Privacy Policy

Document date: 08.08.2026

Introduction and Who We Are

This Privacy Policy explains how Tradornet ("we", "us", "our") collects, uses, discloses, and protects personal information when you access or use the Tradornet B2B marketplace platform, including websites, mobile applications, APIs, and related services (collectively, the "Platform"). Tradornet operates a global business-to-business commerce infrastructure connecting individual customers, authorised dealers (retail and wholesale), and manufacturers.

This policy applies worldwide to all users of the Platform regardless of location. Where mandatory local privacy, consumer, or data protection laws in your country or region provide you with rights or impose obligations that differ from this policy, those mandatory local provisions prevail to the extent required by applicable law. Examples include, where relevant, the EU and UK General Data Protection Regulation (GDPR), US state privacy laws such as the California Consumer Privacy Act (CCPA/CPRA), Turkish Personal Data Protection Law (KVKK), and comparable regulations in other jurisdictions.

Tradornet is the data controller for personal information processed through the Platform unless otherwise stated in a separate notice or contract. For privacy-related enquiries, please use the contact details in the Contact section below.

Role-Based Access on the Platform

Tradornet is designed with role-based access controls so that each user type sees and manages only the information necessary for their commercial relationship with the Platform.

Individual customers

Individual customer accounts may browse retail-priced product catalogues, place orders, manage delivery addresses, track shipments, communicate with support, and view their own transaction history. Customers cannot access dealer pricing tiers, wholesale terms, manufacturer back-office data, or other customers' accounts.

Dealers (retail and wholesale)

Dealer accounts, once approved by Tradornet or the relevant manufacturer, may access authorised dealer pricing, request and submit quotes, manage carts and orders under B2B terms, and view commercial records relating to their own dealership. Dealers cannot view confidential pricing, discounts, or order data belonging to other dealers, nor can they modify manufacturer product master data beyond permitted fields.

Manufacturers

Manufacturer accounts manage their company profile, product catalogues, inventory indicators, order fulfilment workflows, logistics integrations, and communications with dealers and customers relating to their products. Manufacturers access customer or dealer personal data only where necessary to fulfil orders, provide warranty or support, or comply with law, and only to the extent permitted by Platform rules and applicable contracts.

Information We Collect

We collect personal information that you provide directly, that is generated through your use of the Platform, and that we receive from third parties where lawful and necessary.

Information you provide

• Account registration data: name, email address, phone number, password or authentication credentials, preferred language, and role selection
• Business identity data for dealers and manufacturers: legal company name, trade name, registration or tax identifiers, business address, authorised representative details, and supporting documentation submitted during onboarding
• Commercial and transaction data: orders, quotes, invoices, payment references, delivery addresses, customs or import information where required, and communications sent through the Platform
• Customer support and dispute records: messages, attachments, and notes relating to enquiries, complaints, or claims
• Marketing preferences and survey responses where you choose to participate

Information collected automatically

• Device and usage data: IP address, browser type, operating system, device identifiers, session timestamps, pages viewed, clicks, and referral URLs
• Security and fraud-prevention data: login history, authentication logs, risk signals, and records of suspicious activity
• Location data derived from IP address or, where you enable it, more precise location for delivery or fraud prevention
• Cookies and similar technologies as described in our cookie notice, where applicable

Information from third parties

• Payment processors confirming transaction status without storing full payment card details on our servers where avoidable
• Logistics and customs partners providing shipment and delivery updates
• Identity verification, credit, sanctions-screening, or business registry providers where required for onboarding or compliance
• Other Platform users when they include your information in orders, quotes, or messages

How We Use Your Information

We use personal information for the following purposes, relying on appropriate legal bases under applicable law such as contract performance, legitimate interests, legal obligation, and consent where required.

• Creating, administering, and securing your account and authenticating your identity
• Enabling product discovery, pricing appropriate to your role, quotes, orders, payments, fulfilment, and after-sales support
• Communicating with you about transactions, account activity, policy updates, and service announcements
• Preventing fraud, abuse, sanctions violations, unauthorised access, and other unlawful activity
• Complying with tax, customs, trade, accounting, and regulatory obligations in relevant jurisdictions
• Improving Platform performance, usability, and security through analytics and testing, using aggregated or de-identified data where possible
• Enforcing our terms of service, resolving disputes, and protecting the rights, property, and safety of Tradornet, users, and third parties
• Sending marketing communications where permitted by law and your preferences

We do not use personal information for purposes materially incompatible with those described above without providing notice or obtaining consent where required.

