PRIVACY POLICY

In our User Privacy Notice we have compiled all essential information about our handling of your personal data and your corresponding rights for you. By creating a new account or having an existing account on snagRC, user acknowledges reading and accepting our User Privacy Policy .

1. Scope and updates of this User Privacy Notice

Protecting your private information is our priority. This User Privacy Policy applies to your use of this website and all snagRC applications, services (including payment services), products and tools (collectively the "Services"), regardless of how you access or use these Services, including access via mobile devices and apps.

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This User Privacy Policy also applies if explicit reference is made to it via a link or in a similar manner, e.g. on websites, partners and affiliates on which Services from snagRC are offered.

We may change this User Privacy Policy at any time by posting the revised User Privacy Policy on this website and indicating the effective date of the revised User Privacy Policy or simply updating the User Privacy Policy. You will be notified of any material changes to this User Privacy Policy via Messages under My Account on the snagRC website and/or by email.

2. What personal data we collect and process

We do not collect any personal information about you unless you voluntarily provide it to us. We collect your personal data when you use our Services, create a new snagRC account, provide us with information via a web form, add or update information in your snagRC account, or otherwise interact with us.

In total, we collect the following personal data:

2.1 Personal data you provide when using our Services or creating a snagRC account

· Data that identifies you, such as your name, address, telephone numbers or email addresses and your user name,

· Data regarding bids, purchases, or sales that you provide in a transaction, as well as advertising.

· Financial information (payment details) in connection with your snagRC account and related transactions.

· Shipping, billing, and other information you provide in connection with the purchase or shipping of an item, and relevant shipping information (such as shipment numbers and tracking information) if provided by the shipper.

· You may provide us with additional information through a web form or by updating or adding information to your snagRC account, by participating in, member chats, inquiries, dispute resolution, customer service interaction, or if you contact us for any other reason regarding our Services.

· Other data that we are required or entitled by applicable law to collect and process and that we need for your authentication or identification, or for the verification of the data we collect.

· Content that you share with other users through our messaging tools.

2.1A What happens when you share your personal data on our sites or applications?

snagRC collects and uses your personal information to operate its website(s) and deliver the services you have requested. snagRC may also use your personally identifiable information to inform you of other products or services available from snagRC and its affiliates.

Other users have access to the information you share on snagRC or disclose to other users. For example, other users can see your bids, purchases, items for sale, saved interests, sellers and searches, storefronts, feedback, ratings, product reviews and associated comments. Other users can also see any information you chose to share in your profile.

When you use our Services, your public user ID may be displayed and available to the public and associated with all of your public snagRC activity. Notices sent to other users about suspicious activity and notice violations on our sites may refer to your public user ID and specific items. Accordingly, if you use a username that allows others to identify you, these others may be able to identify your snagRC activities.

To help protect your personal data, we allow only limited access to other users' contact, shipping and financial information as necessary to facilitate your transactions and collect payments. However, when users are involved in a transaction, they have access to each other's name, user ID, email address and other contact and shipping information. For example, we may allow users to exchange telephone numbers in order to contact each other prior to completing a transaction (e.g. a seller may opt to share their telephone number with a buyer so that the buyer may call with questions about a listed item). In this case, sellers are prohibited from using a buyer's telephone number for other purposes (e.g. completing a transaction off snagRC or adding the buyer to a marketing list).

Your responsibilities over transactional information you receive through snagRC

When you complete a transaction with another user (or a transaction has been cancelled, failed, or subsequently invalidated), we will provide you with the other user's personal data (such as name, username, email address, contact information, shipping and billing information). Independent from us, you are the controller of such data and responsible for any processing that you perform after we have shared this data with you, including compliance with any limitations imposed by this User Privacy Notice and our User Agreement..

Unless you act for purely personal purposes, we recommend that you explain your data processing activities in your own privacy notice and protect the privacy of other users. As a seller, you must in any case comply with the applicable data protection laws and in particular protect the rights of other users as data subjects, e.g. give them the opportunity to access the personal data collected by you and demand that it be erased.

You may use the personal data that you have access to only for snagRC transaction-related purposes, or for other Services offered through snagRC (such as shipping, fraud complaints, and member-to-member communications), and for purposes expressly consented by the user to whom the data relates. Using personal data of other users that you have access to for any other purpose constitutes a violation of our User Agreement.

