Privacy Policy

Introduction

This Privacy Policy has been prepared with consideration of the Law of Georgia on Personal Data Protection, effective from March 1, 2024, and other applicable legislation of Georgia. Where applicable, it also reflects the requirements of Regulation (EU) 2016/679, the General Data Protection Regulation, hereinafter referred to as the “GDPR”.

The purpose of this Policy is to explain, in a clear and transparent manner, what personal data may be processed by Auto Parts Tech LLC, for what purposes, on what legal bases, for how long, to whom it may be disclosed and what rights individuals have in relation to their personal data.

If you do not agree with this Privacy Policy, please do not use the website and do not submit personal data through website forms or other communication channels.

1. Data Controller

Unless otherwise stated in a separate agreement, Auto Parts Tech LLC determines the purposes and means of processing personal data collected through this website and related business communication channels.

2. Scope of this Policy

This Privacy Policy applies when:

• you visit our website;
• you submit a contact, demo, consultation or project inquiry form;
• you contact us by email, messenger, phone or another business communication channel;
• you discuss potential cooperation, integrations, catalogues, automotive data or B2B services with us;
• we prepare commercial offers, technical proposals, contracts or project materials;
• we use website hosting, CRM, analytics, anti-spam, security, email and technical support tools.

This Policy does not apply to third-party websites, platforms or services that are not controlled by Auto Parts Tech LLC, even if they are linked from our website.

3. Personal Data We May Collect

We collect only the data that is reasonably necessary for website operation, inquiry processing, business communication, provision of information about our services, security and compliance with legal obligations.

3.1. Data Provided by You

• first name and last name;
• company name and business role;
• email address, phone number, messenger handle or other contact details;
• country, city or business location, if provided;
• message content and inquiry details;
• information about a project, catalogue, supplier system, ERP, CRM, online store, API or integration request;
• documents, files, specifications, technical descriptions or business materials that you voluntarily send to us;
• any other information that you choose to include in your communication.

3.2. Technical Data

• IP address;
• browser type and version;
• device type and operating system;
• date and time of visit;
• pages viewed and actions on the website;
• referral source, UTM tags and advertising parameters;
• cookies and similar identifiers;
• error logs, security logs and information about suspicious or unauthorized activity.

3.3. Business Communication Data

If you or your company communicate with us regarding a potential project or cooperation, we may process the history of correspondence, meeting notes, commercial inquiries, technical requirements, contractual and pre-contractual documents, project status, CRM notes and internal records related to the inquiry.

4. Purposes of Personal Data Processing

We process personal data for specific, lawful and predetermined purposes, including:

• receiving and processing website inquiries;
• responding to messages and requests;
• organizing business communication;
• preparing commercial offers and technical proposals;
• assessing compatibility of automotive data, catalogues, supplier systems, APIs and integrations;
• maintaining CRM records and inquiry history;
• entering into, performing and administering contracts;
• improving website functionality, services and user experience;
• analyzing website traffic and performance;
• protecting the website, CRM, forms, email and technical infrastructure from spam, fraud, abuse and unauthorized access;
• complying with tax, accounting, corporate, regulatory and legal obligations;
• protecting the rights, legitimate interests and property of Auto Parts Tech LLC;
• preparing, bringing, exercising or defending legal claims.

We do not process personal data for purposes that are incompatible with the purposes for which it was collected, unless such further processing is permitted by law or based on your separate consent.

5. Legal Bases for Processing Personal Data

Depending on the situation, we may process personal data on one or more of the following legal bases.

5.1. Consent

We may process data based on your consent, for example, when you voluntarily submit a form, agree to receive communications, accept optional cookies or provide data for a specific purpose. You may withdraw consent at any time.

5.2. Pre-Contractual Steps and Contract Performance

When you contact us to request information, discuss a project, receive a proposal, evaluate services or enter into an agreement, processing may be necessary to take steps before entering into a contract or to perform a contract.

5.3. Legitimate Interest

We may process data where it is necessary for legitimate business interests, provided that such interests do not override the rights and freedoms of the individual. Such interests may include B2B communication, inquiry management, CRM records, service improvement, fraud prevention, technical security and protection of legal rights.

