Legal

Privacy Policy

Effective date: May 16, 2026 · Last updated: May 17, 2026

Tradora AI, Inc. ("Tradora," "we," "us," or "our") provides an AI-powered automotive commerce platform for consumers, dealers, lenders, insurers, service providers, OEMs, and other partners (the "Services"). This DPA-based Privacy Policy explains how we collect, use, disclose, protect, retain, and otherwise process personal information and customer information across the Services.

This Policy applies to www.tradora.ai, our consumer and dealer web applications, our mobile applications, APIs, and other Tradora-branded products that link to this Policy. It does not apply to third-party websites, products, or services that have their own privacy terms.

1. Scope and Processing Roles

Tradora may process information in different roles depending on the product and relationship:

• When you use Tradora directly as a consumer, dealer representative, or account holder, Tradora determines the purposes and means of processing for the account and Services we provide.
• When Tradora processes information for a dealer, lender, insurer, OEM, fleet, service provider, or other enterprise customer under a written agreement, Tradora may act as a service provider or processor and process information only for the agreed business purposes.
• When a vendor, subcontractor, or integration provider processes information for Tradora, that provider must follow contractual data protection, confidentiality, security, and use restrictions appropriate to the information it receives.

If a signed agreement or data protection and processing addendum applies to your organization, that agreement controls where it is more specific than this public Policy.

2. Definitions

• Applicable U.S. Data Protection Laws means applicable federal, state, and local laws, rules, and regulations in the United States relating to the collection, use, retention, storage, security, disclosure, transfer, sale, sharing, or other processing of personal information.
• Business Purpose means an operational, service, security, compliance, or other purpose permitted by applicable law and reasonably necessary for the Services or a written agreement.
• Customer Information means information relating to a Tradora customer, consumer, dealer, partner, or end user that is provided to, generated by, accessed by, or processed through the Services.
• Confidential Information means nonpublic business, technical, financial, security, operational, customer, vehicle, transaction, or platform information provided to or generated by Tradora or its customers.
• Personal Information means information that identifies, relates to, describes, can reasonably be associated with, or could reasonably be linked to a particular person, household, or device.

3. Information We Process

We process information you provide directly, information generated by your use of the Services, and information we receive from third parties or integrations.

Account, business, and contact information

Name, email address, phone number, mailing address, login credentials, authentication identifiers, profile details, communication preferences, dealership affiliation, job title, permissions, onboarding data, billing status, service configuration, campaign data, and support communications.

Vehicle, transaction, and financial information

VIN, license plate, make, model, year, mileage, condition, photos, registration and title data, finance or lease terms, equity calculations, valuations, trade-in offers, service history, recall information, warranty coverage, insurance details, repair orders, bookings, payment details, credit reports, payoff information, and related transaction records. 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, technical, and third-party information

Driver license, registration, business verification, fraud prevention, document-extraction information, IP address, device identifiers, browser and operating system data, usage logs, diagnostics, cookies, SDK data, and information from dealers, DMS systems, OEM and telematics providers, valuation providers, lenders, insurers, warranty providers, payment processors, identity-verification providers, authentication providers, marketing partners, and public sources.

4. Business Purposes for Processing

We process information to:

• Provide, operate, maintain, and improve the Services and related modules, including digital retail, inventory, Trade Timer, Equity Calculator, Axia AI Agent, AutoReel, Autocoin, insurance, warranty, recall, maintenance, service, campaign, support, analytics, and dealer tools.
• Create and authenticate accounts, manage permissions, verify identity or business affiliation, and protect account integrity.
• Calculate valuations, equity, payment estimates, financing terms, service recommendations, transaction outcomes, and other platform outputs.
• Connect consumers, dealers, lenders, insurers, warranty providers, service providers, and other counterparties when requested or required to complete a workflow.
• Process payments, reconcile transactions, send service or legal communications, detect and prevent fraud or abuse, respond to cybersecurity incidents, comply with legal obligations, and enforce agreements.
• Train, test, evaluate, and improve models, automations, analytics, and product features subject to this Policy and any applicable agreement.

5. DPA Processing Commitments

Where Tradora processes Personal Information or Customer Information as a service provider, processor, or similar restricted recipient, we apply the following DPA-style commitments:

• We process the information only for the applicable Business Purpose, the Services, documented instructions, or another purpose permitted by applicable law.
• We do not sell or share restricted Customer Information except as permitted by applicable law and the applicable agreement.
• We do not retain, use, or disclose restricted Customer Information outside the direct business relationship unless permitted by applicable law or authorized by the relevant customer.
• We do not combine restricted Customer Information with other personal information except where permitted by applicable law or needed to provide, secure, debug, analyze, or improve the Services.
• We require personnel and service providers with access to Customer Information to follow confidentiality, security, and use restrictions.
• We provide reasonable assistance for privacy rights requests, regulatory inquiries, security reviews, audits, and deletion or return obligations required by applicable law or a written agreement.

