PRIVACY POLICY

Publication date: 01/01/2024

The Privacy Policy governs the processing of Personal Data by the Company.

The provisions of this Privacy Policy describe how the Company processes, stores, and receives Personal Data.

Reference to the words "we", "our" or "us" (or equivalent terms) means the Company.

Reference to the words “you” or “your” (or similar words) means the User receiving the Services.

The words he/she and their derivatives in the text of the document can be applied to either a male person or a female person, depending on the context of the document.

We are grateful to you for using the Company's services.

1. DEFINITIONS

1.1. Personal Data means any information that directly or indirectly allows you to identify the User. For example, first name, last name, phone number, and IP address.

1.2. Statistical Data means any information that is publicly available and directly or indirectly relates to the User.

1.3. Data means a generalized concept for Personal and Statistical Data.

1.4. Services means the set of actions performed by the Company, including the selection, purchase, delivery, customs clearance, repair, certification, and registration of vehicles, as well as consultation and assistance related to vehicle financing, installment plans, and post-delivery support.

1.5. Company's website (hereinafter referred to as the "Site") means a web page or a group of web pages on the Internet located at: https://trp.com.ua/

1.6. Company (hereinafter referred to as the "Company" or "TRP") means FAST DEALS Sp. z o.o., a legal entity registered under the laws of the Republic of Poland, NIP 5223271193, with its registered office at Ogińskiego 11/9, 03-318 Warszawa, Poland and TURBO PARTNERS LLP, a legal entity registered under the laws of the United Kingdom, with company number OC444668 and registered office at 27 Old Gloucester Street, London, United Kingdom, WC1N 3AX, each of which provides the Services as defined in the Contract.

1.7. Contract means a legally binding agreement concluded between the Company and the User that defines the scope, procedure, and conditions for the provision of the Services.

1.8. User is an individual or legal entity to whom the Company provides Services.

1.9. Third Party means a natural or legal person, government agency, institution or body besides the Company or the User, the Controller or the Processor.

1.10. Controller - means any natural or legal person, government agency, institution, or other body that independently determines the purposes and means of personal data processing.

1.11. Processor - is a natural or legal person, government agency, institution, or other body that processes Personal Data on behalf of and behalf of the Controller.

1.12. Cookies - are a piece of information in the form of text or binary data that is transmitted to the browser from the site.

1.13. User's Consent (hereinafter "Consent") - means a voluntary, specific, informed, and unequivocal expression of will, in which the User using a statement or explicit affirmative action agrees to the processing of his Personal Data and to comply with the terms of this Privacy Policy.

2. GENERAL PROVISIONS

2.1. The Company processes and stores Data on the basis of the following legislative acts:

2.1.1. Compliance with the principles of lawfulness, fairness, and transparency in accordance with the General Data Protection Regulation (EU) 2016/679 (GDPR);

2.1.2. Compliance with the provisions of the Act of 10 May 2018 on the Protection of Personal Data (Journal of Laws of 2019, item 1781) of the Republic of Poland and other applicable national regulations.

2.1.3. The Law of Ukraine “On Personal Data Protection.”

2.2. The Company is not responsible for the processing of Personal or Statistical Data by any Third Parties that are not controlled by and do not belong to the Company.

3. PERSONAL DATA

3.1. The Service may obtain the following Personal Data about the User:

3.1.1. full name;

3.1.2. email address;

3.1.3. telephone;

3.1.4. local address;

3.1.5. transaction, credit, subscription, and payment history (if applicable and solely for the purpose of receiving payment for the Services).

3.2. The Company may receive the following Statistical Data about the User:

3.2.1. generalized analytical information about the use of the Site, including the number of visits, viewed vehicle listings, time spent on pages, and navigation activity;

3.2.2. anonymized data on the effectiveness of advertising campaigns and inquiries related to vehicle selection, delivery, or consultation requests;

3.2.3. technical metrics collected through analytics tools (such as Google Analytics), including session duration, visited sections, type of device and browser, and operating system;

3.2.4. aggregated data about User interaction with the Company’s communications, including the number of submitted forms and responses to messages, processed in statistical form;

3.2.5. other non-personal statistical information that does not identify the User individually but is used for analytics, reporting, improvement of Services, and optimization of vehicle search and delivery processes.

