1. Introduction

Welcome to Tradoly of Europe, SL ("Tradoly", "we", "our", or "us"). By accessing or using our platform (website, mobile app, and services collectively, "Services"), you agree to be bound by these Terms & Conditions ("T&C").

Tradoly is a digital car aggregator platform that connects traders and dealers for buying, selling, and managing vehicle transactions across Spain and the EU.

Use of the Services is subject to compliance with Spanish law, EU regulations, and good faith. Misuse for illegal, fraudulent, or unauthorized purposes is strictly prohibited.

1.1 Nature of Tradoly Service

Tradoly is a B2B lead mediation platform that facilitates contact between registered business users for the purpose of vehicle trading.

Tradoly does not act as a buyer, seller, broker, dealer, agent, representative, or escrow party in any vehicle transaction.

Tradoly is a digital car aggregator platform that connects traders and dealers for buying, selling, and managing vehicle transactions across Spain and the EU.

Use of the Services is subject to compliance with Spanish law, EU regulations, and good faith. Misuse for illegal, fraudulent, or unauthorized purposes is strictly prohibited.

Tradoly provides a structured marketplace workflow including:

• Fixed-price vehicle listings created by Traders
• Optional negotiation via in-platform messaging
• Dealer-initiated purchase or reservation actions
• Order locking mechanism to temporarily reserve vehicles
• Integration with third-party payment processors for transaction handling
• Integration with logistics providers for vehicle transport (where applicable)

Tradoly does not take custody of vehicles or funds unless explicitly processed through third-party integrations.

2. User Types and Account Registration

2.1 User Types

• Trader: Verified professional vehicle sellers (individuals or entities) listing vehicles or access premium platform features or managing inventory.
• Dealer: Verified professional who may browse listing or purchase vehicles or reserving vehicles.

2.2 Account Requirements

Verification & Access Control: Platform access is restricted to verified business users only.

Account activation requires successful completion of:

• Business verification (KYB)
• Identity verification of authorized representatives (KYC)
• VAT validation (where applicable)
• Users must be 18 years or older.
• Accurate personal and business information is required during registration.
• Users must maintain the confidentiality of their login credentials.
• Users may be verified by Tradoly to ensure authenticity.

2.3 Account Suspension & Termination

Accounts may be suspended or terminated for violations of these T&C, illegal activity, or breach of platform rules.

Termination does not remove obligations such as payment for accrued fees or ongoing disputes.

Tradoly may terminate or suspend users for:

• Providing false or misleading information
• Non-payment of fees
• Misuse of the platform
• Diverting business outside the platform
• Breach of these Terms

2.4 Business User Requirement

Users of the Tradoly platform must be registered business entities.

Users are required to provide valid business registration details, including VAT, CVR, or equivalent identifiers, as applicable under their jurisdiction.

3. KYC, KYB & Anti-Money Laundering (AML) Compliance

Access to Tradoly services is conditional upon successful identity verification, customer due diligence, and credit assessment in accordance with applicable anti-money laundering regulations.

3.1. Mandatory Identification & Verification

Tradoly performs identity (KYC) and business (KYB) verification for all Traders and Dealers in accordance with:

• EU Anti-Money Laundering Directive (AMLD 6),
• Spanish Law 10/2010 on AML/CTF, and
• Digital Services Act (DSA) traceability obligations.

3.2. User Data Provision

Users must provide accurate legal entity details, company registration documents, valid identification of authorised persons, and VAT information. Tradoly may request additional documents at any time to confirm the legitimacy of the business or transaction.

3.3. Verification Failure or Refusal

Accounts may be restricted, suspended, or terminated immediately if:

• verification documents are missing, inconsistent, or invalid;
• the user refuses to provide requested documentation;
• Tradoly identifies anomalies in business structure or ownership.