6. How We Disclose Information

We disclose information to the following categories of recipients:

• Dealers, dealership personnel, fleet operators, lenders, insurers, warranty providers, service providers, OEMs, and other counterparties involved in a requested workflow.
• Cloud hosting, storage, analytics, communications, customer support, payment, identity-verification, fraud-prevention, AI, document-processing, monitoring, and security service providers.
• Affiliates, professional advisors, auditors, insurers, legal counsel, compliance reviewers, government authorities, regulators, law enforcement, courts, acquirers, successors, assignees, and other recipients with your direction, authorization, or consent.

We do not sell Personal Information for monetary consideration. Some advertising, analytics, or cookie-based disclosures may be considered a "sale," "sharing," or targeted-advertising disclosure under certain state privacy laws. See "Your Privacy Rights" for opt-out options.

7. Security Program

Tradora maintains a written information security program with administrative, technical, and physical safeguards designed to protect Personal Information, Customer Information, and Confidential Information. The program is designed with reference to applicable legal requirements and recognized security practices, including access controls, encryption in transit and at rest where supported, logging, monitoring, vulnerability management, secure development practices, personnel security, incident response, backup and recovery, and periodic risk assessments.

We assess and update security controls based on risk, system changes, legal obligations, vendor requirements, and changes to the Services. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.

8. Cybersecurity Incidents and Data Breaches

If we identify a cybersecurity incident or data breach involving Personal Information or Customer Information, we will investigate, take reasonable steps to contain and remediate the issue, and provide notices required by applicable law or written agreement. For enterprise customers or partners, notices will be provided through the contact method in the applicable agreement or another established security incident process.

If you believe your account or information has been compromised, contact us at phil@tradora.ai.

9. Vehicle, AI, and Automated Processing

With your authorization or as otherwise permitted, Tradora may process vehicle, telematics, DMS, valuation, recall, repair, service, finance, insurance, and warranty information to provide requested features and improve the Services.

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. These features may process information you provide, vehicle and transaction data, uploaded documents, and prior interactions to generate responses, content, extracted fields, scores, recommendations, summaries, or workflow outputs.

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. Outputs can be incomplete or inaccurate, and users and partners remain responsible for reviewing outputs before relying on them for decisions required by law, agreement, or internal policy.

When you upload documents during vehicle setup, we may send driver license and vehicle registration files to a document-processing provider to extract fields such as driver name, registration owner name, and registration VIN. We compare extracted information to verify ownership before creating the vehicle record and may store verification metadata, extracted fields, confidence values, VIN, and verification timestamp. We do not store the raw uploaded driver license or registration file as part of that verification workflow unless a separate feature, support need, or legal requirement requires it.

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.

We apply 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.

We do not use customer-submitted financial or credit data to train general-purpose foundation models.

10. Cookies and Tracking

We and our service providers use cookies, pixels, SDKs, local storage, and similar technologies to operate the Services, remember preferences, measure performance, improve features, secure sessions, and, where permitted, deliver or measure marketing. You can manage cookies through browser settings or any cookie preference control we make available. Disabling certain cookies may limit functionality.

11. Retention, Return, and Deletion

We retain 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 we process Customer Information under a written agreement that requires return or deletion, we will return or delete that information in accordance with the agreement, unless retention is required or permitted by law, backup retention, security, fraud prevention, audit, dispute, or compliance needs. We may retain de-identified, aggregated, or anonymized information that does not identify a person.

12. Your 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 where processing is based on consent; or appeal a privacy-rights decision.

You can exercise these rights by signing into your account settings where available or by contacting phil@tradora.ai. We will verify requests as required by law and respond within the applicable statutory period. We will not discriminate against you for exercising privacy rights.

If we process your information on behalf of a dealer, lender, insurer, employer, fleet, or other enterprise customer, we may refer your request to that customer or assist that customer in responding.

13. Children’s Privacy

The Services are not directed to children under 16, and we do not knowingly collect Personal Information from children under 16. If you believe a child has provided Personal Information to us, contact us so we can take appropriate action.

14. Changes to This Policy

We may update this Policy from time to time. The "Last updated" date reflects the most recent changes. If we make material changes, we will provide notice through the Services, by email, or by another method required by law.

15. Contact Us

For privacy questions, requests, or complaints, contact:

Tradora AI, Inc.
Attn: Privacy Office
Email: phil@tradora.ai
Legal notices: wendy@tradora.ai
Web: www.tradora.ai