1. Introduction

Carfundo (“we”, “us”, “our”) is committed to protecting the privacy of our customers and
dealership partners. This Privacy Policy explains how we collect, use, and share information
about you when you use our website, services, and products. It also outlines your rights
under the General Data Protection Regulation (GDPR) and how we ensure compliance with
these regulations.

2. Information We Collect
2.1 Personal Information

We collect personal information that you voluntarily provide to us when you use our website,
sign up for services, or engage with us in other ways. This may include:
– **Customers:**
– Name
– Email address
– Phone number
– Address
– Driver’s license number
– Payment information (e.g., credit card details for holding deposits)
– Information provided through our AI Car Finder questionnaire (e.g., budget, preferred car
brands)
– **Dealership Partners:**
– Dealership name
– Contact person’s name
– Email address
– Phone number
– Dealership location(s)
– Inventory details (e.g., car brands sold, number of vehicles)
– Website URL

2.2 Usage Information

We automatically collect certain information when you visit our website or use our services.
This includes:
– IP address
– Browser type and version
– Operating system
– Pages visited on our website
– Time and date of your visit
– Referral source (e.g., how you reached our website)

2.3 Cookies and Tracking Technologies

We use cookies and similar tracking technologies to enhance your experience on our
website. Cookies are small data files stored on your device. You can manage your cookie
preferences through your browser settings.

3. How We Use Your Information
3.1 Providing Services

We use your personal information to provide you with the services you request, such as:
– Matching you with suitable luxury vehicles based on your preferences.
– Facilitating car test drives, including at-home test drives.
– Processing payments, including refundable holding deposits for test drives.
– Connecting you with dealership partners.

3.2 Communication

We may use your contact information to communicate with you about your account, respond
to inquiries, send newsletters, or provide updates about our services.

3.3 Marketing

With your consent, we may use your information to send promotional offers, updates, or
marketing communications. You can opt-out of marketing communications at any time.

3.4 Improving Our Services

We may process your information to comply with legal obligations, resolve disputes, and
enforce our agreements.

3.5 Legal Compliance

We use the information collected to improve our website, services, and customer
experience. This includes analyzing usage patterns, conducting research, and implementing
new features.

4. Sharing Your Information
4.1 With Dealership Partners

If you express interest in a vehicle or request a test drive, we may share your information
with the relevant dealership partner to facilitate your request.

4.2 Service Providers

We may share your information with third-party service providers who assist us with payment
processing, website hosting, analytics, marketing, and customer support.

4.3 Legal Obligations

We may disclose your information if required by law, regulation, or legal process, or to
protect the rights, property, or safety of Carfundo, our customers, or others.

5. Your GDPR Rights

As a user in the European Economic Area (EEA), you have the following rights under the
GDPR:
– **Right to Access:** You can request a copy of the personal data we hold about you.
– **Right to Rectification:** You can request correction of inaccurate or incomplete data.
– **Right to Erasure (“Right to be Forgotten”):** You can request the deletion of your
personal data under certain circumstances.
– **Right to Restrict Processing:** You can request that we limit the processing of your data.
– **Right to Data Portability:** You can request the transfer of your data to another service
provider.
– **Right to Object:** You can object to the processing of your data for certain purposes,
such as direct marketing.
– **Right to Withdraw Consent:** If we are processing your data based on your consent, you
have the right to withdraw that consent at any time.
To exercise any of these rights, please contact us at [Insert Contact Email].

6. Data Security

We implement appropriate technical and organizational measures to protect your personal
data from unauthorized access, loss, or misuse. However, no method of transmission over
the Internet or electronic storage is completely secure, and we cannot guarantee absolute
security.

7. Data Retention

We retain your personal data only for as long as necessary to fulfill the purposes for which it
was collected, including legal, accounting, or reporting requirements. We will securely delete
or anonymize your data when it is no longer needed.

8. International Transfers

Your personal data may be transferred to and processed in countries outside of the EEA. We
ensure that any such transfers comply with applicable data protection laws, including the
GDPR, by implementing appropriate safeguards.

9. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or
legal requirements. We will notify you of any significant changes by posting the updated
policy on our website and indicating the effective date.

10. Contact Us

If you have any questions or concerns about this Privacy Policy or our data practices, please contact us at: