Trader Interactive, LLC Privacy Policy

Last Update: 02/01/2024

TABLE OF CONTENTS

1. Scope of the Privacy Policy
2. Summary
3. Information We Collect
4. How We Use, Share, or Disclose Information
5. How We Store Information
6. How We Secure Information
7. Privacy Choices
8. Children and Our Services
9. Residents of the State of California
10. Users Located in the UK or European Union
11. Changes to This Privacy Policy

1. SCOPE OF THE PRIVACY POLICY

Trader Interactive, LLC (“Trader Interactive”, “we”, or “us”) owns and/or operates a number of specialty marketplace websites (“marketplaces” or “websites”) that connect buyers, original equipment manufacturers (“OEMs”), sellers, and owners of various types of vehicles and equipment, including boats, motorcycles and other powersports equipment, private aircraft, and commercial equipment and vehicles. We believe that when you visit our marketplaces, you should always know what personal data we collect from you and how we use it, and that you should have meaningful control over both. To further that purpose, we provide this Privacy Policy to consumer visitors and users of any website or webpage/webform owned or operated by Trader Interactive or its affiliates that links to or displays this Privacy Policy. Please note that this Privacy Policy does not generally apply to our business customers (e.g., sellers or owners advertising on our websites) – if you are a business customer, please see your contract with Trader Interactive for more information regarding your use and participation in our marketplaces.

2. Summary

You should read this Privacy Policy in full, but below we have provided a brief summary of the key takeaways:

• The purpose of our marketplaces is to share the information provided by an interested buyer with those specific third-party sellers or owners identified by the interested buyer. Certain of our marketplaces include “blind listings”, in which case interested buyers will not receive identifying information of any third-party seller or owner unless and until they submit an online interest form with respect to a specific vehicle or equipment listing.
• We also develop and/or operate marketplace webpages on behalf of OEMs, to enable them to display inventory from various dealerships on one website. Interested buyers that interact with our OEM marketplaces will be connected with both the OEM and the identified dealer.
• If you are interested buyer, after you have been connected with a seller, owner, or OEM regarding your interest, any subsequent personal information or additional information you share directly with a seller, owner, or OEM via any method is not covered by this Privacy Policy.
• Trader Interactive does not broker, sell, or lease any motor vehicles, recreational vehicles, boats, or other vehicles or equipment.
• Visitors don’t have to provide any information to search our marketplaces, check the prices of different vehicles, explore the inventory a specific seller or owner is offering, or otherwise browse our marketplaces. However, when you use Trader Interactive’s websites, even if you simply search our marketplaces, we receive some personal information from you, such as the type of device you’re using and your IP address. We also use tracking data during your active session on our marketplaces so you can move around the site and go back to previously visited information without losing that information.
• You can choose to share additional information with us, including your email address, phone number, mailing address, or phone number. For example, if you submit an online interest form with respect to a listed vehicle, you will be asked to provide certain information so that we can connect you with the listing seller.
• As a seller or owner advertising on our marketplaces or listing inventory for sale, you are a third-party business customer of Trader Interactive and this Privacy Policy does not generally apply to you. (However, if you are a business customer residing in the State of California, please see the “Residents of the State of California” section of this Privacy Policy.) Instead, your use and participation in our marketplaces, including the information you provide, will be governed by your contract with Trader Interactive as well as by other separate terms, conditions, and agreements as posted at the bottom of each marketplace page. If you are a business customer, you will provide Trader Interactive with detailed information on your business and your inventory. You will designate employees as key contacts (and provide their detailed business contact information) for your Trader Interactive relationship. All information you provide to Trader Interactive should be tied to your business or dealership – please don’t provide any personal contact information or data as part of our business relationship.
• Trader Interactive is a subsidiary of carsales Holdings US, LLC. We may share your information from our marketplaces with the marketplaces or affinity sites of our parent company and/or direct or indirect affiliates and subsidiaries of our parent.
• If you have questions about this Privacy Policy, how we collect or process your personal information, or anything else related to our privacy practices, we want to hear from you. You can contact us at any time at our Contact Us page or by email at privacy@traderinteractive.com.