3.4. Ongoing Monitoring & Activity Review

Tradoly conducts continuous monitoring to identify unusual or high-risk behaviour, including:

• repeated high-value transactions inconsistent with business profile,
• mismatched VAT information or irregular cross-border transactions,
• abnormal listing behaviour or rapid account changes,
• suspected fraudulent vehicle listings or payment anomalies.

3.5. Document Updates

When required, Tradoly may request updated documents or clarifications.

3.6. Suspicious Activity Reporting (SAR)

If Tradoly detects activity that may indicate money laundering, tax fraud, VAT evasion, identity misuse, or criminal behaviour, Tradoly will:

• temporarily freeze affected transactions or accounts,
• preserve required logs and data, and
• file a Suspicious Activity Report with the relevant Financial Intelligence Unit (e.g, SEPBLAC – Spain's FIU) without notifying the user, as required by law.

3.7. Transaction Screening & Payment Controls

Payments processed through Tradoly or third-party payment partners (e.g. Stripe, and / or PayProff) may be subject to:

• sanctions list screening (EU, UN, OFAC),
• fraud checks and velocity monitoring,
• VAT number verification.

3.8. Validation Delays

Any failed or suspicious validation may delay or block the transaction.

3.9. Obligation to Provide Accurate VAT & Tax Information

Traders and Dealers are solely responsible for providing correct tax classification, VAT status (e.g. Intra-EU Supply, Margin Scheme), and cross-border obligations.

Incorrect or fraudulent VAT declarations may result in account suspension and mandatory reporting to tax authorities.

3.10. Right to Suspend Transactions

Tradoly reserves the right to pause, review, or block:

• payments,
• withdrawals,
• listings, or
• account access

where compliance indicators require enhanced due diligence (EDD).

3.11. No Liability for Compliance-Driven Restrictions

Tradoly is not liable for delays, financial loss, or business impact arising from:

• AML/KYC checks,
• regulatory reporting obligations,
• account restrictions required by law, or
• third-party processor compliance actions.

4. Services and Platform Role

No Responsibility for Transactions

• Tradoly does not hold, store, or process user funds directly.
• All payments are processed via regulated third-party payment service providers.
• Tradoly only facilitates transaction initiation and status updates.

Tradoly is not a party to any transaction between users and bears no responsibility for agreements, payments, vehicle condition, delivery, or disputes arising between users.

• Tradoly acts as an intermediary between traders and dealers.
• Tradoly does not own, sell, or guarantee vehicles listed by users.
• All listings, prices, and descriptions are provided by the respective trader or dealer. Tradoly is not liable for accuracy.
• Users interact, negotiate, and purchase vehicles at their own risk, in compliance with applicable law.

4.1 Fees & Charges

The following fees may apply on the Tradoly platform:

• Subscription Fees: Paid by Traders and Dealers for platform access (Trader vs Dealer plans). Subscriptions tier may include: First-time subscriptions, Plan upgrades or downgrades, and Automatic renewals. Subscription fees are governed by the Refund Policy and are non-refundable once activated, except where legally required.
• Service Fees: Charged for platform usage, payment processing, or logistics integrations (where applicable)
• Transaction Charges: Applied to transactions where Tradoly acts as a technical intermediary

Fees may vary based on:

• Subscription tier (Trader vs Dealer plans)
• Number of active listings
• Access to premium features (promoted listings, exclusive listing, third-party integration services, priority visibility)
• Transaction-related services (where applicable)

All fees are exclusive of VAT, unless explicitly stated otherwise.

4.2 Dealer-Specific Fees

• Order Payments: Dealers pay to purchase vehicles through the platform.
• Order Item Lock Extension: Dealers pay to temporarily lock a vehicle, preventing others from purchasing it.

These fees are non-refundable once processed, unless mandated by law or caused by a verified technical error.

