Privacy Policy

This Privacy Policy describes how your personal information is collected, used, and shared when you visit or make a purchase from us. When you click “Accept”, it means that you consent to each provision contained in this document as though it was physically signed. Please note that you do not need to consent to our policy as a condition to receive any of our services

We and our affiliates own and operate this Website, and any and all computer applications or mobile applications in connection with the same (each a “Website” and collectively the “Website”) through our various subsidiaries (collectively, “Services”).

Our Privacy Policy (“Policy”) states what information we collect, how that information is collected, for what purposes we collect information (including specifically the legal basis on which Personal Information we collect from you will be processed), how that information is used, who we share it with and under what circumstances that information would be released. Our Policy will also explain what rights you have in relation to your Personal Information, what steps we take to secure your private information and what steps you should take to safeguard that information. Finally, our Policy will tell you who you can contact regarding questions about our Policy. Should you require assistance or are having any trouble accessing this Policy or our Website, please contact us through our website using the “Contact Us” link. Material changes will be communicated by posting an updated version of the Policy on this Website.

The following are commonly asked questions about our Privacy Policy, as follows:

• What Type of Personal Information Do You Collect? The types of information that we may collect from you are as follows:
  
  • Identifiers. Identifiers, such as your name, address (including, city, state, postal code, and country), email address, telephone phone number, secondary number, account name, IP address, and other information you provide to us.
  • Commercial Information. Commercial information, including records of personal property, product or services purchased, obtained or considered, or other purchasing or consumer history.
  • Financial Information. Financial information, such as your VAT or government-issued Tax ID, or any other financial information you provide to us.
  • Network Activity. Internet or other electronic network activity information, such as your usage statistics, information about your device (including browser and operating system), your browsing history, access times, and referring site.
  • General Information. Audio, electronic, visual, thermal, olfactory or similar information.
  • Background Information. Professional, employment, or education information, such as your job title, company name (including company website URL and number of employees).
  • Profile. Inferences drawn from any of the information we collect to create a profile about you reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
  • Additional Information. We may request additional information from you depending on certain transactions, contractual or regulatory requirements. In such event, we will notify you of what information we need, and how it will be used.
• What is the Source of the Personal Information? We collect information about you and how you interact with us in several ways, including but not limited to the following ways:
  
  • Information You Provide. We collect the information you provide to us directly, such as when you register for an account with us through any of our Websites or submit information to us (such as in connection with a bid or purchase, when you submit an inquiry, etc.).
  • Information Automatically Collected. Information automatically collected or inferred from your interaction with us. We automatically collect technical information about your interactions with us (such as IP address and browsing history).
  • Public Sources. Information from public sources.
  • Information From Third Parties. We receive information about you and your interactions with us from third parties, such as from your employer or co-workers, third party service and content providers, credit reporting agencies, companies that provide or sell lists of potential purchasers, and others interacting with us.
  • Cumulative Information. We may combine information that we receive from the various sources described in this Policy, including third party sources and public sources, and use or disclose it for the purposes identified herein.
  • Applicable Policy. If you provide your Personal Information to us offline, this Policy applies to our collection and use of your information.
• How Do You Use My Personal Information? We may use your information in the following ways:
  
