Terms and Conditions
Platform Terms & Conditions – Volocar Online Marketplace (Romania / EU)
Last updated: [●]
1. Scope, Parties and Acceptance
1.1 These Platform Terms & Conditions (“Terms”) govern your use of the Volocar online marketplace, including our website, mobile applications, partner dashboards, APIs and related services (collectively, the “Platform”).
1.2 In Romania and the European Union, the Platform is operated by [Volocar Romania SRL], a company organised under Romanian law and registered with the Romanian Trade Register under number [●], with registered office at [●], Romania (“Volocar”, “we”, “us”, “our”). Volocar is an information society service provider within the meaning of Law no. 365/2002 on electronic commerce.[web:93][web:106]
1.3 These Terms form a binding agreement between you and Volocar when you create an account, access or use the Platform in any way, or click to accept these Terms where that option is made available.
1.4 If you use the Platform on behalf of a company or another legal entity (for example, a Rent‑a‑Car Company or vehicle dealership), you represent and warrant that you have authority to bind that entity, and references to “you” or “User” will include that entity.
1.5 If you do not agree to these Terms, you must not use the Platform.
2. Definitions and Interpretation
2.1 In these Terms, unless the context requires otherwise:
(a) “Account” means a registered user account on the Platform.
(b) “Annex A” means Annex A – Rental & Mobility Terms.
(c) “Annex B” means Annex B – Vehicle Sales & Lead Terms.
(d) “Annex C” means Annex C – Partner & Listing Terms.
(e) “Customer” means a natural or legal person using the Platform to search for and/or book rental or mobility services.
(f) “Individual Host” means a natural person who lists one or more vehicles they own or are authorised to use for rental on the Platform, outside a professional fleet or rent‑a‑car business.
(g) “Rent‑a‑Car Company” means a legal entity or registered sole trader whose professional activity includes renting or leasing vehicles to customers and which lists such vehicles on the Platform.
(h) “Vehicle Seller” means a natural or legal person who lists vehicles for sale or lead generation on the Platform, including vehicle dealers and private vehicle sellers.
(i) “Vehicle Buyer” means a natural or legal person using the Platform to browse, enquire about or purchase vehicles from Vehicle Sellers.
(j) “Partner” means any Individual Host, Rent‑a‑Car Company or Vehicle Seller that offers vehicles or related services through the Platform.
(k) “Listing” means any vehicle or mobility product or service offered on the Platform by a Partner (for rent, monthly rent, or sale/lead).
(l) “Booking” means a confirmed rental or mobility transaction concluded through the Platform between a Customer and a Partner.
(m) “Lead” means an enquiry or expression of interest sent by a Vehicle Buyer to a Vehicle Seller through the Platform regarding a potential vehicle purchase.
(n) “Services” means the digital marketplace and related intermediation services provided by Volocar through the Platform.
(o) “User Content” means any content uploaded, submitted or transmitted by a User, including Listings, reviews, messages and documents.
2.2 Headings are for convenience only and do not affect interpretation.
2.3 If there is any conflict between these Terms and a product‑ or role‑specific annex (Annex A, Annex B, Annex C, each a “Specific Terms Annex”), the Specific Terms Annex prevails for the relevant product or role, subject always to mandatory provisions of Romanian and EU law.[web:89][web:115]
2.4 If any provision of these Terms is found to be invalid, illegal or unenforceable under mandatory consumer protection law (including Law no. 193/2000 on unfair terms in consumer contracts), that provision will be disapplied to the extent necessary, without affecting the validity of the remaining provisions.[web:128][web:132]
3. Volocar’s Role as Marketplace and Intermediary
3.1 Volocar operates a technology platform and online marketplace that enables:
(a) Customers to search for, compare and book vehicles and related mobility services offered by Partners;
(b) Vehicle Buyers to browse and enquire about vehicles offered for sale by Vehicle Sellers;
(c) Partners to list vehicles for rent or sale, manage availability and pricing, and receive bookings or leads;
(d) Users to communicate via Platform messaging, WhatsApp and other supported channels, and to leave reviews.
3.2 Volocar does not own or operate the vehicles listed on the Platform and, unless expressly stated otherwise for a particular transaction, Volocar is not:
(a) a vehicle rental company or lessor;
(b) a seller or reseller of vehicles;
(c) an insurer or insurance intermediary;
(d) a transport provider.
3.3 Unless explicitly indicated in a Specific Terms Annex for a specific product, Volocar is not a party to the rental, subscription, leasing or sale contract between a Customer or Vehicle Buyer and a Partner. Those contracts are concluded directly between the relevant User and Partner, as described in Annex A and Annex B.
3.4 Volocar may act as a commercial agent or payment collection agent for certain Partners solely for the purpose of facilitating bookings, leads and payments through licensed payment service providers (for example, Stripe). This does not change the allocation of contractual responsibilities described above.
3.5 Volocar maintains minimum onboarding and listing standards for Partners and may suspend or remove Partners who fail to meet legal or safety requirements. This oversight does not limit or replace Partners’ primary responsibilities under law and does not make Volocar a rental company, seller or insurer.
3.6 Volocar is an information society service provider and online intermediary, subject to the liability regime and safe harbours under Law 365/2002 and relevant EU legislation, provided that it acts expeditiously upon obtaining actual knowledge of unlawful content or activity.[web:93][web:106]
4. User Accounts and Eligibility
4.1 To use most features of the Platform, you must create an Account and provide accurate, current and complete information.
4.2 You must keep your login credentials confidential and not share them with any third party. You are responsible for all activities carried out using your Account, except where security incidents are caused solely by Volocar’s fault.
4.3 By creating an Account, you represent that:
(a) if you are a natural person, you are at least 18 years old and have full legal capacity;
(b) you are not barred from using the Platform under applicable law;
(c) all information provided is true, accurate and not misleading;
(d) if you act on behalf of a company or other entity, you are duly authorised to bind that entity.
4.4 Volocar may refuse, suspend or cancel an Account where:
(a) you provide false, misleading or incomplete information;
(b) you breach these Terms or any Specific Terms Annex;
(c) we reasonably suspect fraud, abuse or unlawful activity;
(d) required identity verification or KYC checks fail or are not completed.
4.5 Volocar will apply any suspension or cancellation in a proportionate manner and will not use such measures to deprive consumers of statutory rights in relation to existing bookings or acquired benefits.
5. Use of the Platform
5.1 Subject to these Terms, Volocar grants you a limited, non‑exclusive, non‑transferable, revocable licence to access and use the Platform for its intended purposes.
5.2 You must not:
(a) use the Platform for any unlawful purpose or in violation of applicable laws and regulations;
(b) use the Platform to infringe any third‑party rights, including intellectual property, privacy or personality rights;
(c) reverse engineer, decompile, or disassemble the Platform, except to the extent permitted by mandatory law;
(d) circumvent or attempt to circumvent any security or access control measures;
(e) use automated tools (bots, scrapers) to access or extract data from the Platform without our prior written consent;
(f) upload or transmit malware, spam or any harmful code;
(g) misuse the messaging, review or communication features to harass, defame, discriminate or spam other Users or Partners.
5.3 Volocar may update, modify, suspend or discontinue parts of the Platform at any time, provided that such changes do not unreasonably affect ongoing bookings or acquired rights of consumers.
