Privacy Policy

1. Introduction and Scope

This Privacy Policy explains how Auto Vado Holding Limited (“we”, “us”, “our” or “Auto Vado Holding Limited”), the operator of the AUTO VADO marketplace (the “Platform”), collects, uses, shares, and protects your personal data when you use the Platform, place or fulfil orders, or otherwise interact with our websites, apps, and services (together, the “Services”).

This Policy applies to all users of the Platform — buyers, sellers, and visitors — except where a section states that it applies only to one group. Where we act as the party that decides why and how your personal data is processed, we are the “controller” of that data. Where a third-party seller processes your data for its own purposes (for example, to fulfil your order or meet its legal duties), that seller is an independent controller (see Section 8).

2. Who We Are and How to Contact Us

Controller: Auto Vado Holding Limited

Registration Number: 79817373

Company Address: Unit 1003, 10/F., Tower 2, Silvercord, 30 Canton Road, Tsim Sha Tsui, Kowloon, Hong Kong (this is not a returning address)

Privacy contact: customer@autovado.com.

3. Personal Data We Collect

Depending on how you use the Services and whether you are a buyer, seller, or visitor, we may collect the following categories of personal data:

• Identity & contact data: name, email, phone number, delivery and billing address; and for account verification, date of birth or ID document where required by law.
• Account & profile data: username, password (stored in hashed form), profile details, preferences, and communication settings.
• Order & transaction data: items purchased or sold, order and delivery details, returns, and amounts.
• Payment data: payment method and billing details needed to process payments. Full card numbers are handled by our payment processor(s); we do not store full card numbers.
• Communications, reviews & complaints: messages, chats, call records with customer support, product reviews, photos, and dispute or complaint information.
• Usage & device data: IP address, device and browser type, identifiers, pages viewed, and how you interact with the Platform, collected via cookies and similar technologies (Section 4).
• Approximate location data: derived from your IP address or, with your permission, more precise location for delivery/pick-up features.
• Marketing data (buyers): interests, survey responses, and your marketing and communication preferences.
• Seller business data (sellers): company name and registration number, business licence, tax information, bank/settlement account, and identity data of directors, legal representatives, or authorised contacts, plus your product listings.

Sources. We collect data (i) directly from you; (ii) automatically when you use the Services; and (iii) from third parties such as our payment processors, logistics and customs partners, fraud-prevention and analytics providers, our affiliates, and social-login providers where you choose to connect an account. Where you provide another person’s data (e.g., a delivery recipient), you confirm you may lawfully do so.

4. Cookies and Similar Technologies

We use cookies, SDKs, pixels, and similar technologies to run the Platform, remember your settings, keep the cart working, measure performance, and — where permitted — personalise content and advertising. Strictly necessary cookies are always active; non-essential cookies (analytics, personalisation, advertising) are used only with your consent where required (e.g., in the EU/UK), which you can manage at any time via our cookie banner. We also honour recognised opt-out preference signals such as Global Privacy Control (GPC) where required.

5. How and Why We Use Your Data

Our uses and the bases we rely on are:

5.1 To perform our contract with you

• Create and manage your account; enable you to buy or list and sell products;
• Process orders and payments, arrange delivery, and pass necessary details to sellers, logistics partners, and customs;
• Provide customer support and handle returns, refunds, cancellations, and disputes.

5.2 For our legitimate interests, balanced against your rights

• Prevent, detect, and investigate fraud, abuse, and security incidents, and operate buyer/seller risk controls;
• Maintain, secure, analyse, and improve the Platform, and develop new features;
• Send service and relationship communications, and market our own similar products to existing customers where permitted;
• Enforce our terms and protect our legal rights.

5.3 With your consent

• Non-essential cookies and similar technologies; certain marketing where consent is required; and any optional features that request it. You may withdraw consent at any time.

5.4 To comply with legal obligations

• Tax, accounting, invoicing, and marketplace-facilitator/VAT record-keeping; responding to lawful requests from authorities; and sanctions, anti-money-laundering, and other compliance screening.

6. Marketing and Your Choices

Where required, we send marketing only with your consent; in the US, we may send marketing on an opt-out basis. You can opt out at any time using the unsubscribe link in our emails or your account settings. Turning off marketing does not stop essential service messages (e.g., order and security notices).

7. Automated Decision-Making and Profiling

We use automated tools for fraud and risk scoring and to personalise your experience. Where a decision producing legal or similarly significant effects about you is based solely on automated processing, we will only do so where permitted by law and, where the GDPR applies, we will provide the safeguards it requires — including the ability to request human review, express your view, and contest the decision.