Personal data relating to third parties

If you provide us with personal data relating to another person, you must obtain the consent of this person or the disclosure of the data to us must be otherwise legally permissible. You must inform the other person of how we process personal data in accordance with our User Privacy Notice.

Filtering of messages sent via our messaging tools

We filter the messages sent via our messaging tools automatically according to certain criteria and check conspicuous messages manually if necessary. The messages are first received by us and then forwarded to the recipient. All messages are automatically filtered according to certain criteria. If necessary, conspicuous messages are checked manually by our customer service. In the event of a violation of our User Agreement (including any of our rules and policies), we reserve the right to block the transmission of the message and to restrict the purchase and sales functions of your snagRC account or to block your snagRC account.

This is to protect legitimate interests such as protecting against fraudulent or suspicious activities (e.g. spam, viruses, phishing, or other illegal activities) or enforcing our User Agreement and our other rules and policies (e.g. illegal and other prohibited content), including but not limited to enforcing the prohibition of purchases and sales outside of snagRC.

Are you obliged to provide your personal data to us?

Some of the personal data that you provide to us (e.g. data by which we can identify you) are required to enter into the User Agreement and any third party Payments Services Agreement. The provision of any other personal data is voluntary, but may be necessary for the use of our Services, such as bidding, purchase and sales data to complete a transaction.

Children's Privacy

Our services are not intended for the use by children. We do not knowingly collect personal data from users who are considered children under applicable national laws. Under our User Agreement, children are not permitted to use our Services.

Staying Signed in

When you sign in to your account on our Services, we give you the option to stay signed in to your account for certain amount of time. If you are using a public or shared computer, we encourage you not to choose to stay signed in. You or any other user of the computer/browser you signed in on will be able to view and access most parts of your account and take certain specific actions during this signed in period without any further authorization. The specific actions and account activities that you or any other user of this computer/browser may take include:

Bid, buy or make an offer on an item

Check out or add items to your cart

Purchase an item with PayPal

View the activity on the account

View the My Account page or related Dashboard activities

View or edit the Watch List or order details

View the profile page

Send member-to-member messages

Conduct after-sale activities, like leaving Feedback, canceling orders, requesting returns or submitting claims

If you attempt to change your password or user ID, update any other account information or attempt other account activity beyond those listed above, you may be required to enter your password.

You can typically end your signed in session by either signing out and/or clearing your cookies. If you have certain browser privacy settings enabled, simply closing your browser may also end your signed in session. If you are using a public or shared computer, you should sign out and/or clear your cookies when you are done using our Services to protect your account and your personal data.

2.2 Personal data we collect automatically when you use our Services or create a snagRC account

· Data that is generated as part of one of your transactions (bids, purchases, sales) or that is linked to your snagRC account as a result of a transaction in which you are involved, such as transaction amounts, time and location of transactions and payment methods.

· Data that is generated through your other actions when you use our Services and which is linked to your snagRC account, e.g. when you place items in your shopping cart, place items on the watch list, save sellers, searches or interests, or follow users.

· Data regarding all other interactions with our Services, your advertising preferences, and your communications with us.

· Location data, including the location data of your mobile device. Please note that for most mobile devices, you can manage or disable the use of location services for all applications in the settings menu of your mobile device.

· Computer and connection information, such as statistics regarding your use of services from snagRC, information on data traffic to and from websites, referral URL, information on advertisements, your IP address, your access times, your browser history data, your language settings and your weblog information.

2.3 Personal data we collect in connection with the use of cookies and similar technologies

We use cookies, web beacons and similar technologies to collect data while you use our Services. We collect this data from the devices (including mobile devices) that you use our Services with. The data collected includes the following usage- and device-related information:

· Data about the pages you visit, the access time, frequency and duration of visits, the links on which you click and other actions you take as part of your use of our Services and in advertising and email content.

· Data about your activities and interactions with our advertising partners including data about the advertisements you were shown, how often they were shown, when and where they were shown, and whether you took any action, such as clicking on an advertisement or making a purchase.

· Your user segment.

· Model or device type, operating system and version, browser type and settings, device ID or individual device identifier, advertisement ID, individual device token, and cookie-related data (e.g. cookie ID).

· The IP address from which your device accesses the Services.

· Location data, including the location data of your mobile device. Please note that most mobile devices allow you to manage or disable the use of location services for all applications in the settings menu.