6. Online Marketplace Transparency and Key Information
6.1 For each Listing, Volocar will display, in a clear and prominent manner before you are bound by a contract:[web:89][web:115]
(a) the identity and contact details of the relevant Partner and, where applicable, their trader/non‑trader status;
(b) the main characteristics of the vehicle or service;
(c) the total price inclusive of taxes and all mandatory fees, and the nature and conditions of any additional or optional fees;
(d) information on deposits, pre‑authorisations or the absence of deposits, and key conditions (age, licence, usage limits);
(e) the main elements of the applicable cancellation and change rules;
(f) a summary of insurance/coverage and major exclusions for rentals;
(g) indications of whether personalisation or dynamic pricing is used, where relevant.
6.2 Volocar will clearly indicate, for each Listing, whether the Partner is acting as a trader or as a private/non‑trader and will explain, in summary, how this affects the consumer’s rights, in line with the Romanian implementation of EU “Omnibus” rules for online marketplaces.[web:45][web:103]
6.3 Volocar uses ranking algorithms to order Listings in search results and other sections. The main parameters (such as price, relevance, ratings, availability, location and Partner performance) and the impact of any paid placements will be described in a dedicated ranking transparency section linked from the Platform.
6.4 Where Volocar offers sponsored or paid placements, these will be clearly labelled as such.
6.5 Volocar will provide pre‑contract information in accordance with GEO 34/2014 and related rules, including the identity of the trader, total price, contract duration, and, where applicable, the existence of withdrawal rights or their absence.[web:123][web:115]
7. Booking, Leads and Contracts between Users
7.1 The process and legal effects of rental and mobility bookings are described in Annex A. By placing a Booking request or confirming a Booking, you agree to Annex A in addition to these Terms.
7.2 The process and legal effects of vehicle sales and leads are described in Annex B. By sending an enquiry, placing an order or entering into a purchase transaction via the Platform, you agree to Annex B in addition to these Terms.
7.3 Volocar may facilitate communication and documentation between Users and Partners, but is not responsible for the performance of rental or sale contracts, except as expressly set out in these Terms or in a Specific Terms Annex.
8. Fees, Payments, Chargebacks and Stripe
8.1 Volocar uses Stripe and other licensed payment service providers to process payments for transactions conducted through the Platform. You may be required to accept Stripe’s terms and conditions when making or receiving payments.[web:27][web:41]
8.2 For rental and mobility transactions, the payment flows, applicable fees, deposits, and the timing of charges are described in Annex A. For vehicle sales and leads, they are described in Annex B and Annex C.
8.3 Volocar may charge:
(a) service fees to Customers or Vehicle Buyers for use of the Platform; and/or
(b) commissions to Partners on successful Bookings or sales/leads.
All fees and commissions will be disclosed before booking or listing, as applicable.
8.4 Payments may be processed as:
(a) charges to Customers’ or Vehicle Buyers’ payment instruments;
(b) payouts to Partners’ Stripe‑connected accounts or designated bank accounts;
(c) withholding of security deposits and subsequent adjustments.
8.5 Volocar does not operate as a payment institution and acts as a technical and commercial agent in relation to payments processed through Stripe under the marketplace model.[web:17][web:27]
8.6 Users and Partners agree to cooperate with Volocar and its payment providers in investigating and responding to disputes and chargebacks, including by providing documentation and evidence (such as booking confirmations, inspection reports, correspondence) within requested timeframes.[web:35][web:38]
8.7 Volocar may, where reasonably required to manage chargeback, fraud or credit risk in line with its obligations towards payment providers and card schemes, temporarily withhold payouts or establish a reserve for a Partner. Such measures will take into account the Partner’s historic performance and forecasted exposure. Volocar will inform the Partner of the reasons and, where possible, the expected duration and amount of such reserve and will periodically review the reserve to reduce or remove it when risk decreases.[web:44][web:35]
8.8 By using payment services on the Platform, Users and Partners agree to comply with the terms and policies of the relevant payment providers (including Stripe) and applicable card network rules. Volocar may take necessary measures, including suspension of payments or services, to ensure compliance with these obligations.[web:27][web:41]
8.9 We may share relevant data with payment providers, card schemes and competent authorities where reasonably necessary to investigate, prevent or report suspected fraud, chargeback abuse or other unlawful activity, in accordance with data protection law.
9. Reviews, Ratings and User Content
9.1 Users may leave reviews, ratings and other User Content regarding their interactions on the Platform, subject to these Terms.
9.2 By submitting User Content, you grant Volocar a worldwide, non‑exclusive, royalty‑free, sublicensable licence to use, reproduce, modify, translate and display such content in connection with the Platform and Volocar’s business.
9.3 You must ensure that your User Content:
(a) is accurate and not misleading;
(b) does not contain unlawful, defamatory, offensive or discriminatory material;
(c) does not infringe third‑party rights.
9.4 Volocar may moderate, edit or remove User Content that violates these Terms or legal obligations, while respecting freedom of expression and transparency requirements.
9.5 Volocar may implement verification mechanisms (for example, “verified booking” labels) to indicate that a review is linked to an actual transaction and will describe those methods in a separate, accessible review policy.
9.6 Volocar will not suspend or terminate a consumer solely for submitting a legitimate complaint or leaving a fair review in good faith, even if negative.
10. Messaging, AI Assistants and Communications
10.1 The Platform includes messaging features (in‑app messages, email, SMS, WhatsApp or similar) enabling communication between Users and Partners and between Users and Volocar.
10.2 You must use these features only for legitimate purposes related to the Platform and not for unsolicited marketing, harassment or abuse.
10.3 Volocar may use AI‑assisted support and sales assistants to:
(a) answer questions;
(b) guide you through booking or enquiry processes;
(c) draft suggested responses for human agents.
10.4 AI assistants are clearly identified as such. They are provided for convenience only and may not always be accurate or complete. They do not constitute legal advice or a binding commitment by Volocar or Partners. Where there is any inconsistency between information provided by AI assistants and the information displayed in the booking summary, the Specific Terms Annexes or written human communications, the latter will prevail. Consumers’ statutory rights are determined by applicable law and final contract terms, not by AI‑generated wording.
10.5 Final decisions that have legal or similarly significant effects (for example, final denial of refunds, deposit retention, permanent bans) will be subject to human review on request, as required by data protection law.[web:67][web:116]
10.6 Some communications are transactional (for example, booking confirmations, safety notices) and are necessary for contract performance; others are marketing and will only be sent where you have given valid consent or where permitted by law.
10.7 For WhatsApp and similar channels:
(a) transactional messages (such as booking confirmations, reminders, safety messages) may be sent under contract necessity or legitimate interests;
(b) marketing messages via WhatsApp will only be sent with your prior consent and will include a simple opt‑out mechanism;
(c) you should not send copies of identity documents, full payment card numbers or other sensitive data via WhatsApp; where such data are needed, we will provide secure upload channels.
11. Moderation, Misuse and Enforcement
11.1 Volocar may take action if a User or Partner:
(a) breaches these Terms, a Specific Terms Annex or applicable law;
(b) engages in fraud, attempted fraud or chargeback abuse;
(c) poses a safety or legal risk to other Users or to Volocar;
(d) lists or provides unsafe, illegal or misleading vehicles or content;
(e) repeatedly cancels bookings without valid reasons;
(f) generates unusually high complaint or chargeback rates;
(g) fails to maintain required insurance or licences;
(h) misuses messaging or review systems.
11.2 Available measures include, in line with our internal moderation policy:
(a) written warnings and guidance;
(b) temporary restrictions on certain features (for example, new listings or bookings);
(c) temporary suspension of the Account;
(d) rejection or removal of Listings or User Content;
(e) withholding of payouts in relation to disputed transactions;
(f) permanent bans or termination of the Account and related contracts.
