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PRIVACY POLICY

The owner and operator of the websites suprisingmarket.com. and any and all applications or mobile applications offered by us, (each a “Website” and collectively the “Websites”) through its various subsidiaries (collectively, “suprisingmarket”, “us,” “we,” and “our”), wants you to know that we take your privacy seriously. 

Our Privacy Policy (“Policy”) states what information we collect, how that information is collected, for what purposes we collect information (including specifically the legal basis on which Personal Information we collect from you will be processed), how that information is used, who we share it with and under what circumstances that information would be released.   Our Policy will also explain what rights you have in relation to your Personal Information, what steps we take to secure your private information and what steps you should take to safeguard that information.Finally, our Policy will tell you who you can contact regarding questions about our Policy.   Should you require assistance or are having any trouble accessing this Policy or the Websites, please contact us at [email protected] Material changes will be communicated by posting an updated version of the Policy on this Website. 

Types of Personal Information We Collect´╝Ü
The types of information that we collect may collect from you are: 
Identifiers, such as your name, address (including, city, state, postal code, and country), email address, telephone phone number, secondary number, account name, IP address, and other information you provide to us. 

Sources of Personal Information

We collect information about you and how you interact with us in several ways, including: 
Information you provide to us directly. We collect the information you provide to us directly, such as when you register for an account with us through any of our Websites or submit information to us.

How We Use Your Personal Information:

We may use your information described in the following ways: 
To provide services to you, such as to consummate transactions with you; register and administer your account; to respond to an inquiry, complaint, or request from you. 
For legal, safety or security reasons, such as to comply with legal requirements; protect our safety, our property or rights of those who interact with us, or others; and detect, prevent, and respond to security incidents or other malicious, deceptive, fraudulent, or illegal activity. 
In a de-identified, anonymized or aggregated format. When converted to a de-identified, anonymized, or aggregated format, data no longer constitutes Personal Information and we may use this information for any purpose.   We may use and share anonymized or aggregated information with third parties. 
For marketing. We may use your Personal Information to send you e-mail alerts and newsletters regarding upcoming auctions, sales events and information about our products and services which we anticipate may be of interest to you. 
For any other purposes for which you provide consent. 

We do not sell or release your Personal Information to any third party (except as set out in this Policy) without your consent, unless we are required to by law, or in the good-faith belief that such action is necessary to conform to the edicts of the law or comply with an official investigation by a law enforcement organization. 
We may share your Personal Information with the categories of recipients described below: 
Service providers: We may share your Personal Information with external service providers such as Salesforce, Oracle Eloqua, Amazon Web Services and Microsoft Azure whose services we may utilize from time to time to assist us in our provision of services to you and to assist us in carrying out our business activities. We will only share your information where it is lawful and required for the provision of services to you or where you have consented to this. 
For legal, security and safety purposes: In case of a subpoena, court order or official request, we may share your Personal Information to investigate, prevent or take action regarding suspected illegal activities, fraud or potential threats, or exercise legal rights or defend against claims, when we believe that doing so may protect your safety or the safety of us or others, or as otherwise permitted or required by law. 
In connection with a corporate transaction or other corporate reason: As we continue to develop our business, we may sell or purchase assets. If another entity acquires us or merges with us your Personal Information will be disclosed to such entity. 

Auditing Purposes: We may provide transaction-related information to government or private auditors to inspect or validate our business practices, accounting records, or financial reports.Any release of information for such a purpose will be done under standard confidentiality restrictions. 

Data protection laws require that there is a specific lawful basis for processing. We process your Personal Information when our interests are not overridden by your data protection rights. 
Where you provide Personal Information to us for the purposes of an enquiry, the basis for processing is that it is required as a legitimate interest of ours as a business to respond to your enquiry. 

Where we process your Personal Information for the purposes of sending you marketing communications (such as buy alert emails, information on upcoming sales events, special announcements, etc.), we will rely upon the legal basis of legitimate interests and/or consent (if required and obtained) for processing your Personal Information for those purposes. You have the right to withdraw consent at any time. Where consent is the only legal basis for processing, we will cease to process data after consent is withdrawn 

Where we process your Personal Information to comply with our legal and regulatory obligations we rely on the legal basis that such processing is required in order to fulfil a legal obligation. 