3. INFORMATION WE COLLECT

A. Information You Share With Us Whether you are a buyer, seller, or owner, you can generally browse our marketplaces without creating an account or providing your personal information. (As used in this Privacy Policy, “personal information” or “personal data” means information that is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to an individual person.) However, in order to access or utilize some features of our marketplaces, you will be required to provide certain information. Below is a summary of when you may need to share your personal information with us and what kinds of information you may be required to share.

• Request and Account Information:If you choose to create an account on our marketplaces, receive our newsletters, participate in sweepstakes/giveaways, or engage in other marketplace activities (aside from basic searching), you must provide us with some personal information so we can enroll you in those services or set up your account. Each contact form, interest form, account set-up, or reservation request identifies the required personal information fields to be completed prior to submitting it to us, which may include email address, first and last name, phone number, and account login credentials, among other information. Additional fields may be shown but are not required to complete your submission – if you volunteer additional personal information, we will treat it in accordance with this Privacy Policy.
• Public Information – Customer Reviews:
  • Some of our marketplaces include the ability for buyers to provide reviews or comments on sellers of vehicles or equipment. Your comments and reviews are posted publicly on our marketplace. Prior to posting your review or comments, we will use reasonable efforts to assess your posting to ensure it meets our content standards and is not inappropriate, offensive, or discriminatory, but we are not and cannot be liable or otherwise responsible for any legal or other claims that arise out of or relate to any of your comments, reviews, or other personal submissions. Please note that any personal information you post may be visible to everyone on the website.
  • If you would like to have your posted customer review removed from a marketplace, please send us a request through our Contact Us page. Please provide sufficient information to help us to identify the customer review that you wish to have removed. We may contact you if we require additional evidence to verify that you are the author of the review. Please note, even if we delete your customer review from the marketplace, copies of your review may remain viewable in cached and archived pages, or might have been copied or saved by other users.
• Social Media Accounts: You may choose to follow Trader Interactive or our marketplaces via provided links to our social media accounts, including Facebook, X, LinkedIn, or Instagram. We will have visibility into the connection information you share via these social media platforms. You may also choose to use your Facebook or Google accounts to sign-in and create a MyTrader user account. According to your privacy settings on those platforms, these social or sign-in connections with our marketplaces may automatically provide us with access to certain personal information they have stored about you (such as content you have viewed or enjoyed, information about the advertisements you have been shown or clicked on, etc.).
• Payment Information: Trader Interactive does not process payments for any parties on our marketplaces. When you are ready to complete a payment transaction allowed via our marketplaces, your payment will be completed by a third-party payment processing company identified at checkout. The third party processor will accept and store your payment information, process your payment transaction, and provide confirmation back to you, the owner, and us, as applicable, that your payment has completed successfully. Please refer to the applicable payment processor’s privacy policy available at the bottom of their website when you provide your payment information.
• Other Data You May Share with Our Company: In addition to your interaction with our marketplaces, you may share information about yourself and your interests through:
  • Information that you provide by completing and submitting “help” inquiries. This includes requesting specific services or support that may be tied to an account or other relationship you have with our marketplaces.
  • Records and copies of your correspondence (including email addresses), if you contact us, including through the “Contact” or “Send Us Feedback” page of our marketplaces.
  • Information you share in the free-from text box on our email inquiry form that could include additional personal information we did not specifically request from you. Other information you provide in that text box that could identify you and could be used to associate you to an existing account or other relationship with our company or marketplaces.

You control how and what you share with our marketplaces. If you would like to limit the information you provide or otherwise make a request with respect to your information, below are a few actions you can take. Please also see the “Privacy Choices” section of this Privacy Policy.

• Only share your personal information when you want to be connected to a seller, and be contacted on a vehicle or piece of equipment. You can search and look without providing any information or identifying yourself.
• If you have a MyTrader account, you can update and change the information associated with your account via our marketplaces. The account information clearly shows what information is required to maintain your account. It is your choice to enter additional information on optional fields.
• MyTrader account holders may also send us an email at privacy@traderinteractive.com to request access to correct or delete any personal information that you have provided to us. Some of your personal information cannot be deleted by us except by also deleting your user account. We may not accommodate a request to change information if we cannot verify the personal information relates to you or if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

B. Automatic Collection As noted above, we often collect your personal information when you submit it to us in connection with your use of our marketplaces. However, as described below, we may also use automatic data collection technologies to collect certain information.

• Location Information: We require information about current location, which we get from signals such as your IP address or device settings, to determine content and services available to you through our marketplaces. We use one or more outside vendors to resolve your IP address during a browsing session to a location. We do not retain your IP address as part of your activity or account.
• Links:
  • Our marketplaces may provide links or references to third party sites that we do not operate and/or that will allow you to leave our websites or open an additional browser connecting you to the third party site. Any such links to third party sites are provided merely as a convenience to you, and such links do not imply endorsement by Trader Interactive of such other third party sites or the content contained therein. Trader Interactive disclaims all liability with regard to your access to such linked websites and your use of and access to any other websites linked to any Trader Interactive website is at your own risk. Further, Trader Interactive has no responsibility for the content of such third party sites and shall not be liable for any damages or injury arising from that content or your use of, reliance on, or access to such third party sites. If you click on an external link or ad on our marketplaces, the advertiser or website operator might figure out that you came from our site, along with other information associated with the ad you clicked, such as characteristics of the audience it was intended to reach. They may also collect other personal information from you, such as cookie identifiers or your IP address. For information about such third party websites, we encourage you to consult the specific terms of use and privacy policies of such other websites.
• YouTube and Google Analytics:
  • We use YouTube API Services to provide video upload services and to store user videos, among other things. By using these optional services, you expressly agree to YouTube’s Terms of Service, currently available at https://www.youtube.com/t/terms.
  • As noted elsewhere in this Privacy Policy, we use Google Analytics to help us collect statistics on visitors to our websites. As part of this service, your web browser will automatically send certain information to Google. Please see Google’s Privacy Policy, currently available at https://policies.google.com/privacy, for more information on how Google collects and uses such information. If you would like to opt-out of having your site activity available to Google Analytics, you can download the Google Analytics Opt-Out Browser Add-On.
• Cookies, Web Beacons, and Similar Technology: We use cookies which recognize your computer or mobile device and IP address, web beacons and similar technologies to collect additional website usage data, store and read data files on your computer, and to operate our marketplaces. This is typically done to maintain your preferences or to improve speed and performance by storing certain files locally. However, these technologies can also store a unique identifier for your computer, which can be used to track behavior. When your browser or device allows it, we use both session cookies and persistent cookies to better understand how you interact with our marketplaces, to monitor aggregate usage patterns, and to personalize and otherwise operate our services such as by providing account security and personalizing the content we show you, including advertising content. We do not currently support the Do Not Track browser or any Global Opt Out/Global Privacy Control option – please see the “Privacy Choices” section of this Privacy Policy for more information on how to opt out of cookies.
• Log Data:
  • We receive information when you view content on or otherwise interact with our marketplaces, which we refer to as “Log Data,” even if you have not created an account. For example, when you visit our marketplaces, sign into your account, or interact with our email or contact forms, we may receive information about you. This Log Data includes information about your computer and internet connection, as well as details of your visit to our marketplaces. Specifically, this includes traffic data, logs, and other communication data and the resources that you accessed and used – some data may be used only during your active session (and then forgotten) while other data, such as your preferences or remembering you when you return, may persist. We may also collect IP address, browser type, operating system, the referring web page, pages visited, location (based on IP address), device information (including device and application IDs), search terms, and cookie information.
  • We use Log Data to operate our websites and services and ensure their secure, reliable, and robust performance. For example, we use Log Data to protect the security of accounts and to determine what content is popular on our marketplaces. We also use this data to improve the content we show you, including ads. Additionally, we use the information you provide to us and data we receive, including Log Data and data from third parties, to make inferences, such as topics you may be interested in, which helps us better design our websites and services for you and personalize the content we show you, including advertising content.
• Personalizing Across Your Devices: When you log into our marketplaces on a browser or via our mobile application on a device, we will associate that browser or device with your account for purposes such as authentication, security, and personalization. We may also associate your activity on one browser or device and share it with the other. We do this to operate and personalize our marketplaces and make them more relevant to you.