Third Parties and Data Sharing

We share personal information only as necessary to operate the Platform, fulfil contracts, comply with law, or with your direction. Categories of recipients include:

• Payment service providers and financial institutions processing transactions on our behalf
• Cloud hosting, content delivery, email, SMS, and customer-support tooling providers
• Logistics, freight, customs brokerage, and warehouse partners involved in order fulfilment
• Manufacturers, dealers, and customers where sharing is necessary to complete a transaction or provide requested services
• Professional advisers, auditors, insurers, and legal counsel under confidentiality obligations
• Law enforcement, regulators, courts, or other authorities when required by law or to protect legal rights
• Successors in the event of a merger, acquisition, or asset transfer, subject to continued protection consistent with this policy

We require service providers that process personal information on our behalf to implement appropriate contractual and technical safeguards. We do not sell personal information for monetary consideration. Where US state law defines "sale" or "sharing" broadly, we provide applicable opt-out mechanisms as required.

Marketing Communications

We may send commercial communications about products, promotions, Platform features, or events by email, in-app messages, or other channels where permitted by law. Dealers and manufacturers may receive B2B marketing relevant to their account type. Individual customers may receive retail-oriented communications.

You may opt out of marketing emails by using the unsubscribe link in the message or by updating preferences in your account settings. Opting out of marketing does not affect transactional or legally required notices. Where consent is the legal basis for a specific communication channel, you may withdraw consent at any time without affecting the lawfulness of prior processing.

Automated Decision-Making and Profiling

We may use automated systems to support fraud detection, account security, sanctions screening, credit or onboarding checks for business accounts, and personalisation of content such as displaying role-appropriate pricing or product recommendations. These processes may involve profiling as defined under applicable law.

Automated decisions that produce legal or similarly significant effects concerning you are not made solely on the basis of automated processing unless permitted by law, necessary for contract performance, or based on your explicit consent. Where required, you may request human review, express your point of view, or contest the decision. Contact us using the details below to exercise these rights.

Security Incidents and Breach Notification

We maintain administrative, technical, and organisational measures designed to protect personal information against unauthorised access, loss, destruction, or alteration. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.

In the event of a personal data breach likely to result in a risk to your rights and freedoms, we will notify the relevant supervisory authority and affected individuals in accordance with applicable law, including GDPR Article 33 and 34 timelines where applicable, KVKK notification requirements, and US state breach-notification statutes. Notifications will describe the nature of the incident, likely consequences, and measures taken or proposed to address it, to the extent permitted by law and investigation needs.

International Data Transfers

Tradornet serves users globally. Personal information may be transferred to, stored in, or accessed from countries other than your own, including countries that may not provide the same level of data protection as your jurisdiction.

Where required, we implement appropriate safeguards such as Standard Contractual Clauses approved by the European Commission, UK International Data Transfer Agreement addendum, binding corporate rules, or reliance on adequacy decisions. We assess transfer mechanisms regularly and apply supplementary measures where necessary. You may request further information about cross-border transfers applicable to your data by contacting us.

Data Retention

We retain personal information only for as long as necessary to fulfil the purposes described in this policy, including to satisfy legal, tax, accounting, audit, and dispute-resolution requirements. Retention periods vary depending on data category, your relationship with the Platform, and applicable law.

• Account and profile data is retained while your account is active and for a reasonable period thereafter to handle reactivation, disputes, or legal claims
• Transaction and invoice records may be retained for statutory commercial and tax retention periods in relevant jurisdictions
• Security logs and fraud records may be kept for a longer period where necessary to protect the Platform and comply with investigations
• Marketing suppression records are retained as needed to honour opt-out requests

When retention periods expire, we delete, anonymise, or securely destroy personal information unless further retention is required or permitted by law.

Your Rights

Depending on your location and applicable law, you may have some or all of the following rights regarding your personal information:

• Right of access to confirmation and a copy of personal information we hold about you
• Right to rectification of inaccurate or incomplete data
• Right to erasure in certain circumstances, subject to legal exceptions
• Right to restrict processing in defined situations
• Right to object to processing based on legitimate interests or for direct marketing
• Right to data portability for information you provided, in a structured, commonly used format where technically feasible
• Right to withdraw consent at any time where processing is consent-based, without affecting prior lawful processing
• Right not to be subject to solely automated decisions producing significant effects, where applicable
• Right to lodge a complaint with a supervisory authority in your country of residence, place of work, or place of alleged infringement

To exercise your rights, submit a request through your account privacy settings or contact us using the details below. We may need to verify your identity before responding. We aim to respond within the timeframe required by applicable law. Mandatory local rights that cannot be limited by contract remain fully available to you.

Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in law, Platform features, or our practices. Material changes will be communicated through the Platform, by email, or by other appropriate means before or when the updated policy takes effect. The "last updated" date at the top of the published policy indicates the latest revision. Continued use of the Platform after the effective date of an updated policy may constitute acceptance where permitted by law.

Contact Us

For privacy questions, rights requests, or complaints, contact Tradornet through the official privacy contact channel listed on the Platform or via your account support centre. Please include sufficient detail to identify your account and describe your request. We will respond in accordance with applicable data protection law.

Printable counterpart of the Tradornet platform agreement. Electronic acceptance is recorded at registration; wet-ink counterpart may be requested separately.