AUCTION EDGE PRIVACY POLICY V2.2.0

IMPORTANT - PLEASE READ CAREFULLY

This policy is meant to help you understand, in general, the data we collect, why we collect it and some of the ways in which it may be used. It also explains how you can manage or have the information deleted. We may modify or amend this policy at any time and for any reason. Please check back with this policy from time to time to remain current or if you have privacy concerns.

We build and service a range of websites and products. This policy pertains to all sites, products or services provided by Auction Edge, such as EDGE Pipeline, AuctionEdge.com, EDGE ASI, EDGE AOS, EDGE DATA, EDGE CR Simplified, EDGE Spark, EDGE Lookout sites, EDGE.Auction and others. Our sites, products or services may, from time to time, include links or offerings from third parties. Any third parties will likely provide their own independent privacy policies. We are neither responsible nor liable for the privacy policies of third parties. Please note that our sites, products and services are designed for enterprise customers, and the information we collect is typically collected in a commercial context. As a result, many U.S. state privacy laws do not apply to personal information we process under this policy.

By accessing or using our sites, products, or services, you acknowledge that you have read, understood, and agree to this Policy, including the use of the tracking technologies described in the Tracking Technologies section below. This consent extends to the recording of electronic communications routing and addressing information by these technologies, including but not limited to IP addresses, URLs accessed, device identifiers, and browser information. This consent is provided in accordance with California Penal Code §§ 631, 632, 638.51, and related provisions of the California Invasion of Privacy Act. If you do not consent to the use of these tracking technologies, you should not use our sites, products, or services.

By using, visiting or browsing the sites, products or services, you acknowledge that you have read, understood, and agreed to this Policy and any modifications that may be made to it from time to time. By providing information to us, in any way, you agree and acknowledge that we are collecting this information and may use it in various ways. Please be advised that we do not knowingly comply with any EU-U.S. Data Privacy Framework, the UK-U.S. Data Privacy Framework, the Swiss-U.S. Data Privacy Framework or other Data Privacy Frameworks which may be in existence outside of the United States or between the United States and other countries or non-US Authorities, such as the European Union. If you are an EU citizen, someone to whom GDPR may apply, the citizen of another country or non-US authority with its own Data Privacy standards, or someone to whom a non-US data privacy policy may apply, do not use this site or our services. We do not make any representation that we are compliant with those policies. If you are a natural person in the State of California, please review the section in this policy labeled Consumer Privacy Provisions. If you are under the age of 16 do not use our sites, products or services.

In general, we collect information to help improve our services and the products or services which we offer to you and our customers. The information may be licensed or shared with third parties. The information may be used by our customers and third parties for purposes of their businesses. The information may also be used to respond to reasonable inquiries from regulatory and/or investigative authorities.

Generally, we collect information that you provide to us and information that is generated by your use of our websites and products. As examples, information you provide may include your name, email address, mobile number, other phone numbers, information around your dealership and companies you do business with or for. This information may be required as part of registering with our sites, using our sites or being able to do business with any of our customers or partners. Information that is generated by your use of our websites and products may include, as examples, the devices you use, location information, the vehicles you look at, the vehicles you bid on, the vehicles you purchase, how you pay for vehicles, the services you order around those vehicles or around the way you do business with the companies you do business with and, how you do business.

We may ask you to provide your mobile number to receive and potentially reply to text based notifications (standard carrier text and data rates may apply). This will strictly be on an opt-in basis. You will have the ability to opt-out of receiving these notifications.

Tracking Technologies

We and our third-party service providers use cookies, web beacons, tracking pixels, embedded content, and similar technologies to automatically collect certain information when you visit our sites. The following tracking technologies are currently deployed:

This table is reviewed periodically and updated whenever tracking technologies are added or removed. While we make commercially reasonable efforts to identify and disclose all tracking technologies deployed on our sites, our web properties use third-party platforms and tag management systems that may load additional technologies. If you have questions about a specific technology you observe on our sites, please contact us at privacy@auctionedge.com.

Third-Party Data Sharing

Information collected through the tracking technologies described above may be shared with the following third parties:

  • Google LLC — through the use of Google Analytics and Google Tag Manager, for purposes of website usage analytics and tag management

  • Freshworks Inc. — through the FreshWorks customer engagement platform, for purposes of customer support

  • Hotjar Ltd. — through the HotJar user experience analytics platform, for purposes of understanding how visitors interact with site features

We may share personal information with third parties for marketing and commercial purposes, including but not limited to vehicle purchase data, dealer activity data, and related information. The categories of third parties who may receive this information include vehicle data providers, marketing partners, buyers, consignors and other parties in the remarketing or financial services industry.

We also analyze data provided by you in various ways to generate further data about you. We also correlate data about you with other information to generate further data about you.

Cookies and Opt-Out Options

Most web browsers accept cookies by default. You can modify your browser settings to decline cookies or alert you when cookies are being sent. You may also opt out of certain third-party tracking as follows:

Google Analytics: Visit tools.google.com/dlpage/gaoptout to install the Google Analytics opt-out browser add-on

Interest-based advertising: Visit optout.aboutads.info or optout.networkadvertising.org

Browser settings: Adjust your browser’s privacy and cookie settings to block or delete cookies

Please note that disabling cookies or tracking may affect the functionality of our sites, products, and services.

Data Security

We implement commercially reasonable administrative, technical, and physical safeguards to protect the information we collect. However, no method of transmission over the Internet or electronic storage is completely secure, and we cannot guarantee absolute security.

Data Retention

We retain personal information for as long as necessary to fulfill the purposes for which it was collected, comply with our legal obligations, resolve disputes, and enforce our agreements. Analytics data may be retained in aggregate form for longer periods.

If you have any questions about your data and how its being used, if you would like to manage your data, or if you’d like data to be deleted, please contact us by calling us at 206-858-4826, emailing us at privacy@auctionedge.com or sending mail to Auction Edge, Inc., Attn: Privacy Policy, 1000 Corporate Centre Drive, Franklin, TN 37067, USA

California Consumer Privacy Provisions

If you are a natural person residing in the State of California, the California Consumer Privacy Act and the California Privacy Rights Act give you the following rights: (a) the right to know which personal information is being collected; (b) the right to know if personal data is being sold or shared, and to whom; (c) the right to object to the sale or sharing of your personal data; and (d) the right to access your personal information; (e) the right to request deletion of your personal information; and (f) the right to equal service and price, even if you exercise your privacy rights. In addition, you have the right to require that we disclose to you certain information about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you the following: (i) the categories of personal information we collected about you; (ii) the categories of sources for the personal information we collected about you; (iii) the specific pieces of personal information we have collected about you (a “data portability request”); (iv) our business or commercial purpose in collecting this information; (iv) the categories of parties with whom we have shared that personal information; and (v) if we share or disclose your personal information for a business or commercial purpose, we will disclose to you the category of personal information that each category of recipient obtained. To access data portability and deletion rights, as described above, or if you have any questions or concerns, submit a verifiable consumer request to us by either calling us at 206-858-4826 or emailing us at privacy@auctionedge.com. Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verified consumer request related to your personal information. You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative and describe your request with sufficient detail that allows us to properly understand, evaluate and respond to it.