11.3 Volocar will act in a proportionate manner, taking into account the severity and frequency of breaches, and will not use enforcement measures to deprive consumers of statutory rights in relation to existing bookings.
11.4 For significant measures such as suspension, delisting or termination, Volocar will provide the affected User or Partner with a statement of reasons and information on how to contest or appeal the decision.
11.5 Partners may submit a written appeal within [X] days of receiving a suspension or termination notification. Volocar will review the appeal and respond within a reasonable time (normally within [Y] days).
11.6 Enforcement measures do not affect obligations already incurred, including obligations to provide services, pay amounts due or handle refunds, which remain governed by applicable law and the relevant contracts.
11.7 Volocar will not suspend or terminate a consumer solely for submitting legitimate complaints or reviews in good faith.
12. Complaints, ANPC, ODR and Dispute Resolution
12.1 If you are a consumer and have a complaint related to the Platform or to a transaction facilitated by the Platform, you should first contact Volocar using the contact details provided on the Platform. We will attempt to resolve your complaint within a reasonable time.
12.2 If your complaint relates to a rental or sale contract with a Partner, Volocar may assist in facilitating communication but cannot impose a resolution on the Partner unless otherwise provided by law or a Specific Terms Annex.
12.3 Consumers may also address complaints to the Romanian National Authority for Consumer Protection (ANPC) and, for cross‑border disputes within the EU, through the European Online Dispute Resolution (ODR) platform.[web:39][web:28][web:121]
12.4 Nothing in these Terms limits your right to bring claims before competent courts according to applicable law.
13. Liability and Disclaimers
13.1 Nothing in these Terms excludes or limits liability for:
(a) death or personal injury caused by intent or gross negligence;
(b) damages caused by wilful misconduct;
(c) any liability that cannot be excluded or limited under mandatory law.
13.2 To the maximum extent permitted by applicable law and subject to clause 13.1:
(a) Volocar is not liable for the proper performance of rental, mobility or sale contracts between Users and Partners, including for:
(i) the condition, safety or legality of vehicles;
(ii) the accuracy or completeness of Listings and Partner information;
(iii) the availability of vehicles;
(iv) delays, cancellations or damages arising from Partner conduct;
(b) Volocar’s total liability to you arising from or in connection with the use of the Platform and Services, whether in contract, tort or otherwise, will be limited to the higher of:
(i) the total service fees paid by you to Volocar in the twelve (12) months preceding the event giving rise to the claim; and
(ii) [●] EUR, except where mandatory law requires a higher amount.
13.3 For consumers, the limitations in this Section do not exclude or limit liability for lack of conformity of digital services, for non‑compliance with mandatory consumer protection rules, or in any situation where such limitation would be considered unfair or prohibited under Law no. 193/2000 or other mandatory consumer legislation.[web:128][web:132][web:126]
13.4 The Platform and Services are provided on an “as is” and “as available” basis. Volocar does not guarantee uninterrupted or error‑free access but will use reasonable efforts to maintain availability.
13.5 Any indemnity obligations contained in these Terms or in any Specific Terms Annex do not apply to consumers to the extent that such obligations would be considered unfair or prohibited under Romanian or EU consumer law.[web:128][web:132]
13.6 These limitations have been drafted taking into account the Romanian and EU rules on unfair terms and do not deprive consumers of core rights granted by mandatory legislation.[web:128][web:132][web:126]
14. Intellectual Property
14.1 All intellectual property rights in and to the Platform (software, design, trademarks, content) are owned by or licensed to Volocar.
14.2 Nothing in these Terms transfers any ownership rights to Users; only limited usage rights as specified in clause 5.
14.3 Users grant Volocar the licence described in clause 9.2 for User Content.
15. Changes to the Platform and Terms
15.1 Volocar may modify the Platform and these Terms from time to time, for example to reflect changes in law, technical developments or business needs.
15.2 Where changes significantly affect your rights or obligations, we will notify you in advance (for example via email or Platform notice) and they will only apply to new bookings or interactions after the effective date.
15.3 For ongoing bookings and contracts, the terms in force at the time of booking or conclusion will continue to apply, unless a change is required by law and does not reduce acquired consumer rights.[web:112][web:89]
15.4 Nothing in this clause affects your right to terminate the use of the Platform or to exercise rights granted by mandatory law if you do not agree with updated Terms.
16. Governing Law, Jurisdiction and Language
16.1 These Terms are governed by Romanian law, without prejudice to mandatory consumer protection provisions that may apply under the law of your place of residence in the EU.[web:115][web:108]
16.2 If you are a consumer resident in the EU, you may bring proceedings in the courts of your domicile or in the courts of Romania, as provided by EU jurisdiction rules.
16.3 These Terms are made available in Romanian and English. For users in Romania, the Romanian version prevails in case of discrepancy.
17. Regional Specific Terms (UAE / GCC)
17.1 For users in the United Arab Emirates or other GCC countries, additional or different local terms may apply to reflect local consumer, data protection and e‑commerce laws (including UAE Consumer Protection Law, Digital Commerce Law and PDPL).[web:139][web:24][web:145][web:146]
17.2 In case of conflict between these Terms and any mandatory provisions of UAE or other GCC laws, the local terms will prevail to the extent required by such laws. Nothing in these Terms is intended to constitute a “harmful term” under UAE Consumer Protection Law or equivalent local rules; in case of conflict, such terms will be interpreted or disapplied to preserve consumer rights.[web:77][web:143][web:146]
17.3 For UAE‑based services, certain information and contracts may be provided in Arabic in compliance with local law. In case of conflict between language versions where local law so requires, the Arabic version may prevail.
18. Miscellaneous
18.1 If any provision of these Terms is held invalid or unenforceable, the remaining provisions will remain in full force and effect.
18.2 You may not assign or transfer your rights or obligations under these Terms without Volocar’s prior written consent, except as permitted by law. Volocar may assign these Terms in connection with a merger, acquisition or sale of business, subject to applicable law and with notice where required.
18.3 No failure or delay in exercising any right or remedy will constitute a waiver.
``` DOCUMENT 2 HTML ```htmlAnnex A – Rental & Mobility Terms
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1. Scope and Relationship with Platform Terms
1.1 This Annex A – Rental & Mobility Terms (“Rental Terms”) supplements the Platform Terms & Conditions (“Platform Terms”) and applies to all rentals, monthly rentals and related mobility services (“Rental Services”) booked through the Platform by Customers from Partners.
1.2 In case of conflict between these Rental Terms and the Platform Terms, these Rental Terms prevail for issues specifically related to Rental Services, subject to mandatory consumer protection law.
2. Rental Products and Parties to the Rental
2.1 Rental Services available through the Platform may include:
(a) short‑term car rentals;
(b) monthly rentals or longer‑term mobility products (excluding financial leasing regulated separately);
(c) optional add‑on services (delivery/collection, child seats, navigation devices, etc.).
2.2 For each Booking, the rental contract (“Rental Contract”) is concluded between:
(a) the Customer; and
(b) the Partner, which may be:
(i) an Individual Host (peer‑to‑peer rental); or
(ii) a Rent‑a‑Car Company.
2.3 Volocar is not a party to the Rental Contract and is not the lessor, unless expressly indicated for a specific product. Volocar provides marketplace, booking and payment facilitation services only.