8. How We Share Your Data

We share personal data only as needed for the purposes above, with:

• Third-party sellers: for orders you place, we share your name, delivery address, and contact details with the relevant seller so it can fulfil, ship, and provide after-sales for your order. Sellers are independent controllers for their own processing and must comply with applicable data-protection law and our seller data terms.
• Payment processors: to collect payment, process refunds, and prevent fraud.
• Logistics, shipping, and customs partners: to deliver orders and complete import/export formalities.
• Service providers (processors): hosting, IT, analytics, customer service, communications, and security vendors that act on our instructions under contract.
• Advertising and analytics partners: where you have consented / not opted out, to measure and (where applicable) personalise advertising.
• Our affiliates: within the Auto Vado Holding Limited group, for the purposes described in this Policy.
• Authorities and advisers: courts, regulators, and law-enforcement where legally required, and professional advisers.
• Corporate transactions: in connection with a merger, acquisition, or sale of assets, subject to appropriate protections.

We do not sell your personal data for money. For the CCPA meaning of “sell”/“share”, see Section 11.2.

9. International Data Transfers

Operating a cross-border marketplace means your personal data may be transferred to, and processed in, countries other than your own — including the transfer of buyers’ name, address, and contact details to sellers and service providers located in outside your country, which is necessary to fulfil orders (especially for items shipped directly from the seller’s country).

10. Data Retention

We keep personal data only for as long as necessary for the purposes described in this Policy, or as required by law (for example, tax, accounting, and transaction records are kept for the periods required by applicable law). When data is no longer needed, we securely delete or anonymise it; where that is not immediately possible (e.g., in backups), we isolate it from further processing until deletion is possible. Retention criteria include the nature of the data, the purpose, and legal or regulatory requirements.

11. Your Privacy Rights

11.1 EU/EEA and UK residents (GDPR / UK GDPR)

Subject to conditions and exemptions in law, you have the right to: access your data; have it rectified; have it erased; restrict or object to processing (including objecting to direct marketing at any time); data portability; withdraw consent where processing is based on consent; and not be subject to a solely automated decision producing legal or similarly significant effects. You also have the right to lodge a complaint with your local supervisory authority.

11.2 California residents (CCPA/CPRA)

California residents have the right to: know the categories and specific pieces of personal information we collect, use, disclose, and share; delete personal information; correct inaccurate information; opt out of the “sale” or “sharing” of personal information; limit the use of sensitive personal information; and not be discriminated against for exercising these rights.

To the extent we “share” personal information for cross-context behavioral advertising, you can opt out.

You may submit requests via customer@autovado.com; authorized agents may submit on your behalf with proof of authorization. We will verify your identity before responding and will not discriminate against you for exercising your rights.

11.3 Other U.S. states

Residents of other U.S. states with comprehensive privacy laws may have similar rights (to access, correct, delete, obtain a copy of, and opt out of targeted advertising or certain profiling). We honor these rights where the applicable state law grants them.

11.4 How to exercise your rights

Contact us as set out in Section 2. We respond within the timeframes required by applicable law. Exercising most rights is free; where the law permits a fee for manifestly unfounded or excessive requests, we will tell you first.

12. How We Protect Your Data

We use appropriate administrative, technical, and physical measures — such as access controls, encryption in transit, and monitoring — to protect personal data against unauthorised access, loss, or misuse, and we review these measures regularly. No method of transmission or storage is completely secure; please protect your account credentials and take care when sharing personal data outside the Services. Where required by law, we will notify you and the relevant authority of a personal-data breach.

13. Children’s Privacy

The Services are not directed to, and we do not knowingly collect personal data from, children under 16 in the EU / 13 in the US, or as required locally. If you believe a child has provided us personal data without appropriate consent, contact us and we will delete it.

14. Third-Party Websites and Services

The Platform may link to, or integrate, third-party sites and services (e.g., sellers’ sites, payment gateways, social media). We are not responsible for their privacy practices; please review their policies. Where you accept a third party’s service, that party may act as an independent controller under its own privacy policy.

15. Changes to This Policy

We may update this Policy from time to time. We will post the updated version with a new “last updated” date and, where changes are material or the law requires, provide additional notice. Your continued use of the Services after the effective date constitutes acceptance to the extent permitted by law.

16. Contact Us

For questions, requests, or complaints about this Policy or your personal data, contact us at customer@autovado.com. Users also have the right to complain to their supervisory authority.