PRIVACY POLICY

1. General provisions

This Privacy Policy (the “Policy”) sets out how PE Lutsiak Y.V. (the “Provider”, “we”, “us”) collects, stores, processes, uses and protects personal data of users of our website and of our clients. By using our services or making a payment via our website, the user confirms that they have read this Policy and consent to the processing of their personal data in accordance with the Law of Ukraine “On Personal Data Protection” No. 2297-VI dated 01.06.2010.

2. Data controller details

Private Entrepreneur Lutsiak Yan Valeriiovych

Individual Tax No. (IPN): 3290522673

Address: Chernivtsi, Ukraine

Phone: 0 800 330 204

Email: [email protected]

3. What data we collect

When providing services we may collect the following categories of personal data:

Full name of the user.

Contact details: mobile phone number, email address, messenger IDs (Viber, Telegram, WhatsApp).

Passport details and individual tax number — used solely for executing the service contract, customs clearance and vehicle registration.

Payment details: masked card number, payment system, transaction status (full card data is not transmitted to us — it is processed by the payment provider LiqPay / JSC CB “PrivatBank”).

Technical data: IP address, browser type, visit time, cookies, device data.

Order information: vehicle VIN, lot number, make/model, auction, delivery route.

4. Purposes of processing

Personal data is processed solely for:

execution and performance of the service contract for sourcing, purchasing, delivery, customs clearance and (if required) repair of a vehicle;

client identification and communication;

preparation of documents required by the laws of Ukraine (contracts, acts, powers of attorney, customs and vehicle registration documents);

payment processing via LiqPay and refund processing where applicable;

compliance with Ukrainian tax, currency and customs legislation;

informing clients about order status;

handling of inquiries, complaints and claims;

improving the quality of our services and website.

5. Legal basis for processing

the user’s consent (Art. 11 of the Law of Ukraine “On Personal Data Protection”);

necessity for the performance of a contract to which the data subject is a party;

necessity for compliance with a legal obligation of the Provider.

6. Sharing data with third parties

We do not sell personal data. Data may be shared only in the following cases:

with the payment provider LiqPay (JSC CB “PrivatBank”) — to process payments and refunds;

with customs brokers and logistics companies — for delivery and customs clearance;

with state authorities — upon their lawful request under Ukrainian legislation;

with partner repair shops — if vehicle repair services are provided;

with auction organisers and car dealers — within the scope of order fulfilment.

7. Payment data and payment security

Payments on our website are processed via the secure LiqPay service (JSC CB “PrivatBank”). The Provider does not store full card data of users. All payments are processed in compliance with the PCI DSS security standard. Data is transmitted over a secured (TLS) connection.

8. Cookies

The website may use cookies for proper operation, analytics and improved user experience. The user may disable cookies in their browser settings, but this may limit website functionality.

8.1. Microsoft Clarity and Microsoft Advertising

We partner with Microsoft Clarity and Microsoft Advertising to capture how you use and interact with our website through behavioral metrics, heatmaps, and session replay to improve and market our products/services. Website usage data is captured using first and third-party cookies and other tracking technologies to determine the popularity of products/services and online activity. Additionally, we use this information for site optimization, fraud/security purposes, and advertising. For more information about how Microsoft collects and uses your data, visit the Microsoft Privacy Statement.

9. Data retention

Personal data is stored for the period necessary to achieve the processing purposes and for the periods required by Ukrainian law (in particular, tax law — at least 3 years from the date of the last operation). After these periods data is deleted or anonymised.

10. Rights of the data subject

Under the Law of Ukraine “On Personal Data Protection”, the user is entitled to:

be informed about the sources of collection and purposes of processing of their personal data;

receive information about the conditions of granting access to personal data;

access their personal data;

request correction of inaccurate data;

request erasure of their personal data where there is no legal basis for processing;

withdraw consent to the processing of personal data;

lodge complaints with the Ukrainian Parliament Commissioner for Human Rights.

To exercise any of these rights, contact us at 0 800 330 204 or [email protected].

11. Data security

The Provider applies organisational and technical measures to protect personal data against unauthorised access, loss, alteration or disclosure, including restricting data access, using secure communication channels and regular backups.

12. Amendments to the Policy

The Provider reserves the right to amend this Policy. The current version is always published on the website. Continued use of the website after changes have been made constitutes acceptance of the updated version.

13. Contacts

Private Entrepreneur Lutsiak Yan Valeriiovych

Phone: 0 800 330 204

Email: [email protected]