your account. Additionally, if your vehicle is listed in an ongoing auction or you have submitted a bid, we reserve the right to suspend or cancel your account in the event of a material breach of the Terms and Conditions or applicable laws by you. In such cases, ongoing auctions of your vehicles will be suspended, and any bids placed will be annulled.

9.6.       We may refuse to exercise your rights other than to object to the processing of your Personal Data where it is processed on the basis of consent, including consent for direct marketing, where We are not permitted to comply with your request under the GDPR.

9.7.       We do not normally charge any fee for exercising your rights. However, the law allows us to charge a reasonable fee or to refuse to comply with your request if it is manifestly unfounded or excessive.

9.8.       Upon receipt of your request or instruction regarding the processing of your Personal Data, We will provide You with a response within no later than 1 month from the date of the request and will carry out the actions specified in the request or inform You why We refuse to do so. If necessary, the time limit may be extended by a further 2 months, depending on the complexity and number of requests. In this case, We will inform You of the extension within 1 month of receipt of the request.

9.9.       If Personal Data is erased at your request, We may retain copies of the information as necessary to protect our legitimate interests and those of others, to comply with obligations of public authorities, to resolve disputes, to identify disturbances or to comply with agreements.

10.  HOW DO WE PROTECT YOUR PERSONAL DATA?

10.1.    Your Personal Data is processed responsibly and securely and is protected against loss, unauthorized use and alteration. We have put in place physical and technical measures to protect the information we collect from accidental or unlawful destruction, damage, alteration, loss, disclosure or any other unauthorized processing. The security measures for Personal Data shall be determined taking into account the risks involved in the processing of Personal Data.

10.2.    Our employees are under a written obligation not to disclose or distribute your Personal Data to any unauthorized third party.

11.  HOW DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

11.1.    A cookie is a small text file that is stored in the browser or on your device (computer, tablet, mobile phone). In this Privacy Policy, we use the term “cookies” to refer to cookies and other similar technologies such as Pixel Tags, Web Beacons and Clear GIFs.

11.2.    Cookies may be used to analyse information flows and user behaviour, to promote trust, to ensure security and the proper functioning of the Platform, to remember preferences, to personalise the content displayed, and to link the Platform to Social Accounts.

11.3.    We may use mandatory cookies that are necessary for the operation of the Platform, analytical cookies that analyse the use of the Platform, functional cookies that remember users' preferences, ensure the smooth and secure operation of the Platform and help to improve the functionality of the Platform, performance cookies, third party cookies, advertising cookies that are designed to show you both personalised and generic advertisements.

11.4.    Cookies used on our Platform:

Cookie name

Description

 

Creation moment

 

Period of validity

 

Data used

 

 

 

 

 

 

11.5.    We also use technological tools and solutions that record cookies and collect data:

Name of the tool

Purpose of the tool

Google Analytics

 

Generate statistics on the use of the Platform, aiming to reduce the frequency of requests. The collected data is transmitted to the USA. You can prevent Google Analytics from working by adjusting your browser settings or installing a browser plug-in. More information: https://tools.google.com/dlpage/gaoptout?hl=en.

Google Tag Manager

Analyse the popularity of the Platform. The data collected is transmitted to the USA. More information: https://support.google.com/tagmanager/answer/9323295?hl=en.

11.6.    Some third parties, such as social network operators, may use their own anonymous cookies to tailor the apps or applications they create to your needs. We do not control the use of these cookies. We recommend that you check the privacy policy of the third party for more detailed information.

11.7.    On the Platform, you can manage cookies (by ticking the options in the cookie bar) or change the settings of the browser you use. You can refuse the use of optional cookies, but this may result in some of the Platform's functionality not working and may slow down its performance. To manage cookies on your mobile device, you must follow the official instructions for that device. For more detailed information on managing cookies, please visit http://www.AllAboutCookies.org or https://www.google.com/privacy_ads.html, as well as the help page of the browser you are using. You can manage the use of advertising cookies on the Network Advertising page at http://www.networkadvertising.org/managing/opt_out.asp.

12.  CONTACT US

12.1.    If you have any questions, comments or complaints about how We collect, use and store information about You, or if You wish to exercise your rights as a data subject, You may contact us at info@tradercars.eu.

12.2.    If you believe that the processing of Your personal data infringes the GDPR provisions, You have the right to lodge a complaint with the supervisory authority of the EU Member State in which you have your habitual residence, place of work or the place where the alleged infringement took place.

The supervisory authority in Lithuania is the State Data Protection Inspectorate, address L. Sapiegos str. 17, LT-10312 Vilnius, Lithuania, email: ada@ada.lt, website: https://vdai.lrv.lt/.

13.  FINAL PROVISIONS

13.1.    If we change this Privacy Policy, we will notify you by posting the updated Privacy Policy on the Platform or by other customary means of communication.

 

 

The date of the last update: 2024 04 18.