3.3. The Company may receive the following Personal Data about the User’s personnel – legal entity:

3.3.1. full name;

3.3.2. email;

3.3.3. telephone.

3.4. The Company may receive the following Statistical Data about the User – legal entity:

3.4.1. data obtained from publicly available sources, such as official company registers, business directories, or corporate websites (including company name, public contact details, and area of activity related to vehicle trade or logistics);

3.4.2. information related to the interaction of the legal entity with the Company, including the number and type of requested or completed vehicle-related Services, cooperation frequency, and communication history;

3.4.3. aggregated analytical data regarding the effectiveness of vehicle import, delivery, and registration processes carried out for the User;

3.4.4. technical and operational indicators derived from analytics tools, including anonymized traffic metrics, conversion data, and general performance statistics of the Company’s Site or connected digital systems;

3.4.5. corporate information such as company name, registration number, legal address, and payment details provided within the scope of cooperation;

3.4.6. other statistical information that does not identify natural persons but reflects the business activity and interaction of the legal entity with the Company for analytical, reporting, and Service optimization purposes.

3.5. The Company may also receive the User’s Data during the conclusion and execution of the Contract. Such Data may include information provided by the User for identification, communication, invoicing, or contractual purposes, such as the User’s full name, company details, registration number, tax identification number, legal and correspondence address, email, and contact phone number. The processing of this Data is necessary for the preparation, signing, and proper performance of the Contract and for compliance with applicable legal and accounting requirements.

3.6. The Company purposefully does not process the User's banking data, and such data is processed exclusively by the payment system, which is used to receive payments. The Company may process payment data solely to resolve disputes and/or to comply with the requirements of the legislature and/or the decision of the judicial/executive authority.

3.7. Personal Data and Statistical Data may be processed by FAST DEALS Sp. z o.o., a legal entity registered under the laws of the Republic of Poland, NIP 5223271193, with its registered office at Ogińskiego 11/9, 03-318 Warszawa, Poland, and/or TURBO PARTNERS LLP, a legal entity registered under the laws of the United Kingdom, with company number OC444668 and registered office at 27 Old Gloucester Street, London, United Kingdom, WC1N 3AX. Such processing may occur jointly or separately, depending on the nature of the Services, technical requirements, or contractual obligations. Both entities ensure an equivalent and adequate level of protection of Personal Data in accordance with applicable data protection legislation, including the EU General Data Protection Regulation (GDPR) and the UK Data Protection Act.

3.8. The Company does not collect or process sensitive Personal Data of Users, such as race or ethnic origin, political views, religious or philosophical beliefs, union membership, genetic or biometric data, health information, sexual life or sexual orientation.

3.9. When visiting the Site or receiving Services, Company may collect the following Personal Data automatically:

3.9.1. IP address;

3.9.2. time zone and language settings;

3.9.3. browser type and version;

3.9.4. operating system, device type, and screen extension;

3.9.5. the country in which you are located;

3.9.6. data about your visit to the Site, including full URL information, routes to and from the Site (including date and time), page response time, data loading errors, length of stay on certain pages, page activity (such information such as scrolling and mouse movements, clicks), methods used to exit the page and telephone numbers to contact the User' support.

3.10. The Company has the right to collect and receive Personal Data as follows when:

3.10.1. the User fills out application forms on the Site to request vehicle selection, delivery, customs clearance, repair, or certification services;

3.10.2. the User contacts the Company through online chat, email, phone, or social media to obtain consultations or updates on vehicle status;

3.10.3. the User concludes a Contract or performs actions aimed at entering into a Contract with the Company;

3.10.4. the User provides documents and information required for identification, communication, or performance of the Services;

3.10.5. automatically, through cookies, analytics tools, and other technical means when the User visits or interacts with the Site;

3.10.6. from publicly available sources, if such collection does not violate the User’s rights and complies with applicable data protection laws.

