Privacy Policy

1. Scope and Processing Roles

Tradora AI, Inc. provides an AI-powered automotive commerce platform for consumers, dealers, lenders, insurers, service providers, OEMs, and other partners. This DPA-based Privacy Policy explains how Tradora collects, uses, discloses, protects, retains, and otherwise processes personal information and customer information.

Depending on the relationship, Tradora may process information as a business, service provider, processor, or vendor. If a signed agreement or data protection and processing addendum applies to your organization, that agreement controls where it is more specific than this Policy.

2. Information We Process

• Account, contact, profile, authentication, support, and communication information.
• Dealer, business, role, onboarding, billing, permission, and service configuration information.
• Vehicle, transaction, finance, insurance, warranty, repair, service, booking, payment, credit, consumer report, and customer workflow information. Where Tradora receives or processes consumer report information, it does so only as permitted by the Fair Credit Reporting Act (FCRA) and applicable state credit reporting laws.
• Identity, verification, fraud-prevention, document-extraction, technical, usage, device, cookie, diagnostic, and third-party integration information.

3. Business Purposes

Tradora processes information to provide and improve the Services, authenticate accounts, verify identity or business affiliation, calculate valuations and transaction outputs, connect requested counterparties, process payments, provide support, send service or legal communications, detect and prevent fraud or abuse, respond to cybersecurity incidents, comply with legal obligations, enforce agreements, and improve models, automations, analytics, and product features subject to applicable restrictions.

4. DPA Processing Commitments

• Where Tradora acts as a service provider, processor, or similar restricted recipient, it processes customer information only for the applicable business purpose, documented instructions, the Services, or another purpose permitted by law.
• Tradora does not sell or share restricted customer information except as permitted by applicable law and the applicable agreement.
• Tradora does not retain, use, or disclose restricted customer information outside the direct business relationship unless permitted by law or authorized by the relevant customer.
• Tradora requires personnel, vendors, subcontractors, and service providers with access to customer information to follow confidentiality, security, and use restrictions.
• Tradora provides reasonable assistance for privacy rights requests, security reviews, audits, and return or deletion obligations required by applicable law or a written agreement.

5. Security and Incidents

Tradora maintains a written information security program with administrative, technical, and physical safeguards designed to protect personal information, customer information, and confidential information. If Tradora identifies a cybersecurity incident or data breach, it will investigate, take reasonable containment and remediation steps, and provide notices required by applicable law or written agreement.

6. Vehicle, AI, and Automated Processing

Tradora may process vehicle, telematics, DMS, valuation, recall, repair, service, finance, insurance, warranty, uploaded document, and interaction information to provide requested features. Certain features, including Axia AI Agent, AutoReel, vehicle setup document verification, valuation models, recommendation tools, and analytics workflows, use machine learning, document processing, rules engines, or other automated processing.

The data used by these features depends on the workflow and may include information supplied by you or an enterprise customer, vehicle and transaction data, uploaded documents, third-party integration data, prior interactions, and system telemetry. Automated outputs are designed to support workflows and are not a substitute for required human, dealer, lender, insurer, partner, or legal review.

To the extent Tradora receives, accesses, or processes personal information obtained from motor vehicle records, Tradora does so only for permitted purposes under the Driver's Privacy Protection Act (18 U.S.C. § 2721 et seq.) and applicable state equivalents. Tradora does not use or disclose such information for any purpose not authorized by law or the applicable agreement.

Tradora applies safeguards for automated processing that may include access controls, vendor restrictions, logging, testing, monitoring, confidence thresholds, human review where appropriate, and correction, dispute, or privacy-rights workflows when required by law. Tradora does not use customer-submitted financial or credit data to train general-purpose foundation models.

7. Retention, Return, and Deletion

Tradora retains information for as long as reasonably necessary to provide the Services, fulfill the purposes described in this Policy, comply with legal obligations, resolve disputes, enforce agreements, maintain security and audit records, and support legitimate business needs. Where a written agreement requires return or deletion of customer information, Tradora follows that agreement unless retention is required or permitted by law.

8. Privacy Rights

Depending on where you live and how you interact with the Services, you may have rights to access, correct, delete, or receive a copy of personal information; opt out of certain targeted advertising, sale, sharing, or profiling; limit certain uses of sensitive information; withdraw consent; or appeal a privacy-rights decision. If Tradora processes information on behalf of an enterprise customer, it may refer your request to that customer or assist that customer in responding.