Privacy policy

Last updated: 22.06.2026

1. GENERAL PROVISIONS AND CONSENT

1.1. The personal data of individuals – users of the website imperiya-auto.com.ua (the «Site») – is processed by IMPERIYA AUTO DIGITAL LIMITED LIABILITY COMPANY, a legal entity registered under the laws of Ukraine, with its registered address at: 01032, Ukraine, Kyiv, Zhylianska street, building 126/23, office 220 (the «Company», «We»). The Company is the owner of the Database of personal data of Site users.

1.2. Users' personal data is processed on secure servers located both within and outside the European Economic Area.

1.3. This Privacy policy describes the procedure established by the Company for processing personal data collected through the Site `imperiya-auto.com.ua`, its mobile versions, and the related services and tools. These services allow users to register on the Site, browse cars and related services, submit applications for purchase, sale, exchange, a test drive, credit or insurance, and to use other services of the Company. In all of these cases the Company processes users' personal data solely within the requirements of the Law of Ukraine «On the protection of personal data» and the Convention for the Protection of Individuals with regard to Automatic Processing of Personal Data. This Privacy policy has been drawn up in accordance with the provisions of those documents.

1.4. By using the Site and/or other related services, the User gives the Company consent to process their personal data, such as: user's first name, surname; region of residence, email address, contact phone number; IP addresses, geolocation data, device data; history of viewed cars, saved searches; messages and correspondence with the Company's managers. The User also consents to the transfer of their personal data to third parties, including the transfer of personal data abroad, in accordance with this Privacy policy and the User agreement.

1.5. Users should be aware that when following some links placed on the Site, they may be redirected to the websites of other companies (for example, partner banks or insurance companies), where information about Users is collected outside the Company's direct control. In that case, the privacy policies of the third-party sites will govern how the information obtained is processed.

1.6. This Policy applies to the website imperiya-auto.com.ua, its mobile versions, and to the «Imperiya Auto» mobile app for iOS and Android (together — the «Service» or the «Platform»).

2. INFORMATION WE COLLECT AND PROCESS

2.1. Registration and profile information: When a User creates an account on the Site, we may require certain information: first name, surname, phone number, a valid email address and a password. The account allows you to manage your data, track the status of applications, save selected cars and communicate effectively with our managers.

2.2. Applications and Transactions: As part of the Site's operation, we may collect and process the information required to carry out car purchase and sale transactions, arrange credit, leasing or insurance, and book servicing or a test drive. This may include passport data, an identification number, income details and other information required to provide the relevant services.

2.3. Advertising and Promotion: We may collect personal information (name, contact details) during your participation in quizzes, promotions and other marketing activities organised by the Company. We may also process information related to the performance of our advertising campaigns.

2.4. Customer service: When you contact our support service, we may collect the personal information required to fulfil your request, obtain feedback and improve the quality of our services. This includes recordings of telephone conversations with managers, chat correspondence history, and the reviews you leave about our work.

2.5. Website and technical data: We may automatically receive and record on our servers information from your browser or device, including your IP address, geolocation data, details of software and hardware attributes, the pages you request, information about app usage and other system-level data.

2.6. Information from social media profiles: By registering on the Site or signing in using social media authentication services (for example, Google, Facebook), the User gives the Company consent to collect and process the information available from the relevant profiles (name, email, profile photo).

2.7. Photos and media files: When creating a listing or filling in your profile, you upload photographs (a photo of the car and a profile photo). For this the app requests access to your device's camera and gallery. Uploaded images are stored on our servers and in the service provider's cloud storage.

2.8. Push notifications: With your consent we process your device's push notification token (via Google's Firebase Cloud Messaging service) to deliver messages about listing status, new messages and service notifications.

2.9. Crash data and diagnostics: To ensure the stable operation of the app we use the Sentry service, which automatically collects technical information about crashes, errors and performance (device model, OS version, app version, error logs, IP address and user identifier). This data is used solely to diagnose and improve the stability of the Service.

Information the Company does not collect or process:
We deliberately do not collect or process sensitive personal data on racial or ethnic origin, political, religious or philosophical beliefs, membership of political parties and trade unions, or similar information.

3. IP ADDRESS AND COOKIES

3.1. We may collect certain information using technologies such as cookies, pixels and local storage (in your browser or on your mobile device). A detailed description of how we use these technologies is contained in our Cookie policy.

3.2. Using cookies we can store your preferences and settings, which makes using the Site more convenient (for example, you do not need to sign in again on your next visit). We use both persistent and session cookies.

3.3. We may allow third parties (providers of advertising and/or analytics services, for example Google Analytics, Microsoft Clarity, Meta (Facebook) Pixel) to collect information using these technologies directly on the Site. The data they collect is protected in accordance with the privacy policies of those third parties.

3.4. Microsoft Clarity: We use Microsoft Clarity to analyse user behaviour on our Site. This service collects anonymous data about how users interact with the Site, including clicks, scrolling and navigation. The data collected is used solely to improve the functionality and user experience of the Site. Detailed information about the collection and processing of data by Microsoft Clarity can be found in their Privacy policy.