5.4. Legal Obligation

We may process or retain data where required by applicable law, court order, lawful request of a public authority, tax, accounting, corporate or regulatory obligation.

5.5. Legal Claims and Protection of Rights

We may process data where necessary to establish, exercise or defend legal claims, protect our rights and property or respond to disputes, complaints and requests.

6. Requirement to Provide Data

Providing personal data through the website is generally voluntary. However, without certain information, we may be unable to respond to your inquiry, identify the relevant communication, prepare a proposal, assess a technical request, provide information or review a request concerning your rights.

For example, if you do not provide an email address or another contact method, we may not be able to send you a response.

7. Direct Marketing

We do not send direct marketing messages without an appropriate lawful basis. If consent is required for marketing communications, we will request it separately.

You may unsubscribe from marketing communications or withdraw consent at any time. Withdrawal of consent does not affect the lawfulness of processing carried out before withdrawal.

Opting out of marketing communications does not prevent us from sending service, contractual, technical, transactional or legally significant messages.

8. Cookies and Similar Technologies

The website may use cookies and similar technologies to ensure website functionality, security, form submission, analytics and improved user experience.

8.1. Necessary Cookies

Necessary cookies are required for the basic operation of the website, correct page display, security and form submission.

8.2. Analytics Cookies

Analytics cookies help us understand how visitors use the website, which pages are viewed, how users arrive at the website and whether technical errors occur.

8.3. Functional Cookies

Functional cookies may be used to remember user preferences and improve interaction with the website.

8.4. Marketing Cookies

If advertising or retargeting tools are used, marketing cookies may help measure advertising performance and configure advertising campaigns. Such cookies are used only where permitted by applicable law and, where required, based on consent.

You may disable cookies in your browser settings. Some website features may not function properly if cookies are disabled.

9. Website, CRM and Third-Party Services

The website may be created, hosted or operated using third-party website platforms and technical service providers, including form processing, CRM, hosting, email notification, analytics, anti-spam, backup and technical support services.

When you submit a form, your data may be technically processed through the website platform, CRM system, email service, hosting provider or connected technical tools. Such providers may act as processors or independent controllers depending on their role and applicable terms.

We seek to use service providers that apply reasonable technical and organizational measures to protect personal data.

10. Recipients of Personal Data

We do not sell personal data.

We may disclose personal data only where necessary for the purposes described in this Policy or where required or permitted by law. Recipients may include:

• employees, managers and authorized representatives of Auto Parts Tech LLC;
• hosting, website infrastructure and technical support providers;
• CRM, form processing and email service providers;
• analytics, anti-spam and information security services;
• contractors, consultants, developers and technical specialists involved in project assessment or service delivery;
• lawyers, accountants, auditors and other professional advisers;
• banks, payment service providers or financial institutions where relevant to contractual relations;
• public authorities, courts, regulators or law enforcement bodies where disclosure is required by law;
• counterparties or partners where necessary to assess, prepare or implement a project or integration.

11. International Data Transfers

Because website platforms, CRM systems, email services, hosting, analytics, security or other technical tools may use international infrastructure, personal data may be transferred to, stored in or accessed from countries outside Georgia.

International transfer may take place where it is necessary for website operation, inquiry processing, CRM, email, hosting, technical support, contract performance, pre-contractual steps or other purposes described in this Policy.

Where required by applicable law, we use appropriate safeguards, contractual arrangements, technical and organizational measures, consent or other lawful mechanisms for international data transfers.

12. Additional Provisions for Users from the EU/EEA

This section applies if you are located in the European Union or the European Economic Area, or if the processing of your personal data is subject to the GDPR.

12.1. Applicability of the GDPR

Auto Parts Tech LLC is registered in Georgia. Nevertheless, the GDPR may apply if we offer goods or services to individuals located in the EU/EEA or monitor the behavior of such individuals within the EU/EEA.

12.2. GDPR Legal Bases

• consent;
• contractual necessity and pre-contractual steps;
• legitimate interests;
• legal obligation;
• necessity for the establishment, exercise or defense of legal claims.

12.3. GDPR Rights

• right of access;
• right to rectification;
• right to erasure;
• right to restriction of processing;
• right to data portability;
• right to object to processing;
• right to withdraw consent;
• right to object to direct marketing;
• rights related to automated decision-making, where applicable;
• right to lodge a complaint with a competent supervisory authority.

