Privacy Policy
Effective Date: May 10, 2026 | Last Updated: May 10, 2026
A. Introduction
This Privacy Policy applies to the U.S. website platforms, mobile applications, and other digital services (each a “Digital Service”) linking to this policy and owned or operated by Exclusive Racing, Inc. (“Exclusive Racing,” “we,” “us,” or “our”).
This Privacy Policy describes our privacy practices only and does not cover the practices of other users with whom you may engage through the Digital Services, or other companies — including those that may advertise or sponsor content, products, or services on the Digital Services.
When you use or interact with a Digital Service, we and certain third parties may obtain information about you. This Privacy Policy explains what information we collect, how we use and share it, the choices available to you, and the rights you may have under applicable law.
We encourage you to read this Privacy Policy in its entirety. By using or accessing the Digital Services, you acknowledge that you have read and understand the practices described herein.
B. What Information We Collect
When you use a Digital Service, we may collect various types of information related to you and your use of the service. This may include information that directly identifies you — such as your name, address, or contact information (sometimes called “personal information,” “personally identifiable information,” or “personal data”). The information we collect generally falls into four categories:
1. Information You Provide to Us
We may ask you to provide information when you use the Digital Services. For example, during account registration you will need to provide an email address. You may not be able to use certain features if you choose not to submit the requested information. The information you provide may include:
Contact Information. Name, mailing address, email address, or phone number. This may include personal or professional contact information if you are a dealer.
Account & Purchase Information. Contact, billing, and shipping details you provide when creating an account or completing a purchase.
Demographic Information. Age, gender, education, interests, and household information.
Auction & Listing Information. Details you provide in auctions and Buy Now/Make Offer listings, including year, make, model, geographic location, VIN, photos, videos, and other listing-related content.
Payment Information. Payment card number, expiration date, and billing information for transactions made through the Digital Services. Payment information is directed to our third-party payment processor. We do not store your financial account information on our systems; however, we may have access to and retain subscriber information through our payment processor.
User-Generated Content. Comments, photos, videos, and other content you choose to publish on the Digital Services or share with us, which may include license plate information visible in listing photos.
Marketing & Promotions. Information you provide when participating in newsletters, contests, or promotions.
Location Information. Location data, which may include precise geolocation when you permit the Digital Services to access your device location. To prevent collection of precise location information, refer to instructions provided by your mobile service provider or device manufacturer.
Transaction & Activity Information. Data regarding listings, bids, requests, and other transaction-based content that you generate or that is derived from your activities.
Platform Communications. Messages, inquiries, offers, Counter-Offers, and other communications exchanged between buyers and sellers through the EXR platform. We may log, monitor, and review these communications for quality assurance, fraud prevention, dispute resolution, and enforcement of our Terms of Service. Communication records may be retained for the duration of the applicable listing and any subsequent transaction or dispute period, plus an additional two (2) years.
Testimonials. We may publish customer testimonials on our site with customer names and job titles. We obtain authorization from every customer before publishing any testimonial.
2. Information You Provide About Others
You may provide us with information about other people, such as the name and email of a friend or contact with whom you want to share content. Do not give us information about others unless you are authorized or have their consent to do so. We will use their information for the purposes described in this Privacy Policy.
3. Information Collected Automatically
When you use or interact with the Digital Services, certain information is collected automatically through cookies, pixels, web beacons, tags, scripts, local shared objects (including HTML5 cookies), software development kits (“SDKs”), and similar tracking technologies. These technologies may be included in our web pages, mobile apps, emails, and other digital content.
The information collected automatically may include:
- Device, browser, and operating system details (type, model, version)
- Internet protocol (IP) address, which may be used to derive your general geographic area
- Device identifiers (e.g., mobile advertising IDs)
- Browsing activities and clickstream data reflecting content you accessed, clicked on, or viewed
- Referring and exit URLs — details about websites or apps visited immediately before or after accessing a Digital Service
- Demographic, interest, and household information
- Interactions with email messages and other communications, such as whether you opened or forwarded an email or clicked on links
- Date, time, and duration of your visits
For more information about cookies and tracking technologies, and how to manage your preferences, see Section E below.
4. Information We Obtain from Other Sources
We receive information about you from other sources, and it may be combined with other information about you. For example, we may obtain data from:
- Third-party site and app operators — content distribution channels, platforms, voice-activated assistants, or other devices and technologies when you interact with our content, products, services, or ads on those channels
- Third-party data suppliers — data aggregators, data resellers, public databases, and business partners who may provide demographic and transactional information
- Social media platforms — when you engage with our content or ads on social media, or interact with features on the Digital Services that contain social media content or features (e.g., login tools, share buttons), we may obtain your username, user ID, demographic information, and other data, subject to the settings and privacy practices of the relevant platform
C. How We Use Information We Collect
We use the information we collect for the following purposes:
1. To Provide and Improve the Digital Services
- Processing your requests, including listing or bidding on items, and participation in newsletters, contests, promotions, or events
- Publishing and promoting your listings and related content on affiliated sites, apps, or digital properties, and cooperating with third-party operators for such publication and promotion
- Providing customer assistance, technical support, and resolving disputes related to auctions or fee claims
- Customizing content, providing recommendations, and enhancing your overall experience
- Maintaining, operating, improving, and developing the Digital Services and related products and features
- Analyzing how you and others interact with the Digital Services, including measuring usage, conducting market research, analyzing trends, and supporting our operations
- Processing payments, refunds, or exchanges, and tracking and confirming online orders
If you successfully win a bid or complete a transaction with another user or third party, we will provide them with your personal information (including your name and contact information) to facilitate the transaction you requested.
Please note: Other users (including sellers) and third parties are independent from us and are responsible for their own handling of your personal information, including compliance with applicable privacy laws. Direct any questions or concerns about how they handle your information to them.
2. To Communicate with You
- Sending informational messages about the Digital Services (e.g., confirming your listing or bid, notifying you of changes)
- Delivering marketing or promotional communications, including offers about our or third parties’ products and services
- Responding to your questions or requests
- Communicating about newsletters, contests, promotions, or events
3. For Advertising and Marketing, Including Interest-Based Advertising
We develop, manage, and conduct advertising and marketing campaigns, promotions, and offers — including about auctions, listings, our products and services, and third-party products and services.
Interest-based advertising (also called targeted or personalized advertising) is advertising based on your interests as inferred from your activities over time on the Digital Services and third-party online services, as well as information from other sources. Interest-based ads may be displayed based on factors including site context, information you provided, your activities, and demographic, interest, and household information.
On the Digital Services and on third-party sites, apps, or other media, we, our service providers, and third parties may use automated means — including cookies, pixels, web beacons, tags, scripts, local shared objects, and SDKs — to collect information for interest-based advertising purposes or to serve you interest-based ads.
We may use and combine online and offline information, including your personal information, for interest-based advertising purposes. We may aggregate information to create audiences most likely to respond to ads based on demographic, interest, or household information.
Cross-device linking: If you access the Digital Services from multiple browsers or devices, we, our service providers, and third parties may try to establish connections among your different browsers and devices to provide a seamless experience and serve more relevant content and ads.
There are steps you can take to limit the collection of your information for interest-based advertising purposes. See Section E below for your choices and opt-out options.
4. For Automated Decision-Making and Profiling
We may use automated processes to help detect fraud, enforce our terms, serve relevant advertising, and improve the Digital Services. Where required by applicable law, we will provide you with information about the logic involved in such automated decision-making and give you the opportunity to request human review of any decision that significantly affects you.
5. To Protect Our Rights or the Rights of Others
- Detecting, preventing, and responding to fraud, potentially illegal activities, misuse of the Digital Services, intellectual property infringement, or other violations of law
- Performing audits, assessments, testing, and troubleshooting
- Backing up systems and enhancing the overall security of the Digital Services
- Complying with and enforcing applicable legal requirements, including legal process such as court orders, warrants, or subpoenas
D. How We Share Information
We may share the information we collect with the following categories of recipients:
1. Sellers, Other Users, and Third Parties. If you transact with another user or third party in connection with an auction or other feature on the Digital Services, we share your personal information with them to facilitate the transaction. If subsequent issues arise (such as a dispute), we may also share your information to help resolve them.
