Updated as of June 22, 2021
Types of Information We Collect and Use
Our Digital Services may collect, use, store and transfer different kinds of information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with you as a particular consumer or device (“Personal Information”), such as:
- Contact Data includes billing address, delivery address, email address, and telephone numbers.
- Transaction Data includes details about payments, products and services you have purchased, or other purchasing or consuming histories or preferences, bank account number, credit card number, debit card number, or any other financial information.
- Technical Data includes internet protocol (IP) addresses, your browser type and version, time zone setting and location, geolocation, cookies, carrier information, browser plug-in types and versions, operating system and platform, sensory data (e.g., audio, electronic, visual, or similar information), or other technology on the devices you use to access the Digital Services.
- Profile Data includes your username, password, preferences, settings, login and profile information, feedback, and survey responses.
- Usage Data includes information about how you use the Digital Services, such as the session duration, pages surfed, the source of the request, and the preceding page views.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties (including our brand partners), your communication preferences, and the materials that you have viewed and interacted with.
- Information from Third Parties: information that may be obtained from other sources, such as business partners, data suppliers and social media platforms.
We may also collect, use and share “Vehicle-Specific Data”, which includes chassis or vehicle identification numbers, vehicle specifications and features, as well as visual media, such as photographs and video, of vehicles and parts. Though Personal Information may be derived from Vehicle-Specific Data, such as from photos of vehicles that include license plate information, Vehicle-Specific Data is inherently shared data that is provided to us for the purpose of disclosing it publicly. When users of the Digital Services submit or provide Vehicle-Specific Data to auction, describe, or comment on a vehicle, they consent to such Vehicle-Specific Data to be shared and made accessible in any manner to both users of the Digital Service, whether registered or not, and third parties. We may collect, use and share Vehicle-Specific Data even after an auction has closed for purposes including, displaying results of completed bids, marketing and business analytics to improve the Digital Service.
We do not collect any special categories of personal information about you (this includes details about your race or ethnicity, citizenship, medical condition, physical or mental disability, marital and/or family status, religious or philosophical beliefs, veteran or military status, sexual orientation, political opinions, criminal history, information about your health, and genetic and biometric data).
How do we Collect Personal Information?
Submitted by You: We may collect Personal Information you provide to us, for example if you:
- Register an account on the Website;
- Contact us with a question, comment, or request.
- Submit a vehicle for auction on our Digital Services and include your contact information, description and photographs or videos of a vehicle.
- Initiate a search on the Websites or use any of the Digital Services.
- Complete a transaction on our Websites to use the Digital Services.
- Respond to any promotional and/or other marketing offers, including any offers initiated by us or third-party marketing automation providers.
- Participate in our subscription program.
- Respond or leave any survey, feedback or comments to any posts, auctions, or articles published on our Website.
- Submit any other content, such as on our social media pages.
IP Addresses: An IP address is a number that is automatically assigned to your computer whenever you access the Internet. When you request pages from any Digital Services, we automatically log your IP address.
Third-Party Sources: In addition to the Personal Information that we may collect directly from your use of the Digital Services, we may have access to other Personal Information from third-parties, depending on the privacy policies of those third-party services and the information you have authorized them to share with us. For example, we may obtain Personal Information from research and analytic companies, marketing partners, public databases, payment processors, mobile carriers, and similar third-party sources. We may also receive your Personal Information from other sources, such as people that you are in some way connected with, or our own affiliates and representatives.
Location Tracking: Additionally, when you visit our Website or use our Digital Services, we may collect information about your location. This type of information may be used to locate your proximity to other users of our Digital Services including sellers, bidders, and buyers, or to identify offers and other location specific items that may be of interest to you.
Interactive Services: If you post information, visual media, or otherwise provide feedback and/or Personal Information by and through the Website, you should be aware that any personally identifiable information that you submit there can be read, collected or used by other users of the Website and/or Digital Services and could be used to send you unsolicited messages or otherwise contact you without your consent or desire. We are not responsible for the personal information that you choose to submit in this manner. Further, by submitting feedback and other material, you: (a) represent and warrant that our use of your submission does not and will not breach any agreement, violate any law or infringe upon any third party’s rights; (b) agree that we are free to use in any manner all or part of the feedback and other material on an unrestricted basis without the obligation to notify, identify or compensate you or anyone else; and (c) grant us all necessary rights, including a waiver of all copyright, trademark, privacy and moral rights, to use all feedback and other material, in whole or in part, or as a derivative work, without any duty by us to anyone whatsoever.
How is the Personal Information that We Collect Used?
We may use Personal Information in a variety of ways, including:
- To provide you access and use of the Digital Services, including registering you as a member and subscriber to our exclusive list to hear about auctions, special offers and upcoming collections.
- To administer the Digital Services, including troubleshooting, data analysis, testing, maintenance, support, reporting, and hosting of data.
- For marketing, promotion and advertising purposes, including conducting analytics, aggregating data, contests, surveys and sweepstakes. For example, email marketing from us and our third-party advertisers and brand partners. You have the right to opt out at any time from receipt of further marketing communications, as described in the “Your Rights” section below.
- For marketing analysis, for example, to assess trends amongst our consumers and what people are saying about the Digital Services, to evaluate the impact and effectiveness of our marketing campaigns and promotions, and to analyze the number and types of visitors to our Websites and/or users of our Apps (including the locations from which such visitors/users access our Websites and Apps). We may aggregate your Personal Information for these purposes so that it no longer identifies any particular individual.
- For “online behavioural advertising”, which involves the use of your Personal Information (and the sharing of it with our service providers) to display the most appropriate and relevant advertising to you either on our Websites, Apps or third party websites (including social media platforms). You have the right to opt-out at any time from the use of your Personal Information for online interest-based advertising as described in the “Your Rights” section below.
