Privacy Policy

Effective date: 13/8/2026

This Privacy Policy explains how Elframon Trading SRO, a company established and operating under the laws of the Slovak Republic, processes personal data in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council (“GDPR”), Act No. 18/2018 Coll. on Personal Data Protection, as amended, and other applicable Slovak legislation.

Where applicable, electronic communications and cookies are also governed by Act No. 452/2021 Coll. on Electronic Communications, as amended.

This Privacy Policy applies to customers, potential customers, suppliers, business partners, website visitors and other individuals whose personal data we process in connection with our business activities, including the purchase and sale of used trucks and commercial vehicles.

1. DATA CONTROLLER

The controller of your personal data is:

Elframon Trading SRO
Cínová ulica 1915/7b
900 41 Rovinka
Slovak Republic

Company registration number (IČO): 50915428
Tax identification number (DIČ): 2120525737
VAT identification number (IČ DPH): SK2120525737

Represented by: Frank Johannes Antonius Wilhelmus van Kronenburg

Email: info@elframontrading.com
Telephone: 00421948952481
Website: www.elframontrading.com

Hereinafter referred to as “we”, “us”, “our” or the “Company”.

We are responsible for determining the purposes and means of processing your personal data.

Unless required by applicable law, the Company is not obliged to appoint a Data Protection Officer (DPO).

For any questions concerning the processing of your personal data, you may contact us using the contact details above.

2. APPLICABLE DATA PROTECTION LEGISLATION

The processing of personal data by the Company is primarily governed by:

• Regulation (EU) 2016/679 (General Data Protection Regulation – GDPR);
• Act No. 18/2018 Coll. on Personal Data Protection, as amended;
• Act No. 452/2021 Coll. on Electronic Communications, as amended, where applicable;
• other applicable Slovak and European legislation concerning the processing and retention of personal data.

We process personal data in accordance with the principles of lawfulness, fairness, transparency, purpose limitation, data minimization, accuracy, storage limitation, integrity and confidentiality.

3. PERSONAL DATA WE PROCESS

Depending on the nature of our relationship with you, we may process the following categories of personal data.

3.1 Identification data

This may include:

• first name and surname;
• title;
• date of birth, where legally or contractually necessary;
• identification document details where required for identification;
• signature;
• company name;
• position or job title;
• business registration information.

3.2 Contact data

This may include:

• residential or business address;
• telephone number;
• email address;
• other contact information provided by you.

3.3 Vehicle and transaction data

In connection with the purchase, sale, brokerage or transportation of a truck or other commercial vehicle, we may process:

• vehicle make and model;
• vehicle identification number (VIN);
• registration number;
• chassis number;
• mileage;
• vehicle documentation;
• ownership information;
• purchase and sale information;
• contractual information;
• delivery and collection information;
• correspondence relating to the vehicle;
• information concerning inspections, repairs or vehicle history where relevant to the transaction.

3.4 Financial and accounting data

Where necessary, we may process:

• bank account details;
• payment information;
• invoice details;
• payment status;
• tax information;
• VAT information;
• information required for accounting and tax purposes.

We generally obtain personal data directly from you.

In certain cases, we may obtain information from your company, business partners, vehicle registration authorities, public registers, transport companies, insurers, financing companies or other parties involved in a transaction, where this is lawful and necessary.

4. PURPOSES AND LEGAL BASES FOR PROCESSING

We process personal data only where there is a lawful basis for doing so.

4.1 Responding to enquiries

If you contact us by telephone, email, contact form, social media or another communication channel, we may process your name, contact information and the contents of your enquiry.

We use this information to:

• respond to your enquiry;
• provide information about available vehicles;
• provide vehicle specifications;
• prepare quotations;
• arrange vehicle viewings;
• arrange appointments;
• discuss potential purchases or sales;
• communicate with you regarding a potential transaction.

The legal basis may be:

• Article 6(1)(b) GDPR, where processing is necessary to take steps at your request prior to entering into a contract; or
• Article 6(1)(f) GDPR, where processing is necessary for our legitimate interest in responding to business enquiries.

4.2 Purchase and sale of vehicles

If you purchase or sell a truck or another commercial vehicle through us, we process the personal data necessary to perform the transaction.

This may include preparing contracts, invoices, vehicle documentation, arranging payment, collection or delivery and communicating with parties involved in the transaction.

The primary legal basis is Article 6(1)(b) GDPR, where processing is necessary for the performance of a contract.