3. Pre‑contract Information (GEO 34/2014 and EU Law)
3.1 In accordance with Government Emergency Ordinance 34/2014 and EU consumer law, Volocar and the Partner shall ensure that all information required for distance contracts is provided to the Customer in a clear and comprehensible manner before the Customer is bound by a Rental Contract, and that the booking confirmation on a durable medium contains or confirms such information.[web:123][web:115]
3.2 This includes at least:
(a) the identity and contact details of the Partner, and its trader/non‑trader status;
(b) the main characteristics of the vehicle and any included services;
(c) the total price for the Rental Services, including taxes and mandatory fees, and the nature and conditions of any additional charges (e.g. young driver fees, cross‑border fees);
(d) the amount, method and timing of any security deposit or pre‑authorisation, or a statement that no deposit is required;
(e) key conditions of use (minimum age, driving licence requirements, geographic restrictions, mileage limits, etc.);
(f) applicable cancellation, change and no‑show rules;
(g) a summary of insurance and coverage, including deductibles and major exclusions;
(h) the duration of the Rental Contract and, where applicable, minimum commitment periods;
(i) whether a statutory right of withdrawal exists or is excluded, and, where applicable, the conditions, time limits and procedures for exercising that right.
4. Booking Process and Contract Formation
4.1 The Platform displays availability of vehicles based on information provided by Partners. Availability is not guaranteed until a Booking is confirmed.
4.2 Booking steps:
(a) The Customer selects the desired vehicle, rental dates, pick‑up/drop‑off locations and any add‑ons.
(b) The Platform displays a clear and prominent summary of price, deposit (or no‑deposit), key conditions, cancellation rules and main exclusions.
(c) The Customer confirms the Booking request and provides payment details.
(d) Depending on Partner configuration, the Booking may be:
(i) Instant Booking: automatically accepted when the Customer confirms; or
(ii) Manual Approval Booking: subject to Partner approval within a specified time window.
4.3 For Manual Approval Bookings:
(a) a Booking request remains pending for up to [X] hours (or such period as displayed on the Platform);
(b) if the Partner does not accept within that period, the request lapses automatically, any pre‑authorisation is released and no Rental Contract is formed;
(c) a request may be declined by the Partner or automatically by the system based on availability or risk assessment; automated declines based solely on profiling are subject to human review upon request as described in our Privacy & Cookie Policy.
4.4 For Instant Bookings, the Rental Contract is formed when the Platform shows the Booking as confirmed and the Customer receives a confirmation on a durable medium (e.g. email or in‑app message), including or confirming the pre‑contract information set out above.[web:93][web:112]
4.5 The confirmation will reference these Rental Terms and the Platform Terms.
5. Prices, Fees, Deposits, No‑Deposit and Payments
5.1 All prices are shown in the currency indicated on the Platform and include applicable taxes and mandatory charges, unless explicitly stated otherwise.
5.2 In addition to the rental price, the Customer may be required to pay:
(a) a security deposit or pre‑authorisation by card at the time of Booking or at pick‑up; and/or
(b) charges for add‑on services selected by the Customer; and/or
(c) charges under clause 8 (damage, fines, cleaning), where applicable.
5.3 Deposits and certain fees may be set on a risk‑based and dynamic basis (for example, taking into account vehicle category, rental duration or risk signals from payment providers). The fact that deposits may be dynamic will be clearly disclosed before Booking, together with the main parameters used at a high level, without revealing confidential fraud‑prevention details.
5.4 In some cases, no security deposit will be required. This will be clearly indicated before Booking. The absence of a deposit does not affect your obligation to pay for damage, fines, fuel or other charges incurred under the Rental Contract, which may be charged to your payment method in accordance with these Rental Terms, based on evidence described in clause 8.
5.5 By confirming a Booking, you authorise the Partner and/or Volocar (acting as commercial agent) to charge your payment method for:
(a) the rental price and agreed fees;
(b) deposits and any subsequent authorised adjustments;
(c) amounts properly due for damage, fines, fuel, late return or special cleaning, in each case supported by evidence and within the limits of applicable law and insurance coverage.
5.6 Payments are processed by Stripe or other licensed payment service providers. Volocar may act as commercial agent for the Partner for the purpose of collecting and disbursing rental payments.
5.7 In case of no‑show, early return or cancellation, applicable fees are determined by the cancellation policy shown at the time of Booking and by these Rental Terms.
5.8 Additional costs (e.g. fuel, overtime, fines) may be charged by the Partner in accordance with these Rental Terms and the Partner’s specific conditions, based on appropriate evidence as set out in clause 8.
6. Right of Withdrawal, Cancellations, Changes and Withdrawal Mechanisms
6.1 Many Rental Services involve accommodation, transport or leisure services for a specific date or period. In such cases, the statutory 14‑day right of withdrawal for distance contracts under GEO 34/2014 may not apply, as those services fall under recognised exceptions (such as car rental for a specific period).[web:129][web:123]
6.2 Where a Rental Service falls under a legal withdrawal exception, this will be clearly indicated before Booking. Where a statutory right of withdrawal applies (for example, to certain long‑term contracts if structured in a way that the right is not excluded), the conditions, time limit and procedures, including any “withdrawal button” or equivalent functionality implemented under Romanian law, will be clearly explained and made accessible through the Platform.[web:23][web:123]
6.3 Regardless of statutory withdrawal rights, the Platform will present a cancellation policy for each Listing, which may include:
(a) a free‑cancellation period;
(b) partial refund rules;
(c) a no‑refund period;
(d) conditions for changes (e.g. date changes or modification fees).
6.4 If a Partner cancels a confirmed Booking without a valid reason or due to overbooking, the Customer will be entitled to a full refund of all amounts paid through the Platform for that Booking. Where reasonably possible, Volocar will assist in arranging a comparable alternative at no additional cost to the Customer or, if an alternative is not available, may offer a goodwill voucher up to [●] EUR, without prejudice to any higher statutory rights the Customer may have.
6.5 If a Customer cancels or changes a Booking, applicable fees will be as displayed and accepted at the time of Booking, in line with pre‑contract information and these Rental Terms.
7. Pick‑up, Use and Return of Vehicles
7.1 The Customer must present at pick‑up:
(a) a valid driving licence meeting the requirements shown on the Platform;
(b) a valid identification document;
(c) the payment card used for deposit (if required by Partner).
7.2 The Partner may refuse to deliver the vehicle if:
(a) the Customer fails to present required documents;
(b) the Customer does not meet age or licence criteria;
(c) there is reasonable suspicion of fraud, intoxication or misuse.
In such cases, cancellation or no‑show fees may apply only if this was clearly disclosed at the time of Booking and is not contrary to mandatory consumer law.
7.3 At pick‑up and return, Partners must use the Platform’s inspection and photo tools (or equivalent documented methods) to record the vehicle’s condition. Customers are strongly encouraged to participate and verify these records.
7.4 The Customer must use the vehicle in accordance with:
(a) applicable laws (e.g. traffic rules, vignettes/tolls);
(b) limitations specified in the Listing (territory, off‑road use, prohibited uses);
(c) instructions from the Partner and insurance conditions.
7.5 Late returns may incur additional charges as disclosed in the Booking, reasonably reflecting the additional time.
8. Damage, Accidents, Fines, Cleaning and Evidence
8.1 The Customer must immediately inform the Partner and, where required, the police, in case of accident, theft, or significant damage.