4.3 Payment Methods

• Payments are processed through GDPR-compliant providers (e.g. Stripe, Payproff).
• Tradoly does not control third-party payment processing timelines or fees
• All fees are exclusive of VAT, unless otherwise indicated.
• Failed, delayed, or blocked payments may result from compliance, AML, or fraud checks

4.3.1 Payment Processors

Tradoly uses reliable standard third-party payment processors to handle payments between users and for subscription fees. Such processors operate independently, and Tradoly does not control their processing times, compliance decisions, or fees.

Payments initiated on Tradoly are processed by third-party providers (Stripe and / or PayProff). Depending on the transaction structure:

• Payments may be transferred directly between users, or
• Processed via third-party regulated payment escrow infrastructure

Tradoly does not act as a payment institution or financial intermediary.

4.4 Refunds

Refunds follow the Refund & Cancellation Policy:

• Refundable for duplicate payments, technical errors, or cancellations within the legal withdrawal period (14 days for digital services under EU law).
• Non-refundable: completed ads, activated campaigns, expired listings, or services already provided.
• Subscription cancellations take effect at the end of the current billing cycle; no partial refunds apply.
• Refund requests should be submitted with transaction reference and proof of payment.

4.5 Returns & Logistics Workflow

Where vehicle transactions involve returns, the following platform-managed workflow applies:

Request & Approval

• Dealers have 14 days from delivery to submit a return request
• After that a 5-day approval window follows, during which the Trader may approve or reject the request
• Approved returns are processed automatically via a system automated jobs
• Return orders are created and grouped by consignment location

Logistics services are facilitated through third-party providers (TransConnect and other integrated logistics providers) integrated into the platform.

Tradoly does not:

• Operate transport services
• Control delivery timelines
• Guarantee condition upon delivery

Logistics & Financial Settlement

• Returned items are delivered back to the Trader
• Upon confirmed delivery from trader and/or logistics provider side, the refund process is triggered
• Funds are settled directly to the Dealer's escrow account or the original method
• Platform systems update refund status accordingly

Tradoly does not act as the payer, recipient, or custodian of vehicle ownership.

4.6 Incorrect Payments

Incorrect payouts or transfers must be returned immediately by the receiving party.

Tradoly reserves the right to offset such amounts against future payments or take necessary recovery actions.

5. Advertising & Sponsored Listings

Sponsored listings may appear in:

• Top positions within search results
• Recommendation list within category pages
• Featured sections on the homepage

• Paid or promoted content is labeled clearly ("Exclusive", or "Promoted").
• Placement depends on payment, relevance, and listing quality.
• Advertiser identity is visible.
• Users may report misleading or inappropriate listings through the platform's reporting tools.
• Ranking may be influenced by: Paid promotion level, Listing completeness and quality, User interaction pattern
• Personalized ad recommendations are based on user consent and can be managed via account settings.

6. Messaging and Communication

• Tradoly may monitor messaging activity for fraud prevention and compliance purposes.
• Messaging is restricted to registered users within the platform.
• Messages are retained for up to 6 months after last communication or transaction.
• Users must not misuse the chat system for harassment, fraud, or illegal activity.
• Contact details may be shared only after: A user initiates interaction, or A transaction-related action occurs

7. User Content & Intellectual Property

• User-generated listings (including images, vehicle data, and descriptions) are visible to other registered users of the platform and indexed within platform search and recommendation systems.
• Users retain ownership of content (images, descriptions, listings) they upload.
• By uploading content, users grant Tradoly a non-exclusive, worldwide license to display, store, and process it for platform services, analytics, and promotions.
• Unauthorized use of Tradoly intellectual property (logos, software, graphics) is prohibited.
• Users are responsible for ensuring that uploaded content does not contain unauthorized personal data.

8. Prohibited Conduct

Users may not:

• Misrepresent vehicle condition, pricing, or listing details
• Abuse platform features, including order locking, to block inventory
• Create or use multiple accounts to bypass restrictions
• Post false, misleading, or unlawful content
• Impersonate other users or Tradoly personnel
• Use bots, scraping tools, or automated methods to access or extract data
• Harass, threaten, or engage in abusive behavior toward others
• Circumvent applicable platform fees or services
• Attempt unauthorized access to Tradoly systems or user accounts

Violations may result in suspension or termination of access and, where applicable, legal action.

