PRIVACY POLICY
(Last revised December 12, 2024)
1. Introduction. The following Privacy Policy (the “Policy”) describes how Sales Caddy, LLC
(“Operator”) collects, uses and shares personally identifiable information and non-personally
identifiable information (collectively, “Data”) collected through Operator’s website, mobile
website and mobile applications (collectively, the “Site”) and the services, features,
advertisements or content Operator offers at the Site (collectively, the “Services”). The Policy
describes (a) the kinds of Data Operator may gather when you use the Site or access the Services,
(b) how Operator may use your Data, (c) when Operator might disclose your Data, and (d) how
you can manage your Data.
2. Revisions. Operator may change the Policy at any time by posting revisions to the Policy on
the Site. If Operator makes material changes to how it treats your Data, Operator will notify you
through a general notice posted on the Site. If you do not accept all of the terms, conditions and
notices set forth in the Policy, you must not use the Site or access the Services. Please note that
the Site and the Services are under constant development. As such, this Policy may be modified
and updated at any time and on an ongoing basis. Each such modification will be effective on
posting on the Site and the effective date will be noted at the beginning of the revised Policy. The
date the Policy was last revised is identified at the top of the page. Your continued use of the Site
after Operator posts a revised Policy signifies your acceptance of the revised Policy. You should
therefore review the Policy periodically so that you are up to date on Operator’s current policies
and practices.
3. Collection of Information from Children. The Site and the Services are not directed to, or
intended for use by, anyone under the age of 18. If you are under the age of 18, you may only use
the Site and the Services with permission from your parent or legal guardian. Operator does not
knowingly collect personally identifiable information from users under the age of 18. If you are
under the age of 18, (a) do not use or provide any information on the Site, (b) register on the Site
or for any of the Services, (c) make any purchases through the Site or the Services, (d) use any of
the interactive or public comment features of the Site or the Services, or (e) provide any
information about yourself to Operator, including your name, address, telephone number, email
address or any screen name or user name you may use. If a child under 18 submits information
through any part of the Site or the Services, and Operator becomes aware that the person
submitting the information is under 18, Operator will delete the information. If you believe
Operator might have any information from or about a child under 18, please contact Operator at
[hyperlink].
4. Information Collected.
Type of Information Collected. When you use the Site or access the Services, Operator may
collect several types of information about you, your use of the Site or the Services or both. The
general categories of information include personally identifiable information (“PII”), as well as
non-personally identifiable information (“non-PII”).
PII includes the following:
Information you Provide to Operator. Operator collects your personal data or information
when you use the Site or access the Services. There are numerous circumstances where
you may volunteer or be required or invited to provide Operator with personal
information, such as (a) when you create an account, (b) subscribe to a publication,
newsletter or other content, (c) register for or use the Site or the Services, (d) submit
content or post a comment, (e) send Operator an email, or (f) request information. This
information may include:
o Your name, any alias, email address, birth date, gender, street address and one or
more telephone numbers;
o Employment information or other demographic information, including, without
limitation, employment history and educational background;
o Audio, digital, video or other electronic information provided by you, including,
without limitation, audio or video recordings;
o Social security numbers;
o Driver’s license; and
o Bank account number, credit card number, debit card number or any other
financial information provided by you.
Account Information. Operator may assign you a user id, account name, unique personal
or online identifier, other identifiers that permit physical or online contact with you or
any information about you collected online and maintained in personally identifiable
form in combination with any of the preceding categories.
Usage Information. Operator may collect certain usage information associated with you.
This may include:
o Internet or other similar network activity on the Site or the Services, including
browsing history, search history or information regarding your interaction with
the Site or the Services, your advertising preferences and your communications
with or through Operator and the user segment or category into which you as a
user are classified by Operator internally;
o Data about the pages you visit, the access time, frequency and duration of visits,
the links on which you click and other actions you take as part of your use of the
Site or the Services;
o Geolocation data;
o Data that is generated as part of your transactions using the Site or the Services;
and
o Data that is generated through your communications through use of the Site or the
Services, including your communications with Operator, its third-party providers
or other users of the Site or the Services.
Information from Third Parties. Operator may receive information about you from third
parties consistent with relevant law and combine it with information Operator receives
from or about you, including, without limitation, information from social media websites
or information from publicly or commercially available sources. This information could
include:
o When you engage with the Site or the Services and their content through such
third-party sites, plug-ins or applications, Operator may have access to certain
information from your social media profile, such as your name, photograph,
gender, birthday, location, videos, your list of friends and so on;
o When you link your account to any other account on a third-party website,
including, without limitation, a social media website, Operator may have access to
data regarding your use of that website, as well as personal data such third party
websites may have collected about you;
o Commercial information, including records of purchasing habits;
o Engagement with the Site or the Services through third-party social networking
sites or social media plug-ins and applications; and
o Information from other public sources, including, without limitation, data from
credit agencies or bureaus or data from data aggregators.
Non-PII includes information about your use of the Site, the Services or both. Operator may
collect information about your use of the Site, the Services or both, including:
Device Information. Operator may collect your computer or mobile device model, IP
address, operating system version, browser type, language and settings, device type and
settings and other unique device identifiers.
Location Information. Operator may collect your location when using the Site or the
Services. Operator may collect and store your device’s source IP address and latitude and
longitude, which may disclose your device’s approximate or precise location when you
access the Site or the Services. Advertisements and certain content, including from third
parties, may be directed to you based on this data.