3.11. The Company has the right to use Personal Data for the following purposes:

3.11.1. provision of the Services;

3.11.2. to ensure the security of the Site;

3.11.3. to administer the Site and conduct internal operations, including troubleshooting, data analysis, testing, and completing surveys;

3.11.4. to improve your navigation on the Site in accordance with your preferences;

3.11.5. communication with you;

3.11.6. respond to law enforcement requests;

3.11.7. to initiate responses to legal claims, investigations, or dispute resolution with you.

4. TRANSFER OF PERSONAL DATA

4.1. The Company may transfer Personal Data to entities with which the Company cooperates in the implementation and provision of Services:

4.1.1. Banks and financial institutions. For the purpose of processing payments, issuing invoices, and receiving remuneration for the Services, Data may be transferred directly and automatically to authorised banks and financial institutions cooperating with the Company. Each such institution acts as an independent Controller under applicable legislation. The Company does not store or process payment card details or other banking credentials; all financial transactions are carried out through secure banking channels in accordance with applicable Polish and EU regulations.

4.1.2. Key technological partners. Data may be transferred solely to essential service providers without which the operation of the Company would not be possible, including hosting providers and email distribution services.

4.1.3. Contractors and consultants. Where necessary for the proper operation of the Company, Data may be shared with carefully selected contractors such as legal, tax, accounting, marketing, and IT service providers, bound by confidentiality and data protection obligations.

4.1.4. Counterparties in corporate transactions. Data may be disclosed in the context of an acquisition, merger, financing, corporate reorganisation, joint venture, or sale of assets, subject to compliance with applicable data protection requirements.

4.1.5. Courts, law enforcement and state bodies. Data may be transferred where required by applicable law, including Law 125(I)/2018 of the Republic of Cyprus, the GDPR, or upon a binding order of a competent court or regulatory authority.

5. USER CONSENT

5.1. The User’s Consent to the processing of Data shall be deemed to have been duly provided in the following cases:

5.1.1. when the User marks (ticks) the checkbox on the Site confirming that they have read, understood, and agreed to this Privacy Policy, which serves as a clear affirmative action expressing the User’s Consent to the processing of Personal Data;

5.1.2. when the User signs the Contract with the Company, whereby the provision of Personal Data and its processing are necessary for the preparation, conclusion, and performance of the Contract in accordance with applicable law.

5.2. The Company may also collect additional explicit Consent in writing or digital if required by applicable law (for example, for marketing or promotional communications).

5.3. By performing any of the above actions, the User confirms that they have read and understood this Privacy Policy and voluntarily provide their Consent to the processing of their Data by the Company for the following purposes to:

5.3.1. provide and perform the Services related to vehicle selection, purchase, delivery, customs clearance, repair, certification, and registration;

5.3.2. conclude, and execute the Contract between the User and the Company, including verification of provided information and documentation;

5.3.3. contact the User regarding the status of vehicle selection, transportation, documentation, or other related processes;

5.3.4. prepare and execute contracts, invoices, and other documentation necessary for the provision of the Services;

5.3.5. improve the quality, safety, and efficiency of the Services provided by the Company;

5.3.6. maintain communication, respond to inquiries, and provide updates or recommendations related to the User’s requests;

5.3.7. comply with applicable legal, financial, and tax obligations of the Company.

5.4. The Company reserves the right to obtain the User's Consent via the Pop-up form. The Pop-up form may contain a Consent form in the сheckbox view.

6. PERSONAL DATA STORAGE AND PROTECTION

6.1. The Company uses all necessary security and protection measures for Data to ensure their confidentiality and prevent loss or improper disclosure.

6.2. The Company protects and stores Data from:

6.2.1. losses;

6.2.2. unlawful use, transfer, disclosure, modification, deletion, and/or destruction.

6.3. We may use the following methods to protect Data in accordance with the article "Security of processing" 32 GDPR:

6.3.1. pseudonymization and encryption of Data;

6.3.2. ability to ensure constant confidentiality, integrity, availability and fault tolerance of Personal Data processing systems;

6.3.3. regular testing, evaluation and measurement of the effectiveness of technical and organizational measures to ensure the security of processing Personal Data.

6.4. The Company does not store the User's Data in the event of a request to delete Personal Data on his behalf in accordance with the right to delete, as provided in Article 17 of the "Right to Erase" GDPR.