2. Affiliates and Subsidiaries. We share information with affiliates and subsidiaries within the Exclusive Racing family of companies as necessary to operate the Digital Services.
3. Service Providers. We engage third parties to provide services on our behalf, such as payment processing, email distribution, cloud computing, analytics, ad serving, and managing sweepstakes, contests, or promotions. These service providers use the information we provide as necessary for the performance of their services and are contractually obligated to handle it in accordance with this Privacy Policy and applicable law.
4. Advertisers and Marketing Partners. We may provide your information to advertisers, advertising agencies, ad networks, ad exchanges, marketing businesses, technology vendors, and other entities that create, deliver, and assess advertising or marketing campaigns, including interest-based ads.
5. Content Measurement Companies. We and third parties seek to measure the performance of content across the internet, including on the Digital Services. We may include third-party measurement software to enable market research or measure digital and video content consumption.
6. Social Media Platforms. If you interact with social media widgets, share content using social media buttons, or access features that contain content provided by social media platforms, those platforms may collect information. We encourage you to review the privacy policies of the social media platforms you engage with.
7. Business Partners. We may provide your information to business partners, including joint marketing partners and content sponsors, for purposes such as co-branded, co-sponsored, or cross-promotional offerings.
8. Other Parties When Required by Law. We may share your information as we believe is necessary to protect, enforce, or defend our legal rights, the privacy or safety of our employees or users, or to comply with applicable law or legal process, including responding to court orders, warrants, or subpoenas.
9. Corporate Transactions. We reserve the right to transfer information we have about you in connection with the consideration, negotiation, or completion of a sale or transfer of all or a portion of our business or assets — such as a merger, acquisition, disposition, bankruptcy reorganization, dissolution, or liquidation.
10. With Your Consent. We may also share your information with third parties when you consent to or request such sharing.
E. Your Choices, Including Marketing and Interest-Based Ad Opt-Outs
Direct Marketing Opt-Outs
Email marketing. You may opt out of receiving marketing or promotional emails by clicking the “unsubscribe” link contained in those emails or by logging into your account and managing your email preferences. Even if you opt out of marketing emails, we may still send you transactional emails relating to your use of the Digital Services (e.g., bid confirmations, service changes, password recovery).
Text message marketing. If you participate in a text message marketing campaign, you may opt out by following the instructions in those messages (e.g., texting the word STOP).
Direct mail. You may request that we stop sending you postal mail offers by notifying us in writing at: Exclusive Racing, Inc. Legal Department, Attn: Privacy, 1401 21st Street, Suite R, Sacramento, CA 95811. Please indicate the Digital Service to which your request applies.
Marketing by third parties. We may provide your contact information to third parties for their own marketing purposes. To request that third parties do not use your postal mailing contact information for their marketing purposes, notify us in writing at the address above. You may also be able to adjust your email preferences by logging into your account.
Co-branded, co-sponsored, or cross-promotional offerings. If you participate in a co-branded or cross-promotional offering, the third party involved may use your information for its own purposes. Contact the relevant third party directly to exercise your opt-out choices.
Cookies and Tracking Technology Choices
Browser settings. Most browsers accept cookies by default. You may be able to change your settings to refuse certain cookies or notify you before accepting cookies. Disabling cookies may make some features of the Digital Services difficult to use or unavailable.
Opt-out cookies. You can place opt-out cookies on your browser to block participating companies from installing future cookies. If you subsequently clear or delete cookies, your opt-out cookies may also be deleted and you may need to renew your opt-out choices. The opt-out mechanisms offered by third parties include:
- Digital Advertising Alliance (DAA) Opt-Out
- Network Advertising Initiative (NAI) Opt-Out
Mobile device settings. To limit interest-based advertising on your mobile device, review and adjust the settings provided by your device manufacturer (e.g., “Limit Ad Tracking” on iOS or “Opt Out of Ads Personalization” on Android).
Global Privacy Control (GPC) and Do Not Track
Exclusive Racing recognizes and honors the Global Privacy Control (GPC) signal. If your browser or device transmits a GPC signal, we will treat that signal as a valid opt-out of the sale or sharing of your personal information for the browser or device from which you send the signal, as required by applicable law (including the California Consumer Privacy Act and the Colorado Privacy Act).