8.2 The Customer is responsible for:
(a) damage to the vehicle during the rental period, up to the applicable deductible/excess unless insurance arrangements provide otherwise;
(b) traffic, parking and toll fines incurred during the rental period;
(c) special cleaning costs for unusual dirt or contamination, to the extent permitted by law.
8.3 Partners must base damage charges on documented evidence, using the Platform’s inspection tools or equivalent methods, such as:
(a) before/after photos and condition reports;
(b) repair invoices, cost estimates or standard damage matrices;
(c) official fine notices.
8.4 Volocar may require Partners to provide such evidence before allowing damage‑related charges to be processed through the Platform or presented in disputes.
8.5 Where there is a dispute over damage or fines, Volocar may mediate and facilitate evidence exchange but is not an arbitrator. Final allocation is determined by applicable law and the Rental Contract, without prejudice to the Customer’s right to challenge charges before competent authorities or courts.
9. Insurance and Coverage
9.1 Each Rental Listing will indicate the type of insurance and coverage included or required, for example:
(a) mandatory third‑party liability;
(b) collision damage waiver (CDW);
(c) theft protection;
(d) optional additional coverage.
9.2 The Partner is responsible for ensuring that the vehicle is properly insured in accordance with applicable law and the Rental Contract. Volocar is not an insurer and does not guarantee coverage.
9.3 Major exclusions (e.g. driving under the influence, unauthorised drivers, off‑road use, specific geographical restrictions) will be clearly summarised in the Listing or pre‑contract information.
9.4 Customers must read and comply with any insurance terms provided by the Partner or its insurer and should consider purchasing optional coverage where appropriate.
10. Customer Obligations
10.1 Customers must:
(a) provide accurate information when making Bookings;
(b) ensure that any additional drivers meet eligibility criteria and are properly registered where required;
(c) treat vehicles with care and return them on time and in substantially the same condition;
(d) comply with law, insurance terms and Partner instructions;
(e) pay amounts due under the Rental Contract and these Rental Terms.
10.2 Misuse of vehicles (e.g. intentional damage, illegal activities, use contrary to insurance rules) may result in immediate termination of the Rental Contract, liability for damages and enforcement measures under the Platform Terms, subject to consumer law.
11. Partner Obligations (Individual Hosts and Rent‑a‑Car Companies)
11.1 Partners offering Rental Services must:
(a) ensure vehicles are roadworthy, properly maintained and legally registered;
(b) maintain at their own cost appropriate motor insurance that covers rental use, including any coverage they advertise;
(c) provide accurate Listings and pre‑contract information consistent with these Rental Terms;
(d) honour confirmed Bookings, except in cases of force majeure or legitimate safety/legal reasons;
(e) handle customer issues and complaints promptly and in good faith;
(f) use the Platform’s inspection and photo tools (or equivalent procedures) at pick‑up and return when reasonably possible.
11.2 Partners are solely responsible for compliance with sector‑specific and licensing requirements applicable to rental activities in the jurisdictions where they operate.
12. Support, Remedies and Escalation
12.1 Volocar provides customer support to facilitate communication between Customers and Partners in relation to Rental Services.
12.2 Disputes relating to Rental Services should first be raised with the Partner, with Volocar’s assistance where needed.
12.3 Where a Partner fails to provide the Rental Service as agreed (for example, unjustified cancellation, non‑delivery), Volocar will assist the Customer to obtain refunds and, where possible, alternatives as set out in clause 6.4, without prejudice to the Customer’s legal remedies against the Partner.
12.4 If disputes are not resolved, Customers may use the complaint mechanisms described in Section 12 of the Platform Terms and may escalate to ANPC, EU ODR or courts as permitted by law.
``` DOCUMENT 3 HTML ```htmlAnnex B – Vehicle Sales & Lead Terms
Last updated: [●]
1. Scope and Relationship with Platform Terms
1.1 This Annex B – Vehicle Sales & Lead Terms (“Sales Terms”) supplements the Platform Terms and applies to all vehicle sale and lead‑generation interactions facilitated by the Platform between Vehicle Buyers and Vehicle Sellers.
1.2 In case of conflict between these Sales Terms and the Platform Terms regarding vehicle sales, these Sales Terms prevail, subject to mandatory consumer protection rules.
2. Volocar’s Role in Vehicle Sales and Leads
2.1 Volocar operates the Platform as a marketplace and lead generator for vehicle sales.
2.2 Unless explicitly stated otherwise, Volocar:
(a) is not the seller of vehicles;
(b) does not acquire title to vehicles at any time;
(c) is not responsible for vehicle registration, roadworthiness or compliance;
(d) is not an insurer or guarantor of vehicle condition or financing.
2.3 Volocar may enable:
(a) the submission of Leads from Vehicle Buyers to Vehicle Sellers;
(b) the exchange of information, offers and documents;
(c) optional payment or deposit flows via Stripe, as described in the Platform Terms and Annex C.
2.4 The sale contract for a vehicle is concluded directly between the Vehicle Buyer and the Vehicle Seller, whether or not the contract is generated or signed through the Platform.
3. Trader vs Private Seller Status and Impact on Rights
3.1 Each Vehicle Seller must declare whether they act as a trader (professional seller) or as a private seller (non‑trader) in relation to their Listings.
3.2 For each Listing, the Platform will indicate the declared status and explain, in clear language, how this affects the Vehicle Buyer’s rights, including:
(a) the existence of legal guarantees and remedies in trader sales;
(b) the more limited rights typically available against private sellers.[web:45][web:115]
3.3 Volocar relies in good faith on these declarations but may request additional information, and where there is strong evidence of professional selling activity, may reclassify a seller as a trader to comply with marketplace transparency obligations.
3.4 Vehicle Buyers should carefully check the seller’s status and understand that purchasing from a private seller generally offers fewer consumer rights than purchasing from a professional dealer.
4. Pre‑contract Information (Trader Sales)
4.1 Before entering into a sale contract with a trader Vehicle Seller, the Vehicle Buyer will be provided, via the Platform or directly by the seller, with the pre‑contract information required by GEO 34/2014 and EU law, including at least:[web:123][web:115]
(a) the identity and contact details of the Vehicle Seller;
(b) the main characteristics of the vehicle (make, model, year, mileage, previous use, accident history where disclosed, etc.);
(c) the total price, including taxes and any additional charges;
(d) delivery/collection arrangements, costs and timing;
(e) payment methods and any deposit or prepayment rules;
(f) the existence and conditions of the legal guarantee and any additional commercial guarantees;
(g) the existence of a right of withdrawal, where applicable, or its absence and the legal basis for any exception;
(h) complaint mechanisms and dispute resolution options.
4.2 This information will be provided in a clear and comprehensible manner before the Vehicle Buyer is bound by the sale contract.
5. Legal Guarantees and Conformity (Trader Sales)
5.1 Where the Vehicle Seller is a trader and the Vehicle Buyer is a consumer, the sale is subject to legal guarantee and conformity rules under applicable EU and Romanian law (including rules on conformity of goods and reversed burden of proof within certain periods).[web:48][web:115]
5.2 The Vehicle Seller is responsible for ensuring that the vehicle is in conformity with the contract at the time of delivery, taking into account its age, mileage and disclosed defects.
5.3 If the vehicle is not in conformity, the consumer may have statutory remedies such as repair, replacement, price reduction or contract termination, as provided by applicable law.
5.4 Volocar is not responsible for the Vehicle Seller’s compliance with legal guarantees but may assist in facilitating communication between parties.
6. Private Seller Transactions
6.1 In sales involving private Vehicle Sellers, many consumer protection rules applicable to trader sales (including legal guarantees and withdrawal rights) do not apply in the same way.