6.5. Company has the right to retain Data of User for 3 (three) years after the termination of the relationship in the following cases:

6.5.1. for statistical accounting;

6.5.2. if the current legislation requires their storage;

6.5.3. if they are necessary for doing business.

7. GROUNDS FOR PERSONAL DATA PROCESSING

7.1. The Company processes Data based on the following legal grounds:

7.1.1. User's Consent;

7.1.2. receiving Services from the Company;

7.1.3. to comply with the provisions of applicable law, for the proper level of our business, the conclusion, and execution of corporate transactions (sale of shares/stocks, mergers, acquisitions), to fulfill your obligations to you and/or the Third Party.

7.2. In cases where the basis for the processing of Data is Your Consent, You have the right to withdraw it at any time. To withdraw your Consent, You may email:888bmwbmw888@gmail.com If Your Consent is withdrawn, the Company has the right to terminate the provision of the Services and terminate all relations with You. If Consent is withdrawn, your Data will be permanently deleted.

7.3. The Company undertakes to stop processing Data within 15 (fifteen) business days from the date of receipt of the withdrawal of Consent.

8. USER RIGHTS (EEA JURISDICTION)

8.1. This section of the Privacy Policy governs the processing of Data belonging to Users who are residents of the member states of the European Economic Area (EEA), in accordance with the provisions of the General Data Protection Regulation (Regulation (EU) 2016/679, GDPR). The processing of such Users’ Data is carried out on lawful grounds and in compliance with the principles of lawfulness, transparency, proportionality, purpose limitation, and data minimization as set forth by the GDPR.

8.2. When processing personal and statistical data, the Service grants the User the following rights:

8.2.1. Right of access (Article 15 GDPR). The User may contact us directly to access the Data we hold about them, as well as any additional information provided for in Article 15 of the General Data Protection Regulation (GDPR).

8.2.2. Right to erasure (Article 17 GDPR). The User has the right to request the deletion of their Data. In such a case, the Data will be permanently deleted in accordance with Article 17 GDPR, unless legal exceptions apply.

8.2.3. Right to data portability (Article 20 GDPR). The User has the right to receive their Data in a structured, commonly used, and machine-readable format and to transmit it to another controller or request its direct transmission to a third party, where technically feasible, pursuant to Article 20 GDPR.

8.2.4. Right to rectification (Article 16 GDPR). The User has the right at any time to request the update, correction, or completion of inaccurate or incomplete Data in accordance with Article 16 GDPR.

8.2.5. Right to object (Article 21 GDPR). The User has the right to object at any time to the processing of their Data on grounds relating to their particular situation, pursuant to Article 21 GDPR.

8.2.6. Automated individual decision-making, including profiling (Article 22 GDPR). The User has the right not to be subject to a decision based solely on automated processing, including profiling, if such a decision produces legal effects concerning them or similarly significantly affects them, as set forth in Article 22 GDPR.:

9. USER RIGHTS (USA)

9.1. This section of the Privacy Policy regulates the procedure for processing personal data of Users who are residents of the United States of America, taking into account the requirements of the legislation of individual U.S. states on the protection of personal information, in particular the California Consumer Privacy Act (CCPA/CPRA).

9.2. This section applies to Users who are residents of the United States of America. Within the framework of applicable legislation, including the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA), Users have the right to exercise the following rights with respect to their Data:

9.2.1. Right of access. The User has the right to request which Data about them is stored by the Service, as well as to learn about the purpose of its processing, its source, and the categories of third parties to whom it may have been disclosed.

9.2.2. Right to deletion. The User has the right to request full deletion of their Data, except in cases where its retention is necessary under applicable law.

9.2.3. Right to rectification. The User has the right to update, change, or supplement inaccurate or incomplete Data stored by the Service.

9.2.4. Right to data portability. The User has the right to receive a copy of their Data in a commonly used machine-readable format and to transfer this data to another service provider upon request.

9.2.5. Right to object. The User may object at any time to the processing of their Data, including for marketing or analytical purposes.

9.2.6. Right to withdraw Сonsent. The User has the right to withdraw previously given Сonsent to the processing of Data. In such a case, the Service reserves the right to discontinue the provision of Services.