3.5. Meta (Facebook) Pixel: We use the Meta (Facebook) Pixel to support marketing activities and to display and measure the performance of advertising. This tool operates on the website and processes data in accordance with Meta's privacy policy. We apply it on the basis of your consent.

4. USE OF PERSONAL DATA

4.1. We use the information we collect for the following purposes:

• providing high-quality customer service, creating and managing accounts, resolving technical difficulties;
• tailoring offers of cars, financial products and services, including advertising;
• monitoring general and individual user activity (searching by car model, submitting applications) and managing traffic on the Site;
• contacting you on service and support matters or permitted marketing communications through any available channels;
• carrying out research and analytical activity in order to improve our services;
• ensuring compliance with the User agreement, including combating fraud;
• assessing certain factors of personal information in order to analyse and predict personal preferences, interests and behaviour.

4.2. Data retention: We will retain Your personal data for as long as is necessary to achieve the purposes for which it was collected, including to meet any legal or accounting requirements. If there has been no activity on your account for more than 36 months, we reserve the right to delete your account, including all personal data stored in it.

5. SHARING INFORMATION

5.1. We do not provide users' personal information to non-affiliated parties, except where we have your permission or in the following circumstances:

• We may engage third-party service providers (for example, hosting providers, CRM systems, analytics services). They gain access to your data solely in order to provide services to the Company and are obliged to comply with the terms of this Policy.
• We may transfer data to payment providers — to process payments for listing publication and promotion services. Payment card details are processed directly by the payment provider, not by the Company.
• We may provide your data to financial institutions (banks), insurance companies and other partners solely in the event that you apply for their services (for example, a car loan or insurance) through our Site.
• We reserve the right, in accordance with legal requirements, to exchange information with government authorities in order to combat fraud, investigate breaches of the law or comply with lawful requests from competent authorities (including under Article 93 of the Criminal Procedure Code of Ukraine).
• If the Company's business is sold or reorganised, users' personal data may be transferred to the new owner in order to ensure continuity of service.
• We may transfer anonymised information (data that does not allow you to be identified individually) to trusted partners or authorised researchers in order to improve the quality of services and advertising.

6. MANAGING PERSONAL DATA AND YOUR RIGHTS

6.1. Access, Correction and Deletion: Users who have created an account can access, correct or delete the information they provide through their personal account on the Site. Mobile app users can delete their account directly in the app: Profile → Settings → Delete account. You are responsible for the accuracy of the data provided. To delete Your personal data completely, please send a request with notice of withdrawal of consent to the processing of personal data.

6.2. Cookies: Most web browsers allow you to control, restrict or block the placement of cookies. Please note that disabling cookies may result in limited functionality of our Site.

6.3. Users' rights (personal data subjects):
Under the Law of Ukraine «On the protection of personal data», you have the right:

1. To know the sources of collection and the location of your personal data, the purpose of its processing, the location or place of residence (stay) of the owner or administrator of the personal data, or to give an appropriate instruction to persons authorised by you to obtain this information, except in the cases established by law.
2. To receive information about the conditions for granting access to personal data, in particular information about the third parties to whom your personal data is transferred.
3. To access your personal data.
4. To receive, no later than thirty calendar days from the date the request is received, except in the cases provided for by law, an answer as to whether your personal data is being processed, and to receive the content of such personal data.
5. To submit a reasoned demand to the owner of the personal data objecting to the processing of your personal data.
6. To submit a reasoned demand for the modification or destruction of your personal data by any owner and administrator of personal data, if such data is processed unlawfully or is inaccurate.
7. To have your personal data protected against unlawful processing and accidental loss, destruction or damage in connection with deliberate concealment, failure to provide or untimely provision of such data, and to be protected against the provision of information that is inaccurate or damages the honour, dignity and business reputation of an individual.
8. To lodge complaints about the processing of your personal data with the Ukrainian Parliament Commissioner for Human Rights or with a court.
9. To apply legal remedies in the event of a breach of personal data protection legislation.
10. To withdraw consent to the processing of personal data.
11. To know the mechanism of automatic processing of personal data.
12. To be protected against an automated decision that has legal consequences for you.

7. SECURITY

7.1. All the information we collect is, within reasonable limits, protected by modern technical means and security procedures in order to prevent unauthorised access to or use of the data. Our partners and independent service providers undertake to use the information received from us in accordance with our security requirements and this Privacy policy.

8. CHANGES TO THIS POLICY

8.1. We may update this Policy from time to time. A new version of the Privacy policy takes effect from the moment it is published on the Site, unless the new version provides otherwise. The current version of the Privacy policy is always available on the page at: https://imperiya-auto.com.ua/privacy-policy.

8.2. If we make any changes to the Policy that you do not agree with, you must stop using the Site's services. Continuing to use the Site confirms your agreement to and acceptance of the relevant version of the Privacy policy.