  • General Services. To provide services to you, such as to consummate transactions with you; register and administer your account; to establish and facilitate our business relationship with you; to respond to an inquiry, complaint, or request from you; and to understand your preferences and needs.
  • Business Purposes. For our own internal business purposes, such as to administer and improve our Website; to track and report Website traffic; to analyze our customers’ demographics and interests; to help diagnose potential problems with our server; to enhance or develop features, products, and services; to monitor and analyze information regarding your browsing and viewing preferences; and to otherwise protect or further our legitimate interests.
  • Compliance Purposes. For legal, safety or security reasons, such as to comply with legal requirements; protect our safety, our property or rights of those who interact with us, or others; and detect, prevent, and respond to security incidents or other malicious, deceptive, fraudulent, or illegal activity.
  • Anonymity. In a de-identified, anonymized or aggregated format. When converted to a de-identified, anonymized, or aggregated format, data no longer constitutes Personal Information, and we may use this information for any purpose. We may use and share anonymized or aggregated information with third parties.
  • Marketing. We may use your Personal Information to send you e-mail alerts and newsletters regarding upcoming auctions, sales events and information about our products and services which we anticipate may be of interest to you.
  • Consent and Lawful Purpose. For any other lawful purposes for which you provide consent.
• Who Do You Share My Personal Information With? We do not sell or release your Personal Information to any third party (except as set out in this Policy) without your consent, unless we are required to by law, or in the good-faith belief that such action is necessary to conform to the edicts of the law or comply with an official investigation by a law enforcement organization. With the above said, we may share your Personal Information with the categories of recipients described below:
  
  • Services Affiliates. We may share your Personal Information within the Services group of business entities.
  • Service Providers. We may share your Personal Information with external service providers such as Salesforce, Oracle Eloqua, Amazon Web Services and Microsoft Azure whose services we may utilize from time to time to assist us in our provision of services to you and to assist us in carrying out our business activities. We will only share your information where it is lawful and required for the provision of services to you or where you have consented to this.
  • Third Parties That Provide Services or Communications. We may also provide other Website users, vendors, third party partners, subcontractors, or service providers with information as required in order to provide services you request or to complete a transaction.
  • Business Partners, Other Website Users or Other Third Parties. We may also provide your Personal Information to our business partners for their own purposes, including for third party marketing. If legally required, we will seek your consent before engaging in such sharing.
  • Legal, Security and Safety Purposes. In case of a subpoena, court order or official request, we may share your Personal Information to investigate, prevent or take action regarding suspected illegal activities, fraud or potential threats, or exercise legal rights or defend against claims, when we believe that doing so may protect your safety or the safety of us or others, or as otherwise permitted or required by law.
  • Corporate Reasons and Transactions. As we continue to develop our business, we may sell or purchase assets. If another entity acquires us or merges with us your Personal Information will be disclosed to such entity. Also, where we carry out an asset sale of a particular business division, your Personal Information (if held by such business division) may be considered an asset of ours and as such it is possible it will be sold or transferred to the purchasing third party.
  • Auditing Purposes. We may provide transaction-related information to government or private auditors to inspect or validate our business practices, accounting records, or financial reports. Any release of information for such a purpose will be done under standard confidentiality restrictions.
• Why Do You Process My Data? Data protection laws require a specific lawful basis for processing data, as follows:
  
  • Data Protection Rights. We process your Personal Information when our interests are not overridden by your data protection rights.
  • Inquiries. Where you provide Personal Information to us for the purposes of an inquiry, the basis for processing is that it is required as a legitimate interest of ours as a business to respond to your inquiry.
  • Business Relationship. Where we enter into a business relationship with you, we rely on the legal basis of performance of a contract with you for processing your Personal Information on the basis of that contractual relationship and to complete a transaction with you.
  • Marketing Communications. Where we process your Personal Information for the purposes of sending you marketing communications, we will rely upon the legal basis of legitimate interests and/or consent (if required and obtained) for processing your Personal Information for those purposes. You have the right to withdraw consent at any time. Where consent is the only legal basis for processing, we will cease to process data after consent is withdrawn
  • Feature Enhancement. Where we use your Personal Information to enhance or develop features, products and services we rely on the legal basis of legitimate interest as it is necessary for our legitimate interest to provide a responsive service to our customers to keep them satisfied.
  • Legal and Regulatory Obligations. Where we process your Personal Information to comply with our legal and regulatory obligations we rely on the legal basis that such processing is required in order to fulfil a legal obligation.
  • Notification. Before we alter the reason for using any Personal Information you have provided to us, we will notify you of our intended change in use of that information, ensuring such use complies with applicable data protection law and where necessary obtain your consent prior to using your Personal Information in a new way.
• Do You Send My Information Outside My County? Your Personal Information shall generally be stored and processed in the United States. However, your personal data may be stored and processed in any country where we or our affiliates or approved partners have facilities or operations throughout the world, but rest assured that appropriate security measures and

  legal safeguards are in place whenever any cross-border transfers of Personal Information are conducted.