6.2 Private sellers must, however:
(a) provide truthful information about the vehicle;
(b) not engage in fraud or misrepresentation;
(c) respect mandatory legal obligations regarding transfer of ownership and roadworthiness.
6.3 Volocar is not responsible for investigating each private sale but may suspend or remove Listings and/or Users where there is credible evidence of fraud, illegal activity or serious misrepresentations.
7. Payment, Delivery and Transfer of Title
7.1 Payment for vehicles may occur:
(a) directly between Vehicle Buyer and Vehicle Seller outside the Platform; or
(b) through payment channels facilitated by Volocar and Stripe (for example, deposits or reservation fees), as described in the relevant flows and in Annex C.
7.2 Where Volocar facilitates payments, its role and limitations will be disclosed before payment. Funds may be collected on behalf of the Vehicle Seller, subject to the Platform Terms and Annex C.
7.3 The transfer of title and responsibility for registration, taxes and insurance is determined by the sale contract and applicable law between Vehicle Buyer and Vehicle Seller. Volocar is not responsible for delays or failures in transfer of title or registration, except where caused directly by Volocar’s fault in a payment process under its control.[web:51][web:57]
8. Right of Withdrawal, Withdrawal Mechanisms and Returns
8.1 For distance contracts with trader Vehicle Sellers, a statutory 14‑day right of withdrawal may apply under GEO 34/2014, subject to exceptions and conditions, unless clearly exempted by law.[web:123][web:131]
8.2 Where a statutory right of withdrawal applies, the seller and/or the Platform will clearly describe the conditions and procedures, including any “withdrawal button” or equivalent functionality implemented under Romanian law, and will make the required forms or mechanisms available.[web:23][web:123]
8.3 For private seller sales, there is generally no statutory right of withdrawal, unless otherwise agreed between the parties.
8.4 Returns and refunds in trader sales are handled directly between Vehicle Buyer and Vehicle Seller, with Volocar acting as facilitator where practicable, without prejudice to the Buyer’s rights to seek redress in court or via consumer authorities.
9. Disputes and Liability Allocation
9.1 Disputes concerning vehicle condition, title, payment or registration are primarily between Vehicle Buyer and Vehicle Seller.
9.2 Volocar may provide tools and support to exchange evidence and mediate disputes but is not an arbitrator and has no obligation to impose a solution unless required by law or a specific agreement.
9.3 Except where required by mandatory law, Volocar is not liable for:
(a) hidden defects or non‑conformity of vehicles;
(b) title defects or encumbrances;
(c) non‑completion of sale or transfer;
(d) misrepresentations made by Vehicle Sellers in Listings or communications.
9.4 The liability limitations in Section 13 of the Platform Terms apply accordingly.
``` DOCUMENT 4 HTML ```htmlAnnex C – Partner & Listing Terms
Last updated: [●]
1. Scope and Relationship with Platform Terms
1.1 This Annex C – Partner & Listing Terms (“Partner Terms”) supplements the Platform Terms and governs the rights and obligations of all Partners (Individual Hosts, Rent‑a‑Car Companies, Vehicle Sellers) in relation to Listings and transactions on the Platform.
1.2 In case of conflict between these Partner Terms and the Platform Terms for matters specific to Partner obligations, these Partner Terms prevail, subject to mandatory law.
2. Partner Onboarding, Trader Status and KYC
2.1 To become a Partner, you must:
(a) create a Partner Account;
(b) provide requested onboarding information and documents (e.g. ID, company registry extract, VAT number, proof of vehicle ownership or usage rights, proof of insurance);
(c) complete any identity verification or KYC steps requested by Volocar or its providers (including Stripe Identity);
(d) accept these Partner Terms and the Platform Terms.
2.2 You must declare whether, for each Listing, you act as a trader or as a non‑trader (private individual).
2.3 You must notify Volocar without undue delay of any change that affects your trader/non‑trader status (for example, increased volume or professional branding).
2.4 Volocar may carry out checks and, where there is strong evidence of professional selling or rental activity, may reclassify you as a trader to comply with marketplace transparency obligations and protect consumers.[web:45][web:103]
2.5 You must not bypass KYC, sanctions or risk controls implemented by Volocar or payment providers.
3. Listings and Quality Standards
3.1 You are solely responsible for the content of your Listings and must ensure they are:
(a) accurate, complete and not misleading;
(b) kept up to date;
(c) compliant with applicable laws, including advertising and consumer protection laws.
3.2 Listing content must include, as applicable:
(a) key characteristics of the vehicle (make, model, year, mileage, fuel, transmission, category);
(b) price and any additional fees, clearly labelled;
(c) main conditions (e.g. driver eligibility, usage limits, extra charges);
(d) for Vehicle Sellers, relevant information on vehicle history and condition to the extent known;
(e) for Rentals, clear summary of insurance and coverage and main exclusions.
3.3 You must not list vehicles that:
(a) you do not own or have valid rights to use/sell;
(b) are unregistered or unroadworthy;
(c) are subject to legal restrictions that prohibit renting or selling them through a marketplace.
3.4 Volocar may set quality standards (e.g. minimum photo quality, description completeness, response times) and may restrict visibility or availability if these standards are not met.
4. Insurance, Safety and Compliance
4.1 If you offer Rental Services, you must:
(a) maintain at your own cost appropriate motor insurance that covers rental use, including any coverage you advertise;
(b) ensure vehicles comply with safety, technical and inspection requirements in each jurisdiction of use;
(c) ensure any additional coverage (e.g. CDW, theft) is valid and that exclusions and deductibles are clearly communicated to Volocar for inclusion in Listings.[web:11][web:9][web:4]
4.2 If you are a Vehicle Seller, you must ensure compliance with applicable laws on vehicle sale, registration and tax, including obligations regarding legal guarantees where you act as trader.
4.3 You must comply with all applicable laws and regulations, including consumer protection, competition, tax, insurance, road traffic and data protection laws.[web:126]
4.4 You must co‑operate with Volocar and competent authorities in safety‑related matters and, where necessary, withdraw unsafe vehicles from Listings.
5. Commissions, Fees, Payouts, Reserves and Taxes
5.1 Volocar may charge you commissions or fees for transactions facilitated through the Platform. Applicable rates and structures will be communicated separately (e.g. in the Partner dashboard) and form part of these Partner Terms.
5.2 Unless otherwise agreed:
(a) Volocar will calculate commissions based on the gross amount paid by the Customer or Vehicle Buyer (excluding local taxes and fees that are not consideration for your services);
(b) Volocar may deduct commissions and applicable fees before paying out amounts due to you.
5.3 Payments to Partners are processed via Stripe or other payment processors, and you must comply with their onboarding and KYC requirements, as well as with card scheme rules.[web:27][web:41]
5.4 You are solely responsible for:
(a) determining and paying any taxes (including VAT, income tax, local rental or tourism taxes) arising from your activity;
(b) issuing invoices or receipts to Customers or Vehicle Buyers where required by law.