You can learn more about GPC and how to enable it at globalprivacycontrol.org.
With respect to other “Do Not Track” browser signals, there is currently no industry-wide standard for how websites should respond to such signals beyond GPC. We will continue to monitor developments and update our practices accordingly.
Additional Choices
User account. If you have created an account, you may review and update your information or preferences by logging in.
Device settings. For relevant Digital Services, you may review and adjust preferences by updating your device settings (e.g., permitting or denying precise location collection).
Push notifications. If a Digital Service enables push notifications, you may update your preferences by adjusting your device settings — for example, selecting the relevant app from “Notifications” (iOS) or “App notifications” (Android).
F. Data Retention
We retain your personal information for as long as necessary to fulfill the purposes for which it was collected, as described in this Privacy Policy, unless a longer retention period is required or permitted by law. The criteria we use to determine retention periods include:
- The duration of our relationship with you (e.g., whether you have an active account or open transaction)
- Whether there is a legal or regulatory obligation to which we are subject (e.g., tax, financial reporting, or audit requirements)
- Whether retention is necessary to establish, exercise, or defend legal claims
- Whether retention is necessary for fraud prevention and platform security
When personal information is no longer required for these purposes, we will delete, anonymize, or de-identify it in accordance with our data retention policies and applicable law.
G. How We Protect Your Information
We implement administrative, technical, and physical safeguards designed to protect personal information from unauthorized access, use, alteration, and disclosure. These measures include encryption of data in transit and at rest, access controls, and regular security assessments.
However, no method of transmission over the internet or method of electronic storage is 100% secure. While we make reasonable efforts to protect your personal information, we cannot guarantee its absolute security. If we become aware of a security breach that affects your personal information, we will notify you in accordance with applicable law.
H. Non-U.S. Visitors
We operate the Digital Services from the United States. Any information we collect in connection with your use of the Digital Services may be processed, stored, and transferred in the United States or other countries that may have different data protection standards than your home country. By using the Digital Services, you acknowledge this transfer. Where required by applicable law, we implement appropriate safeguards for cross-border transfers of personal data.
I. Children’s Privacy
The Digital Services are intended for a general audience and are not directed at children. We do not knowingly collect, sell, or share personal information from children under the age of 13, or under the age of 16 where required by applicable law. If we learn that we have collected personal information from a child under the applicable minimum age without verifiable parental consent, we will take steps to delete that information as promptly as possible.
If you believe that a child under the applicable age has provided us with personal information, please contact us at [email protected] so that we can take appropriate action.
J. Links to Third-Party Websites, Apps, and Services
The Digital Services may contain links to websites, mobile apps, or other services operated by companies not affiliated with Exclusive Racing. The Digital Services may also be made available through third-party platforms such as app stores or social media platforms. We are not responsible for the privacy practices of any non-Exclusive Racing websites, apps, or services, and we encourage you to review the privacy policies published by those third parties before providing them with your information.
K. Careers & Job Opportunities
This Privacy Policy does not apply to web pages hosting our careers or job opportunities. Any information obtained through such pages is governed by the privacy notice published on those pages.
L. Dispute Resolution
Any dispute concerning the Digital Services (including our use of your personal information) will be resolved per the dispute resolution provisions in our Terms & Conditions, which govern your use of the Digital Services. Please review the Terms & Conditions before using the Digital Services.
M. Changes to This Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in our privacy practices, applicable laws, or regulatory guidance. We will publish the updated version on the relevant Digital Services and indicate at the top when it was most recently updated. Where changes have a material impact on you or your rights, we will provide notice as required by applicable law (such as by email or a prominent notice on the Digital Services) before the changes take effect. Your continued use of the Digital Services after such changes constitutes your acknowledgment of the updated Privacy Policy.
N. Contact Us
If you have any questions about this Privacy Policy, wish to exercise any of your privacy rights, or would like to submit a complaint, please contact us:
Exclusive Racing, Inc. 1401 21st Street, Suite R Sacramento, CA 95811 Phone: +1 (888) 977-7885 Email: [email protected]
O. Your U.S. State Privacy Rights
A growing number of U.S. states have enacted comprehensive privacy laws that grant residents specific rights regarding their personal information. This section provides information for residents of those states. Where state laws differ, we comply with the requirements of each applicable state law.