  • For EU Residents. Where your Personal Information is transferred from within the EEA to a country outside the EEA (including the United States) we ensure that security measures and adequate safeguards are in place for the transfer of Personal Information in compliance with applicable data protection laws on the transfer of Personal Information outside the EEA. To find out more about how we safeguard your Personal Information (including obtaining a copy of such safeguards) in relation to transfers outside the EEA, please contact us via the details provided in the contact us section below.
• How Long Do You Retain My Personal Information? We retain your Personal Information for no longer than is necessary for the purposes for which the information is collected and in line with this Policy. When determining the relevant retention periods, we will take into account factors including the following:
  
  • Our Contractual obligations.
  • Legal obligation(s) under applicable law to retain data for a certain period of time.
  • Statute of limitations under applicable law.
  • [Potential] Disputes.
  • Compliance, regulatory and auditing purposes.
  • Guidelines issued by relevant national data protection regulators.

    Please be advised that we securely anonymize and/or erase your Personal Information once it is no longer required. For further information about how long we will keep your Personal Information, please contact us using the contact details provided in the contact us section below.

• What are my rights?
  
  • California Rights. Under California Civil Code §§ 1798.80-1798.85 and California Business and Professions Code §§ 22575 – 22579, California residents are entitled to the following rights pertaining to protecting their Personal Information. Residents have the right to reasonable security of their Personal Information by us, and to destruction of any Personal Information that is no longer to be retained by the company via shredding, erasing or otherwise modifying the

    Personal Information in the records to make them indecipherable. Residents may expect that a business that discloses Personal Information about a California resident under a contract with a non-affiliated third party shall require by contract that the third party implement and maintain reasonable security procedures and practices appropriate to the nature of the information, to protect the Personal Information from unauthorized access, destruction, use, modification, or disclosure. Residents have a right to timely notification by us if we learn of an unauthorized disclosure or acquisition of your Personal Information. Residents have the right to be informed by our customer relations staff of how they can inquire about our privacy practices or compliance with the above-referenced California laws. Residents have the right to be provided contact information for inquiring about the company’s privacy practices at every location in California where we do business. Residents have a right to a response to any inquiry regarding our privacy practices or compliance with California law within 30 days of receipt of the inquiry by us. We may not request you waive any of your rights under the above-referenced California laws. California residents also have certain rights under the California Consumer Privacy Act (“CCPA”), subject to legal limitations and applicable exceptions, regarding the collection, use, and sharing of your Personal Information. California residents may exercise the following rights by using the “contact us” section of our Website.