Usage Information. Operator may collect information about the Site or the Services you
use, the time, duration and date of your use, your interaction with content offered through
the Site or the Services, how you contacted the Site or the Services, search terms used
and browsing history. Operator also collects information stored using cookies, mobile ad
identifiers and similar technologies set on your device. Operator’s servers may
automatically keep an activity log of your use of the Site, the Services or both.
Inferential Data. Operator may use your personal information or other information it
collects from you or your activity while using the Site or the Services to create consumer
profiles reflecting preferences, characteristics, psychological trends, predispositions,
behavior, attitudes, intelligence, abilities or aptitudes.
Certain features available within the Site or the Services will require you to submit PII about
yourself as a condition of participation. Some of the features may be offered by Operator, while
others may be offered by third parties. When you choose to submit PII to a third party in
connection with your use of the Site or the Services, the third party’s privacy policy, rather than
this Policy, will control the use of your PII.
YOU CAN ALWAYS REFUSE TO PROVIDE PII TO OPERATOR, BUT THIS MAY RESULT
IN DECREASED FUNCTIONALITY OF THE SITE AND THE SERVICES FOR YOU AND
LIMIT YOUR ABILITY TO RECEIVE INFORMATION THAT MAY BE OF PARTICULAR
INTEREST TO YOU.
You also may provide information to be published or displayed (“posted”) on public areas of the
Site or the Services, transmitted to other users of the Site or the Services or to third parties
(collectively, “User Contributions”). Your User Contributions are posted on and transmitted to
others at your own risk. Operator cannot control the actions of other users of Site or the Services
with whom you may choose to share your User Contributions. Operator therefore cannot and
does not guarantee that your User Contributions will not be viewed by unauthorized persons.
5. How Information is Collected. Operator collects information both actively and passively. For
example, Operator will collect information about you that you voluntarily provide while using
the Site or the Services. In addition to information provided directly by you, Operator (and third
parties that offer features through the Site or the Services) may collect non-PII through the use of
“cookies,” “web beacons” or by other electronic means.
If you use the Site or the Services or read or download information from the Site or the Services,
your web or mobile browser may automatically send Operator your internet or other network
activity.
If you use the Site or the Services, Operator will receive and store information you enter on the
Site or the Services or which you give Operator in-person or via telephone, email or otherwise.
Operator may also collect personal information from third parties that operate (a) portions of the
Site or the Services on Operator’s behalf, or (b) independent websites. When Operator obtains
personal data from third parties, it will treat such personal data the same as it does information it
obtains directly.
6. Cookie Policy.
Generally. Operator may place, or allow to be placed, cookies, web beacons and similar
technologies on the Site and the Services to store your username for easy logon, store your
preferences, keep you logged in, perform analytics, analyze traffic or personalize content.
Operator may use these technologies to collect information when you use the Site, the Services
or both, such as your IP address, web browser, mobile network information and browsing and
conversion information, to provide you a customized user experience. These technologies may
include Google Analytics and similar providers. You can learn more about how Google uses the
information collected through this service at: www.google.com/policies/privacy/partners/.
Cookies. In general, a cookie is a small amount of data sent to your browser from a web
server and stored on your computer’s hard drive, where it can be used to identify your
computer. Cookies can be used to measure website usage, improve navigation around a
website and personalize a returning visitor’s experience on the website. In most cases,
you can set your browser to turn off cookies or to notify you before you receive one so
that you can decide whether to accept it or not. If you block or reject cookies, some of the
features on the Site may not work for you. You can refer to the instructions for your
browser to learn more about these functions.
Web Beacons. Operator and its third-party service providers, advertisers and partners may
also use “web beacons” or similar technologies. Web beacons are small strings of code
placed on a web page to collect data about how visitors use the Site, the Services or both.
For example, web beacons may be used to count the number of users who visit the Site or
the Services or to deliver a cookie to the browser of a visitor to the Site or the Services. If
you set your browser to turn off cookies, web beacons and similar technologies will
detect your visits to the Site or the Services, but they will not associate your activity on
the Site or the Services with information that otherwise would be stored in cookies.
Operator may also allow its affiliates and certain third parties to use cookies on the Site, the
Services or both. These affiliates and third parties may use cookies alone or in conjunction with
web beacons or other tracking technologies to collect information about you when you use the
Site website. The information they collect may be associated with your personal information or
they may collect information, including personal information, about your online activities over
time and across different websites and other online services. They may use this information to
provide you with interest-based (behavioral) advertising or other targeted content on the Site, as
well as other websites, apps, platforms and so on that you visit. Some of these affiliates and third
parties may use cookies in ways that Operator does not. You may refuse to accept cookies by
activating the setting on your browser which allows you to refuse the setting of cookies. If you
select this setting, you may be unable to access all or certain parts of the Site or the Services.
Unless you have adjusted your browser setting so that it will refuse cookies, Operator’s system
will issue cookies when you log onto Operator’s website.
Operator does not control tracking technologies used by affiliates or third parties on Operator’s
website or how those technologies may be used.
7. How Information is Used and Shared. Operator may use Data it collects as indicated in the
following list, which is not exhaustive.
To present the Site and its contents to you; To offer the Site and the Services; To monitor and analyze web traffic and online behavior
for search engine optimization and social media marketing; To manage security, including monitoring individuals with access to the Site, the Services
or both, applications, systems or facilities, investigation of threats and, as needed, for any data security breach notification; To provide you with information,
products or services that you request from Operator or from other users of the Site or the Services; To fulfill any other purposes for which you provide
Operator information; To allow you to participate in other interactive features associated with the Site; To notify you about changes to the Site, the Services or both;
To contact you; To respond to your inquiries; To provide notices with respect to your account; To troubleshoot or provide you with technical support;
To create and to manage your account; To place calls or send text messages through automated means that may include
prerecorded messages that include advertising or non-advertising messages; To place calls or send text messages manually that may
include advertising or advertising-related information; To send you communications you have requested, including emails, newsletters and other
electronic communications; To enroll you in programs or other offers you request; To inform you about other products and services that
may be of interest to you; To deliver advertising; To process payment for purchases you have made; To protect against or identify possible fraud;
To manage and mitigate risk; To view and incorporate content hosted on external sites; To resolve a dispute; To conduct a poll or survey;
To analyze the use of the Site, the Services or both; To personalize the content of the Site, the Services or both; To develop new products and services;
To improve the Site, the Services and Operator’s overall business; To understand how you arrived at the Site, the Services or both;
To manage the Site and the Services;To enforce Operator’s Terms of Use and any other user agreements incorporated by
reference; To enforce the terms of this Policy; To enforce Operator’s legal rights; To comply with the law; For other uses Operator may
disclose to you at the point of collection, as authorized by you or as otherwise permitted by law, and
For any other purposes with your consent.
The third parties with whom the following categories of personal information are shared for a
business purpose may include, but are not limited to, those corresponding third parties listed
below:
Categories of Personal Information Third Parties Disclosed to:
Category A: Personal Information and
Identifiers
Service providers, affiliates, partners, parent or subsidiary organizations, internet cookie data recipients, data brokers or aggregators,
social networks, operating systems and platforms, government entities, data analytic providers, internet service providers, advertising networks.
Category B: Protected Class Information Service providers, affiliates, partners, parent or subsidiary organizations, internet cookie data
recipients, data brokers or aggregators, social networks, operating systems and platforms, government entities, data analytic providers,
internet service providers, advertising networks. Category C: Commercial InformationService providers, affiliates, partners, parent or
subsidiary organizations, internet cookie data recipients, data brokers or aggregators, social networks, operating systems and platforms,
government entities, data analytic providers, internet service providers, advertising networks. Category D: Biometric Information
Service providers, affiliates, partners, parent or subsidiary organizations, internet cookie data recipients, data brokers or aggregators, social
networks, operating systems and platforms, government entities, data analytic providers, internet service providers, advertising networks.
Category E: Internet and Network Information Service providers, affiliates, partners, parent or subsidiary organizations, internet cookie data
recipients, data brokers or aggregators, social networks, operating systems and platforms, government entities, data analytic providers,
internet service providers, advertising networks. Category F: Geolocation Information Service providers, affiliates, partners, parent or
subsidiary organizations, internet cookie data recipients, data brokers or aggregators, social networks, operating systems and platforms,
government entities, data analytic providers, internet service providers, advertising networks. Category G: Sensory Information
Service providers, affiliates, partners, parent or subsidiary organizations, internet cookie data recipients, data brokers or aggregators,
social networks, operating systems and platforms, government entities, data analytic providers, internet service providers, advertising networks.
Category H: Employment Information Service providers, affiliates, partners, parent or subsidiary organizations, internet cookie data
recipients, data brokers or aggregators, social networks, operating systems and platforms, government entities, data analytic providers,
internet service providers, advertising networks. Category I: Non-Public Education Information Service providers, affiliates, partners, parent or
subsidiary organizations, internet cookie data recipients, data brokers or aggregators, social networks, operating systems and platforms,
government entities, data analytic providers, internet service providers, advertising networks. Category J: Profile Information
Service providers, affiliates, partners, parent or subsidiary organizations, internet cookie data recipients, data brokers or aggregators, social
networks, operating systems and platforms, government entities, data analytic providers, internet service providers, advertising networks.
8. Disclosure. Operator may disclose Data as follows:
For all reasons set forth in “How Information is Used and Shared” above; Operator may share your telephone number(s) with its authorized
services providers that may use automated or manual dialing means to contact you to carry out any of the activities identified in “How Information is
Used and Shared” above; To service providers or parties that Operator has engaged to perform business-related
functions on its behalf. This may include service providers that conduct research and analytics, create content, provide customer, technical or
operational support, conduct or support marketing, fulfill orders and user requests, maintain databases, send or support
online or mobile advertising and otherwise support the Site, the Services or both; To Operator’s business partners or joint marketing partners;
To Operator’s advertising and marketing partners; To other third parties that support the Site, the Services or both, including, without
limitation, third parties that may provide financing; In response to legal processes such as court orders or subpoenas, law enforcement or
government agency requests or similar requests or otherwise if Operator determines that disclosure is prudent to comply with law, to assist
in the identification, investigation or prosecution of fraud or to comply with requests of law enforcement or data protection
agencies; With affiliates of Operator so they can provide, improve and communicate with you about their own, or their marketing partners’,
products and services; If Operator is considering a sale of its business in its entirety or a component thereof, or
substantially all of its assets are acquired, or a portion thereof, or a merger, divestiture, restructuring, reorganization, dissolution or other sale or
transfer of some or all of Operator’s assets, whether as a going concern or as part of bankruptcy, liquidation or
similar proceeding, Data may be one of the transferred assets and may therefore be used by a third-party acquirer in accordance with this Policy.
Such use by a third party may include review of PII, using such PII to contact you either before or after such a transfer
or sale, use or transfer of non-PII before or after such a transfer or sale or for other purposes;
In addition, Operator may share your information as described below:
Information You Elect to Share. You may choose to share information with third parties
by clicking on links to third parties from within the Site or the Services. In addition, you
may elect to share information, including PII, through the Site or the Services by, for
example, posting comments on comment boards. Some of your activity on the Site, the
Services or both, including content you have posted, is public by default. Some of this
content may include PII.
Information Disclosed to Vendors, Partners, Service Providers and Others for Business
Purposes. Operator contracts with vendors to provide services related to the Site and the
Services and may share information with such vendors in order to provide products or
services to you or to help maintain the Site and the Services. Operator may also share PII
and non-PII with its partners, service providers and other persons with whom it conducts
business.
Information Disclosed for the Protection of the Site and the Services and for Others.
Operator may disclose PII and non-PII when (a) required by law or to respond to legal
process or lawful requests, including from law enforcement, (b) when Operator believes
it is necessary to prevent, investigate or address (i) possible illegal activities, including
fraud, (ii) violation of Operator’s Terms of Use, (iii) violation of this Policy, or (iv)
threats to the physical safety of any person, or (c) to protect Operator’s rights or property.
9. Forums. The Site and the Services may include forums, such as message boards, chat rooms,
comment boards and reviews, that enable users to post a comment or communicate with each
other. Operator is under no obligation to moderate or edit the forums and will not be responsible
for the content or use of any material posted on any forum within the Site or the Services.
Operator retains the right to delete at any time and for any reason any material posted within the
Site or the Services.
10. Information Security. Operator uses reasonable administrative, technical and physical
safeguards to protect PII it collects from unauthorized access, use or disclosure. When Operator
uses third-party service providers, it asks those providers to implement similar safeguards.
Operator cannot guarantee that your information is completely secure either within Operator’s
business or on the systems of third-party service providers.
Operator has no control over the security of other websites that you might visit even when a link
may appear to those websites on the Site or through the Services. If you share your computer or
use a computer that is accessed by the general public, remember to sign off and close your
browser window when you have finished your session. This will help to ensure that others cannot
access your PII.
Although Operator takes reasonable steps to secure your information, it does not promise, and
you should not expect, that your PII, searches or other communications will always remain
secure. Unfortunately, the transmission of information via the internet is not completely secure.
Operator cannot guarantee the security of your personal information transmitted to the Site. Any
transmission of personal information is at your own risk. Operator is not responsible for
circumvention of any privacy settings or security measures contained on the Site.
If a breach of the confidentiality or security of your PII occurs, Operator will notify you if
reasonably possible and as reasonably necessary so that you can take appropriate protective
steps. Operator may notify you under such circumstances using the email address it has on record
for you. You should also take care with how you handle and disclose your PII. Please refer to the
Federal Trade Commission's website at http://www.consumerftc.gov/ for information about how
to protect against identity theft.
Operator retains Data it collects from you when it has an ongoing legitimate business need to do
so, such as to provide you with services you have requested or to comply with applicable legal
requirements. When Operator no longer has an ongoing legitimate business need to process Data
it collects from you, Operator will physically destroy, delete or anonymize it or, if this is not
possible, then Operator will store your personal data and isolate it from any further processing
until deletion is possible.
11. General Contact Information. Questions regarding the Policy or how to exercise your
privacy rights should be directed to: [hyperlink].
12. State Privacy Rights. If you are a California, Colorado, Connecticut, Nevada, Utah or
Virginia resident, your state’s laws may provide you with additional rights regarding Operator’s
use of your personal information. Please see the state-specific sections below. Note that the terms
“we,” “our” and “us” below refer to Operator and “website” or “site” refer to the Site.
Important Information for California Residents: Your California Privacy Rights
California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of the Site and
the Services that are California residents to request certain information regarding Operator’s
disclosure of personal information to third parties for their direct marketing purposes. To make
such a request, please contact Operator at [hyperlink].
These additional disclosures for California residents apply only to individuals who reside in
California. The California Consumer Privacy Act of 2018, as amended and together with all
applicable regulations (“CCPA”) provides additional rights to know, delete and opt out and
requires businesses collecting or disclosing personal information to provide notices and means to
exercise those rights. The words used in this section have the meanings given to them in the
CCPA, which may be broader than their common meaning. For example, the definition of
“personal information” under the CCPA includes your name, but also more general information
such as age.
Notice of Collection
The categories of personal information that Operator may have collected – as described by the
CCPA – in the past 12 months are:
Identifiers: name, alias, postal address, unique personal identifier, online identifier, Internet
Protocol (IP) address, email address, account name. Operator may use this data to provide
customers with an account, enabling them to post listings or messages or subscribe to Operator’s
newsletters. Additionally, Operator uses online identifiers to understand how consumers use its
products and services.
Customer records information: name, address, telephone number, bank account number, credit or
debit card number. Operator collects this information when a user performs a payment
transaction on one of its services.
Commercial information: Operator uses a unique identifier to track consumer behavior on the
Site. Operator then uses that data to personalize content and or advertising products to the
consumer.
Internet or other electronic network activity information: We collect this data specific to our
websites and applications. We do not operate a web browser or search technology, but we track
searches performed on our website. We do this for a few purposes. We allow users to create
saved searches and alerts. Saved searches and alerts enable users to opt-in to a notification
service. When the user creates a saved search, if a new product is posted on our service that
matches their search criteria, we will send them an email or mobile phone alert. We also use their
search behavior to personalize content and advertising.
Geolocation data: When using the Site, a user can search for information using location data such
as a city or zip code. Furthermore, on a mobile device, users can opt-in to the mobile device
geolocation service to show the user listings from a selected mile radius from their current
geolocation.
Inferences: We use consumer behavior to create profiles and make inferences about future
consumer behavior. We collect and use these categories of personal information for the business purposes
and sharing practices described in the Policy above. We do not generally “sell” personal information as the term “sell” is
traditionally understood. However, to the extent “sale” under the CCPA is interpreted to include advertising technology
activities such as those disclosed in the above sections as a “sale,” we provide you the option to
request that we not “sell” your personal information. We do not sell the personal information of
minors known to be under the age of 16 without affirmative authorization.
We sell or disclose the following categories of personal information for commercial purposes:
identifiers, demographic information, commercial information, internet activity, geolocation data
and inferences. We use and partner with different types of entities to assist with our daily
operations and manage our services.
Right to Know and Delete
If you are a California resident, you have the right to delete the personal information we have
collected from you and the right to know certain information about our data practices in the
preceding 12 months (also called a data portability request). In particular, you have the right to
request the following from us:
The categories of personal information we have collected about you; The categories of sources from which the
personal information was collected;The categories of personal information about you we disclosed for a business
purpose or sold; The categories of third parties to whom the personal information was disclosed for a
business purpose or sold; If we sold or disclosed your personal information for a business purpose, two
separate lists disclosing: if sold, personal information categories that each category of recipient
purchased, and if disclosed for a business purpose, the personal information categories
that each category of recipient obtained; The business or commercial purpose for collecting or selling the
personal information;and The specific pieces of personal information we have collected about you.
To exercise any of these rights, please submit a request [hyperlink]. You may also contact us by
calling [insert telephone number]. We will use the information you provide to us solely for the
purpose of verifying your request and locating your data, if any, within our records. Please note,
under California law, such requests can be made a maximum of twice per twelve-month period.
We have a duty as the holder of certain personal information to verify your identity when making
requests to know or delete personal information and to ensure that dissemination of that
information would not cause harm to you if it were distributed to another person. To verify your
identity, we will request and collect additional personal information from you to match it against
our records. We may ask for additional information or documentation if we feel it is necessary to
confirm your identity with the necessary degree of certainty. We may communicate with you
through email, a secure message center, or other reasonably necessary and appropriate means.
We do have the right to deny requests under certain circumstances. In such cases, we will notify
you of the reasons for denial. We will not provide you with specific pieces of personal
information if the disclosure creates a substantial, articulable, and unreasonable risk to the
security of that personal information, your account with us, or the security of our systems or
networks. In no event will we disclose, if we have collected it, your Social Security number,
driver’s license number or other government-issued identification number, financial account
number, any health insurance or medical identification number, an account password, or security
questions and answers.
Right to Opt-Out
To the extent we sell your personal information as the term “sell” is defined under the California
Consumer Privacy Act, you have the right to opt-out of the sale of your personal information by
us to third parties at any time. You may submit a request to opt-out of by clicking [hyperlink].
You may also call [insert telephone number].
Non-discrimination
You have the right not to receive discriminatory treatment by us for exercising any of your rights.
Authorized Agent
You may be entitled, in accordance with applicable law, to submit a request via an authorized
agent acting on your behalf. To do so, we must receive written authorization or a power of
attorney, signed by you, for the agent to act on your behalf. You will still need to verify your
identity directly with us.
California Do Not Track Disclosure
Certain web browsers may allow you to enable a “do not track” option that sends signals to the
websites you visit indicating that you do not want your online activities tracked. This is different
than blocking cookies as browsers with the “do not track” option selected may still accept
cookies. Right now, there is no industry standard for how companies should respond to “do not
track” signals, although one may be adopted in the future. We do not respond to “do not track”
signals at this time. If we do so in the future, we will modify this Policy accordingly. More
information about “do not track” is available at www.allaboutdnt.com.
Important Information for Colorado Residents: Your Colorado Privacy Rights
These additional disclosures for Colorado residents apply only to individuals who reside in
Colorado. The Colorado Privacy Act provides additional rights to confirm and access, correct,
delete, obtain a copy and opt-out and requires businesses collecting or disclosing personal
information to provide notices and means to exercise those rights. The words used in this section
have the meanings given to them in the CPA, which may be broader than their common meaning.
Notice of Collection
The categories of personal information that we may have collected in the past 12 months are:
Identifiers: name, alias, postal address, unique personal identifier, online identifier, Internet
Protocol (IP) address, email address, account name. We may use this data to provide customers
with an account which enables them to post listings or messages, or to subscribe to our
newsletters. Additionally, we use online identifiers to understand how consumers use our
products and services.
Customer records information: name, address, telephone number, bank account number, credit,
or debit card number. We collect this information when a user performs a payment transaction on
one of our services.
Commercial information: We use a unique identifier to track consumer behavior on our products.
We then use that data to personalize content and/or advertising products to the consumer.
Internet or other electronic network activity information: We collect this data specific to our
websites and applications. We do not operate a web browser or search technology, but we may
track searches performed on our website. We do this for a few purposes. We allow users to create
saved searches and alerts. Saved searches and alerts enable users to opt-in to a notification
service. When the user creates a saved search, if a new product is posted on our service that
matches their search criteria, we will send them an email or mobile phone alert. We also use their
search behavior to personalize content and advertising.
Geolocation data: When using our service, a user can search for information using location data
such as a city or zip code. Furthermore, on a mobile device, users can opt-in to the mobile device
geolocation service to show the user listings from a selected mile radius from their current
geolocation.
Inferences: We use consumer behavior to create profiles and make inferences about future
consumer behavior.
We collect and use these categories of personal information for the business purposes and
sharing practices described in the Policy above.
We do not generally “sell” personal information as the term “sell” is traditionally understood.
However, to the extent “sale” under the CPA is interpreted to include advertising technology
activities such as those disclosed in the above sections as a “sale,” we provide you the option to
request that we not “sell” your personal information. We do not sell the personal information of
minors known to be under the age of 16 without affirmative authorization.
We may sell or disclose the following categories of personal information for commercial
purposes: identifiers, demographic information, commercial information, internet activity,
geolocation data and inferences. We use and partner with different types of entities to assist with
our daily operations and manage our services.
What Are My Rights Under the CPA? If you are a Colorado resident and are engaged in a
direct business relationship with Operator as a consumer for the provision of the Site or the
Services, you may have the following rights:
Right to Know and to Access. You may confirm whether or not we are processing your
personal data. You may also request access to your personal data.
Though you may request specific pieces of your personal information that we have collected, we
may not provide the following information in order to protect the security of such information:
social security numbers, driver’s license or other state or government-issued identification
numbers, bank account numbers or other financial information, any health insurance or medical
identification numbers or related information, account passwords or security questions and
answers.
Right to Correct. You may request the correction of any inaccuracies in your personal
data, taking into account the nature of the personal data and the purposes of the
processing of the personal data.
Right to Delete. Under certain, limited circumstances, you may request that we delete
personal information that we have collected from you or from a third party. Once we
receive your request and confirm your identity, we will review your request to see if an
exception allowing us to retain the information applies.
Right to Obtain a Copy. You may request a copy of your personal data, which you
previously provided to us, in a portable and readily usable format to the extent that it is
technically feasible to do so.
Right to Opt Out. You may opt out of the processing of your personal data for the
purposes of (a) targeted advertising, (b) the sale of personal data, or (c) profiling that may
have a legal or other significant impact.
To exercise any of these rights, please submit a request [hyperlink].We will use the information
you provide to us solely for the purpose of verifying your request and locating your data, if any,
within our records.
Non-discrimination
You have the right not to receive discriminatory treatment by us for exercising any of your rights.
Authorized Agent
You may be entitled, in accordance with applicable law, to submit a request via an authorized
agent acting on your behalf. To do so, we must receive written authorization or a power of
attorney, signed by you, for the agent to act on your behalf. You will still need to verify your
identity directly with us.
Important Information for Connecticut Residents: Your Connecticut Privacy Rights
These additional disclosures for Connecticut residents apply only to individuals who reside in
Connecticut. The Connecticut Data Privacy Act provides additional rights to confirm and access,
correct, delete, obtain a copy and opt-out and requires businesses collecting or disclosing
personal information to provide notices and means to exercise those rights. The words used in
this section have the meanings given to them in the CTDPA, which may be broader than their
common meaning.
Notice of Collection
The categories of personal information that we may have collected in the past 12 months are:
Identifiers: name, alias, postal address, unique personal identifier, online identifier, Internet
Protocol (IP) address, email address, account name. We may use this data to provide customers
with an account which enables them to post listings or messages, or to subscribe to our
newsletters. Additionally, we use online identifiers to understand how consumers use our
products and services.
Customer records information: name, address, telephone number, bank account number, credit,
or debit card number. We collect this information when a user performs a payment transaction on
one of our services.
Commercial information: We use a unique identifier to track consumer behavior on our products.
We then use that data to personalize content and/or advertising products to the consumer.
Internet or other electronic network activity information: We collect this data specific to our
websites and applications. We do not operate a web browser or search technology, but we may
track searches performed on our website. We do this for a few purposes. We allow users to create
saved searches and alerts. Saved searches and alerts enable users to opt-in to a notification
service. When the user creates a saved search, if a new product is posted on our service that
matches their search criteria, we will send them an email or mobile phone alert. We also use their
search behavior to personalize content and advertising.
Geolocation data: When using our service, a user can search for information using location data
such as a city or zip code. Furthermore, on a mobile device, users can opt-in to the mobile device
geolocation service to show the user listings from a selected mile radius from their current
geolocation.
Inferences: We use consumer behavior to create profiles and make inferences about future
consumer behavior.
We collect and use these categories of personal information for the business purposes and
sharing practices described in the Policy above.
We do not generally “sell” personal information as the term “sell” is traditionally understood.
However, to the extent “sale” under the CTDPA is interpreted to include advertising technology
activities such as those disclosed in the above sections as a “sale,” we provide you the option to
request that we not “sell” your personal information. We do not sell the personal information of
minors known to be under the age of 16 without affirmative authorization.
We may sell or disclose the following categories of personal information for commercial
purposes: identifiers, demographic information, commercial information, internet activity,
geolocation data and inferences. We use and partner with different types of entities to assist with
our daily operations and manage our services.
What Are My Rights Under the CTDPA? If you are a Connecticut resident and are engaged in
a direct business relationship with Operator as a consumer for the provision of the Sites or
Services, you may have the following rights:
Right to Confirm and to Access. You may confirm whether or not we are processing your
personal data. You may also request access to your personal data.
Though you may request specific pieces of your personal information that we have collected, we
may not provide the following information in order to protect the security of such information:
social security numbers, driver’s license or other state or government-issued identification
numbers, bank account numbers or other financial information, any health insurance or medical
identification numbers or related information, account passwords or security questions and
answers.
Right to Correct. You may request the correction of any inaccuracies in your personal
data, taking into account the nature of the personal data and the purposes of the
processing of the personal data.
Right to Delete. Under certain, limited circumstances, you may request that we delete
personal information that we have collected from you or from a third party. Once we
receive your request and confirm your identity, we will review your request to see if an
exception allowing us to retain the information applies.
Right to Obtain a Copy. You may request a copy of your personal data, which you
previously provided to us, in a portable and readily usable format to the extent that it is
technically feasible to do so.
Right to Opt Out. You may opt out of the processing of your personal data for the
purposes of (a) targeted advertising, (b) the sale of personal data, or (c) profiling that may
have a legal or other significant impact.
To exercise any of these rights, please submit a request [hyperlink].We will use the information
you provide to us solely for the purpose of verifying your request and locating your data, if any,
within our records.
Non-discrimination
You have the right not to receive discriminatory treatment by us for exercising any of your rights.
Authorized Agent
You may be entitled, in accordance with applicable law, to submit a request via an authorized
agent acting on your behalf. To do so, we must receive written authorization or a power of
attorney, signed by you, for the agent to act on your behalf. You will still need to verify your
identity directly with us.
Important Information for Nevada Residents: Your Nevada Privacy Rights
If you are a resident of Nevada, you have the right to opt-out of the sale of certain personal data
to third parties who intend to license or sell that personal data. You can exercise this right by
contacting us [email protected].
Important Information for Utah Residents: Your Utah Privacy Rights
These additional disclosures for Utah residents apply only to individuals who reside in Utah. The
Utah Consumer Privacy Act provides additional rights to confirm, access, delete, obtain a copy,
and opt-out, and requires businesses collecting or disclosing personal information to provide
notices and means to exercise those rights. The words used in this section have the meanings
given to them in the UCPA, which may be broader than their common meaning.
Notice of Collection
The categories of personal information that we may have collected in the past 12 months are:
Identifiers: name, alias, postal address, unique personal identifier, online identifier, Internet
Protocol (IP) address, email address, account name. We may use this data to provide customers
with an account which enables them to post listings or messages, or to subscribe to our
newsletters. Additionally, we use online identifiers to understand how consumers use our
products and services.
Customer records information: name, address, telephone number, bank account number, credit,
or debit card number. We collect this information when a user performs a payment transaction on
one of our services.
Commercial information: We use a unique identifier to track consumer behavior on our products.
We then use that data to personalize content and/or advertising products to the consumer.
Internet or other electronic network activity information: We collect this data specific to our
websites and applications. We do not operate a web browser or search technology, but we may
track searches performed on our website. We do this for a few purposes. We allow users to create
saved searches and alerts. Saved searches and alerts enable users to opt-in to a notification
service. When the user creates a saved search, if a new product is posted on our service that
matches their search criteria, we will send them an email or mobile phone alert. We also use their
search behavior to personalize content and advertising.
Geolocation data: When using our service, a user can search for information using location data
such as a city or zip code. Furthermore, on a mobile device, users can opt-in to the mobile device
geolocation service to show the user listings from a selected mile radius from their current
geolocation.
Inferences: We use consumer behavior to create profiles and make inferences about future
consumer behavior.
We collect and use these categories of personal information for the business purposes and
sharing practices described in the Policy above.
We do not generally “sell” personal information as the term “sell” is traditionally understood.
However, to the extent “sale” under the UCPA is interpreted to include advertising technology
activities such as those disclosed in the above sections as a “sale,” we provide you the option to
request that we not “sell” your personal information. We do not sell the personal information of
minors known to be under the age of 13 without affirmative authorization.
We may sell or disclose the following categories of personal information for commercial
purposes: identifiers, demographic information, commercial information, internet activity,
geolocation data and inferences. We use and partner with different types of entities to assist with
our daily operations and manage our services.
What Are My Rights Under the UCPA? If you are a Utah resident and are engaged in a direct
business relationship with Operator as a consumer for the provision of the Site or the Services,
you may have the following rights:
Right to Confirm and to Access. You may confirm whether or not we are processing your
personal data. You may also request access to your personal data.
Though you may request specific pieces of your personal information that we have collected, we
may not provide the following information in order to protect the security of such information:
social security numbers, driver’s license or other state or government-issued identification
numbers, bank account numbers or other financial information, any health insurance or medical
identification numbers or related information, account passwords or security questions and
answers.
Right to Delete. Under certain circumstances, you may request that we delete personal
information that we have collected from you or from a third party. Once we receive your
request and confirm your identity, we will review your request to see if an exception
allowing us to retain the information applies.