2.4 Social network and email provider data you share with us

· We allow you to share personal data with social networks, to use social networks or email service providers to create a snagRC account or to link your snagRC account to a social network. These social networks may automatically provide us with access to certain personal data they have stored about you (e.g. content you have viewed or enjoyed, information about the advertisements you have been shown or clicked on, etc.). You can determine the personal data that we can access through the privacy settings of each social network.

· If you give us access to video content pages, your grant of access is your consent that we may, for at least two years, or until you withdraw your consent or are no longer connected to the social network, share with and collect from social networks information regarding your viewing of videos.

· We may also use plug-ins or other technologies from various social networks. If you click on a link displayed through a social network plug-in, you voluntarily connect to that social network.

3. Purposes and legal basis for data processing and categories of recipients

We process your personal data for various purposes and pursuant to various legal bases. We process your personal data primarily to provide and improve our Services, to provide you with a personalized user experience on this website, to contact you about your snagRC account and our Services, to provide customer service, to provide you with personalized advertising and marketing communications, and to detect, prevent, mitigate and investigate fraudulent or illegal activity. We may also share your information with third parties for these purposes.

Learn more

Below you will find a summary of the purposes for which we process your personal data, including the categories of recipients to whom we transmit personal data for the purposes stated, sorted by legal basis:

3.1 We process your personal data in order to fulfil our contract with you and to provide you with our Services. This includes the following purposes:

· Processing of data relating to you or your company for the purpose of entering into a contract with you and executing it.

· Provision of our Services, including but not limited to enabling and performing transactions with other users (including the transmission of your personal data to other users where necessary to perform the transaction, including in cases of terminated, failed or subsequently voided transactions), providing and enhancing features such as payment processing, ratings and snagRC account management, providing other services you may use (as described in connection with such services), and ensuring the functionality of our Services. In connection with the provision of our Services, we will send you notifications relating to the execution of transactions and the use of our Services in accordance with the communication preferences in your snagRC account.

· Enabling the delivery of purchased items by logistics/shipping service providers including notifications in connection with the delivery (such as tracking information), the latter to the extent permitted by applicable law without your consent.

· Provision of third party payment service.

· Solution of problems with your snagRC account, arbitration of disputes, providing other services within the scope of customer service as well as enforcement of fee claims. For these purposes, we may contact you via notification in the snagRC messages panel, email, telephone, or by mail.

· Processing of general location data (such as IP address or postal code) in order to provide you with location-based services (such as radius search and other content that is personalized on the basis of your general location data).

· Enforcement of our User Agreement, this User Privacy Notice and other rules and policies.

· Publication and promotion of your listings and related content on the websites or in the applications, services and tools. Where necessary, we transmit your personal data to processors and the following recipients for one or several of the purposes described above:

· Other snagRC users

· External service providers and shipping companies (such as UPS, FedEx, USPS, etc.)

· Payment service providers including PayPal and Stripe.

· External operators of websites, applications, services and tools.

3.2 We process your personal data in order to comply with legal obligations to which we are subject. This includes the following purposes:

· Participation in investigations and proceedings (including judicial proceedings) conducted by public authorities or government agencies, in particular, for the purpose of detecting, investigating and prosecuting illegal acts.

· Prevention, detection and mitigation of illegal activities (e.g. fraud, money laundering and terrorist financing).

· Complying with information requests from third parties based on any statutory information rights they have against us (e.g. in the event of an intellectual property infringement, product piracy, or other unlawful activity).

· Ensuring the information security of our Services.

· Retention and storage of your personal data to comply with specific legal retention requirements

Your personal data will be stored by us and our service providers in accordance with applicable data protection laws to the extent necessary for the processing purposes set out in this User Privacy. Subsequently, we will delete your personal data in accordance with our data retention and deletion policy or take steps to properly render the data anonymous, unless we are legally obliged to keep your personal data longer (e.g. for legal compliance, tax, accounting or auditing purposes). In Europe, the retention periods are generally between 6 and 10 years (e.g. for contracts, notifications and business letters). As far as legally permissible or required, we restrict the processing of your data instead of deleting it (e.g. by restricting access to it). This applies in particular to cases where we may still need the data for the execution of the contract or for the assertion of or defense against legal claims, or where such retention is otherwise required or permitted by law. In these cases, the duration of the restriction of processing depends on the respective statutory limitation or retention periods. The data will be deleted after the relevant limitation or retention periods have expired.