C. Information Provided by Third Parties In addition to collecting information directly and indirectly from you, we also receive certain information from third parties, as described below.

• Advertisers and Other Ad Vendors: Advertising revenue allows us to support and improve our marketplaces, and we use the information we collect from our advertisers, advertising vendors, and affiliates (such as browser cookie IDs, mobile device IDs, hashed email addresses, aggregated demographic or interest data, and content viewed or actions taken on a website or app) to help make our advertising more relevant to you. Some of our advertisers and advertising vendors also enable us to collect similar information directly from their website or app by integrating our advertising technology. Trader Interactive adheres to the Digital Advertising Alliance Self-Regulatory Principles for Online Behavioral Advertising (also referred to as “interest-based advertising”) and respects the DAA’s consumer choice tool for you to opt out of interest-based advertising. You can visit the Network Advertising Initiative’s Opt Out page for more information about your privacy options for interest-based ads.
• Other Third Parties and Affiliates: We may receive information about you from third parties who are not our advertisers or advertising vendors, such as vendors and service providers who help us evaluate the safety and quality of content on our websites.

4. How We Use, Share, or Disclose Information

The nature of our marketplaces requires that we share your personal information directly with the seller or owner of the vehicle or equipment you have identified in your interest/contact form to make these connections. You play a large part in what personal information we share and with whom we share it. However, in limited circumstances we may also disclose your personal information for additional purposes. We make such disclosures (a) at your direction or with your consent, (b) subject to your right to opt-out, (c) as necessary to operate our services, and/or (d) as required by law.

• Sharing You Control:
  • We share or disclose your personal information with your consent or at your direction to connect you with the designated seller or owner that has the vehicle or equipment you are interested in. If you visit a marketplace that we have developed or otherwise operate on behalf of an OEM, then we will also share your information with such OEM (in addition to the listed seller of the vehicle or equipment you are interested in).
  • Subject to your settings, we also provide certain third parties with personal information to help us offer or operate our services. For example, we share with advertisers the identifiers of devices that saw their ads to enable them to measure the effectiveness of our advertising business. You can learn more about these partnerships in our Help Center, and you can control whether we share your personal information in this way by using the “Share your data with Trader Interactive business partners” settings. Note that this setting does not control sharing described elsewhere in our Privacy Policy, such as when we share data with our service providers in the manner described below.
• Service Providers:
  • We engage service providers to perform functions and provide services to us in the United States. For example, we use third-party services such as YouTube API Services and Google Analytics to help operate our marketplaces, such as hosting our content and to help us understand the use of our services. We may share your personal information with such service providers subject to obligations consistent with this Privacy Policy and any other appropriate confidentiality and security measures. We also share data with service providers only on the condition that the third parties use your private personal information only on our behalf and pursuant to our instructions. These third parties are prohibited from further sharing or selling any of the personal information we provide to them.
  • While we don’t process your payments, we facilitate the connection to our third party payment processing providers to accept your payment data, store that data as needed, process your payment transaction, and manage any post-transaction activities. Our payment processors may send us information indicating when the charge was accepted or that it has failed or was otherwise fraudulent, or that there is a dispute on a charge made on our behalf. We may also share additional data with our payment processors to investigate and resolve activities resulting from the payment process.
• Law, Harm and the Public Interest: Notwithstanding anything to the contrary in this Privacy Policy or controls we may otherwise offer to you, we may preserve, use, or disclose your personal information if we believe that it is reasonably necessary to:
  • Comply with a law, regulation, legal process, or lawful governmental requests, including to meet national security or law enforcement requirements;
  • Protect the safety of any person;
  • Protect the safety or integrity of our marketplaces, including to help prevent spam, abuse, or malicious actors on our websites, or to explain why we have removed content or accounts from our websites;
  • Address fraud, security, or technical issues; or
  • Protect our rights or property or the rights or property of those who use our services.

However, nothing in this Privacy Policy is intended to limit any legal defenses or objections that we may have to a third party’s, including a government’s, request to disclose your personal information.

• Affiliates and Change of Ownership: If we are involved in a merger, acquisition, reorganization, or sale of assets, your personal information may be sold or transferred as part of that transaction. This Privacy Policy will apply to your personal information as transferred to the new entity. We may also disclose personal information about you to our parent company or other corporate affiliates in order to help operate our and our affiliates’ services, including the delivery of advertising content.
• Non-Personal Information: We collect, share and/or disclose non-personal information, such as anonymized or “de-identified” information and aggregated information about our customers and marketplace users, as well as the total number of times people engaged our marketplaces this month, the states those visits came from, or information related to advertising clicks or other metrics. This information does not identify any individual. All such non-personally identifiable information collected by us through our marketplaces, and all aggregated/compilations of non-personally identifiable information that we create, are the exclusive property of Trader Interactive. We may use any such non-personally identifiable or aggregated information for any lawful purpose, including monitoring user traffic patterns, analyzing and quantifying user preferences, improving the design and content of our marketplaces and other services, and personalizing your user experience, and we may share it with customers, advertisers, service providers, and other third parties.
• Other Uses. Trader Interactive also uses personal information collected from or about you, as well as non-personal information, to provide and improve our services and products, including to:
  • provide and deliver our products and services, assist with processing transactions and send related information such as confirmations and invoices;
  • send you technical notices, updates, security alerts and support and administrative messages;
  • communicate with you about products, services, offers, promotions, rewards and events offered by Trader Interactive and others, including via surveys and other marketing/promotional communications, and provide news and information we think will be of interest to you;
  • monitor and analyze trends, usage and activities in connection with our products and services;
  • revise, modify, and update existing services and products and develop new services and products;
  • personalize our services and products and present you with advertising, content or features that we believe will be of interest or useful to you, including via surveys and other marketing/promotional communications; and
  • carry out any other appropriate purpose described to you at the time the information was collected.

5. How We Store Information

Trader Interactive is located in the United States, and all information that we receive or collect is stored in the United States. This means your personal information may be subject to the laws of general application in the United States.

6. How We Secure Information

Trader Interactive employs technological and organizational measures designed and intended to ensure that your personal information is protected against unauthorized or unlawful access, use or disclosure. The security of your personal information is important to us, but please remember that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially reasonable means to protect your information, we cannot and do not warrant or guarantee the absolute safety and security of your personal information. Any transmission of information through our marketplaces is at your own risk.

7. Privacy Choices

As noted above, we believe that you should have meaningful control over the personal information we collect or receive about you. To that end, we offer you several choices with respect to your personal information:

• To Opt-Out of Cookies.
  • You have the ability to adjust your browser settings to manage how we or other websites track your browsing activity. More information can be found at StaySafeOnline.org.
  • Cookies are not required for many parts of our marketplaces, such as searching. Although most web browsers automatically accept cookies, many browser settings can be set to decline cookies or alert you when a website is attempting to place a cookie on your computer. However, some of our services may not function properly if you disable cookies.
• Accessing or Rectifying Your Personal Information:
  • You can request access to the personal information we maintain about you by contacting us at privacy@traderinteractive.com. We will respond within 30 days. We will provide you access to your personal information unless we are prohibited from doing so, for example, if providing you access violates the privacy of another person. If we cannot give you access to your personal information, we will provide you with a written explanation.
  • If you have submitted a contact or interest form that we shared with the designated seller or owner, you can obtain a copy of what we sent by filling out this Web Form. We may include, as part of your contact or interest form submission, other information that is inferred from your visit or passively obtained via third parties about you and your activity. This additional information is only included along with the contact information you provided to businesses that sell the vehicles or equipment you are interested in.
  • If you have created an account on our marketplaces, we provide you with tools and account settings to access, correct, delete, or modify the personal information you provided to us and associated with your account.
• Retention and Deletion:
  • Except as otherwise permitted or required by applicable law or regulation, (1) we keep Log Data for a maximum of 18 months and (2) we retain all other personal information for as long as reasonably necessary to fulfill the purposes we collected it for, as required to satisfy any legal, accounting, or reporting obligations (including bona fide record retention policies), or as necessary to resolve disputes. To determine the appropriate retention period for personal information, we consider our legal obligations, the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information, and whether we can achieve those purposes through other means.
  • If you would like to deactivate and delete your MyTrader account, please send a request to privacy@traderinteractive.com. When deactivated, your MyTrader account will no longer be viewable on our marketplaces. For up to 30 days after deactivation, it is still possible to restore your account if it was accidentally or improperly deactivated. The account and all data in the account will be deleted if you take no action within 30 days after it was deactivated.
• Object, Restrict, or Withdraw Consent: When you are logged into your MyTrader account, you can manage your settings and other account features through your account at any time.
• Portability: If you would like a copy of the personal information you have shared through our marketplaces, please send a request to privacy@traderinteractive.com. We will endeavor to provide such information in a portable format that is easily transferable to others.

Additional Information or Assistance: Thoughts or questions about this Privacy Policy? Please let us know by emailing us at privacy@traderinteractive.com or writing to us at the address below. The data privacy officer responsible for your personal information can be contacted at: Trader Interactive, LLC Attn: Privacy Requests 4525 Main Street Suite 1101 Virginia Beach VA, 23462

8. Children and Our Services

Our marketplaces assume all users expressing interest in purchasing vehicles or equipment from our sellers and owners are of majority age, can sign a contract, have a payment form issued in their name, and have a valid driver’s license. Our services are not directed to children, and you may not use our services if you are under the age of 18. You must also be old enough to consent to the processing of your personal information in your country or state of residence.

9. Residents of the State of California

If you are a resident of the State of California, you may have additional privacy rights under the California Consumer Privacy Act or other California laws. Learn more about these privacy rights by visiting our Privacy Notice for California Residents.

10. Users Located in the UK or European Union

Currently, the Trader Interactive marketplaces are not open for use by individuals located in the European Union or the United Kingdom and we block IP addresses that trace back to locations within the European Union, European Economic Area, or the United Kingdom. If you are located in the EU or UK and have accessed our marketplace from inside the United States, you may search our marketplaces, create an account (tied to a non-European Union/UK identity), or make connections with sellers on our marketplace. However, your transaction or interaction may be denied or blocked if you provide personal information that identifies you as located in the European Union or UK.

11. Changes to This Privacy Policy

We may revise this Privacy Policy from time to time. If we make a change to this Privacy Policy that materially reduces your rights or significantly changes the way we use or share your personal information, we will display a banner on our homepage. Such changes will be effective when posted. The date the Privacy Policy was last revised is identified at the top of this page. If you object to any of the changes we make, you may always to stop using our marketplaces. By continuing to use our marketplaces following our posting of such changes, you agree to our Privacy Policy as modified. [END OF PRIVACY POLICY]