5.5 Volocar may, where required or permitted by law, withhold or remit taxes on your behalf, and may request additional information or documents to satisfy such obligations.[web:40][web:42][web:36]
5.6 Volocar may, where reasonably required to manage chargeback, fraud or credit risk in line with its obligations towards payment providers and card schemes, temporarily withhold payouts or establish a reserve for you, taking into account your historical performance and forecasted exposure. Volocar will inform you of the reasons and, where possible, the expected duration and amount of such reserve and will periodically review the reserve to reduce or remove it when risk decreases.[web:44][web:35]
6. Data Protection and Data Use
6.1 Each Partner acknowledges that Volocar processes personal data of Users and Partners as controller, as described in the Privacy & Cookie Policy. Partners must also comply with applicable data protection laws when processing personal data received from Volocar or Users.[web:111][web:120]
6.2 Depending on the data flows, Partners may be independent controllers, joint controllers or processors. Specific roles and responsibilities may be further detailed in separate data processing or joint controller arrangements, the essence of which will be made available on request where required by GDPR.
6.3 You may only use personal data obtained through the Platform:
(a) for the purpose of performing the relevant rental or sale contract and related customer service;
(b) in compliance with data protection law and Volocar’s instructions where applicable;
(c) not for unrelated marketing without an appropriate legal basis (e.g. consent or another lawful basis).
6.4 You must implement appropriate security measures to protect personal data and promptly inform Volocar of any data breach that may affect Users.
7. Customer Service and Complaints Handling
7.1 You must provide diligent customer service, including:
(a) timely responses to enquiries;
(b) addressing complaints and issues in good faith;
(c) cooperating with Volocar in handling escalated complaints and regulatory enquiries.
7.2 You must respect consumer rights and remedies granted by law, including rights related to non‑performance, non‑conformity, withdrawal (where applicable) and unfair terms.[web:126][web:115]
7.3 Persistent poor service, high complaint rates or regulatory sanctions may trigger enforcement measures under clause 8.
8. Moderation, Suspensions, Delisting, Termination and Chargeback Cooperation
8.1 Volocar may take proportionate enforcement measures where you:
(a) breach these Partner Terms, the Platform Terms or applicable law;
(b) list unsafe, illegal or misleading vehicles;
(c) repeatedly cancel Bookings without valid reasons (for example, more than [X]% of confirmed bookings over a relevant period);
(d) generate unusual levels of complaints or chargebacks;
(e) fail to maintain required insurance or licences;
(f) engage in fraud, abusive conduct, or attempt to circumvent payment or KYC controls.
8.2 Measures may include:
(a) written warnings and guidance;
(b) temporary suspension of new Listings or Bookings;
(c) delisting of specific vehicles or Listings;
(d) withholding of payouts for disputed transactions;
(e) termination of the Partner Account and associated contracts.
8.3 Volocar will provide you with a statement of reasons for significant measures and information on how to contest them, including timelines for appeals, in line with digital platform transparency expectations.[web:91][web:109]
8.4 You agree to cooperate with Volocar and its payment providers in investigating and responding to disputes and chargebacks, including by providing requested documentation (e.g. booking confirmations, inspection reports, communications) within requested timeframes, in order to reduce fraud and chargeback risk.[web:35][web:38]
8.5 Termination does not affect rights and obligations already incurred, including obligations towards Customers and Vehicle Buyers.
9. Indemnities and Liability
9.1 To the extent permitted by law, you agree to indemnify and hold harmless Volocar, its affiliates and personnel from and against any claims, damages, fines, penalties, losses and costs (including reasonable legal fees) arising out of or related to:
(a) your breach of these Partner Terms, the Platform Terms or applicable law;
(b) your Listings and marketing;
(c) your failure to maintain required insurance or safety standards;
(d) your failure to pay applicable taxes;
(e) claims by Users or third parties arising from your vehicles, services or conduct.
9.2 This indemnity does not apply to consumers to the extent it would be considered unfair or prohibited under mandatory consumer law.
9.3 The liability limitations in Section 13 of the Platform Terms apply accordingly to Partners.
``` DOCUMENT 5 HTML ```htmlPrivacy & Cookie Policy – Volocar Platform
Last updated: [●]
1. Who We Are
1.1 This Privacy & Cookie Policy (“Policy”) describes how [Volocar Romania SRL], as controller, processes personal data in connection with the Volocar Platform.
1.2 Contact details:
- Address: [●], Romania
- Email: [●]
- Data Protection Contact / DPO: [●]
1.3 We process personal data in accordance with the EU General Data Protection Regulation (GDPR) and Romanian Law no. 190/2018.[web:111][web:120]
2. Scope of this Policy
2.1 This Policy applies to personal data of:
(a) Customers and Vehicle Buyers;
(b) Individual Hosts and Rent‑a‑Car Companies;
(c) Vehicle Sellers;
(d) visitors to our website and apps;
(e) other persons whose data we process in connection with the Platform.
2.2 It applies to all processing activities carried out by Volocar in Romania and, where applicable, in the EU/EEA.
3. Roles and Responsibilities (Controllers)
3.1 For most processing activities related to the operation of the Platform (account management, bookings, payments facilitation, messaging, fraud and risk management, analytics, marketing), Volocar acts as an independent controller.
3.2 Partners (such as Rent‑a‑Car Companies and Vehicle Sellers) act as independent controllers for their own customer management, including performance of rentals or sales, handling of fines, claims and legal obligations.
3.3 For certain shared activities (for example, shared risk and fraud management regarding specific transactions), Volocar and certain Partners may act as joint controllers. In such cases, the essence of the joint controller arrangement, including allocation of responsibilities for compliance and data subject rights, is available on request.[web:120][web:111]
3.4 In limited circumstances, Volocar may act as a processor for Partners (for example, hosting certain data strictly on their instructions). Where this is the case, a separate data processing agreement will apply.
4. Data Categories We Process
4.1 We may collect and process the following categories of personal data:
(a) Identification and contact data: name, email address, phone number, address, language, account IDs.
(b) Account and profile data: login credentials, preferences, roles (Customer, Partner), profile photo.
(c) Identity verification and KYC data: ID cards, passports, driving licences, selfies or biometric templates processed by Stripe Identity or similar providers where applicable; verification results and status. We primarily receive only verification outcomes and limited metadata (e.g. document type and status), not full biometric templates.[web:116][web:25]
(d) Booking and transaction data: Booking details, rental/sale dates, prices, vehicle details, invoices and receipts.
(e) Vehicle and listing data: vehicle registration, VIN, characteristics, photos.
(f) Payment data: partial card details, payment tokens, transaction IDs, billing information (full card details are handled by payment processors).
(g) Communications and support data: messages exchanged via the Platform, emails, calls or chats with support, AI‑assisted conversations.
(h) Reviews and feedback: ratings, comments and other User Content.
(i) Technical and device data: IP address, device identifiers, browser type, operating system, log data.
(j) Risk and fraud data: risk scores, flags, behaviour patterns, dispute and chargeback information.
4.2 We generally obtain personal data directly from you, from your use of the Platform, from Partners and from service providers (e.g. payment and ID verification providers).[web:116][web:111]
5. Purposes and Legal Bases
5.1 We process personal data for the following purposes and legal bases:[web:116][web:111]
(a) Account creation and management
To register and manage Accounts, provide access to Platform features, and maintain user settings.
Legal bases: performance of contract; legitimate interests (providing and improving services).
(b) Booking, rental and sale facilitation
To enable search, comparison, Booking of Rental Services, and vehicle sales/leads; to communicate Booking and sale information to Partners and Users.
Legal bases: performance of contract; legitimate interests (operating a marketplace).
(c) Payments and billing
To process payments, manage refunds and chargebacks, and maintain accounting records.
Legal bases: performance of contract; legal obligations; legitimate interests (managing financial risk).
(d) Identity verification and KYC
To verify identity, assess eligibility to drive or partner with us, prevent fraud and comply with legal and payment‑provider requirements.