9.3. The Service does not support the "Do Not Track" (DNT) signal, in accordance with the California Online Privacy Protection Act (CalOPPA). DNT is a browser setting that allows Users to notify websites that they do not wish to be tracked. The User can enable or disable the DNT feature in their web browser settings.

10. USER RIGHTS (JURISDICTION OF UKRAINE)

10.1. The provisions of this section apply to Users and concern specific requirements in accordance with the legislation of Ukraine, in particular the Law of Ukraine “On Personal Data Protection,” and grant the User the following rights to:

10.1.1. receive information about the conditions of access to Personal Data, including information about Third Parties to whom it is transferred;

10.1.2. receive information, no later than thirty calendar days from the date of the request (except in cases provided by law), regarding whether Personal Data is being processed;

10.1.3. send a reasoned request objecting to the processing of Personal Data;

10.1.4. send a reasoned request for the modification or deletion of Personal Data;

10.1.5. protect Personal Data from unlawful processing and accidental loss, destruction, damage due to intentional concealment, failure to provide or untimely provision, as well as to protect against the provision of information that is inaccurate or discredits the honor, dignity, and business reputation of the User;

10.1.6. file complaints with the court regarding the processing of Personal Data;

10.1.7. apply legal remedies in the event of violation of the legislation on Personal Data protection;

10.1.8. make reservations regarding the restriction of the right to process Personal Data when giving consent;

10.1.9. withdraw consent to the processing of Personal Data;

10.1.10. know the mechanism of automatic processing of Personal Data;

10.1.11. protection against an automated decision that has legal consequences for them.

11. OTHER JURISDICTIONS

11.1. The Company processes Data in jurisdictions outside the EEA and the United States in accordance with applicable local laws and recognized international standards for data protection, applying privacy-by-design principles and proportionate safeguards.

11.2. This Privacy Policy sets out the Company’s general approach to processing and the core legislative frameworks primarily applicable to the Services. Where the laws of a particular jurisdiction grant additional rights or impose additional obligations, the Company will comply with those requirements. Nothing in this Privacy Policy limits mandatory provisions of applicable local law.

11.3. Due to the global nature of the Services, it is not feasible to list every data-protection law in every jurisdiction. Jurisdiction-specific notices or addenda may be provided where required and shall supplement this Privacy Policy.

11.4. The basic rights described in this Privacy Policy apply to the extent required by the law of the User’s place of residence. The scope, conditions, and exceptions to such rights may vary by jurisdiction. The Company will handle requests in accordance with applicable law, may request information necessary to verify the requester’s identity, and will inform the User where an exemption or lawful refusal applies.

12. SUBMISSION OF REQUEST

12.1. A User in any jurisdiction has the right to submit a request to the Company if he believes that his rights have been violated by writing a request in writing to the support of the Company at the address: 888bmwbmw888@gmail.com

12.2. The User's request must contain accurate information about the requirements for the Company. If the exact requirements are not specified in the request, the Company has the right to refuse to fulfill the request.

12.3. We will not be able to respond to your request or provide you with Data unless we can verify your identity and confirm that the Data belongs to you. In case of receiving a request with inaccurate information and/or in case of inability to confirm the User's identity, the Company has the right not to process the received request and contact the User for clarification. In case of receiving a response to a request for clarifications, the User must provide a new corrected request or submit a new request.

12.4. The Company must respond to the request or fulfill the conditions set forth in the request within 21 (twenty one) business days from the moment of its receipt.

13. RESPONSIBILITY

1.1. The Company informs the User that Data may be used to provide the Services, and in case of disagreement with this, the User is not entitled to receive the Services.

1.2. The Company shall not be liable for any consequences arising from the provision of inaccurate, incomplete, or outdated Data by the User, or for the User’s failure to update such Data in a timely manner.

1.3. The Company’s liability for any direct damages related to the processing of Data shall be limited to the extent permitted by the applicable laws of the Republic of Poland and, where applicable, the United Kingdom. The Company shall in no event be liable for any indirect, consequential, or incidental losses, including loss of profit, revenue, or data, arising out of or in connection with the processing of Data or the use of the Site

1.4. The Company is not responsible for any damage caused to the User as a result of the use of his Data by a Third Party without his knowledge.