8.1 Non-Circumvention

Users may not bypass Tradoly to conduct transactions with contacts obtained through the platform.

Any attempt to circumvent the platform, including conducting off-platform deals using information gained through Tradoly, may result in immediate termination and potential legal liability.

9. Data Protection & Privacy

• When users share personal or business data with other users: the receiving user becomes an independent data controller and Tradoly is not responsible for further processing of such data.
• Personal data is collected, used, and stored in accordance with the Privacy Policy and Data Retention Policy, and in compliance with applicable data protection laws, including GDPR and Spanish law.
• Users have rights including access, rectification, erasure, portability, and objection.
• Marketing communications are sent only with user consent or under legitimate interest for existing customers, and users may opt out at any time (Settings > Notifications > Preferences).
• Cookies and similar tracking technologies are used as described in the Privacy Policy.

10. Security

Tradoly implements appropriate technical and organizational measures in accordance with GDPR Article 32 to ensure the confidentiality, integrity, and availability of systems and personal data.

Security measures include encryption in transit using HTTPS/TLS, secure password hashing (PBKDF2 with SHA-256), JWT-based authentication, role-based access control (RBAC), secure cloud configurations, and protection against common attack vectors (SQL injection, XSS). Additional safeguards include rate limiting, anomaly detection, continuous monitoring via SIEM systems, regular patching, and encrypted backups.

Access to personal data is restricted on a need-to-know basis. All integrated third-party providers are contractually required to implement appropriate security measures.

Tradoly monitors platform activity to detect unauthorized access, fraud, and abnormal usage patterns. In the event of a security incident or personal data breach, appropriate containment and notification measures will be taken, including reporting to the AEPD and affected users where required by law.

Users are responsible for maintaining the confidentiality of their credentials and reporting any suspected unauthorized access.

Further details are available in Tradoly's Security Policy.

11. Chargebacks & Payment Disputes

Users agree not to initiate chargebacks for valid, authorized transactions.

In the event of a chargeback:

• Tradoly may suspend or freeze the account
• Payouts may be withheld pending investigation

Abusive or fraudulent chargebacks may result in:

• Account termination
• Legal recovery of losses
• Reporting to payment processors and authorities

During payment dispute users acknowledge that:

• Payment processors (Payproff or Stripe) may independently investigate disputes
• Tradoly may share transaction data with payment providers for dispute resolution
• Accounts may be restricted during investigation

12. Liability Disclaimer

Tradoly is not responsible for:

• Accuracy of listings
• Trader-Dealer transactions
• Vehicle condition or legal compliance
• Service interruptions, technical failures, or unauthorized access
• Payment processor (Payproff or Stripe) decisions (delays, holds, reversals)
• Logistics provider (TransConnect and other integrated logistics providers) performance
• Third-party service data accuracy (vehicle history, VIN data, pricing insights, market price value, damage report)

To the maximum extent allowed by law, liability is limited to fees paid to the platform.

No warranties are made regarding outcomes, suitability, or merchantability of user transactions.

13. Governing Law and Dispute Resolution

These T&C are governed by Spanish law.

All disputes shall be subject to the exclusive jurisdiction of the courts of Málaga, Spain.

14. Modifications to Terms

Tradoly reserves the right to update these T&C at any time.

Changes will be posted with an updated "Last Updated" date.

Continued use of Services constitutes acceptance of the revised T&C.

15. External Links

The platform may include links or integrations with third-party services, including:

• Vehicle data providers (VIN decoding, history reports)
• Logistics providers
• Payment processors
• Trader / dealer websites and social links

These third parties operate independently and may collect and process personal data in accordance with their own privacy policies.

Tradoly does not control and is not responsible for their content, services, or data practices.

16. Contact Information

For any questions, complaints, or legal notices: