The privacy of our website visitors is very important to us, and we are committed to safeguarding it. This policy explains what we will do with your personal information. Consenting to our use of cookies in accordance with the terms of this policy when you first visit our website permits us to use cookies every time you visit our website.

The following types of personal information may be collected, stored, and used:

• information about your computer including your IP address, geographical location, browser type and version, and operating system;
• information about your visits to and use of this website including the referral source, length of visit, page views, and website navigation paths;
• information, such as your email address, that you enter when you register with our website;
• information that you enter when you create a profile on our website—for example, your name, profile pictures, gender, birthday, relationship status, interests and hobbies, educational details, and employment details;
• information, such as your name and email address, that you enter in order to set up subscriptions to our emails and/or newsletters;
• information that you enter while using the services on our website;
• information that is generated while using our website, including when, how often, and under what circumstances you use it;
• information relating to anything you purchase, services you use, or transactions you make through our website, which includes your name, address, telephone number, email address, and credit card details;
• information that you post to our website with the intention of publishing it on the internet, which includes your username, profile pictures, and the content of your posts;
• information contained in any communications that you send to us by email or through our website, including its communication content and metadata;
• documents that you upload for registration requirements such as, passports, business license etc.
• any other personal information that you send to us.

Before you disclose to us the personal information of another person, you must obtain that person’s consent to both the disclosure and the processing of that personal information in accordance with this policy.

We may disclose your personal information to any of our employees, officers, insurers, professional advisers, agents, suppliers, or subcontractors as reasonably necessary for the purposes set out in this policy. We may disclose your personal information to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) as reasonably necessary for the purposes set out in this policy.

We may disclose your personal information:

• to the extent that we are required to do so by law;
• in connection with any ongoing or prospective legal proceedings;
• in order to establish, exercise, or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk);
• to the purchaser (or prospective purchaser) of any business or asset that we are (or are contemplating) selling; and
• to any person who we reasonably believe may apply to a court or other competent authority for disclosure of that personal information where, in our reasonable opinion, such court or authority would be reasonably likely to order disclosure of that personal information.

Except as provided in this policy, we will not provide your personal information to third parties.

• Information that we collect may be stored, processed in, and transferred between any of the countries in which we operate in order to enable us to use the information in accordance with this policy.
• Information that we collect may be transferred to the following countries which do not have data protection laws equivalent to those in force in the European Economic Area: the United States of America, Russia, Japan, China, and India.
• Personal information that you publish on our website or submit for publication on our website may be available, via the internet, around the world. We cannot prevent the use or misuse of such information by others.
• You expressly agree to the transfers of personal information described in this Section.

• We will take reasonable technical and organizational precautions to prevent the loss, misuse, or alteration of your personal information.
• We will store all the personal information you provide on our secure (password- and firewall-protected) servers.
• All electronic financial transactions entered into through our website will be protected by encryption technology.
• You acknowledge that the transmission of information over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.
• You are responsible for keeping the password you use for accessing our website confidential; we will not ask you for your password (except when you log in to our website).

We may update this policy from time to time by publishing a new version on our website. You should check this page occasionally to ensure you understand any changes to this policy. We may notify you of changes to this policy by email or through the private messaging system on our website.

You may instruct us to provide you with any personal information we hold about you; provision of such information will be subject to the following:

• the supply of appropriate evidence of your identity (for this purpose, we will usually accept a photocopy of your passport certified by a notary plus an original copy of a utility bill showing your current address).

We may withhold personal information that you request to the extent permitted by law.

You may instruct us at any time not to process your personal information for marketing purposes.

In practice, you will usually either expressly agree in advance to our use of your personal information for marketing purposes, or we will provide you with an opportunity to opt out of the use of your personal information for marketing purposes.

Our website includes hyperlinks to, and details of, third party websites. We have no control over, and are not responsible for, the privacy policies and practices of third parties.

Please let us know if the personal information that we hold about you needs to be corrected or updated.

A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server. Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed. Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.

We use first party and third party cookies for several reasons. Some cookies are required for technical reasons in order for our Websites to operate, and we refer to these as "essential" cookies. Other cookies also enable us to track and target the interests of our users to enhance the experience on our Website. For example, AuctionXM keeps track of the Websites and pages you visit within AuctionXM, in order to determine what portion of the AuctionXM Website is the most popular or most used. This data is used to deliver customized content within the AuctionXM Website. Third parties serve cookies through our Websites for advertising, analytics and other purposes. This is described in more detail below:

• Essential website cookies: These cookies are strictly necessary to provide you with services available through our Websites and to use some of its features, such as access to secure areas.
• Analytics cookies: These cookies collect information that is used in aggregate form to help us understand how our Website is being used or how effective our marketing campaigns are.

Below is a list of cookies used by AuctionXM:

Most browsers allow you to refuse to accept cookies—for example:

• in Internet Explorer (version 10) you can block cookies using the cookie handling override settings available by clicking “Tools,” “Internet Options,” “Privacy,” and then “Advanced”;
• in Firefox (version 24) you can block all cookies by clicking “Tools,” “Options,” “Privacy,” selecting “Use custom settings for history” from the drop-down menu, and unticking “Accept cookies from sites”; and
• in Chrome (version 29), you can block all cookies by accessing the “Customize and control” menu, and clicking “Settings,” “Show advanced settings,” and “Content settings,” and then selecting “Block sites from setting any data” under the “Cookies” heading.

Blocking all cookies will have a negative impact upon the usability of many websites. If you block cookies, you will not be able to use all the features on our website.