Where necessary, we transmit your personal data to processors and the following recipients for one or several of the purposes described above:

· Law enforcement agencies, courts, government agencies or public authorities or intergovernmental bodies.

· Third party service providers

· Third parties who are involved in judicial proceedings, in particular, if they submit a legal order, court order or equivalent legal order to us.

· Credit agencies or bureaus, data verification services, risk assessment vendors and collections agencies (e.g. information about payment delays, payment defaults, or other irregularities that may be relevant to your credit report, or that we use to confirm your identity, model risk, establish credit limits, or collect unpaid debts)

3.3 We process your personal data in order to protect your vital interests or the vital interests of another natural person and where necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by your interests or fundamental rights and freedoms. This includes the following purposes:

· Prevention, detection, mitigation and investigation of unlawful activities that may result in impairment of your vital interests or the vital interests of another natural person, unless there is a statutory obligation to this effect.

Where necessary, we transmit your personal data to processors and the following recipients for one or several of the purposes described above:

· Law enforcement agencies, courts, government agencies or public authorities, intergovernmental or supranational bodies

· Third parties who are involved in judicial proceedings

· External service providers

· Provision of functions for users that make the processing of transactions easier or more convenient (e.g. administration of several delivery addresses).

· Advertisements by mail (according to your communication preferences in your snagRC account).

· To the extent permitted by applicable law without your consent, communications with you via electronic mail (e.g. email) or telephone to offer you vouchers, discounts and special offers, to conduct opinion polls and surveys, and to inform you about our Services (according to your communication preferences in your snagRC account). If you do not wish to receive marketing communications from us, you can also unsubscribe by clicking on the link in the email you received. For technical reasons, the implementation may take a few days.

· Notifications regarding promotions and information about our Services after logging into your account or in My Messages in My Account (according to your communication preferences in your snagRC account).

· Customization of page content to display the items and services you may like based on the actions you take.

· Evaluation of the quality and success of our email marketing campaigns (e.g. through analysis of opening and click rates).

· Assertion of or defense against legal claims, including those asserted by one snagRC user against another snagRC user.

Where necessary, we transmit your personal data to processors and the following recipients for one or several of the purposes described above:

· External service providers

· Other snagRC users

· Third parties who are involved in judicial proceedings

· Payment service providers including PayPal and Stripe.

· Other companies in the context of a company acquisition

3.4 With your consent, we process your personal data for the following purposes:

· Marketing communications by electronic mail including communications by third parties, unless these communications are permitted without your consent under applicable law

· Processing of your exact location data to provide location-based services

· Processing of your personal data on the basis of your consent, which you have given so that we or third parties can enable you to use certain services or make them available to you

Except as set forth above, snagRC does not rent, sell or share information about you with other people or non-affiliated companies except to provide products or services you’ve requested, when we have your written permission

4. Storage duration and erasure

· Necessity for the provision of our Services

This includes such things as executing the User Agreement with you, maintaining and improving the performance of our products, keeping our systems secure, and maintaining appropriate business and financial records. Most of our retention periods are determined on the basis of this general rule.

· Special categories of personal data

If we store special categories of personal data, a shorter retention period is usually appropriate.

· Consent-based processing of personal data

If we process personal data on the basis of consent (including consent to the extended storage), we store the data for as long as necessary in order to process it according to your consent.

· Statutory, contractual or other similar obligations

Corresponding storage obligations may arise, for example, from laws or official orders. It may also be necessary to store personal data with regard to pending or future legal disputes. Personal data contained in contracts, notifications and business letters may be subject to statutory storage obligations depending on national law.

5. Rights as a data subject

Subject to possible restrictions under national law, as a data subject, you have the right to access, rectification, erasure, restriction of processing and data portability with regard to your personal data. In addition, you can withdraw your consent and object to our processing of your personal data on the basis of our legitimate interests.

Your rights in detail:

· You can withdraw your consent to the processing of your personal data by us at any time. As a result, we may no longer process your personal data based on this consent in the future. The withdrawal of consent has no effect on the lawfulness of processing based on consent before its withdrawal.

· You have the right to obtain access to your personal data that is being processed by us. In particular, you may request information on the purposes of the processing, the existence of the right to request rectification or erasure of personal data or to object to such processing,. Your right to access may be limited by national law.

· You have the right to obtain from us without undue delay the rectification of inaccurate personal data concerning you. Taking into account the purposes of the processing, you have the right to have incomplete personal data completed, including by means of providing a supplementary statement.