4.3 Compliance with legal obligations

We may process personal data where necessary to comply with obligations imposed by Slovak or European legislation.

This may include obligations relating to:

• accounting;
• taxation;
• invoicing;
• vehicle registration;
• customs;
• commercial documentation;
• financial records;
• responses to requests from public authorities;
• prevention and detection of fraud;
• other statutory obligations.

The legal basis is Article 6(1)(c) GDPR.

4.4 Legitimate interests

We may process personal data where necessary for our legitimate interests, provided that these interests do not override your fundamental rights and freedoms.

Our legitimate interests may include:

• protecting our property and business;
• preventing fraud and abuse;
• enforcing contracts;
• recovering unpaid invoices;
• defending legal claims;
• maintaining business records;
• protecting our IT systems;
• ensuring website and network security;
• managing customer and supplier relationships;
• improving our services.

The legal basis is Article 6(1)(f) GDPR.

4.5 Marketing

Where legally permitted, we may use your contact details to inform you about our vehicles, services, offers or other business activities.

Where consent is required by applicable legislation, we will obtain your consent before sending electronic marketing communications.

You may withdraw your consent or object to direct marketing at any time.

5. RECIPIENTS OF PERSONAL DATA

We may provide personal data to third parties where this is necessary for the purposes described in this Privacy Policy or where required by law.

Depending on the circumstances, recipients may include:

• accountants and accounting companies;
• tax advisors;
• lawyers and legal advisors;
• banks and payment service providers;
• insurance companies;
• transport and logistics companies;
• vehicle registration authorities;
• customs authorities;
• financing or leasing companies;
• vehicle inspection providers;
• IT and software providers;
• web-hosting providers;
• email service providers;
• external administrative service providers;
• public authorities and government institutions;
• other contractual partners involved in completing a vehicle transaction.

Where a third party processes personal data on our behalf, we will enter into an appropriate data processing agreement where required under Article 28 GDPR.

We do not sell personal data to third parties.

6. INTERNATIONAL TRANSFERS OF PERSONAL DATA

We primarily process personal data within the European Union and the European Economic Area (EU/EEA).

If personal data is transferred to a country outside the EU/EEA, we will ensure that such transfer complies with the GDPR.

Where required, we will rely on an applicable adequacy decision, Standard Contractual Clauses or another lawful transfer mechanism.

7. RETENTION OF PERSONAL DATA

We retain personal data only for as long as necessary for the purposes for which it was collected or for as long as required by applicable law.

The retention period depends on the type of information and the purpose for which it is processed.

For example:

Enquiries: Information relating to enquiries may be retained for as long as necessary to handle the enquiry and for a reasonable period thereafter.

Contracts and transactions: Information relating to vehicle purchases, sales and contractual relationships will be retained for the period required by applicable commercial, accounting and tax legislation.

Accounting documents: Accounting and tax records will be retained for the period required under applicable Slovak legislation.

Legal claims: Where necessary, personal data may be retained for as long as required to establish, exercise or defend legal claims.

Once the applicable retention period has expired, personal data will be securely deleted, destroyed or anonymized unless another legal basis requires or permits continued retention.

8. RIGHTS OF DATA SUBJECTS

Under the GDPR and applicable Slovak legislation, you have several rights concerning your personal data.

Right of access

You have the right to request confirmation as to whether we process personal data concerning you and, where applicable, to obtain access to that data and information about its processing.

Right to rectification

You have the right to request correction of inaccurate personal data and completion of incomplete personal data.

Right to erasure

Under certain circumstances, you have the right to request deletion of your personal data.

This right is not absolute. For example, we may be required by law to retain certain information or may need the data to establish, exercise or defend legal claims.

Right to restriction of processing

Under certain circumstances, you may request that we restrict the processing of your personal data.

Right to data portability

Where applicable, you have the right to receive personal data that you have provided to us in a structured, commonly used and machine-readable format and to transmit that data to another controller.

Right to object

Where we process personal data on the basis of our legitimate interests, you have the right to object to such processing on grounds relating to your particular situation.

You have an unconditional right to object to processing of your personal data for direct marketing purposes.

Right to withdraw consent

Where processing is based on your consent, you may withdraw your consent at any time.

Withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal.

To exercise any of these rights, please contact us using the contact details provided in Section 1.

We may request additional information necessary to verify your identity before processing your request.

9. COMPLAINTS TO THE SUPERVISORY AUTHORITY

If you believe that we are processing your personal data unlawfully, we encourage you to contact us first so that we can investigate the matter and, where appropriate, remedy the situation.

