TERMS OF USE AND PRIVACY / DATA PROTECTION POLICY AND DISCLOSURE TEXT

User/Users: Real persons who become members of the site by providing their personal data through communication forms with their explicit consent, or who visit the site without providing personal data,

Personal Data: Any information relating to an identified or identifiable real person,

Processing of Personal Data: Any operation performed on data such as obtaining, recording, storing, preserving, modifying, rearranging, disclosing, transferring, or preventing the use of data by automatic or non-automatic means,

Site: The website located at https://vagupdate.com,

Intellectual Property: Refers to U.S. and International Copyright and Trademark laws,

Relevant Laws: Refers to the laws of the State of New Mexico and Federal Laws of the United States regarding internet publications and data privacy,

Privacy Acts: Refers to state and federal data protection regulations applicable to VAGupdate Automotive LLC.

A- TERMS OF USE

TERMS OF USE, ACCESS, LIMITATION OF RISK AND LIABILITY, IP ADDRESSES AND COOKIES

1. The https://vagupdate.com website and all documents on the site are the property of VAGupdate Automotive LLC. These documents may not be copied or reproduced except as necessary for online viewing. Independently of the above, you may take a printout of the site pages for your personal use. VAGupdate Automotive LLC may provide the opportunity to download wallpapers, screen savers, and other programs. Legal responsibilities arising from any use that violates intellectual property rights belong to the user.

2. If you wish to create a link to the site, this link must be directed to the https://vagupdate.com main page.

3. Although measures have been taken by VAGupdate Automotive LLC to ensure the website is free of viruses, the user is obliged to provide their own virus protection system for final security. In this context, the user accepts that they are responsible for all errors and their direct or indirect consequences that may occur in their own software and operating systems due to entering the site.

4. All kinds of prices, information, images, and news on the website are for promotional and informational purposes only. The user cannot claim that the information on the website is incorrect or that they suffered damages based on this information. The user is obliged to obtain final and reliable information from VAGupdate Automotive LLC and its authorized dealers and accepts that the company has no responsibility for non-updated information.

5. VAGupdate Automotive LLC reserves the right to change the content of the site at any time at its own discretion, to change or terminate any service, and to delete user information. Although every precaution has been taken to ensure the website is error-free, no guarantee is given regarding existing or potential errors.

6. Information regarding authorized dealers and the features of vehicles imported/serviced by VAGupdate Automotive LLC is valid as of the last update date. We kindly request that you contact VAGupdate Automotive LLC directly for final information. Unless explicitly stated otherwise, the information on the website does not constitute a sales offer or a commitment.

7. In the event of a criminal complaint or official investigation request from official authorities, or if it is determined that the user has performed any electronic sabotage or attack, VAGupdate Automotive LLC has the right to investigate identity information and notify legal authorities.

Ensuring the security of the website and all sub-sites is the responsibility of VAGupdate Automotive LLC. Scans intended to detect vulnerabilities or the misuse of systems (leaking information, damaging systems, etc.) for commercial or malicious purposes are illegal. In such cases, VAGupdate Automotive LLC reserves the right to initiate legal proceedings under state and federal law, seeking fines or imprisonment as allowed by law.

8. In some cases, non-personal information may be collected. Examples include your browser type, operating system, and the domain name of the site from which you reached our site.

9. When you visit the site, information may be placed on your computer in the form of a "cookie" or similar file to help us in several ways. Cookies are used to determine how you use the website, including where you connected from, what content you viewed, and the duration of your visit.

VAGupdate Automotive LLC also uses Google Analytics, a web analysis service provided by Google, Inc. ("Google"). For more information on Google Analytics usage (including opt-out options), please visit: https://www.google.com/intl/en/policies/privacy/#infocollect

10. Matters Regarding Intellectual Property and Internet Regulations

Users acknowledge that links to other websites may exist on this site and that VAGupdate Automotive LLC has no control over or responsibility for the content, accuracy, or adequacy of these sites. VAGupdate Automotive LLC or its employees/managers shall not be held liable for any material or moral damages resulting from the use of these external sites.

Users acknowledge that any text, information, image, graphic, or other material belonging to VAGupdate Automotive LLC or a third party is protected by Industrial Property Laws and cannot be copied, modified, or published without permission.

All logos, brands, and emblems on this site are protected by law. Logos cannot be copied or used in any way. VAGupdate Automotive LLC is not responsible for any content uploaded by third parties or visitors through general internet practices.

11. VAGupdate Automotive LLC reserves the right to change, renew, or cancel any article of the "Terms of Use" without notice. Every amended provision shall be valid for all users on the date of publication.

12- Governing Law and Jurisdiction

This "Terms of Use and Privacy Text" is subject to the laws of the State of New Mexico, USA. Any dispute or conflict arising from the matters herein shall be exclusively resolved in the Courts and Execution Offices of New Mexico.

13- Final Provision

Users acknowledge, declare, and commit that they have read the "Terms of Use and Privacy Text" before entering the website and will comply with all matters stated above.

B- PRIVACY / DATA PROTECTION POLICY AND DISCLOSURE TEXT

“This policy explains the principles for the processing of personal data that must be known by real persons whose data is processed by VAGupdate Automotive LLC as the Data Controller, such as customers, visitors, and website users.”