States with Comprehensive Privacy Laws
As of the date of this Privacy Policy, the following states have enacted comprehensive consumer privacy laws that may apply to you. This list may not be exhaustive, as additional states continue to enact privacy legislation:
- California — California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA)
- Virginia — Virginia Consumer Data Protection Act (VCDPA)
- Colorado — Colorado Privacy Act (CPA)
- Connecticut — Connecticut Data Privacy Act (CTDPA)
- Utah — Utah Consumer Privacy Act (UCPA)
- Texas — Texas Data Privacy and Security Act (TDPSA)
- Oregon — Oregon Consumer Privacy Act (OCPA)
- Montana — Montana Consumer Data Privacy Act (MCDPA)
- Iowa — Iowa Consumer Data Protection Act (ICDPA)
- Indiana — Indiana Consumer Data Protection Act (INCDPA)
- Tennessee — Tennessee Information Protection Act (TIPA)
- Delaware — Delaware Personal Data Privacy Act (DPDPA)
- New Hampshire — New Hampshire Privacy Act (NHPA)
- New Jersey — New Jersey Data Privacy Act (NJDPA)
- Nebraska — Nebraska Data Privacy Act (NDPA)
- Maryland — Maryland Online Data Privacy Act (MODPA)
- Minnesota — Minnesota Consumer Data Privacy Act (MCDPA)
- Kentucky — Kentucky Consumer Data Protection Act (KCDPA)
If you reside in one of these states, you may have some or all of the rights described below, depending on the specific requirements of your state’s law.
Your Privacy Rights
Depending on your state of residence, you may have the right to:
Right to Know / Access. Request confirmation of whether we are processing your personal information and request access to the specific categories and pieces of personal information we have collected about you, including the sources, purposes, and third parties with whom it has been shared.
Right to Delete. Request that we delete your personal information, subject to certain legal exceptions (e.g., if retention is required by law or necessary to complete a transaction you requested).
Right to Correct. Request correction of inaccurate personal information we hold about you.
Right to Data Portability. Receive a copy of your personal information in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the data to another entity.
Right to Opt Out of Sale or Sharing. Where applicable, opt out of the “sale” of your personal information or the “sharing” of your personal information for cross-context behavioral (targeted) advertising. We may share personal information with third parties in ways that constitute a “sale” or “sharing” under certain state laws.
Right to Opt Out of Targeted Advertising. Opt out of the processing of your personal information for purposes of targeted advertising.
Right to Opt Out of Profiling. Opt out of profiling in furtherance of decisions that produce legal or similarly significant effects concerning you.
Right to Limit Use of Sensitive Personal Information. Where applicable (including under California law), request that we limit the use and disclosure of your sensitive personal information to purposes permitted by law.
Right to Non-Discrimination / Non-Retaliation. Exercise any of your privacy rights without receiving discriminatory or retaliatory treatment.
Right to Appeal. In many states, if we deny your privacy request, you have the right to appeal that decision. We will provide instructions on how to submit an appeal when responding to your request.
How to Exercise Your Rights
To submit a privacy rights request, please contact us at:
Email: [email protected] Mail: Exclusive Racing, Inc. Legal Department, Attn: Privacy, 1401 21st Street, Suite R, Sacramento, CA 95811
In your request, please include your name, email address, state of residence, and the specific right you wish to exercise. We may need to verify your identity before processing your request. Verification may include confirming information we have on file or asking you to verify access to the email address associated with your account.
You may also designate an authorized agent to make a request on your behalf. We may require the authorized agent to provide proof of authorization and may still verify your identity directly.
We will respond to verified requests within the timeframes required by applicable law (generally 45 days for CCPA/CPRA and 45 days for most other state laws, with extensions available where necessary).