  • UK and EEA Rights. You have a number of rights when it comes to your Personal Information. Further information and advice about your rights can be obtained from the data protection regulator in your country of residence. You can exercise any of these rights by writing to us on the email address below in the “contact us” section of our Website.
  • The Right to be Informed. You have the right to be provided with clear, transparent and easily understandable information about how we use your information and your rights, which is the reason we created the Privacy Policy articulated herein.
  • The Right of Access. You have the right to obtain access to your information (if we are processing it), and certain other information (similar to that provided in this Website Privacy Policy). This is so you are aware and can check that we are using your information in accordance with data protection law. You can do this by writing us using the “contact us” section of our Website.
  • Correction Rights. You are entitled to have your information corrected if it is inaccurate or incomplete. You can request that we rectify any errors in personal information that we hold by writing us on the email address below.
  • Erasure Rights. This is also known as ‘the right to be forgotten’ and, in simple terms, enables you to request the deletion or removal of your information where there is no compelling reason for us to keep using it. This is not a general right to erasure; there are exceptions.
  • Rights to Restrict Processing. You have rights to ‘block’ or suppress further use of your information. When processing is restricted, we can still store your information, but may not use it further.
  • The Right to Data Portability. You have rights to obtain and reuse your personal data for your own purposes across different services. For example, if you decide to switch to a new provider, this enables you to move, copy or transfer your information easily between our IT systems and theirs safely and securely, without affecting its usability. This is not a general right however and there are exceptions.
  • The Right to Object to Processing. You have the right to object to certain types of processing, including processing for direct marketing (i.e., receiving telephone calls or emails from us notifying you about other services we provide which we think may be of interest to you or being contacted with varying potential opportunities). You may change your preferences regarding email communications by contacting us using the “contact us” section of our Website.
  • The Right to Lodge a Complaint. You have the right to lodge a complaint about the way we handle or process your personal data with your national data protection regulator.
  • The Right to Withdraw Consent. If you have given your consent to anything we do with your personal data (i.e., we rely on consent as a legal basis for processing your Personal Information), you have the right to withdraw your consent at any time (although if you do so, it does not mean that anything we have done with your personal data with your consent up to that point is unlawful). You can withdraw your consent to the processing of your Personal Information at any time. We usually act on requests and provide information free of charge but may charge a reasonable fee to cover our administrative costs of providing the information for baseless or excessive/repeated requests, or further copies of the same information. Alternatively, we may be entitled to refuse to act on the request. Please consider your request responsibly before submitting it. We will respond as soon as we can. Generally,

    this will be within one month from when we receive your request but, if the request is going to take longer to resolve, we will let you know.

  • Right to Know. You have the right to request information about the categories of Personal Information we have collected about you, the categories of sources from which we collected the Personal Information, the purposes for collecting the Personal Information, the categories of third parties with whom we have shared your Personal Information, and the purpose for which we shared your Personal Information (“Categories Report”). You may also request information about the specific pieces of Personal Information we have collected about you (“Specific Pieces Report”).
  • Right to Delete. You have the right to request that we delete Personal Information that we have collected from you.
  • Anti-Discrimination. We will not discriminate against you, in any manner prohibited by applicable law, for exercising these rights.
  • Verification. In order to exercise your rights, we will need to obtain information to locate you in our records or verify your identity depending on the nature of the request. If you are submitting a request on behalf of a household, we will need to verify each member of the household in the manner set forth above. More information about our verification process is available at our Website.
  • Authorized Agents. You may use an authorized agent to exercise your rights on your behalf. If you are making any of the requests above through an authorized agent, we will request written authorization from you and will seek to verify as described in our Website, or we will accept a legal Power of Attorney under the California Probate Code to the authorized agent. To make a request using an authorized agent, please use the “contact us” section of our Website and upload documentation demonstrating you have authorized the agent to exercise rights on your behalf.
  • Timing. We will make every effort to respond to Requests to Delete and Requests to Know as soon as possible, and usually no later than 90 days after a request is made.
  • CCPA. Pursuant to the CCPA, below is a chart which contains a summary of the personal information we collect from consumers, the sources from which we collect the Personal Information, the business or commercial purpose for which the Personal Information is collected, and the categories of third parties with whom we share consumer Personal Information.
    

    Personal Data	Sources of Personal Data	Business or Commercial Purpose for Collection	With Whom We Share Personal Data
    Identifiers such as name, address, IP address, email address, account name, and telephone number	You, Affiliates, Third Parties, and Service Providers	Auditing, Security, Performing Services, Internal Research, Quality Assurance, Legal, and Marketing	With our Affiliates; with service providers that assist us with providing our products and services, including IT, storage, business operations, and marketing service providers; in the event of a merger, transfer of business assets, or bankruptcy may share your Data with buyers, lawyers, or professional advisors; and to third parties when required to do so by law or otherwise to protect our legal rights, property, and safety
    Commercial information, including records of personal property, product or services purchased, obtained or considered, or other purchasing or consumer history	You or Service Providers	Performing Services, Internal Research, Legal, and Marketing	With our Affiliates; with service providers that assist us with providing our products and services, including IT, storage, business operations, and marketing service providers; in the event of a merger, transfer of business assets, or bankruptcy may share your Data with buyers, lawyers, or professional advisors; and to third parties when required to do so by law or otherwise to protect our legal rights, property, and safety
    Financial information	You	Performing Services	With our Affiliates; with service providers that assist us with providing our products and services, including IT, storage,

    			business operations, and marketing service providers; in the event of a merger, transfer of business assets, or bankruptcy may share your Data with buyers, lawyers, or professional advisors; and to third parties when required to do so by law or otherwise to protect our legal rights, property, and safety
    Internet or other electronic network activity information, including, but not limited to, browsing history, usage statistics, and device information	You or Service Providers	Auditing, Security, Performing Services, Internal Research, Legal, and Marketing	With our Affiliates; with service providers that assist us with providing our products and services, including IT, storage, business operations, and marketing service providers; in the event of a merger, transfer of business assets, or bankruptcy may share your Data with buyers, lawyers, or professional advisors; and to third parties when required to do so by law or otherwise to protect our legal rights, property, and safety
    Audio, electronic, visual, thermal, olfactory or similar information	You or Service Providers	Performing Services, Internal Research, Legal, and Marketing	With our Affiliates; and with service providers that assist us with providing our products and services, including IT, storage, business operations, and marketing service providers
    Professional or employment-related information	You	Auditing, Performing Services, Legal, and Marketing	With service providers that assist us with providing our products and services, including IT, storage, business operations, and marketing service providers

    Inferences drawn from any of the information identified above to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes

    You or Service Providers

    Auditing, Security, Performing Services, Internal Research, and Marketing

    With our Affiliates, with service providers that assist us with providing our products and services, including IT, storage, business operations, and marketing service providers

  • We Do Not Sell Personal Information. We disclosed all of the categories of personal information listed above for a business purpose in the past 12 months.
  • Other Rights. A user may request we discontinue the use of that person’s Personal Information. If you would like to know what information we have collected, would like any information purged, or would like for us to discontinue using Personal Information, please contact us using the “contact us” section of our Website. The return of certain Personal Information by us may prevent you from accessing all or certain portions of our Website, and we will endeavor to communicate to you the extent to which your request will affect your use of our Website prior to complying with your request.
• How Do You Communicate With Me? Upon registration, our site provides users the opportunity to elect to receive the type of communications they prefer. To opt-out of receiving marketing telephone calls and/or email communications from us, please contact us at the details provided in the “contact us” section in our Website, or follow the opt-out/ unsubscribe instructions included in marketing emails. Please be advised that we may utilize third-party providers to assist us with the processing of marketing telephone calls and/or emails to you.
• What Steps Do You Take To Secure My Personal Information? We are committed to keeping your Personal Information safe and secure. We use appropriate technical and organizational measures to protect against the loss, misuse and alteration of Personal Information. Employees having access to Personal Information must undergo data privacy training and are monitored by management to ensure that adequate safeguards are used to protect the private information of our customers. Our Website has security measures in place to protect the loss, misuse, and alteration of the information under our control. Our Website uses SSL (secure sockets layer) encryption for all sensitive data transmitted over the Internet. This includes customers adding data to our Website, and employees transmitting data off our Website. No information, including the passwords that would give access to sensitive information, ever flows over the Internet un-encrypted.
• How Can I Protect My Personal Information? Please be advised that any transmission of data over the internet is never completely secure. It may be possible for third parties not under our control to intercept or access transmissions or private communications unlawfully. Any such transmission of your information is at your own risk. For any transmission of data over the internet, we recommend that you utilize all resources at your disposal to minimize the risk of exposing your personal information, including the use of firewalls, data protection software, antivirus software and similar technologies. Additional precautions that you can take are as follows:
  
  • Email Not Secure. Never send credit card information via email.
  • Protect Your Account. Do not release information about your account to anyone who is not authorized by you to transact business with us on your behalf.
  • Protect Your Password. Do not tell your password to anyone. We will never ask you for your password to verify your identity.
• Do You Use Cookies? Cookies are small text files that are placed onto your device (e.g., computer, smartphone, tablet or other electronic device) when you use a Website (including ours) and contain information such as your username, user preferences, the web pages you have visited and the activities you’ve performed while using our Website. We use cookies to deliver content specific to your interests and customize your experience with our Website, and to store your information so you do not have to re-enter it each time you visit our Website, and for other lawful purposes. For our Website to function as effectively as possible and provide you with the best user experience, it is preferable for you to have cookies enabled. Some of our business partners also use cookies to provide us with anonymous, aggregate data and information regarding our users. We do not have access

  or control over these cookies, and our Policy does not cover the use of third-party cookies. We also use cookies for the following purposes:

  • Functional Cookies. These cookies enable our Website to provide enhanced functionality and personalization. They may be set by us or by third party providers whose services we have added to our pages. If you do not allow these cookies, then some or all of these services may not function properly.
  • Targeting Cookies. These cookies may be set through our site by our advertising partners. They may be used by those companies to build a profile of your interests and show you relevant adverts on other sites. They do not store directly personal information but are based on uniquely identifying your browser and internet device. If you do not allow these cookies, you will experience less targeted advertising.
  • Strictly Necessary Cookies. These cookies are necessary for our Website to function and cannot be switched off in our systems. They are usually utilized in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in or filling in forms. You can set your browser to block or alert you about these cookies, but some parts of our Website will not then work. These cookies do not store any personally identifiable information.
  • Performance Cookies. These cookies allow us to count visits and traffic sources so we can measure and improve the performance of our Website. They help us to know which pages are the most and least popular and see how visitors move around our Website. All information these cookies collect is aggregated and therefore anonymous. If you do not allow these cookies we will not know when you have visited our Website and will not be able to monitor its performance.

    You can manage your Cookie preference settings when accessing each Website.

• Do You Use Web Beacons? We or a third-party analytics provider engaged by us may also use “web beacons” to collect information about your use of our Website, and Websites of selected sponsors and advertisers. Web beacons are tiny graphic image files embedded in a web page or email that provide a presence on the web page or email and send back to its home server information from the user’s browser. The information collected by web beacons allows us to statistically monitor how many people are using our Website, selected sponsors’ and advertisers’ websites and using our services and for what purposes.
• Are Children Allowed On Your Website? Our Website is not directed at, marketed to, not intended for individuals under 18 years of age nor do we knowingly collect information, including Personal Information, from children under age 18 on our Website or offline. If you are under 18, you are not permitted to register for emails or newsletters or to otherwise submit any Personal Information to us. If a child under the age of 18 submits Personal Information to our Website, we delete the information as soon as we discover it was provided by a child under 18 years of age and we do not use it for any purpose.
• How Do I Contact You About My Personal Information? If you believe that your Personal Information has been improperly released by us to a third party, or if you have questions about how we collect, store, use, or destroy your Personal Information, or how to exercise your rights in relation to your Personal Information, you may contact us at the email address, telephone number, or mailing address listed in the “contact us” section of our Website. When contacting us about your Personal Information, please do not include your account password, credit card number, date of birth, driver license number, or social security number in any email to us. If you experience difficulty in correcting Personal Information or have questions regarding our Policy, please contact us using the “contact us” section of our Website. Additionally, if you wish to file a complaint about our collection, use, disclosure, or protection of your Personal Information, or if you have specific questions about our policies or practices regarding collection, retention, use, or disclosure of Personal Information, please contact us using the “contact us” section of our Website. You also have the right to complain to a data protection authority about the collection and use of your personal data. For more information, please contact your local data protection authority.