Handbid Privacy Policy

1. Scope

Handbid Inc., on behalf of its affiliates and subsidiaries (collectively, “Handbid,” “us,” “we,” or “our”) has prepared this Privacy Policy (“Privacy Policy”) to describe to you, or if you represent an entity or other organization, that entity or organization (in either case, “you” or “your”) our practices regarding the personal information (i.e., any information relating to an individual) that Handbid collects, uses, and shares on behalf of end users (each a “User”) of: our proprietary online event, auction, and fundraising platform which enables Users to host online and in-person events and to find events, bid in auctions, or donate to charities (the “Platform”); our website available at https://www.handbid.com/, the https://events.handbid.com website (the “Handbid Events”), and any other website we own or operate and which posts or links to this Privacy Policy (each, the “Site”); the Handbid mobile apps for iPhone, iPad, or Android and any other mobile application that we own or operate and which posts or links to this Privacy Policy (each, the “Handbid Apps”, and the Site and Handbid Apps are treated as part of the “Platform” for purposes of this Privacy Policy); the information, data, reports, and other materials and content (“Content”) available through or otherwise provided by the Platform; and any features or functionality available through the Platform offered via the Site or Handbid Apps (collectively, the “Services”). Capitalized terms not defined in this Privacy Policy, shall have the respective meanings ascribed to them in the Handbid Terms of Service, located at https://www.handbid.com/terms-of-service/ (“Terms of Service”).

Handbid reserves the right, at any time, to modify this Privacy Policy. If we make revisions that change the way we collect, use, or share personal information, we will post those changes in this Privacy Policy. You should review this Privacy Policy periodically so that you keep up to date on our most current policies and practices. We will note the effective date of the latest version of our Privacy Policy at the end of this Privacy Policy. Your continued use of the Platform following posting of changes constitutes your acceptance of such changes.

2. Collection of Personal Information

If you register for our Platform, we will collect your first and last name, email address, mobile phone number, your mailing address, and valid credit card information. We use this information to
provide you our Services and Content.

• Information you provide to us. Personal information you may provide to us on through the Platform or otherwise includes:

• Account activity and usage information, such as information based on your activities on the Platform (e.g., bidding, donating, buying, selling, adding information, public and private chats, or any items or content you upload to, transmit through, or generate from the Services, or that otherwise relates to your account activity) and the use of your mobile device or computer to access and use the Services (e.g., bids, what auctions you are associated with, and purchase information);
• Account and event registration information, such as your first name, last name, email address, phone number, shipping/mailing address, and password that you set to establish an online account with us;
• Authentication information, such as information we may ask you to submit to authenticate yourself or if we believe you are violating our policies (e.g.,, we may ask you to send us an ID or bill to verify your address, or to answer additional questions online to help verify your identity or ownership of an item you have purchased, an auction in which you have participated, a donation you have made, or a bid that you have placed);
• Communications that we exchange, including when you contact us with questions, feedback, or otherwise, and any information that you provide to us through online support chats, community discussions, email tickets for issue resolution, blog comments, or any other correspondence through the Platform or otherwise sent to us;
• Content that you upload to the Platform, such as any text, images, audio, and video, along with any associated metadata that you upload or link to any of your fundraising pages for an organization hosting a fundraiser with us, or to your account;
• Demo request information, such as your first name, last name, email address, phone number, organization name, state/region, how you heard about us, and any questions or comments that you input in the free-form text box when you submit a request to schedule a demo;
• Donation and auction information, such as information about items you donate and donated items you purchase, as well as your name, email address, auction alias, and paddle ID (“Paddle ID”) used in connection with any such donation, auction, or other purchase;
• Payment information, such as your credit card information, held only in secure tokenized form (as further described in the “Credit Card Information” Section below), that you provide to make a donation or purchase an item;
• Chat content that you provide, including any text, images, or other content that you share with other attendees of a Handbid event or with us or an auction manager, as well as any other communications you exchange with other Users via the Platform. For clarity, an auction manager is assigned by the organization hosting the applicable event and may be a volunteer, employee, or independent contractor of such organization; an employee or independent contractor of Handbid; or another third party;
• Shipping information, such as your shipping, billing, and other information you provide to purchase or ship an item; and
• Other information that we may collect which is not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed on the Platform at the time of collection.

If you do not want us to collect information about you, you can simply decide not to submit it to us. If you choose to decline to submit such information, you may not be able to take advantage of all of the Services and Goods offered on the Handbid Events, Handbid Apps, or Site.

• Sources of Personal Information. We obtain personal information from the following categories of sources:

• Personal Information that You Provide. Handbid collects personal information when you voluntarily submit it to us.
• Personal Information that is Obtained from Third Parties. Handbid may receive personal information about you from other third-party sources. For example, a business partner may share your contact information with us if you have expressed interest in learning specifically about our Platform, or the types of Services or Goods we offer. We may obtain your personal information from other third parties, such as customers of Handbid, marketing partners, publicly available sources, or data providers. We may merge or combine such personal information with the personal information we collect from you directly or automatically. For example, if you incur a debt to Handbid, we will generally conduct a credit check by obtaining additional information about you from a credit bureau, as permitted by law.
• Personal Information We Obtain from Social Media Platforms. We may maintain pages for Handbid on social media platforms, such as Facebook, LinkedIn, Twitter, Google, YouTube, Instagram, and other third-party platforms. When you visit or interact with our pages on those platforms, the platform provider’s privacy policy will apply to your interactions and their collection, use, and processing of your personal information. You or the platforms may provide us with information through the platform, and we will treat such information in accordance with this Privacy Policy.
• Cookies and Other Information Collected by Automated Means. We, our service providers, and our business partners may automatically log information about you, your computer or mobile device, and activity occurring on or through the Services, including, but not limited to, your computer or mobile device operating system type and version number, manufacturer and model, carrier and network type, device identifier (such as the Google Advertising ID or Apple ID for Advertising), browser type and language, screen resolution, IP address (which may consist of a static or dynamic IP address and will sometimes point to a specific identifiable computer or device), the website you visited before and after browsing to our website, general location information such as city, state, or geographic area; information about your use of and actions on the Services, such as pages or screens you viewed, how long you spent on a page or screen, navigation paths between pages or screens, information about your activity on a page or screen, access times, and length of access; and other personal information. Our service providers and business partners may collect this type of information over time and across third-party websites and applications.

On the Site, this information is collected using cookies, web beacons, and similar technologies, and our emails may also contain web beacons. In the Handbid Apps, we may collect this information directly or through our use of third-party software development kits (“SDKs”). SDKs may enable third parties to collect information directly from the Handbid Apps.

A “cookie” is a text file that websites send to a visitor’s computer or other Internet-connected device to uniquely identify the visitor’s browser or to store information or settings in the browser. We use cookies on certain of our pages on the Site to help analyze our web page flow, improve performance, keep your session information, customize the Services, Content, and advertising, measure promotional effectiveness, and promote trust and safety. A few important things you should know about cookies are that:

• We offer certain features that are available only through the use of cookies.
• We use cookies to help identify you and maintain your signed-in status.
• Most cookies are “session cookies”, meaning that they are automatically deleted from your hard drive at the end of a session.
• You are always free to decline our cookies if your browser permits, although doing so may interfere with your use of some portions of the Site or Services.
• You may encounter cookies from third parties on certain pages of the Site that we do not control. (For example, if you view a web page created by another user, there may be a cookie placed by that web page.)

A “web beacon”, also known as a pixel tag or clear GIF, is typically used to demonstrate that a webpage was accessed or that certain content was viewed, typically to measure the success of our marketing campaigns or engagement with our emails and to compile statistics about usage of our websites. An SDK is third-party computer code that we may incorporate into the Handbid Apps that may be used for a variety of purposes, including, without limitation, to capture, encrypt, or process payment information, to send smart links to a User’s device to facilitate such User’s login, to enable multi-factor authentication, to provide us with analytics regarding the use of the Handbid Apps, to add features or functionality to the Handbid Apps, or to create or enhance the user interface.

Web browsers may offer users of the Site or Handbid Apps the ability to disable receiving certain types of cookies; however, if cookies are disabled, some features or functionality of the Services may not function correctly. Please see the “Behavioral-Based Advertising” Section for information about how to exercise choice regarding the use of browsing behavior for purposes of targeted advertising.

3. How We Use Your Personal Information

Handbid’s primary purpose in collecting personal information from you is to provide to you the Services, allowing you to register, purchase Goods, bid, donate, and otherwise interact with organizations and their staff and guests, and the Content you otherwise request on the Platform.

Additionally, we may also use your personal information for various purposes, including, without limitation, to:

• provide customer support you request;
• resolve disputes, collect fees, and troubleshoot problems;
• prevent, detect, and investigate potentially prohibited or illegal activities, and enforce our Terms of Service;
• customize, measure and improve the Services, Content, and advertising;
• tell you about our Services, deliver targeted marketing, service updates, and promotional offers based on your communication preferences;
• compare information for accuracy, and verify it with third parties;
• contact you regarding transactions and fee collections to the telephone numbers or e-mail addresses you have provided us;
• notify you if you are outbid on an auction item if you choose to receive push notifications or text messages;
• share your name, email address, phone number, and mailing address with any organization with whom you register;
• send you a receipt confirmation of your purchases, donations, and bids;
• combine your data with other data we collect or obtain;
• aggregate non-identifiable data arising from the use of the Platform for our business purposes;
• use demographic data obtained through the Services and third parties to improve the Services;
• respond to requests from law enforcement and as required by applicable law, court order, or government investigation; and
• any other uses as described when we collect the information.

4. Sharing of Personal Information

In addition to the specific situations discussed elsewhere in this Privacy Policy, Handbid may share your personal information in the following circumstances:

• Bidding and Donations

When you register directly with Handbid through the Services, your information is not shared with any organization until you register for an event associated with that organization. Upon registering, certain personal information of yours will be shared with the organization hosting the event and will be visible to its employees and assigned auction managers who are operating Handbid’s backend auction manager for the applicable event as well as any Handbid employees or independent contractors that the organization engages to help manage the event, process data (e.g., upload contact lists), or otherwise consult with such organization. If you decide to “Bid” in any Handbid auction, you will be assigned a Paddle ID for that auction. Within the auction, you will be (by default) identified to other bidders by your Paddle ID. You have the option to create your own alias to use instead of your Paddle ID. Your alias will be able to be viewed by any other participants in the auction, so please choose your alias wisely. If you include personal information in your alias (such as you name), you will be identifiable.

If you donate to any Handbid event, including, without limitation, any peer-to-peer fundraising page, you will have the option to make your donation “anonymous”. This will hide your name from public view; however, the event hosts and any other people they assign as an “auction manager” in their Handbid account will have access to your name, email, and if you provided it to them, your phone number or address (or both), and may make your name publicly available unless you have selected the anonymous feature.

• Credit Card information

We use a third-party payment processor to process payments made to us. In connection with such processing, Handbid does not have access to complete credit card numbers or information that would allow us to access your payment card account. Rather, all such information is provided directly to our third-party partners: Stripe, CardConnect, and MobileCause, whose use of your personal information is governed by their privacy policy, which may be viewed at: https://stripe.com/privacy, https://cardconnect.com/privacy-policy,  and https://www.mobilecause.com/privacy/, respectively. Please note, however, that in the future MobileCause will no longer be one of our third-party payment processors.

All of our payment processors utilize a secure tokenization method to capture and process credit card transactions through the Platform. When you enter in a credit card’s information through our interface, your credit card information is immediately and securely transferred to one of Handbid’s payment processors. Never does your credit card information pass through Handbid’s servers and never is your credit card information saved in Handbid’s databases. In addition, Handbid employees and contractors and any User (including, without limitation, an organization using the Platform) do not have access to your credit card information.

When a credit card’s information is entered through the Platform or other parts of the Services and securely transferred to a third-party payment processor, such processor returns a secure token to Handbid that we can store and use for future transactions against such credit card. For your convenience, we store this token so that you are not required to re-enter your credit card information. You can remove this token from the Services by logging into your account on the Platform, navigating to your account, and removing your “Card on File” shown in your Handbid account, unless you have an open invoice with Handbid or are actively participating in an auction. It is important to note that charities can restrict bidding or purchases to only individuals with a credit card on file. In those cases, if you have unpaid purchases, Handbid will prevent you from removing your credit card until you pay for those purchases. You can, however, add in a new payment method and remove the original one.

• Registration and sharing through third-party services. We may offer single sign-on (“SSO”) services that allow you to use third-party login credentials to sign into the Platform. If you use such SSO services, with your permission, Handbid may also transfer to your Handbid account certain information contained in your profile of such third-party platform. Handbid may also, for your use, enable you to import information about who you are connected to, as well as enable you to share information with those third-party sites. If you wish to discontinue such sharing, you will be able to do so through your preference page on the Platform.

• Our Disclosure of Your Personal Information. We may disclose personal information to respond to legal requirements, enforce our policies, respond to claims that a listing or other Content violates the rights of others, or protect anyone’s rights, property, or safety.

In addition to the specific situations discussed elsewhere in this Privacy Policy, we may also share your personal information in the following circumstances:

• Service Providers. We may share your personal information with service providers under contract who perform services on our behalf that are necessary for the orderly operation of the Services or Platform or that otherwise help with our business operations (such as fraud investigations, bill collection, credit card processors, affiliate and rewards programs, co-branded credit cards, and email delivery and marketing).
• Consent. We may share your personal information with other third parties to whom you explicitly ask us to send your information (or about whom you are otherwise explicitly notified and consent to when using a specific service), including, without limitation, a Seller that is offering Goods through an auction;
• Legal Compliance. We may share your personal information with law enforcement, governmental agencies, or authorized third-parties, in response to a verified request relating to a criminal investigation or alleged illegal activity, in response to subpoenas, warrants, or court orders, in connection with any legal process, or to comply with relevant laws. We may also share your personal information in order to establish or exercise our rights; to defend against a legal claim; to investigate, prevent, or take action regarding possible illegal activities or fraud; to protect the safety and security of other Users; or to prevent a violation of our Terms of Service or any other activity that may expose us, you, or any other User to legal liability.
• Related Companies and M&A Transactions. We may share your personal information with companies that are affiliated with us (that is, that control, are controlled by, or are under common control with us). In addition, if we sell all or part of our business or make a sale or transfer of assets or are otherwise involved in a merger or business transfer, we may transfer your personal information to a third party as part of that transaction, including, without limitation, at the negotiation stage
• Behavioral-Based Advertising Partners. We participate in behavioral-based advertising. This means that a third-party advertising company may use technology (e.g., a cookie) to collect information about your use of the Platform so that we can provide advertising about products and services tailored to your interests. That advertising may appear either on our Platform, or on other websites.
• Chat. The Platform may provide you with the opportunity to chat. If you decide to submit personal information through chat, such personal information may be made available to other Users.

• Personal Information You Share on Handbid

Your Paddle ID will be displayed, and available to the public, while you are logged into Handbid Events  and within the Handbid Apps, and is connected to all of your activity on the Services for that event. Any person viewing the applicable event page on Handbid Events can see for each particular item on such page that you placed a bid on under your Paddle ID, that your Paddle ID placed a bid on such item and the amount of any such bid. If you share your Paddle ID, you will no longer be anonymous to those with whom you share it. Moreover, Handbid will store login and session information as cookies within the browser you use to access Handbid Events. If you are on a shared computer, others could have access to your account if you do not properly logout of your account. Also, Handbid will send live alerts and notifications to your browser or mobile device. If you access Handbid Events or Handbid Apps from a shared computer or device, certain information about you, such as your User ID, activity, or reminders from Handbid, may also be visible to other individuals who use the computer or device after you.

5. Exchanging Your Personal Information with other Users

Handbid enables you to share personal and financial information with Sellers in order to complete transactions with such Sellers and for such Sellers to collect payments therefor. We encourage you to disclose your privacy preferences and respect the privacy of other Users. We cannot guarantee the privacy or security of your information and therefore we encourage you to evaluate the privacy and security policies of each Seller before entering into a transaction and choosing to share your information. For the avoidance of doubt, Sellers will have access to your name, PIN, email address, phone number, shipping information, and payment information.

6. Privacy Obligations of the Seller

Hosting an auction or event on Handbid designates you as a “Seller” with respect to this Privacy Policy. As a Seller, you will have access to a buyer’s name, PIN, email address, phone number, shipping information, and payment information. In all cases, you must give bidders a chance to remove themselves from your database and a chance to review what personal information you have collected about them.

You agree to use a User’s personal information only for:

• Handbid transaction-related purposes that are not unsolicited commercial messages;
• using services offered through the Services (such as escrow, shipping, and fraud complaints),
• providing support to Users, or
• other purposes that a User expressly chooses and consents to.

7. Your Choices
8. Removal of Your Information from further Access by an Organization. At any time, you may view the current list of organizations who have run events through the Services and that have access to your personal information. For each such organization, you will have the option to remove yourself from their contact list. To do so, please login to https://events.handbid.com with your information and go to “My Data” in the menu. In the future, you will also have the ability to remove yourself from such contact lists via the iOS version of the Handbid Apps, then later via the Android version of the Handbid Apps. When you request to be removed from an organization’s contact list, we will promptly remove that organizations’ further access to your personal information. However, we will maintain your main account information on the Platform. Note that you may also have to contact the organization to request removal of any personal information they have stored on their systems.

• Removal of Account. At any time, you may also remove your account from the Platform. To do this, please go to https://events.handbid.com, login with your information and go to “My Data” in the menu. Once there, you can opt to remove your account. If at any time you are not able to complete this step, please email service@handbid.comand we will promptly remove your account for you.

• Modifications to Your Personal Information. We rely on you to update and correct the personal information contained in your account. You can see, review, and change such personal information by signing on to Handbid Events or the Handbid Apps and viewing your account profile. Generally, we will not manually modify your personal information because it is very difficult to verify your identity remotely. You must promptly update your personal information if it changes or is inaccurate. If the Platform does not permit you to update or correct certain personal information, please contact us as described below.

• Deletion of Your Personal Information. Typically, we retain your personal information for the period necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law. You may, however, request that we delete your personal information by contacting us as described below. Upon your request we will promptly close your account and remove your personal information from view, and will grant a request to delete information as required by law, but you should note that in many situations we must keep your personal information to comply with our legal obligations, resolve disputes, enforce our agreements, or for another one of our business purposes (e.g., to prevent fraud, collect any fees owed, resolve disputes, troubleshoot problems, assist with any investigations). Except as provided above, we will delete, aggregate, or de-identify all of your personal information as described in this Section within the timeframes required by law.

• Promotional Emails. You may choose to provide us with your email address for the purpose of allowing us to send newsletters, surveys, offers, and other promotional materials related to the Services, as well as targeted offers from third parties. We currently use HubSpot and SendGrid for email marketing and delivery services. You can stop receiving promotional emails or certain other transactional emails by clicking the “unsubscribe” links in the emails sent via HubSpot or SendGrid or by contacting us as described below. If you decide not to receive promotional emails, we may still send you Services-related communications, such as those about your account, to fulfill donations or purchases you have submitted or offers you have requested, or to deliver notifications directly to you through the Platform. If you do not wish to receive other marketing or research communications from us or participate in our surveys, simply indicate your preference by following the directions provided with the communication or advertisement. However, you should understand that any organization on the Platform that is running an event (whether an auction, fundraiser, or other type of event) will have access to your personal information if you choose to register for that event. These organizations may use that information for their own purposes.

• Behavioral-Based Advertising. We participate in behavioral-based advertising. This means that a third party may use technology (e.g., a cookie) to collect information about your use of the Platform so that we can provide advertising about Goods and Services tailored to your interests. That advertising may appear either on the Platform, or on other websites. If you wish to limit third parties’ collection of information about your use of the Platform, you can opt out of receiving behavioral-based advertising from participating NAI and DAA members at http://www.networkadvertising.org/managing/opt_out.asp or optout.aboutads.info, respectively. Please note that we also may work with companies that offer their own opt-out mechanisms and may not participate in the opt-out mechanisms that we linked above. ADDITIONALLY, PLEASE NOTE THAT OPTING OUT OF BEHAVIORAL ADVERTISING DOES NOT MEAN THAT YOU WILL NOT RECEIVE ADVERTISING WHILE USING THE PLATFORM. IT WILL, HOWEVER, EXCLUDE YOU FROM BEHAVIORAL-BASED ADVERTISING CONDUCTED THROUGH PARTICIPATING NETWORKS, AS PROVIDED BY THEIR POLICIES AND CHOICE MECHANISMS.

• Do Not Track. Some web browsers and devices permit you to broadcast a preference that you not be “tracked” online. We currently do not respond to “Do Not Track” or similar signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.

8. No Spam, Spyware, or Spoofing

We and our Users do not tolerate spam. Make sure to set your communication preferences for the Services so we communicate to you as you prefer. To report Handbid-related spam or spoof emails to Handbid, please forward the email to service@handbid.com. You (including Sellers and all other Users) may not use our communication tools to send spam or otherwise send content that would violate our Terms of Service.

9. Account Protection

Your password or PIN (for the Handbid Apps) is the key to your account. For passwords, we recommend using a multi-word pass-phrase that you can easily remember, and not disclosing your password or PIN to anyone. If you do share your password, PIN, or your other personal information with other Users or third parties, remember that you are responsible for all actions taken in the name of your account. If you lose control of your password or PIN, you may lose substantial control over your personal information and may be subject to legally binding actions taken on your behalf. Therefore, if your password or PIN has been compromised for any reason, you should immediately notify Handbid and change your password or PIN, as applicable.

10. Security

No method of transmission over the Internet, or method of electronic storage, is fully secure. While we use reasonable efforts to protect your personal information from the risks presented by unauthorized access or acquisition, we cannot guarantee the security of your personal information. In the event that we are required by law to inform you of any unauthorized access or acquisition of your personal information we may notify you electronically, in writing, or by telephone, if permitted to do so by law.

11. Third Parties

Except as otherwise expressly included in this Privacy Policy, this document addresses only the use and disclosure of information we collect from you. If you disclose your information to others, whether they are bidders, organizations, donors, Buyers, Sellers, or other Users of the Services or users of other sites throughout the Internet, different rules may apply to their collection, use, or disclosure of the information you disclose to them. Handbid does not control the privacy policies or practices of third parties, and you are subject to the privacy policies of those third parties where applicable. We encourage you to ask questions before you disclose your personal information to others.

Additionally, the Platform may contain links to other websites and online services operated by third parties. These links are not an endorsement of, or representation that we are affiliated with, any third party. In addition, our content may be included on web pages or online services that are not associated with us. We do not control third party websites or online services, and we are not responsible for their actions. Other websites and online services follow different rules regarding the collection, use, and sharing of your personal information. We encourage you to read the privacy policies of the other websites and online services you use.

12. Children

Although our website is a general audience site, we restrict the use of the Services to individuals who can legally contract. The Services are not directed to, and we do not knowingly collect personal information from, anyone under the age of 13. If a parent or guardian becomes aware that their child has provided us with information without their consent, then such parent or legal guardian should contact us. We will delete such information from our files as soon as reasonably practicable. We encourage parents and guardians with concerns to contact us.

13. International Transfers of Personal Information

Handbid is based in the United States of America. If you are from a country outside of the United States of America with laws governing data collection, use, and sharing that may differ from U.S. law and you provide personal information to us, please note that any personal information that you provide to us may be transferred to the United States of America. By providing such information, where applicable law permits, you hereby specifically and expressly consent to such transfer and processing and the collection, use, and sharing set forth herein or in the Terms of Service related to the use of and access to the Platform. We safeguard and enable the global transfer of personal information in a number of ways. For example, if you or your organization is required to enter into a contract or other binding legal act under EU, UK, or Swiss law with your processors, and Handbid is acting as a processor for you, as the controller, you may request that Handbid enter into a Data Processing Addendum with Standard Contractual Clauses by contacting us at the address listed in the Section titled “How to Contact Us” below.