With this Privacy/Data Protection Policy and Disclosure Text:

A. Introduction

The goal of this Disclosure Text and the written Policies within the Company is to ensure that the personal data of the relevant persons recorded by us is processed and protected in accordance with the State of New Mexico and Federal laws.

B. Definitions

In this Disclosure Text, unless the context requires otherwise:

Explicit Consent: Consent regarding a specific subject, based on information and expressed with free will,

Personal Data: Any information relating to an identified or identifiable real person (e.g., Name-surname, SSN/Tax ID, e-mail, address, birth date, credit card number, bank account number),

Data Subject: The real person whose personal data is processed,

Processing of Personal Data: Any operation performed on data such as obtaining, recording, storing, preserving, modifying, rearranging, disclosing, or transferring data,

Sensitive Personal Data: Data regarding race, ethnicity, political thought, philosophical belief, religion, sect, health, sexual life, or criminal conviction and security measures,

Data Controller: The person who determines the purposes and means of processing personal data.

C. Identity of the Data Controller

VAGupdate Automotive LLC (“The Company"), as the data controller, attaches great importance to the fundamental rights and freedoms of persons and shows the highest sensitivity to the processing, privacy, and security of all personal data in compliance with data protection laws.

D. What Personal Data Do We Process?

• Identity Information: Your name and surname, date of birth, ID/Tax number.
• Contact Information: Your e-mail address, phone number, residential address, and social media account information.
• Product and Service Information: Vehicle plate, model, vehicle information including transaction history, and other information in the vehicle registration document.
• Risk Management Information: IP address information.
• Customer Transaction Information: Information transmitted to VAGupdate Automotive LLC verbally, in writing, or electronically regarding requests and complaints.
• Marketing Data: Preferences regarding our products, surveys, cookie records, campaign information, and marketing messages sent based on your commercial communication permission.
• Financial Data: All information regarding billing and payment tools.
• Audio and Visual Data: Call center records and camera records at certain service points for security purposes.
• Legal Transaction and Compliance Data: Documents/information requested by judicial and administrative institutions and data regarding judicial processes initiated by or against the company.

E. How and on Which Legal Grounds Do We Collect Your Personal Data? For What Purposes Do We Use It?

Your personal data may be collected through (i) Physical Channels (face-to-face meetings at dealers), (ii) Call Channels (call center, e-mail, SMS), (iii) Digital Channels (websites, mobile apps, request forms), and (iv) Social Media Channels.

1. Provision of Products and Services to Our Customers

Your data is processed based on the legal grounds of establishing and fulfilling a contract to provide services such as sales, rental, after-sales services, assistance, and replacement vehicles.

2. Product and Service Development Activities

To increase our efficiency and better understand our customers, we process your data within the framework of our legitimate interests. We create reports and measurements using information in areas such as customer relations and complaint management to capture better quality standards.

3. Carrying Out Marketing Activities and Ensuring Customer Satisfaction

With your explicit consent, we process your identity, contact, marketing, and product data to determine marketing strategies, create statistics, plan campaigns, promotions, and personalized advertising (via social media and search engines).

4. Execution of Financial Operations

Your data is used to perform financial reporting, control, analysis, payment/refund transactions, and to fulfill tax and reconciliation obligations based on legal requirements and legitimate interests.

5. Legal Compliance Audit

We use your vehicle, identity, and contact information to fulfill obligations arising from consumer and financial legislation, including creating invoices, providing after-sales support, and safety-related announcements.

F. With Whom and For What Purposes Can Your Personal Data Be Shared?

Your data may be shared with:

• Public institutions and financial advisors for legal obligations;
• Authorized dealers and authorized services of VAGupdate Automotive LLC to fulfill contract obligations;
• Third-party service providers for technical support, insurance companies, and financial institutions;
• Manufacturer companies of vehicles and their affiliates for after-sales support and marketing activities (with your explicit consent).

G. What Are Your Rights Regarding Your Personal Data?

Under applicable data protection laws, you have the right to:

• Learn whether your personal data is processed,
• Request information if processed,
• Learn the purpose of processing,
• Know the third parties to whom data is transferred,
• Request correction if incomplete or incorrectly processed,
• Request deletion or destruction if the reasons for processing have disappeared,
• Object to results occurring exclusively through automated systems,
• Claim compensation for damages arising from unlawful processing.

Requests regarding your personal data can be sent via:

• A written petition to our corporate address;
• Electronic mail from your registered e-mail address to admin[at]vagupdate.com.

Your application will be evaluated and responded to within 30 (thirty) days at the latest according to the nature of the request.

H. Measures Regarding Personal Data Protection

VAGupdate takes necessary administrative and technical measures to protect personal data against unauthorized access, loss, or misuse. In case of data damage or theft resulting from attacks on the system, the situation will be immediately reported to you and the relevant Data Protection Board.

I. Maintaining Accurate and Up-to-Date Personal Data

Users acknowledge that the accuracy and currency of the information they share on the website are important for exercising their rights and that they are solely responsible for liabilities arising from false information.

K. Changes to the Privacy/Data Protection Disclosure Text

VAGupdate Automotive LLC reserves the right to make changes to this text at any time. Changes become effective immediately upon being posted on "vagupdate.com". You will be informed of such changes as necessary.