1. Objective

Tradoly is committed to transparent advertising practices in compliance with the EU Digital Services Act (DSA) and the Spanish General Advertising Law (34/1988).

This policy also aligns with Regulation (EU) 2016/679 (General Data Protection Regulation – GDPR), particularly regarding transparency, lawful processing, and user consent for personalized advertising.

2. Clear Identification of Ads

All paid content is distinctly marked with clear labels such as "Advertisement," "Sponsored," or "Promoted Listing."

The label is visible and distinguishable from organic listings.

Advertisements may appear within search results, category pages, or recommendation sections alongside organic listings.

Promoted recommended search result slots with Recommended Cars section, sponsored exclusive and new vehicle cards in search grids, and promoted placements within homepage recommendation modules and discovery carousels

Visual indicators (such as exclusive / new labels and design variations) are used to distinguish sponsored content from organic results.

3. Ad Placement and Ranking

Sponsored listings appear in prioritised positions such as search results and Recommended Cars under Browse car sections.

Ad placement is determined based on a combination of:

• Payment or bidding amount
• Relevance to the user's search filters and preferences
• Listing quality and completeness
• User interaction signals (clicks, saved listings, and search behavior)

Where personalization is enabled, ad ranking may also be influenced by user behavior and preferences.

Machine learning driven vehicle visibility used within search and recommendation layers.

No sensitive personal data (e.g. health, religion, political views) is used for ad targeting.

4. Advertiser Identification

For each ad, Tradoly ensures visibility of:

• The advertiser's or seller's identity (company name or verified profile)
• Contact details (or direct message link)
• Disclosure that the listing is paid or promoted

Advertiser Verification: Tradoly may implement verification mechanisms for advertisers, such as email verification, business registration checks, or identity validation.

KYC/KYB verification for traders and dealers, including identity and business validation checks, and issuance of a "Verified Dealer" badge for approved business accounts within the platform

However, Tradoly does not guarantee the accuracy of all advertiser-provided information.

5. Personalization of Ads and Legal Basis

Tradoly may personalize advertisements based on user data, including:

• Location (approximate or device-based)
• Browsing behavior (e.g. searches, viewed listings)
• Interaction history (e.g. clicks, saved vehicles)

Legal Basis:

• Personalization of ads is based on user consent (Article 6(1)(a) GDPR).
• Non-personalized ads may be shown based on legitimate interests (Article 6(1)(f) GDPR).

Users have the right to:

• Withdraw consent at any time
• Disable personalized advertising via account settings or cookie preferences
• Settings (account setting) > Privacy > Data Sharing Preferences

Disabling personalization will not remove ads but will make them less relevant.

Profiling Transparency: Ad personalization may involve automated processing of user behavior to predict preferences and display relevant listings.

This profiling does not produce legal or similarly significant effects on users.

Recommendation engine logic based on trader preference, vehicle type, price segment, brand preference, geographic search patterns, and past listing interactions including saved searches and dealer engagement behavior

6. Reporting Mechanism

Users may report misleading, fraudulent, or inappropriate advertisements through the "Report Ad" feature available on each listing.

Tradoly reviews all reports through a combination of automated detection systems and manual moderation processes.

Initial review typically within 48–72 hours depending on case complexity and evidence availability.

Appropriate actions may include removal of content, restriction of advertiser accounts, or further investigation.

7. Data Sharing for Advertising

Tradoly may share limited data with advertising and analytics partners for the purpose of measuring campaign performance and delivering advertisements.

Such partners act as data processors or independent controllers depending on the context.

Google Ads (used for retargeting and campaign measurement), along with analytics and attribution tools integrated into the platform for performance tracking.

All data sharing is conducted in accordance with GDPR requirements and applicable safeguards.

8. Why You Are Seeing This Ad

Users may be shown information explaining why a particular advertisement is displayed to them.

This may include factors such as:

• Search activity
• Location
• Interaction with similar listings

Info labeled button available within sponsored listings and promoted vehicle cards, accessible via listing menu and info icon.

This is provided in accordance with transparency requirements under the Digital Services Act.