Right to Obtain a Copy. You may request a copy of your personal data, which you
previously provided to us, in a portable and readily usable format to the extent that it is
technically feasible to do so.
Right to Opt Out. You may opt out of the processing of your personal data for the
purposes of (a) targeted advertising, or (b) the sale of personal data.
To exercise any of these rights, please submit a request [hyperlink].We will use the information
you provide to us solely for the purpose of verifying your request and locating your data, if any,
within our records.
Non-discrimination
You have the right not to receive discriminatory treatment by us for exercising any of your rights.
Authorized Agent
Y
ou may be entitled, in accordance with applicable law, to submit a request via an authorized
agent acting on your behalf. To do so, we must receive written authorization or a power of
attorney, signed by you, for the agent to act on your behalf. You will still need to verify your
identity directly with us.
Important Information for Virginia Residents: Your Virginia Privacy Rights
These additional disclosures for Virginia residents apply only to individuals who reside in
Virginia. The Virginia Consumer Data Protection Act provides additional rights to confirm and
access, correct, delete, obtain a copy, and opt out, and requires businesses collecting or
disclosing personal information to provide notices and means to exercise those rights. The words
used in this section have the meanings given to them in the CDPA, which may be broader than
their common meaning.
Notice of Collection
The categories of personal information that we may have collected in the past 12 months are:
Identifiers: name, alias, postal address, unique personal identifier, online identifier, Internet
Protocol (IP) address, email address, account name. We may use this data to provide customers
with an account which enables them to post listings or messages, or to subscribe to our
newsletters. Additionally, we use online identifiers to understand how consumers use our
products and services.
Customer records information: name, address, telephone number, bank account number, credit,
or debit card number. We collect this information when a user performs a payment transaction on
one of our services.
Commercial information: We use a unique identifier to track consumer behavior on our products.
We then use that data to personalize content and/or advertising products to the consumer.
Internet or other electronic network activity information: We collect this data specific to our
websites and applications. We do not operate a web browser or search technology, but we may
track searches performed on our website. We do this for a few purposes. We allow users to create
saved searches and alerts. Saved searches and alerts enable users to opt-in to a notification
service. When the user creates a saved search, if a new product is posted on our service that
matches their search criteria, we will send them an email or mobile phone alert. We also use their
search behavior to personalize content and advertising.
Geolocation data: When using our service, a user can search for information using location data
such as a city or zip code. Furthermore, on a mobile device, users can opt-in to the mobile device
geolocation service to show the user listings from a selected mile radius from their current
geolocation.
Inferences: We use consumer behavior to create profiles and make inferences about future
consumer behavior.
We collect and use these categories of personal information for the business purposes and
sharing practices described in the Policy above.
We do not generally “sell” personal information as the term “sell” is traditionally understood.
However, to the extent “sale” under the CDPA is interpreted to include advertising technology
activities such as those disclosed in the above sections as a “sale,” we provide you the option to
request that we not “sell” your personal information. We do not sell the personal information of
minors known to be under the age of 16 without affirmative authorization.
We may sell or disclose the following categories of personal information for commercial
purposes: identifiers, demographic information, commercial information, internet activity,
geolocation data and inferences. We use and partner with different types of entities to assist with
our daily operations and manage our services.
What Are My Virginia Personal Data Rights? If you are a Virginia resident and are engaged
in a direct business relationship with Operator as a consumer for provision of the Sites or
Services, you may have the following rights:
Right to Confirm and to Access. You may confirm whether or not we are processing your
personal data. You may also request access to your personal data.
Though you may request specific pieces of your personal information that we have collected, we
may not provide the following information in order to protect the security of such information:
social security numbers, driver’s license or other state or government issued identification
numbers, bank account numbers or other financial information, any health insurance or medical
identification numbers or related information, account passwords or security questions and
answers.
Right to Correct. You may request the correction of any inaccuracies in your personal
data, taking into account the nature of the personal data and the purposes of the
processing of the personal data.
Right to Delete. Under certain, limited circumstances, you may request that we delete
personal information that we have collected from you or maintain about you. Once we
receive your request and confirm your identity, we will review your request to see if an
exception allowing us to retain the information applies.
Right to Obtain a Copy. You may request a copy of your personal data, which you
previously provided to us, in a portable and readily usable format to the extent that it is
technically feasible to do so.
Right to Opt Out. You may opt out of the processing of your personal data for the
purposes of (a) targeted advertising, (b) the sale of personal data, or (c) profiling in
furtherance of decisions that produce legal or similarly significant effects.
To exercise any of these rights, please submit a request [hyperlink].We will use the information
you provide to us solely for the purpose of verifying your request and locating your data, if any,
within our records.
Non-discrimination
You have the right not to receive discriminatory treatment by us for exercising any of your rights.
Authorized Agent
You may be entitled, in accordance with applicable law, to submit a request via an authorized
agent acting on your behalf. To do so, we must receive written authorization or a power of
attorney, signed by you, for the agent to act on your behalf. You will still need to verify your
identity directly with us.
13. Users Outside the United States. The Site is hosted in the United States and is governed by
United States law. If you are using the Site from outside the United States, please be aware that
any PII you share with us will be stored and processed in the United States where we locate and
operate our servers and databases. By using the Site, you consent to the storage and processing of
your PII at our facilities and the facilities of those third parties with whom we share your PII asdescribed in this Policy.