Additional Disclosures for California Residents
Categories of Personal Information Collected
The CCPA, as amended by the CPRA, requires specific disclosures for each category of personal information we collect. The table below summarizes our general data handling practices, described more fully in Sections B, C, and D of this Privacy Policy.
| Category of Personal Information | Sources (See Section B) | Purposes (See Section C) | Shared With (See Section D) |
|---|---|---|---|
| Identifiers Contact information, IP address, device IDs, account numbers | You; your contacts; cookies/tracking tech; third-party sites and platforms; data suppliers; social media | Provide and improve services; communicate; advertising/marketing; protect rights | Transaction counterparties; affiliates; service providers; advertising partners; content measurement; social media; business partners; government authorities |
| Demographics Age, gender | You; cookies/tracking tech; third-party sites and platforms; data suppliers; social media | Provide and improve services; advertising/marketing | Affiliates; service providers; advertising partners; content measurement; social media; business partners; government authorities |
| CA Civil Code §1798.80(e) Information Payment card number, expiration date, billing info | You | Provide and improve services; protect rights | Transaction counterparties (if appropriate); affiliates; service providers; government authorities |
| Commercial Information Listings, bids, transactional data | You; cookies/tracking tech | Provide and improve services; communicate; advertising/marketing; protect rights | Transaction counterparties; affiliates; service providers; advertising partners; social media; business partners; government authorities |
| Internet / Electronic Network Activity Browsing data, clickstream, content published, device/browser info | Cookies/tracking tech; third-party sites and platforms; data suppliers; social media | Provide and improve services; communicate; advertising/marketing; protect rights | Affiliates; service providers; advertising partners; content measurement; social media; business partners; government authorities |
| Geolocation Data City/state or precise location | You; cookies/tracking tech | Provide and improve services; communicate; advertising/marketing; protect rights | Affiliates; service providers; advertising partners; content measurement; social media; business partners; government authorities |
| Audio, Electronic, Visual, or Similar Information Call center recordings | You | Provide and improve services; communicate; protect rights | Affiliates; service providers |
| Professional or Employment-Related Information Professional contact info used for listings, bids, or account registration | You | Provide and improve services; communicate; advertising/marketing; protect rights | Transaction counterparties; affiliates; service providers; advertising partners; content measurement; social media; business partners; government authorities |
| Inferences Preferences and characteristics inferred from activity | You; cookies/tracking tech; third-party sites and platforms; data suppliers; social media | Provide and improve services; communicate; advertising/marketing; protect rights | Affiliates; service providers; advertising partners; content measurement; social media; business partners; government authorities |
| Sensitive Personal Information Precise geolocation; account login credentials; payment information when collected directly | You; cookies/tracking tech | Provide and improve services; process transactions; protect rights; purposes permitted by CPRA §1798.121 | Service providers; government authorities |
Data Retention Periods
We retain each category of personal information for the period described in Section F above. In general, personal information associated with active accounts is retained for the life of the account plus a reasonable wind-down period. Transactional data is retained in accordance with applicable tax and financial record-keeping requirements. Automatically collected data (e.g., cookies, analytics data) is retained for up to 24 months unless longer retention is required for legal or security purposes.
Shine the Light (CA Civil Code § 1798.83)
California residents may have the right to request a list of third parties to which certain personal information was disclosed during the preceding year for those third parties’ direct marketing purposes. To make such a request, contact us at:
Exclusive Racing, Inc. Legal Department, Attn: Privacy 1401 21st Street, Suite R Sacramento, CA 95811
In your request, include the statement “Your California Privacy Rights” along with your name, street address, city, state, and zip code. Attest that you are a California resident and provide a current California address for our response.
California Minors
We do not knowingly collect, sell, or share personal information of minors under the age of 16 without affirmative authorization.
Additional Information for Nevada Residents
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 data. To exercise this right, contact us at [email protected] with the subject line “Nevada Do Not Sell Request” and provide your name and the email address associated with your account. Please note that we do not currently sell your personal data as defined in Nevada Revised Statutes Chapter 603A.
P. Additional Information for European Visitors
To address our legal obligations in Europe (including the UK), Exclusive Racing provides the following additional information for Europe-based visitors to our U.S. Digital Services.
Data Controller
If you use or interact with our U.S. Digital Services, the data controller is Exclusive Racing, Inc. Contact details are provided in the “Contact Us” section above.
