Privacy Policy

This Policy explains what personal data we collect on tirkomis.com, why, whom we share it with and how long we keep it. Processing is carried out under the Law of Ukraine “On Personal Data Protection” No. 2297-VI of 01.06.2010.

By using the site and submitting a request you confirm that you have read this Policy. If you do not agree with it, please do not send us your data through the site's forms.

Data you provide yourself:

• in request forms on a vehicle card (inspection, loan/leasing, price offer, trade-in, export, referral): your name and phone number are required, a comment is optional;
• in the financing calculator: the parameters you had on screen (product, down payment, term, rate, estimated payment) — they are attached to your loan request so that a manager does not have to ask again;
• in the buyer account (if you register): email, name, phone, your password as an irreversible hash, saved vehicles and saved searches;
• in the sell-your-vehicle form: details of the unit, your contacts and the photos and videos you upload;
• in the AI assistant chat: the text of your message. Conversations are stored for quality control and may be attached to your request if you asked to be connected to a manager;
• in a review: name, city (optional) and the text.

Data collected automatically:

• IP address — to protect against spam and to rate-limit submissions;
• User-Agent string (browser and device);
• the page a request was sent from, the landing page, the referrer and advertising tags (utm_source, utm_medium, utm_campaign, utm_term, utm_content, gclid, fbclid) — to understand which channel brings customers;
• listing view counts — anonymised, not linked to an individual.

• to contact you about your request and support the transaction;
• to run the buyer account, saved vehicles and saved searches;
• to send service messages about your requests and subscriptions;
• to protect the site from spam and automated submissions;
• to measure the performance of advertising channels in an aggregated form;
• to comply with the law — accounting and tax records for concluded transactions.

We do not take decisions about you by solely automated means and do not build profiles that would have legal consequences for you.

We do not sell personal data. It is shared only to the extent needed for the stated purposes:

• our hosting provider — servers are located in the European Union (Frankfurt, Germany), where the database is stored as well;
• Cloudflare — domain services and protection of forms against automated submissions (Turnstile);
• Anthropic — processing of AI assistant requests: the text of your message is sent to the model to generate a reply;
• Telegram — delivery of new-request notifications to the responsible manager;
• a partner bank or leasing company — only if you submitted a financing request, and only to the extent needed for a preliminary calculation;
• the other party to the deal (seller or buyer), carriers, insurance and service partners — only within the specific transaction you initiated;
• public authorities — solely in cases expressly provided for by law.

Web analytics (Google Analytics, Google Tag Manager) are not currently connected to the site. If we connect them, they will only run after your consent in the cookie banner.

The site uses the following cookies:

• essential — the buyer account session and temporary markers during Google or Telegram sign-in. Sign-in does not work without them;
• tk_utm — advertising tags and referrer, stored for up to 30 days;
• consent cookie — remembers your answer in the banner, stored for up to a year.

You can change your cookie choice at any time via the “Cookie settings” link in the footer. Essential cookies cannot be switched off, as the site would not work without them. Saved vehicles and comparisons are kept in your browser (localStorage) and are not sent to our servers until you sign in.

• requests and correspondence with a manager — for as long as the customer relationship requires, and for concluded transactions, for the period set by tax law;
• buyer account data — while the account exists; once it is deleted the data is erased or anonymised;
• advertising tags — up to 30 days in the cookie and within the request they belong to.

Security: connections are encrypted (HTTPS), staff access is limited by role, actions on data are logged, passwords are stored as an irreversible hash, integration tokens are encrypted, and the database is backed up regularly.

Under Article 8 of the Law of Ukraine “On Personal Data Protection” you have the right to:

• know who processes your data and for what purpose;
• access your data and obtain a copy of it;
• request correction of inaccurate data;
• request erasure of your data or restriction of processing;
• withdraw your consent to processing;
• object to processing;
• lodge a complaint with the Ukrainian Parliament Commissioner for Human Rights or with a court.

To exercise any of these rights, write or call us: +380 97 102 65 65. We reply within 30 calendar days. We may ask you to confirm your identity so that we do not hand someone else's data over.

The site is intended for adults. We do not knowingly collect data from anyone under 18. If you believe a child has provided us with their data, let us know and we will delete it.

We may update this Policy. A new version takes effect once published on this page; the update date is shown below. If the changes are material, we will announce them on the site.