Legal bases: legitimate interests (fraud prevention and platform safety); legal obligations where applicable.[web:116][web:111]
(e) Customer and partner support
To provide support via email, chat, AI assistants and other channels; to resolve complaints and disputes.
Legal bases: performance of contract; legitimate interests.
(f) Reviews, messaging and community features
To publish and manage reviews and ratings and to enable messaging between Users and Partners.
Legal bases: performance of contract; legitimate interests (social and trust features).
(g) Marketing and communications
To send marketing communications and personalised offers, where allowed by law and your preferences.
Legal bases: consent (for email/SMS/WhatsApp marketing where required); legitimate interests in marketing similar services, with opt‑out options.[web:116][web:111]
(h) Analytics and service improvement
To understand Platform usage, improve functionality, and develop new features.
Legal bases: legitimate interests; consent for non‑essential analytics cookies where required.
(i) Security, fraud prevention and risk management
To monitor, prevent and detect fraud, abuse and security incidents; to manage enforcement actions and reserves.
Legal bases: legitimate interests; legal obligations; performance of contract.
(j) Legal compliance
To comply with tax, accounting, consumer protection, data protection and other legal obligations, and to cooperate with authorities.
Legal bases: legal obligations; legitimate interests.
5.2 We perform Data Protection Impact Assessments (DPIAs) for high‑risk processing activities, such as extensive identity verification, fraud profiling and certain AI‑assisted decision‑making, in line with GDPR and relevant guidance.[web:144][web:142]
5.3 Where we rely on consent, you may withdraw your consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal.
6. Recipients and International Transfers
6.1 We may share personal data with:
(a) Partners (Individual Hosts, Rent‑a‑Car Companies, Vehicle Sellers) to the extent necessary to conclude and perform Bookings or sales and handle related issues;
(b) Payment service providers (e.g. Stripe) for processing payments and verifying identity;
(c) Identity verification providers (e.g. Stripe Identity) for KYC checks;
(d) IT and hosting providers;
(e) Customer support and communication tools providers (including WhatsApp Business API providers);
(f) Insurers and claims handlers in connection with accidents or damages;
(g) Professional advisors (lawyers, auditors) where necessary;
(h) Authorities where required by law or for the protection of rights.
6.2 When you choose to contact us via WhatsApp or similar services, your data may also be processed by those providers (e.g. WhatsApp Ireland / WhatsApp LLC) as independent controllers in accordance with their own privacy policies, which may involve transfers outside the EEA.[web:63][web:69]
6.3 Some recipients may be located outside the EEA. In such cases, we will ensure an adequate level of protection by using appropriate safeguards, such as standard contractual clauses or adequacy decisions, as required by GDPR.[web:120][web:111]
7. Retention Periods
7.1 We will retain personal data only for as long as necessary for the purposes for which they were collected or as required by law. Indicatively:
(a) Account and profile data: for the duration of the Account and for a reasonable period thereafter (e.g. 3–5 years) to handle claims and legal obligations.
(b) Booking and transaction data: for the duration of the contractual relationship and for statutory limitation periods (e.g. 5–10 years) for tax and accounting purposes.[web:116][web:120]
(c) Identity and KYC data: retained for the period necessary to manage risk and comply with legal/PSP requirements, generally not longer than [X] years from the date of verification or the last transaction requiring such verification, unless a longer period is required by law or necessary to establish, exercise or defend legal claims. Access to such data is strictly limited on a need‑to‑know basis.[web:25][web:116]
(d) Communications and support data: for a period necessary to manage issues and evidence interactions (e.g. up to 3–5 years).
(e) Reviews and User Content: retained as long as relevant to the Platform, unless deleted or anonymised earlier.
(f) Technical and log data: for security and auditing purposes, generally for a shorter period (e.g. months to a few years), unless required longer for legal or security reasons.
7.2 We may anonymise data and retain them in aggregated form for statistical and analytical purposes.
8. Cookies and Similar Technologies
8.1 Our website and apps use cookies and similar technologies to:
(a) enable core functionalities (e.g. login, remembering preferences);
(b) perform analytics and improve the Platform;
(c) provide personalised content and marketing.
8.2 When you first visit the site, we will display a cookie banner explaining the types of cookies and offering you the option to accept or reject non‑essential cookies.
8.3 You can change your cookie preferences at any time via the cookie management tool or your browser settings.
8.4 More detailed information about cookie types and purposes is available in our cookie section or cookie table.[web:96][web:116]
9. Automated Decision‑Making, Profiling and AI
9.1 We may use automated tools and profiling to:
(a) assess fraud and security risk;
(b) set certain risk‑based parameters (e.g. deposit levels, verification steps);
(c) personalise recommendations and marketing.
9.2 For example, automated tools may flag a booking as high‑risk based on a combination of factors (e.g. repeated failed payments, mismatched location data). In such cases, additional verification (e.g. 3D Secure or manual review) may be required, or the booking may initially be declined.
9.3 Where such automated processing produces legal effects concerning you or similarly significantly affects you (for example, automated refusal of a Booking), we will ensure compliance with GDPR Article 22, including:
(a) informing you about the existence of such processing and the logic involved;
(b) providing the possibility to obtain human intervention;
(c) allowing you to express your point of view and contest the decision.[web:67][web:116][web:111]
9.4 Our AI assistants (support and sales) process conversation data to assist in answering questions and guiding you through the Platform. These assistants are clearly identified as AI, and you can request human support for complex or sensitive issues. AI outputs are suggestions only and do not override the applicable Terms or legal rights.
9.5 We periodically review and test our profiling and fraud models to ensure they remain accurate, proportionate and fair, and do not use special categories of data (such as health, religion or ethnicity) unless expressly allowed by law and subject to additional safeguards.[web:144][web:142]
9.6 For users located in jurisdictions such as the UAE where equivalent rights exist under PDPL, we will offer comparable protections against solely automated decisions and will conduct impact assessments for high‑risk AI uses in line with local guidance.[web:70][web:145][web:141]
10. Security
10.1 We implement appropriate technical and organisational measures to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure or access.[web:120][web:111]
10.2 Measures include access controls, encryption, secure development practices, logging and regular security testing.
10.3 If we become aware of a personal data breach likely to result in a high risk to your rights and freedoms, we will inform you and the competent supervisory authority as required by law.
11. Your Rights
11.1 Under GDPR and applicable national law, you have the following rights:
(a) Access – to obtain confirmation as to whether we process your personal data and, where applicable, access to those data;
(b) Rectification – to have inaccurate or incomplete data corrected;
(c) Erasure – to request deletion of your data in certain circumstances;
(d) Restriction – to request restriction of processing in certain situations;
(e) Portability – to receive your data in a structured, commonly used format and transmit them to another controller;
(f) Objection – to object to processing based on legitimate interests or for direct marketing;
(g) Rights related to automated decision‑making, as described in Section 9.
11.2 To exercise your rights, please contact us using the details in Section 1. We may need to verify your identity before responding.
11.3 You also have the right to lodge a complaint with the Romanian National Supervisory Authority for Personal Data Processing or with your local supervisory authority in the EU.[web:119][web:111]
12. Contact and Complaints
12.1 For any questions about this Policy or our data practices, you can contact us at: [●].
12.2 We encourage you to contact us first so we can try to resolve any issue. You also retain the right to seek judicial remedies or to contact consumer and data protection authorities as outlined in the Platform Terms and this Policy.[web:28][web:119]
```