Legal Bases for Processing
We process personal data on the following legal bases:
Performance of a contract. We process your information to fulfill our contractual obligations — for example, processing your payment and contact information when you list or bid on an item, and sending transactional communications such as bid confirmations.
Legitimate interests. We process your information for legitimate interests such as improving and customizing the Digital Services, understanding how you interact with our content, sending marketing communications about products and services we think may interest you, and sharing information with affiliates, service providers, and business partners. We maintain safeguards to protect information processed on this basis.
Legal obligation. We process and share information as necessary to comply with legal obligations — for example, collecting information for tax or financial reporting.
Consent. Where required by law, we obtain your consent before processing your information. You can withdraw consent at any time by contacting us at [email protected].
Your Rights
Under applicable European data protection law (including the UK GDPR and EU GDPR), you may have the right to access, correct, erase, restrict, or object to the processing of your personal data. You may also have the right to data portability and to lodge a complaint with your local data protection authority. To exercise any of these rights, contact us at [email protected].
Data Retention
We keep your personal data for as long as we have a relationship with you. After our relationship ends, we retain your data for a period that enables us to maintain business records, comply with legal retention requirements, defend or exercise legal claims, carry out fraud prevention, and deal with complaints. We delete personal data when it is no longer required for these purposes. If any data cannot be deleted for technical reasons, we implement measures to prevent further processing or use.
International Data Transfers
Information collected through the Digital Services will be processed in and subject to the laws of the United States, which may not provide the same level of protection as your home country. Where we transfer personal data from the European Economic Area, United Kingdom, or Switzerland, we put appropriate safeguards in place, such as Standard Contractual Clauses approved by the European Commission, or rely on other lawful transfer mechanisms.
Privacy Officer and Complaints
Our Privacy Officer can be reached at [email protected]. We are committed to working with you to resolve any complaint or concern about privacy. If you believe we have not been able to assist with your concern, you have the right to make a complaint to your local data protection authority.
Q. Additional Information for Users Residing in Brazil
This section supplements the rest of this Privacy Policy and is provided for users who reside in Brazil, in accordance with the Lei Geral de Proteção de Dados (“LGPD”). For such users, these provisions supersede any conflicting provisions elsewhere in this Privacy Policy.
Legal Bases for Processing
We process your personal information only when we have a lawful basis, including: your consent; compliance with a legal or regulatory obligation; the carrying out of public policies; studies conducted by research entities (preferably on anonymized data); performance of a contract; exercise of rights in judicial, administrative, or arbitration proceedings; protection of life or physical safety; protection of health; our legitimate interests (provided your fundamental rights do not prevail); and credit protection.
Your Rights Under the LGPD
You have the right to:
- Confirm the existence of processing activities on your personal information
- Access your personal information
- Correct incomplete, inaccurate, or outdated personal information
- Anonymize, block, or delete unnecessary or excessive personal information
- Obtain information on the possibility of providing or denying consent, and the consequences
- Obtain information about the third parties with whom we share your personal information
- Request portability of your personal information to another provider
- Request deletion of personal information processed based on consent
- Revoke consent at any time
- Lodge a complaint with the ANPD or consumer protection bodies
- Oppose non-compliant processing activities
- Request information about criteria and procedures used for automated decisions
- Request review of decisions made solely through automated processing
You will never be discriminated against for exercising your rights.
How to File a Request
You may submit a request at any time, free of charge, using the contact information in the “Contact Us” section above, or through your legal representative.
When filing an access or processing confirmation request, please specify whether you would like your information delivered in electronic or printed form, and whether you need an immediate simplified response or a complete disclosure (provided within 15 days).
If you request rectification, deletion, anonymization, or blocking, we will communicate your request to third parties with whom we have shared your information, except where doing so would be impossible or involve disproportionate effort.
International Transfers
We may transfer your personal information outside of Brazil in circumstances authorized by law, including: international legal cooperation between public bodies; protection of life or physical safety; authorization by the ANPD; international cooperation agreements; execution of public policy; and compliance with legal or regulatory obligations, contracts, or the exercise of rights in legal proceedings.
