Privacy Policy

Last updated: June 2025

This Privacy Policy explains how UAB Turtema (trading as AgoAuto, "we", "us", "our") collects, uses, and stores personal data when you visit our website agoauto.lt or use our vehicle import brokerage services. We process data in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council (GDPR).

Data Controller

UAB Turtema Company code: 300083248 VAT code: LT100014041219 Registered address: Valančiaus 42, Mažeikiai, LT-89216 Office address: Rūko g. 4, Klaipėda, LT-91273 Email: turtemauab@gmail.com Phone: +370 671 92535

Personal Data We Collect

When you use our website, you may provide us with the following personal data: • Full name • Phone number or other contact details • Email address • Information about the vehicle you are interested in (make, model, budget, preferences) • Contents of conversations with the AI assistant This data is collected through: • Website contact and enquiry forms • AI chat agent (chatbot) • Direct contact by email or phone

Purposes and Legal Basis for Processing

We process your personal data for the following purposes: • To respond to your enquiries and provide consultations on vehicle import — legal basis: performance of a contract or pre-contractual steps (GDPR Art. 6(1)(b)) • To maintain communication with clients during the import process — legal basis: performance of a contract (GDPR Art. 6(1)(b)) • To inform about relevant offers and service updates — legal basis: legitimate interests (GDPR Art. 6(1)(f))

Data Sharing with Third Parties

Your data may be transferred to the following third-party service providers only to the extent necessary to provide our services:

OpenAI (openai.com) — AI service provider. The contents of conversations with the AI assistant are transmitted to OpenAI systems to power the chat agent. Data is processed in accordance with OpenAI's privacy policy.

Telegram — new client enquiries are automatically forwarded to our internal Telegram group for notification purposes. Information transmitted: name, contact details, vehicle of interest. This system is used solely for internal operational notification.

Vercel (vercel.com) — website hosting provider. Vercel servers may temporarily process technical data (e.g., IP address, browser type) in the ordinary course of web service delivery.

Supabase (supabase.com) — database service provider. Supabase stores vehicle auction catalogue data (publicly available data, not your personal data).

Cookies and Tracking Technologies

Our website does not use marketing, advertising, or tracking cookies (e.g., Meta Pixel, Google Analytics, or similar tools). Technical cookies may be used to remember your language preference. These cookies are not used to identify you personally or to track your online behaviour.

Data Retention

We retain your personal data for as long as necessary to fulfil the relevant purpose or as required by applicable law. Client enquiries are generally retained for no more than 2 (two) years from the last contact, unless a longer retention period is required by law.

Your Rights under GDPR

Under the GDPR, you have the following rights: • Right of access — you may request information about the personal data we process about you • Right to rectification — you may request correction of inaccurate or incomplete data • Right to erasure — see the "Data Deletion" section below • Right to restriction of processing — you may request a temporary suspension of processing your data • Right to object — you may object to processing based on legitimate interests • Right to data portability — you may request your data in a structured, machine-readable format To exercise these rights, contact us at: turtemauab@gmail.com

If you believe that your personal data is being processed in violation of the GDPR, you have the right to lodge a complaint with the State Data Protection Inspectorate (SDPI): www.ada.lt, email: ada@ada.lt.

Data Deletion

To request deletion of your personal data, send an email to turtemauab@gmail.com with the subject line "Data Deletion Request". Please include the name and contact details you provided when using our services. Your data will be deleted within 30 (thirty) calendar days of receiving your request. Note: some data may be retained for longer if required by law or if it is needed for the defence of a legal claim.

Changes to This Privacy Policy

We reserve the right to update this Privacy Policy at any time. All changes will take effect upon publication on this page. We recommend reviewing this policy periodically. This policy is effective from June 2025.

Privacy Contact

For privacy inquiries and to exercise your rights, please contact: Email: turtemauab@gmail.com Phone: +370 671 92535 Address: Rūko g. 4, Klaipėda, LT-91273