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PRIVACY POLICY & DATA PROTECTION NOTICE

Effective Date: December 29, 2025

AUTO NORD IMPORT S.R.L. ("We", "Us", or "The Controller") is committed to protecting the privacy and security of your personal data. This Privacy Policy outlines how we collect, use, process, and transfer your information in compliance with the EU General Data Protection Regulation (GDPR) 2016/679 and applicable Romanian legislation (Law 190/2018).

ARTICLE 1: DATA CONTROLLER IDENTITY

The entity responsible for processing your personal data is:

  • Legal Name: AUTO NORD IMPORT S.R.L.
  • Registered Office: Jud. Neamţ, Sat Cut, Comuna Dumbrava Roşie, Strada TEIULUI, Nr. 397, Romania
  • Unique Registration Code (CUI): 53053375
  • Trade Register Number: J2025094450005
  • Contact Email: contact@autonordimport.com

ARTICLE 2: DATA WE COLLECT

To provide our vehicle brokerage and export services, we are legally and contractually required to collect the following categories of data:

  • Identity Data: Full name, date of birth, copy of Passport or National ID card (mandatory for Customs clearance and Export reporting).
  • Contact Data: Billing address, delivery address, email address, and phone number.
  • Financial Data: Bank account details (IBAN/SWIFT), proof of funds, and source of wealth information (mandatory for Anti-Money Laundering checks).
  • Transaction Data: Details of vehicles purchased, invoices, and service history.
  • Technical Data: IP address, browser type, and cookies collected when you visit our website.

ARTICLE 3: PURPOSE AND LEGAL BASIS FOR PROCESSING

We process your data based on the following legal grounds (Art. 6 GDPR):

3.1. Performance of a Contract. We need your data to execute the Service Mandate, arrange logistics, and facilitate the sale of the vehicle by our Canadian partner.

3.2. Legal Obligation. We are required by Romanian and International Law to:
a) Maintain accounting records (Fiscal Law);
b) Verify customer identity to prevent money laundering (AML Law No. 129/2019);
c) Report exports to Customs Authorities.

3.3. Legitimate Interest. To prevent fraud, ensure network security, and defend our legal rights in case of a dispute.

ARTICLE 4: DATA SHARING AND RECIPIENTS

We do not sell your data. However, due to the nature of our international business ("Split Transaction Structure"), we must share your data with strictly defined third parties:

  • The Canadian Seller: Your Identity and Financial data are transferred to our authorized Canadian partner entity to issue the Bill of Sale and acquire the vehicle.
  • Logistics Providers: Shipping lines, inland transporters, and port terminals to arrange delivery.
  • Authorities: Customs Agencies (in Canada, EU, or destination country) and Tax Authorities (ANAF).
  • Professional Advisors: Accountants, lawyers, and banks facilitating the transaction.

ARTICLE 5: INTERNATIONAL DATA TRANSFERS (NON-EU)

5.1. Transfer to Canada. As the vehicles are sourced in Canada, your personal data will be transferred outside the European Economic Area (EEA).

5.2. Legal Safeguards. Transfers to commercial organizations in Canada are covered by the European Commission's Adequacy Decision (confirming that Canada offers a level of data protection essentially equivalent to the EU). For other transfers, we rely on Contractual Necessity (Art. 49(1)(b) GDPR) to perform the contract you have requested.

ARTICLE 6: DATA SECURITY

We implement appropriate technical and organizational measures (including SSL encryption, access controls, and secure servers) to protect your data against unauthorized access, loss, or alteration.

ARTICLE 7: DATA RETENTION

We retain your personal data only as long as necessary:

  • Operational Data: For the duration of the service.
  • Fiscal & Accounting Documents: Retained for 10 years as mandated by Romanian Accounting Law.
  • AML Records: Identification documents are retained for a minimum of 5 years as required by Anti-Money Laundering regulations.

ARTICLE 8: YOUR RIGHTS

Under the GDPR, you have the right to:

  • Access: Request a copy of the data we hold about you.
  • Rectification: Correct inaccurate data.
  • Erasure ("Right to be Forgotten"): Request deletion of data, unless retention is required by law (e.g., we cannot delete invoices or AML records upon request).
  • Restriction & Objection: Limit how we use your data.

To exercise these rights, contact us at contact@autonordimport.com.

ARTICLE 9: SUPERVISORY AUTHORITY

If you believe your rights have been violated, you may lodge a complaint with the Romanian National Supervisory Authority (ANSPDCP): www.dataprotection.ro.

ARTICLE 10: COOKIES

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