1.5. The Company may link to other websites or services. The privacy practices of these websites and services are not governed by this Privacy Policy and the Company, and the Company cannot be held responsible for the processing of User's Data by Third-Party websites and services.

1.6. The User is solely responsible for maintaining the confidentiality of their account credentials, correspondence, and communication with the Company, and for ensuring that access to such information is not provided to unauthorised persons.

1.7. The Company is not responsible for:

1.7.1. for any damage to the User resulting from the processing of his Data;

1.7.2. for the User's consent to the processing of the User's Data by the Company.

1.8. Unfortunately, the transmission of information over the Internet cannot be completely secure. Although we make every effort to protect personal data, we cannot guarantee the secure process of transferring personal data to the site. In this regard, you are solely responsible for possible failures when transferring your Data to the Company.

14. COOKIES

14.1. Site pages may contain electronic images known as web beacons (sometimes also called transparent GIFs or pixel tags). Web beacons are usually small images placed on the web page or email you are viewing. The request that a device connected to the Internet makes to download such an image from the server/computer is recorded, and it provides us with information such as the IP address, the time the image was viewed, and the type of browser used to do so.

14.2. Cookies do not transmit viruses and/or malware to your device, as the data in the Cookie does not change during transit and does not affect your computer's performance in any way. They act more like logs (i.e., record User activity and remember state information) and are updated each time you visit the Site.

14.3. The Company uses the following categories of Cookies:

14.3.1. Essential Cookies – necessary for the operation and security of the Site, including access management and form submission;

14.3.2. Analytical Cookies – used to analyse traffic and usage patterns to improve the functionality and performance of the Site;

14.3.3. Functional Cookies – enable the Site to remember User preferences such as language, region, or saved forms;

14.3.4. Marketing Cookies – used to deliver relevant advertisements and measure the effectiveness of advertising campaigns.

14.4. The use of Essential Cookies is based on the Company’s legitimate interest in ensuring the proper operation of the Site. The use of Analytical, Functional, and Marketing Cookies is based on the User’s Consent, which may be granted through the cookie banner or browser settings. The User can withdraw or modify their Consent at any time by adjusting their browser settings or using the cookie management tool available on the Site.

14.5. The User has the right to refuse or disable Cookies (except Essential Cookies) at any time. Refusal to accept certain Cookies may limit the functionality or user experience of the Site.

14.6. The Company uses Cookies for the following purposes:

14.6.1. authentication and identification;

14.6.2. storage of personal preferences and settings;

14.6.3. access session tracking;

14.6.4. storage of statistical data;

14.6.5. website analysis.

14.7. The Company can use the following web analytics services: Google Analytic.

15. CONFIRM POLICY

15.1. The Services of the Company are intended for people who have reached the age of majority, in accordance with the laws of the country of residence of such a person. The Company does not process the Data of minors.

15.2. The Company has the right to delete the Data of a person who has not reached the age of majority, without warning and any consequences for the Company, as well as to terminate the provision of the Services to such a person.

15.3. If you have information about the receipt of the Services by a person under the age of majority, please contact the Company support service by sending an email to: 888bmwbmw888@gmail.com

16. PRIVACY POLICY CHANGE

16.1. We have the right to periodically make changes to the Privacy Policy, the security of Data, and compliance with the requirements of the laws of the jurisdiction in which we operate.

16.2. The User is obliged to familiarize himself with the new terms of the Privacy Policy and the Company is not responsible if the User has not familiarized himself with the new terms of the Privacy Policy.

16.3. The Company updates the date of changes to the current version of the Privacy Policy in the "Updated" line at the top of the document.

16.4. Our digital or otherwise stored copies of the Privacy Policy are considered true, complete, valid, and enforceable and in effect, at the time you visit the Site.

17. CONTACTS

17.1. The User has the right to contact the Company support service at:888bmwbmw888@gmail.com to ensure his rights, in accordance with the terms of this Privacy Policy, or in case of violation of his rights, or to leave feedback or ask a question.