Before we alter the reason for using any Personal Information you have provided to us, we will notify you of our intended change in use of that information, ensuring such use complies with applicable data protection law and where necessary obtain your consent prior to using your Personal Information in a new way. 

How Long Do We Retain Your Personal Information? 
We retain your Personal Information for no longer than is necessary for the purposes for which the information is collected and in line with this Policy. When determining the relevant retention periods, we will take into account factors including: 
contractual obligations to you; 
legal obligation(s) under applicable law to retain data for a certain period of time; 
statute of limitations under applicable law; 
(potential) disputes; 
for compliance, regulatory and auditing purposes; and guidelines issued by relevant national data protection regulators. 
Otherwise, we securely anonymise or erase your Personal Information once it is no longer required. For further information about how long we will keep your Personal Information, please contact us using the contact details provided in the contact us section below. 

The right to data portability. You have rights to obtain and reuse your personal data for your own purposes across different services. For example, if you decide to switch to a new provider, this enables you to move, copy or transfer your information easily between our IT systems and theirs safely and securely, without affecting its usability. This is not a general right however and there are exceptions. 

The right to object to processing. You have the right to object to certain types of processing, including processing for direct marketing (i.e. receiving emails from us notifying you about other services we provide which we think may be of interest to you or being contacted with varying potential opportunities). You may change your preferences regarding email communications by contacting us. 

The right to lodge a complaint. You have the right to lodge a complaint about the way we handle or process your personal data with your national data protection regulator. 

The right to withdraw consent. If you have given your consent to anything we do with your personal data (i.e we rely on consent as a legal basis for processing your Personal Information), you have the right to withdraw your consent at any time (although if you do so, it does not mean that anything we have done with your personal data with your consent up to that point is unlawful). You can withdraw your consent to the processing of your Personal Information at any time. We usually act on requests and provide information free of charge but may charge a reasonable fee to cover our administrative costs of providing the information for baseless or excessive/repeated requests, or further copies of the same information. Alternatively, we may be entitled to refuse to act on the request. Please consider your request responsibly before submitting it. We will respond as soon as we can. Generally, this will be within one month from when we receive your request but, if the request is going to take longer to deal with, we’ll come back to you and let you know. 

Other Rights
A user may request we discontinue the use of that person’s Personal Information. If you would like to know what information we have collected, would like any information purged, or would like for us to discontinue using Personal Information, please contact [email protected] The return of certain Personal Information by us may prevent you from accessing all or certain portions of our Websites, and we will endeavour to communicate to you the extent to which your request will affect your use of our Websites prior to complying with your request.

What Steps Do We Take to Secure Your Personal Information? 
We are committed to keeping your Personal Information safe and secure. 
We use appropriate technical and organizational measures to protect against the loss, misuse and alteration of Personal Information. 

Employees having access to Personal Information must undergo data privacy training and are monitored by management to ensure that adequate safeguards are used to protect the private information of our customers. Our Websites have security measures in place to protect the loss, misuse, and alteration of the information under our control. Our Websites use SSL (secure sockets layer) encryption for all sensitive data transmitted over the Internet. This includes customers adding data to the Website, and employees transmitting data off the Website. No information, including the passwords that would give access to sensitive information, ever flows over the Internet un-encrypted. 

How Can You Protect Your Personal Information?

Please note no transmission of data over the internet is completely secure. It may be possible for third parties not under the control of us to intercept or access transmissions or private communications unlawfully. Any such transmission of your information is at your own risk. For any transmission of data over the internet we recommend to use means improving data protection such as firewalls, antivirus software and similar technologies.

Never send credit card information via email. Do not release information about your account to anyone who is not authorized by you to transact business with us on your behalf. Do not tell your password to anyone. We will never ask you for your password to verify your identity.

Children

Our Websites are not directed at, marketed to, not intended for individuals  under 18 years of age nor do we knowingly collect information, including Personal Information, from children under age 18 on the Websites or offline. If you are under 18, you are not permitted to register for emails or newsletters or to otherwise submit any Personal Information to us. If a child under the age of 18 submits Personal Information to our Websites, we delete the information as soon as we discover it was provided by a child under 18 years of age and do not use it for any purpose.

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