Personal Data Protection Policy

Volt Energy LLC (hereinafter "the Company" or "we") is a legal entity registered in accordance with the legislation of Georgia, which acts as a data controller (the entity responsible for processing) when processing your data.

Identification code: 405619889

Legal address: Tbilisi, Saburtalo district, Archil Sulakauri Street N 3, apartment 88

Email address: info@emotors.ge

Phone number: 032 2 15 10 10

Our purpose is to inform you of how the Company processes and uses your personal data. Accordingly, through this Privacy Policy we will provide you with information on the following matters:

• The principles by which the Company is guided in the process of processing your personal data;
• What kinds of personal data the Company collects about you when you use the Company's services or purchase a product from it;
• How your data is processed by us and how the security, confidentiality, availability and integrity of your data is ensured;
• How the Company ensures the protection of your rights provided by law.

The Company processes your data in accordance with the Law of Georgia "On Personal Data Protection", for specific, clearly defined purposes and on the grounds defined by the same law. The mentioned purposes and grounds with respect to a specific process can be seen below.

It is not permissible for the Company to process your data for a purpose other than the predetermined one unless it has the appropriate legal basis.

When processing your data, all data-processing principles defined by the Law of Georgia "On Personal Data Protection" are observed.

We protect your data to the maximum extent possible and have implemented appropriate organizational and technical security measures.

The terms used in the Policy have the meaning defined by the Law of Georgia "On Personal Data Protection".

We process, including collecting and storing, the personal data that you provide on the platform when filling in the fields intended for booking a test drive or sending a message. Such data includes:

• First name, last name
• Phone number
• Email address
• Other data provided in the message

If you decide to purchase a vehicle, we process, including collecting and storing, the personal data that you provide for the purpose of receiving our product/service and producing the appropriate legal documentation. Such data includes:

Identifying data

• First name, last name
• Personal ID number
• Address
• Phone number
• Email address

Documentary data

• Vehicle identification data
• Vehicle license plate numbers
• Vehicle registration data
• Information on the price of the purchase item and the method of payment
• Bank account number
• Other information contained in the purchase agreement

In addition to the personal data listed above, the Company may process your other data which is defined by the legislation of Georgia and/or is necessary for the provision of services.

The Company uses Cookie files. A Cookie is a small text file, a so-called "cookie", which a website sends and which is stored in your device's browser when you visit our website. It contains information about the specific visitor, the actions performed on the website, and the website address. Cookies act as a kind of "memory" that remembers your behavior when visiting the website.

We collect details about your visits to our website including, but not limited to, traffic data, location data, visit duration, the number of page views and other communication data.

* This information is confidential and we process it for UX-quality improvement of the website experience and for marketing purposes. The cookies we use do not store personal data that would allow your direct identification. The data collected and stored by cookies is not transferred to third parties, except in cases defined by our Privacy Policy.

You can manage cookies from your own browser. The following links may help you: Firefox (https://shorturl.at/eJ2jP), Chrome (https://shorturl.at/IwzHS), Safari web and iOS (https://support.apple.com/en-us/105082).

If you would like more information about cookies, visit: https://allaboutcookies.org/

Test-drive booking data

First name, last name, phone number, email and other data necessary for booking a test drive — used for booking a test drive on the Company's website, for future product delivery, for improving and developing the Company's services, and for providing services to the customer. Legal basis: providing the product to you as our customer and entering into a transaction with you.

Vehicle-purchase data

First name, last name, personal ID number, address, phone number, email and other information you provide at the stage of purchasing a vehicle — used to process information about the purchase item, including its price and the method of payment. Legal basis: performance of the agreed transaction and provision of service to the customer.

Communication data

Email, mobile phone number — used to establish communication with the customer, develop new ways of cooperation, grow our business and carry out direct marketing. Legal basis: customer consent; our legitimate interests.

Location data

Address — used to manage and deliver products and services and to fulfil contractual obligations. Legal basis: providing service to the customer; protecting the legitimate interests of the responsible party.

Financial data

Information about the price of the purchase item and the method of payment — used to run our business effectively and properly, to protect customer rights and to prevent fraudulent activities. Legal basis: our legitimate interests; provision of service to the customer.

Cookies

Used to fulfil your requests, to identify products and services of interest to you, and to adapt the website and its components to user needs. Legal basis: consent of the data subject.

