PRIVACY POLICY

Last updated: January 20, 2026

GENERAL INFORMATION AND ACCEPTANCE OF TERMS

IMPORTANT: BY ACCESSING AND/OR USING THIS WEBSITE AND OUR SERVICES, YOU CONFIRM THAT YOU HAVE READ, UNDERSTOOD, AND FULLY ACCEPTED THIS PRIVACY POLICY. IF YOU DO NOT AGREE WITH ANY OF ITS PROVISIONS, PLEASE DO NOT USE OUR SERVICES.

USMOTORS S.R.L. (hereinafter "USMOTORS," "we," "us," "the website") processes personal data in accordance with the General Data Protection Regulation (GDPR) (EU) 2016/679, Law of the Republic of Moldova No. 133 of 08.07.2011 on personal data protection, and applicable national legislation.

By accessing our website and using our services, you:

• Expressly and unequivocally accept all provisions of this policy
• Consent to the collection and processing of personal data necessary for service provision
• Understand and accept that the use of services is at your own risk
• Confirm that you are at least 18 years old and have full legal capacity

1. DATA CONTROLLER

Name: USMOTORS S.R.L. Address: Str. Vlaicu Pârcălab 52, MD-2012, Chisinau, Republic of Moldova Email: info@usmotors.md Phone: +373 794 74 777 Working hours: Monday - Friday: 9:00 AM - 6:00 PM

For questions regarding personal data protection, please contact us at: info@usmotors.md

2. CATEGORIES OF PERSONAL DATA COLLECTED

2.1. Identification and contact data

• First and last name
• Home/residence address
• Phone number
• Email address
• Date of birth
• ID card/passport series and number
• Personal identification number

2.2. Data for brokerage services

• Information about vehicles of interest (make, model, year, VIN)
• Purchase preferences and budget
• History of auctions and purchases made through us
• Banking data for payments (IBAN, bank name)
• Payment receipts and bank transfers

2.3. Automatically collected data

• IP address
• Technical data about device and browser
• Cookies and similar technologies
• Navigation and website interaction data
• Approximate geographical location (IP-based)

2.4. Communication data

• Content of messages sent via email, phone, or chat
• Phone call recordings (with prior notice)
• Correspondence related to transactions and services

3. PURPOSES OF PERSONAL DATA PROCESSING

We process your personal data for the following purposes:

3.1. Provision of brokerage services:

• Identification and selection of vehicles according to your preferences
• Participation in auctions on your behalf
• Coordination of vehicle transport and delivery
• Assistance with customs clearance and registration procedures
• Communication with auctions, carriers, and authorities

3.2. Management of commercial relationship:

• Creation and administration of user account
• Payment processing and security deposit management
• Issuance of invoices and accounting documents
• Communications regarding order and delivery status

3.3. Fulfillment of legal obligations:

• Compliance with tax and accounting legislation
• Reporting to authorities (OFAC, customs, etc.)
• Prevention of money laundering and terrorist financing
• Record keeping according to legal requirements

3.4. Legitimate interests:

• Service improvement and user experience enhancement
• Fraud prevention and protection against abuse
• Website and IT systems security
• Statistical and performance analysis

3.5. Marketing (with your consent):

• Sending personalized offers and promotions
• Newsletter and communications about new vehicles at auctions
• Information about new services and features

4. LEGAL BASIS FOR PROCESSING

We process your data based on the following legal grounds:

• Contract performance: for providing requested brokerage services
• Legal obligations: for compliance with tax, customs, and reporting requirements
• Legitimate interests: for security, fraud prevention, and service improvement
• Consent: for marketing communications and non-essential cookies

5. COOKIE POLICY

5.1. Essential cookies (mandatory)

These cookies are necessary for website operation and cannot be disabled:

• Session and authentication cookies
• Security cookies
• Language preference cookies

5.2. Analytical cookies

We use cookies to understand how you interact with our website:

• Google Analytics for traffic statistics
• Performance analysis and website optimization

5.3. Marketing cookies

With your consent, we use cookies for:

• Content and advertising personalization
• Remarketing and retargeting
• Social media integration

You can manage cookie preferences in your browser settings.

6. DATA SHARING WITH THIRD PARTIES

We may share your personal data with the following categories of recipients:

6.1. Service partners:

• U.S. auto auctions (Copart, IAAI, Manheim, Adesa)
• Ground and ocean transport companies
• Customs agents and freight forwarders
• Carfax/AutoCheck report providers
• Insurance companies

6.2. Service providers:

• Payment processors and banks
• IT and hosting service providers
• Email and communication services
• Web analytics services

6.3. Public authorities:

• Tax and customs authorities
• Law enforcement agencies (upon legal request)
• Regulatory authorities (OFAC, BIS)

We do not sell or rent your personal data to third parties for marketing purposes.