14. Residents of Europe

The following applies to individuals in the European Economic Area (EEA) and the United Kingdom.

• Controller

The controller of your personal information covered by this Privacy Policy for purposes of European data protection legislation is Handbid Inc., Attn: Legal – Privacy, 9707 E Easter Lane, Suite B, Centennial CO 80112.

• Lawful Basis for Processing

Handbid is required to inform you of the lawful basis of our processing of your personal information, which are described in the table below. If you have questions about the lawful basis of how we process your personal information, contact us at the address listed in the Section titled “How to Contact Us” below.
‍

Processing PurposeLawful Basis•        
Collection of sensitive personal information.

•        To improve the Services and Platform.

•        To promote use of the Services.
‍

Processing is based on your consent. Where we rely on your consent you have the right to withdraw it anytime in the manner indicated on the Platform or Services.
•        To provide the Services and Platform to you.

•        To communicate with you.

•        To understand your interests.

•        To process your payment for the Services and Platform.

•        To respond to your customer support requests.

* To fulfill the obligations under the Terms of Service or separate Services Agreement.

Processing is necessary for the performance of a contract. You are subject to a contract with us and we need to use your personal information to provide products and services.•        To secure the Services and Platform.

·     As required by law.

Processing is necessary to comply with our legal obligations.•        To improve the Services and Platform.

•        To understand your interests.

•        To promote use of the Services and Platform.

•        To secure the Services and Platform.

•        To use personal information as otherwise described in this Privacy Policy.

Processing activities constitute our legitimate interests. We consider and balance the potential impact on your rights before we process your personal information for our legitimate interests. We do not use your personal information for activities where our interests are overridden by the impact on you (unless we have your consent, or we are otherwise required to perform a contract or by law).

We will use your personal information only for the purposes for which we collected it, unless we reasonably determine we need to use it for another reason and that reason is compatible with the original purpose. For example, we consider deidentification, aggregation, and anonymization of personal information to be compatible with the purposes listed above and in your interest, because the deidentification, aggregation, and anonymization of such information reduces the likelihood of improper disclosure of such information.

PLEASE NOTE WE MAY PROCESS YOUR PERSONAL INFORMATION WITHOUT YOUR KNOWLEDGE OR CONSENT, IN COMPLIANCE WITH THE ABOVE RULES, WHERE THIS IS REQUIRED OR PERMITTED BY LAW.

• Retention

We will retain your personal information for as long as necessary to fulfill the purpose of collection, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish and defend legal claims, for fraud prevention purposes, or as long as required to meet our legal obligations. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements

• Your Rights

European data protection laws give you certain rights regarding your personal information. You may ask us to take the following actions in relation to your personal information that we hold:

• Access. Provide you with information about our processing of your personal information and give you access to your personal information.
• Transfer. Transfer a machine-readable copy of your personal information to you or a third party of your choice.
• Correct. Update or correct inaccuracies in your personal information.
• Restrict. Restrict the processing of your personal information.
• Object. Object to our reliance on our lawful basis as the basis of our processing of your personal information that impacts your rights.
• Delete. Delete your personal information.

When we receive your request, we may ask you to verify your identity before we can act on your request. We may withhold information where we are required by law to do so or if the search for that information would require disproportionate effort or have a disproportionate effect to, for example, the cost of providing the information, the time it would take to retrieve the data, or how difficult it may be to obtain the information requested.

If you are a resident of Europe and would like to exercise any of these rights, please submit your request to the address listed in the Section titled “How to Contact Us” below. If you would like to submit a complaint about our use of your personal information or response to your requests regarding your personal information, you may contact us or submit a complaint to the data protection authority in your jurisdiction. In the European Economic Area, you can find your data protection regulator here. In the United Kingdom, you can find your data protection regulator here.

15. How to Contact Us

Please direct any questions or comments about this Privacy Policy or our privacy practices to service@handbid.com. If you have additional questions and are not able to get them answered via service@handbid.com, you may write to us via postal mail at:

Handbid Inc.
Attn: Legal – Privacy
9Suite
Centennial, CO 80112

Effective Date: April 13, 2022

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