We may share your data with third parties for the following purposes:

• For the purpose of processing payments;
• For the purpose of fulfilling a requirement provided by law;
• In cases directly provided by the current legislation of Georgia.

Your personal data may also be shared if the structure of the Company changes in the future. For example:

• If the Company decides to sell or transfer its assets, or to perform a merger;
• In the event of any of the above-mentioned processes, we may share your data with the relevant party, provided that such party undertakes in advance the obligation to protect the security and confidentiality of your data.

In any case where your data is shared with a third party, we take all measures to ensure their security, confidentiality, integrity and availability.

We reserve the right, in cases strictly defined by law, to grant access to your personal data to law-enforcement and other types of bodies/organizations and to transfer the data for the purpose of detecting, investigating, preventing crime or for other legal purposes. We also reserve the right to disclose your information for the protection of the rights, property or safety of customers or others.

Data is stored in physical form (test-drive data, employee data); all other data is stored electronically on the Company's computer: data about employees is stored on the Company's HR manager's computer, while test-drive data is stored physically by the office manager.

We store your personal data for the entire period of your service. Also, after termination of the service, for a period of at least 8 years, taking into account the following reasons:

• To respond to questions and complaints;
• To ensure the fulfilment of obligations provided by the warranty;
• To fulfil obligations defined by law.

Your data may be stored for more than 8 years if we are unable to delete it due to relevant legal grounds.

In accordance with the Law of Georgia "On Personal Data Protection", you have the right to:

• Request confirmation as to whether your personal data is being processed, with an indication of the basis, purpose and storage period of the processing;
• Get acquainted with the personal data collected about you;
• Request the correction, updating and/or completion of incorrect, inaccurate and/or incomplete data;
• Receive copies of the personal data collected about you (if any);
• Request the blocking of personal data we hold about you (if any);
• Request the withdrawal of consent given by you;
• Exercise other rights guaranteed by Chapter 3 of the Law of Georgia "On Personal Data Protection".

We act in accordance with the legislation of Georgia, which may become a basis for not satisfying your request and not deleting your personal data. Such obligations may stem from tax legislation, consumer-rights legislation and other relevant legislation.

It is important that the processing of your personal data by the Company is not harmful to you. The Company cares about the security and protection of your data, guided by internationally recognized standards.

In accordance with the Law of Georgia "On Personal Data Protection", the rights of the data subject may be restricted if this is directly provided by the legislation of Georgia, fundamental human rights and freedoms are not violated, the measure is necessary and proportionate in a democratic society, and the exercise of these rights may pose a threat to:

• The interests of state security, information security and cybersecurity and/or defence;
• The interests of public security;
• The prevention of crime, the investigation of crime, criminal prosecution, the administration of justice, the enforcement of imprisonment and deprivation of liberty, the enforcement of non-custodial sentences and probation, operative-investigative activities;
• Important financial or economic interests of the country (including monetary, budgetary and tax issues), as well as those related to public-health and social-protection matters;
• The detection of violations of professional, including regulated-profession, ethics by the data subject and the imposition of liability on them;
• The rights and freedoms of the data subject and/or other persons, including the freedom of expression;
• The protection of state, commercial, professional and other types of secrets provided by law;
• The substantiation of a legal claim or defence.

The measure provided for the restriction of your rights as a data subject may only be used to the extent necessary to achieve the purpose of the restriction. When grounds for restriction of the right exist, the Company's decision is communicated to the data subject in such a way that the purpose of the restriction is not damaged.

We provide all organizational and technical measures necessary to protect your personal data, as required by the Law of Georgia "On Personal Data Protection" and other regulatory legal acts. In particular, we take necessary and sufficient measures to protect your information from unauthorized or accidental access, destruction, modification, blocking, copying, distribution, as well as from other illegal actions of third parties.

We cannot be held responsible for the full or partial loss of your personal data caused by cybercriminals and other criminal actions.

The Company is entitled to make changes to this Policy in accordance with legislative changes and/or changes to our personal-data processing rules. Any changes made to the Privacy Policy will be published on the Company's website immediately and become effective upon publication.

If you have questions regarding this Privacy Policy, please contact us:

Email address: info@emotors.ge

Phone number: 032 2 15 10 10

If you agree to receive notifications by email about services, products, news and other offers, please tick the consent box. For this purpose, the Company will only process your email address.

You can opt out of notifications at any time by writing to info@emotors.ge. We will satisfy your request as soon as possible, but no later than 7 (seven) working days from receipt of the request.