7. INTERNATIONAL DATA TRANSFER

Due to the nature of our services (U.S. auto auction brokerage), your data may be transferred and processed in:

• United States of America - for auction participation and transport coordination
• European Union - for ocean shipping and transit
• Other countries - depending on the transport route

We ensure adequate data protection through:

• Standard contractual clauses approved by competent authorities
• Assessment of protection levels in destination countries
• Technical and organizational security measures

8. DATA RETENTION PERIOD

We retain your personal data for different periods depending on purpose:

After retention periods expire, data will be deleted or anonymized.

9. YOUR RIGHTS

In accordance with GDPR and national legislation, you have the following rights:

9.1. Right of access - to obtain confirmation that we process your data and receive a copy thereof.

9.2. Right to rectification - to request correction of inaccurate data or completion of incomplete data.

9.3. Right to erasure ("right to be forgotten") - to request deletion of data, except for data we are legally obliged to retain.

9.4. Right to restriction of processing - to request limitation of processing in certain circumstances.

9.5. Right to data portability - to receive data in a structured, transferable format.

9.6. Right to object - to object to processing based on legitimate interests or for marketing purposes.

9.7. Right not to be subject to automated decisions - including profiling with significant legal effects.

9.8. Right to lodge a complaint - with the National Center for Personal Data Protection of the Republic of Moldova (www.datepersonale.md).

To exercise your rights, contact us at: info@usmotors.md

We will respond to requests within 30 days. In complex cases, the deadline may be extended by another 60 days, with your notification.

10. DATA SECURITY

We implement appropriate technical and organizational measures for data protection:

Technical measures:

• SSL/TLS encryption for data transmission
• Firewall and intrusion detection systems
• Regular backup and recovery plans
• Role-based access control
• Periodic security updates

Organizational measures:

• Internal data protection policies
• Staff training on confidentiality
• Confidentiality agreements with employees
• Periodic risk assessments
• Incident response procedures

11. MARKETING COMMUNICATIONS

11.1. Transactional communications

We will send you without specific consent:

• Order and payment confirmations
• Updates on auction and transport status
• Important notifications about account and services
• Information about changes to terms and conditions

11.2. Promotional communications

With your consent, we may send you:

• Offers for vehicles matching your preferences
• Promotions and discounts
• Newsletter with industry news

You can unsubscribe at any time using the link in the email or by contacting us at info@usmotors.md.

12. AGE RESTRICTIONS

USMOTORS services are intended exclusively for persons aged 18 years or older.

We do not knowingly collect personal data from minors. If we learn that we have collected data from a minor, we will delete it immediately.

Parents or legal guardians are responsible for monitoring the online activity of minors in their care.

13. LINKS TO THIRD-PARTY WEBSITES

Our website may contain links to third-party websites (auctions, carriers, financial institutions).

We are not responsible for:

• Privacy practices of these websites
• Content or services offered by third parties
• Data security on third-party platforms

We recommend reading the privacy policies of any third-party website you access.

14. POLICY CHANGES

We reserve the right to modify this Privacy Policy periodically.

We will notify you of changes through:

• Publication of the updated version on the website
• Email (for significant changes)
• Notification in your user account

The date of the last update is displayed at the beginning of this document. Continued use of services after changes constitutes acceptance of the new version.

15. DISPUTE RESOLUTION

15.1. For any questions regarding personal data processing, please contact us first at info@usmotors.md.

15.2. We will try to resolve any issue amicably within 30 days.

15.3. If you are not satisfied with our response, you have the right to file a complaint with:

National Center for Personal Data Protection Address: MD-2004, Chisinau, Serghei Lazo str., 48 Phone: +373 22 820 801 Email: centru@datepersonale.md Website: www.datepersonale.md

16. FINAL PROVISIONS

16.1. This Privacy Policy is an integral part of the Terms and Conditions for using USMOTORS services.

16.2. In case of discrepancies between language versions, the Romanian version prevails.

16.3. If any provision of this policy is declared invalid, the other provisions remain in force.

16.4. Applicable law: Law of the Republic of Moldova.

17. CONTACT

For any questions regarding this Privacy Policy or the processing of your personal data:

USMOTORS S.R.L. Address: Str. Vlaicu Pârcălab 52, MD-2012, Chisinau, Republic of Moldova Phone: +373 794 74 777 Email: info@usmotors.md Hours: Monday - Friday: 9:00 AM - 6:00 PM