- To use, evaluate, improve or develop the Digital Services.
- To comply with our legal obligations and law enforcement requests.
- To fulfill contractual obligations to third parties, such as brand partners, customs brokers, vehicle transporters, service companies, and licensing agreements.
- To permit you to interact with other users or representatives of ours.
- To establish or defend legal claims or protect our rights.
- To conduct other business analytics, research, planning, reporting or forecasting.
- For any purpose that we disclose to you at the time we collect the Personal Information.
- To handle, respond to, or otherwise process any request that you make.
Please note that 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.
How is the Personal Information We Collect Shared?
Your Personal Information may be shared as follows:
- Users of Digital Services: We may share your Personal Information that you provide us when you submit a vehicle for auction. This information may be shared to both users who have registered with the Digital Services and those who have not. Additionally, we may share your Personal Information revealed by your user history on the Digital Services, including your username, previously auctioned lots, bidding history, including auction wins, and comments made on other bids to users of the Digital Services, whether registered or not.
- Communications with Sellers of Vehicles: We may share your Personal Information with sellers of vehicles if you decide to contact them with respect to a vehicle they are selling. Our Digital Services can be used to submit a message to the seller, and we may share your Personal Information to facilitate your communication with the seller and exchange information between you.
- Communications with Bidders and Buyers of Vehicles: We may share your Personal Information with bidders and buyers of vehicles that you list for sale on the Website. Our Digital Services can be used by bidders and buyers to submit a message to you and we may share your Personal Information to facilitate your communication with bidders and buyers and exchange information between you.
- Vendors and Service Providers: We may share your Personal Information with our vendors and service providers with whom we have a business relationship. For example, we may share your Personal Information with insurance companies, payment and credit card processing companies, accountants and legal advisors, advertising agencies and brand partners, customs brokers, professional photographers and videographers, vehicle transporters, and other vendors.
- Related Parties: We may disclose your Personal Information to any of our direct or indirect parents, subsidiaries or affiliates, and/or any of our or their respective parents, affiliates, subsidiaries, owners, managers, officers, directors or agents, licensees, and/or any other entity that is in common control with any of the foregoing, whether by beneficial ownership, voting power, or the ability to control or direct the management or policies of any such entity, whether by contract or otherwise.
- Merger or Acquisition: We may share your Personal Information with a third-party who directly or indirectly acquires any ownership interest in us or any of our affiliates, or acquires the Digital Services, whether such acquisition is by way of merger, consolidation, or purchase of all or a substantial portion of our assets.
- Permitted by Law: We may share your Personal Information if: (i) we believe that we are required to do so by law or legal process; (ii) we believe that we are permitted to do so by law or legal process; (iii) to respond to a claim; or (iv) to protect the rights, property, or safety of us, our affiliates, or others.
- With Your Consent: We may also share any Personal Information from or about you with any party if you consent to that disclosure. For example, we may need your consent to share information with a social media platform or other sharing functionality.
- Public Disclosures: In addition to Vehicle-Specific Data, we may make certain Personal Information available publicly if it is reasonably apparent at the time you submitted it that it would be shared or would be publicly available, for example, reviews, feedback or photos you share, social media posts and similar content.
The third parties with whom we share this Personal Information and Vehicle-Specific Data may use it for their own purposes and in accordance with their own policies. We are not responsible for their actions.
We take reasonable steps to help protect your Personal Information under our control. However, data transmitted over the Internet is not completely secure and we cannot guarantee the security of any information that is provided to us. If you have reason to believe that your interaction with us is not secure, you should immediately notify us of the problem by contacting us (See “Contacting Us” below).
Retention, Correction and Deletion
We will only retain your Personal Information for as long as reasonably necessary to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your Personal Information for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
You may request that we update or correct any of your Personal Information or delete any of your Personal Information. We will respond to all requests for corrections or deletions in accordance with applicable data protection laws, but we may reject your request if we determine it is unreasonable or not required by law, or if we determine that it could expose us to operational risks or fraud. We do not charge a fee to process or respond to your request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
International data transfers
We may transfer and store your Personal Information to and/or at a destination outside of the jurisdiction in which you live, including jurisdictions that have less strict, or no data protection laws, when compared to those in your jurisdiction. Whenever we do so, we will take reasonably necessary steps to ensure that adequate safeguards are in place to protect your Personal Information and to make sure it is treated securely.
Depending on the jurisdiction in which you live, you have certain rights in relation to your Personal Information. These rights may include the right to:
- Access your Personal Information by contacting us at [email protected].
- Correct any Personal Information that you think is inaccurate by (i) logging in and updating your information or user preferences; or (ii) by contacting us at [email protected].
- Delete any Personal Information that you no longer consent to us having by contacting us at [email protected].
- Unsubscribe from any of our marketing communications at any time, including the right to unsubscribe from:
- Receiving marketing or promotional emails by (i) clicking on the “unsubscribe” link contained in such emails; (ii) by logging into your account and managing your email preferences; or (iii) by contacting us and requesting to be opted out at [email protected]. Please keep in mind that if you opt out of receiving marketing or promotional emails, we may still send you transactional emails or other communications relating to your use of the Digital Services (e.g., to confirm your bids, to inform you of changes to a Digital Service or in response to your password recovery request).
- Receiving SMS text message-based marketing by following the instructions contained in those messages (e.g., texting the word “STOP”); or (ii) contacting us at [email protected].
- Deactivate or opt-out of cookies, flash cookies, web beacons, embedded scripts, location-identifying technology or similar technology we use to deliver interest-based ads when you access the Digital Services. For more information on how to block the use of such technologies on your computer, device or browser, please click here to read the Network of Advertising Initiative’s recommendations for Opting Out of Internet Advertisements.