· You have the right to receive the personal data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format.

If your personal data is processed on the basis of our legitimate interests, you have the right to object to the processing of your personal data on grounds relating to your particular situation. This also applies to profiling. If your personal data is processed by us for direct marketing purposes, you have the right to object at any time to the processing of your personal data for such marketing, which includes profiling to the extent that it is related to such direct marketing.

The exercise of the above data subjects' rights is generally free of charge. Where requests are manifestly unfounded or excessive, in particular because of their repetitive character, we may charge an appropriate fee (at most our actual costs) in accordance with the applicable statutory regulations or refuse to process the application.

You can exercise your rights as a data subject via our Resolution Center. If you would like to change your preferences regarding snagRC notifications (including marketing communications), you can do so at any time in Site Preferences under My Account. If you do not wish to receive marketing communications from us, you can also unsubscribe by clicking on the link in the email you received. For technical reasons, the implementation may take a few days.

Opt-Out & Unsubscribe from Third Party Communications

We respect your privacy and give you an opportunity to opt-out of receiving announcements of certain information. Users may opt-out of receiving any or all communications from third-party partners of snagRC by contacting us through the resolution center.

E-mail Communications

From time to time, snagRC may contact you via email for the purpose of providing announcements, promotional offers, alerts, confirmations, surveys, and/or other general communication.

If you would like to stop receiving marketing or promotional communications via email from snagRC, you may opt out of such communications by clicking on the UNSUBSCRIBE button.

6. Cookies & similar technologies

When you use our Services, we and selected third parties may use cookies and similar technologies to provide you with a better, faster and safer user experience or to show you personalized advertising. Cookies are small text files that are automatically created by your browser and stored on your device when you use the Services.

Our cookies and similar technologies have different functions:

· They may be technically necessary for the provision of our Services

· They help us optimize our Services technically (e.g. monitoring of error messages and loading times)

· They help us improve your user experience (e.g. save font size and form data entered)

We use cookies and similar technologies that remain on your device only as long as your browser is active (session cookies), as well as cookies and similar technologies that remain on your device longer (permanent cookies). Where possible, we take appropriate security measures to prevent unauthorized access to our cookies and similar technologies. A unique ID ensures that only we and/or selected third parties have access to cookie data.

Your choices regarding cookies

You are free to disable the use of cookies and similar technologies if this is supported by your device. You can manage your cookie settings in your browser or device settings.:

You can find information about third-party cookies (and similar technologies) related to advertising and how to prevent their use on the following websites:

· www.youronlinechoices.eu

· www.aboutads.info/choices (only available in English)

· www.networkadvertising.org/choices (only available in English)

Links

This website contains links to other sites. Please be aware that we are not responsible for the content or privacy practices of such other sites. We encourage our users to be aware when they leave our site and to read the privacy statements of any other site that collects personally identifiable information.

7. Data security

We protect your personal data through technical and organizational security measures to minimize risks associated with data loss, misuse, unauthorized access and unauthorized disclosure and alteration. To this end we use firewalls and data encryption, for example, as well as physical access restrictions for our data centers and authorization controls for data access.

We strive to take appropriate security measures to protect against unauthorized access to or alteration of your personal information. Unfortunately, no data transmission over the Internet or any wireless network can be guaranteed to be 100% secure. As a result, while we strive to protect your personal information, you acknowledge that: (a) there are security and privacy limitations inherent to the Internet which are beyond our control; and (b) security, integrity, and privacy of any and all information and data exchanged between you and us through this Site cannot be guaranteed.

We have physical, electronic, and procedural safeguards that comply with federal and other applicable rules and regulations to protect Information about you. However, we cannot absolutely guarantee the strict confidentiality of your Information.

8. Unwanted or threatening email

We do not tolerate abuse of our Services. You do not have permission to add other users to your mailing list (email or postal), call, or send him/her text messages for commercial purposes, even if this user purchased something from you, unless the user has given his/her explicit consent. Sending unwanted or threatening email and text messages is against our User Agreement.

Change of ownership

If we are subject to a merger or acquisition with/by another company, we may share information with them in accordance with our global privacy standards. Should such an event occur, we will require that the new combined entity follow this privacy notice with respect to your personal information. If we intend to handle your personal information for any purposes not covered in this privacy notice, you will receive prior notification of the processing of your personal information for the new purposes.