You also have the right to lodge a complaint with the competent supervisory authority.

In Slovakia, the competent supervisory authority is:

Office for Personal Data Protection of the Slovak Republic
Hraničná 12
820 07 Bratislava 27
Slovak Republic

Website: https://dataprotection.gov.sk

You may also contact the supervisory authority in the EU/EEA country where you normally reside, work or where the alleged infringement occurred, where applicable.

10. COOKIES

Our website may use cookies and similar technologies.

Cookies are small text files stored on your device when you visit a website.

We may use cookies for:

• essential website functionality;
• website security;
• remembering preferences;
• technical functionality;
• website performance;
• analytics;
• embedded third-party services;
• marketing, where applicable.

Essential cookies

Essential cookies are necessary for the basic operation and security of the website.

Where legally permitted, these cookies may be used without obtaining consent because they are necessary to provide the service requested by the user.

Non-essential cookies

Non-essential cookies, such as certain analytics, advertising or tracking cookies, will only be used where the required legal basis has been obtained.

Where consent is required, you may accept or reject such cookies through our cookie-management mechanism.

You may also control cookies through your browser settings.

11. GOOGLE MAPS AND THIRD-PARTY SERVICES

Our website may contain third-party services such as Google Maps, embedded videos, social media content or other external services.

When such content is loaded or used, the relevant third-party provider may process certain technical information, including your IP address, browser information and information concerning your interaction with the service.

Where required by applicable law, we will obtain your consent before loading non-essential third-party content.

Third-party providers process personal data according to their own privacy policies and terms.

12. WEBSITE CONTACT FORMS

If our website contains a contact form, we may request information such as:

• name;
• company name;
• email address;
• telephone number;
• message or enquiry;
• information concerning a vehicle you are interested in.

This information is used solely for handling your enquiry, communicating with you and, where applicable, preparing a quotation or arranging a vehicle transaction.

We do not use information submitted through a contact form for unrelated purposes.

If marketing consent is required, it will be requested separately.

13. SOCIAL MEDIA

We may maintain business profiles on social media platforms.

If you interact with our social media profiles, the relevant social media provider may process your personal data according to its own privacy policy.

We may receive information that you voluntarily provide to us through such platforms.

We recommend reviewing the privacy policies of the relevant social media providers for further information.

14. AUTOMATED DECISION-MAKING AND PROFILING

We do not use automated individual decision-making that produces legal effects or similarly significant effects on individuals.

We do not use profiling for such purposes.

15. DATA SECURITY

We implement appropriate technical and organizational measures to protect personal data against:

• unauthorized access;
• unauthorized disclosure;
• accidental loss;
• destruction;
• alteration;
• unlawful processing;
• other security risks.

Access to personal data is limited to persons who require access for legitimate business or legal purposes.

However, no method of transmission or electronic storage can be guaranteed to be completely secure.

16. DATA PROVIDED BY THIRD PARTIES

In certain circumstances, we may receive personal data from third parties, such as:

• business customers;
• vehicle owners;
• suppliers;
• transport companies;
• financing or leasing companies;
• insurance companies;
• vehicle registration authorities;
• public registers;
• other parties involved in a vehicle transaction.

We process such information only where there is an appropriate legal basis.

Where required by law, we will provide the relevant data subject with information regarding the processing of their personal data.

17. CHILDREN

Our services are primarily intended for businesses and adults.

We do not intentionally collect personal data from children unless this is necessary for a specific lawful purpose.

If you believe that a child has provided us with personal data without appropriate authorization, please contact us.

18. CHANGES TO THIS PRIVACY POLICY

We reserve the right to update this Privacy Policy from time to time to reflect:

• changes in our business activities;
• changes to our website;
• changes in the services we provide;
• changes in applicable legislation;
• changes in data protection requirements.

The latest version will always be published on our website.

The effective date will be stated at the beginning of this document.

Where required by law, we will notify you of significant changes in an appropriate manner.

19. CONTACT INFORMATION

If you have any questions regarding this Privacy Policy or the processing of your personal data, please contact us:

Elframon Trading SRO
Cínová ulica 1915/7b
900 41 Rovinka
Slovak Republic

IČO: 50915428
DIČ: 2120525737
IČ DPH: SK2120525737

Email: info@elframontrading.com
Telephone: 00421948952481
Website: www.elframontrading.com

This Privacy Policy is effective from 13/8/2026