12.4. Transfers from the EU/EEA

If a transfer of personal data from the EU/EEA is subject to the GDPR, we seek to use lawful transfer mechanisms, including Standard Contractual Clauses, applicable derogations, contractual safeguards and other mechanisms provided by the GDPR.

12.5. EU Representative

If Auto Parts Tech LLC becomes legally required to appoint a representative in the European Union, and no exemption applies, the relevant contact details will be published in this Policy.

13. Data Retention Periods

We retain personal data no longer than necessary for the purposes for which it was collected, unless a longer period is required or permitted by law.

• contact form data: up to 3 years from the last communication, unless a longer period is needed to protect rights or comply with legal obligations;
• business correspondence: for the period necessary for negotiations, cooperation, project assessment and protection of legitimate interests;
• contract-related data: during the term of the contract and after termination for periods required for accounting, tax, corporate and legal purposes;
• technical logs: for a reasonable period necessary for security, diagnostics and abuse prevention;
• consent-based processing: until consent is withdrawn or the purpose is achieved;
• marketing data: until consent is withdrawn or the user opts out.

After the relevant purpose is achieved or the retention period expires, data is deleted, anonymized or archived in a manner that restricts further processing, unless retention is required by law.

14. Protection of Personal Data

We apply reasonable technical and organizational measures to protect personal data against unauthorized access, accidental or unlawful loss, destruction, alteration, disclosure, copying, misuse and other unlawful processing.

Such measures may include access restrictions, use of secure service providers, control of CRM and email access, backups, anti-spam and security tools, confidentiality obligations and internal rules for data handling.

No website, email, CRM system or internet service can be completely protected from all possible risks. However, we take reasonable steps to reduce such risks.

15. Data Subject Rights

Subject to applicable law, you may have the following rights in relation to your personal data:

• right to receive information about processing;
• right of access to personal data;
• right to rectification of inaccurate or incomplete data;
• right to erasure or deletion of data;
• right to restriction or blocking of processing;
• right to withdraw consent;
• right to object to processing, including direct marketing;
• right to data portability, where applicable;
• rights related to automated decision-making, where applicable;
• right to appeal or lodge a complaint with a competent authority or court.

As of the effective date of this Policy, Auto Parts Tech LLC does not use fully automated decision-making that produces legal or similarly significant effects for website users.

16. How to Exercise Your Rights

To exercise your rights, contact us at info@autopartstech.llc or through another official contact channel published on the website.

Please indicate your name, contact email, the nature of your request, the data or action you are interested in and information allowing us to identify the relevant communication or inquiry.

We may request additional information if necessary to verify your identity, protect data from unauthorized disclosure or clarify the scope of your request.

17. Complaints and Supervisory Authority

If you believe that your personal data is processed unlawfully, you may contact us with a request or complaint.

You also have the right to contact the Personal Data Protection Service of Georgia or, where the GDPR applies, the competent data protection supervisory authority in the EU/EEA state of your residence, place of work or alleged infringement.

You may also apply to a competent court in accordance with applicable law.

18. Data of Minors

Our website and services are intended for a business audience and are not directed to minors.

We do not knowingly seek to collect personal data of minors. If we become aware that we have received personal data of a minor without an appropriate lawful basis or consent of a parent or legal representative where required, we will take reasonable steps to delete such data unless retention is required by law.

19. Special Categories of Data

We do not request special categories of personal data through the website, including health data, biometric data, genetic data, data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, criminal conviction data or data concerning sex life or sexual orientation.

Please do not submit such data through website forms or ordinary business communication unless we expressly request it and there is a clear lawful basis for such processing.

20. Links to Third-Party Websites

The website may contain links to third-party websites, services, platforms or resources.

We do not control third-party websites and are not responsible for their privacy policies, terms of use, security or data processing practices. Please review the relevant third-party policies before providing personal data to them.

21. Changes to this Privacy Policy

We may update this Privacy Policy from time to time if there are changes to website functionality, data processing methods, services used, legal requirements, company structure or business processes.

The current version is published on this page. The effective date is indicated at the beginning of the document. Continued use of the website after publication of an updated version means that you have reviewed the updated Policy.

22. Contact