Sedo Protecting Your Privacy changes — 20150121_rev01

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You will be notified when your personal information is collected by any third party that is not our agent/service provider so that you can make an informed choice as to whether or not to share your information with that party.

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Under some circumstances we may require some additional financial information, including, without limitation, your billing address, bank account information, a credit card number and expiration date, and tracking information from checks or money orders.

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We may automatically collect certain information based upon your behavior on the site. We use this information to do internal research on our users' demographics, interests, and behavior to serve our users better. This information may include the URL that you come from or go to (whether this URL is on the site or not), your computer browser information, and your IP address.

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This information includes internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and clickstream data. We use this information, which does not identify individual users, to analyze trends, to administer the site, to track users' movements around the site and to gather demographic information about our user base as a whole. We do not link this automatically-collected data to personally identifiable information.

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Most cookies are "session cookies," meaning that they are automatically deleted from your hard drive at the end of a session. You are always free to decline our cookies if your browser permits, although in that case you may not be able to use certain features on the site and you may be required to re-enter your password or provide other information more frequently during a session.

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Some of our business partners (e.g., advertisers) may use "cookies" on our site. We have no access to or control over these "cookies." This privacy policy covers the use of "cookies" by Sedo only and does not cover the use of "cookies" by any advertisers.

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We employ or our third party advertising company employs a software technology called clear gifs (a.k.a. Web Beacons/Web Bugs), that help us better manage content on our site by informing us what content is effective. Clear gifs are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of Web users. The main difference between the two is that clear gifs are invisible on the page and are much smaller, about the size of the period at the end of this sentence. Clear gifs are not tied to users' personal information.

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We and or our third party advertising company employ a software technology called clear gifs (a.k.a. Web Beacons/Web Bugs), that help us better manage content on our site by informing us what content is effective. Clear gifs are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of Web users. The main difference between the two is that clear gifs are invisible on the page and are much smaller, about the size of the period at the end of this sentence. Clear gifs are not tied to users' personal information.

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In addition, we use clear gifs in our HTML-based emails to let us know which emails have been opened by the recipients. This allows us to gauge the effectiveness of certain communications and the effectiveness of our marketing campaigns. If users would like to opt-out of these emails, please email us at contact@sedo.com.

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Flash cookies are different from browser cookies because of the amount of, type of, and how data is stored. Cookie management tools provided by your browser will not remove Flash cookies. To learn how to manage privacy and storage settings for Flash cookies click here:

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[http://www.macromedia.com/support/documentation/en/flashplayer/help/settings\_manager.html#117118](http://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager.html)

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If you choose to make bids, buy or sell through the site, we may collect information about your bidding, buying and selling behavior and transactions.

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If you send us personal correspondence, such as emails or letters, or if other users or third parties send us correspondence about your activities on the site, we may collect such information into a file specific to you.

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If you choose to make bids, buy or sell through the site, we may collect information about your bidding, buying and selling behavior and transactions. If you send us personal correspondence, such as emails or letters, or if other users or third parties send us correspondence about your activities on the site, we may collect such information into a file specific to you.

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We use your information and other information we obtain from your current and past activities on the site to resolve disputes, troubleshoot problems, collect fees owed, pay amounts due you, verify your account data, measure user interest in Sedo's products and services, inform you about online and offline offers, products, services, and updates, customize your experience, detect and protect us against error, fraud and other criminal activity, and enforce our User Agreement. At times, we may look across multiple users to identify problems or resolve disputes, and we may examine your information to identify users using multiple Login Names.

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We may compare and review your information for errors, omissions and for accuracy.

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You agree that we may use your information to contact you and deliver information to you that, in some cases, is targeted to your perceived interests, such as targeted banner advertisements, administrative notices, product offerings, and communications relevant to your use of the site. By accepting this Agreement, you expressly agree to receive this information.

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We may compare and review your information for errors, omissions and for accuracy. You agree that we may use your information to contact you and deliver information to you that, in some cases, is targeted to your perceived interests, such as targeted banner advertisements, administrative notices, product offerings, and communications relevant to your use of the site. By accepting this Agreement, you expressly agree to receive this information.

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## Our Disclosure of Your Information

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We do not sell or rent any of your personal information to third parties without your explicit consent or in any way other than as outlined in this privacy policy. However, the following describes some of the ways that your personal information may be disclosed in the normal course of business as part of our services.

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We do not share, sell or rent any of your personal information to third parties without your explicit consent or in any way other than as outlined in this privacy policy. However, the following describes some of the ways that your personal information may be disclosed in the normal course of business as part of our services.

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_Advertisers._ We aggregate (gather up data across numerous registered user accounts) personal information and disclose such information in a non-personal manner to advertisers and other third parties for their marketing and promotional purposes. For such purposes, we do not disclose any information that could be used to identify Sedo users personally.

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We partner with a third party ad network to either display advertising on our Web site or to manage our advertising on other sites. Our ad network partner uses cookies and Web beacons to collect non-personal information about your activities on this and other Web sites to provide you targeted advertising based upon your interests. If you wish to not have this information used for the purpose of serving you targeted ads, you may opt-out by clicking [here](http://preferences-mgr.truste.com/). Please note this does not opt you out of being served advertising. You will continue to receive generic ads.

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_Site._ Although our pages may be coded with robot exclusion headers, others may illegally attempt to automatically collect your email address from the site. If you are involved in a transaction, we have features that may allow other users to view your email address and obtain your contact and other information to help complete the transaction. Further, we may send out notices to you or other users regarding suspicious activity or policy violations on the site.

+Effective Date: 01/22/2013
+Posting Date: 01/22/2013
+Effective Date: 08/07/2014
+Posting Date: 08/07/2014
 Protecting your privacy and the personal information you provide us is a top priority at Sedo.com LLC ("Sedo"). For this reason, Sedo does not sell or rent your personal information to third parties without your explicit consent or in way other than as outlined in this privacy policy. At Sedo, we want our users to fully understand what information we collect, how we use this information, and the steps we take to protect your personal information.
+Please read this Privacy Policy to learn more about the policies and procedures Sedo has put in place to achieve this goal. In addition, Sedo wants our users to feel comfortable that we take all necessary steps to protect personal information. For this reason, we have created a webpage where users can learn how to report a [Privacy Complaint](http://sedo.com/about/policy.php).
+Please read this Privacy Policy to learn more about the policies and procedures Sedo has put in place to achieve this goal. In addition, Sedo wants our users to feel comfortable that we take all necessary steps to protect personal information. For this reason, we have created a webpage where users can learn how to report a [Privacy Complaint](https://sedo.com/about/policy.php).
+Sedo.com LLC has been awarded TRUSTe's Privacy Seal signifying that this privacy policy and practices have been reviewed by TRUSTe for compliance with [TRUSTe's program requirements](http://www.truste.com/privacy_seals_and_services/consumer_privacy/privacy-programs-requirements.html) including transparency, accountability and choice regarding the collection and use of your personal information. The TRUSTe program does not cover information that may be collected through downloadable software. The TRUSTe program covers only information that is collected through this Web site, [http://www.sedo.com](http://www.sedo.com/).
+Sedo.com LLC has been awarded TRUSTe's Privacy Seal signifying that this privacy policy and practices have been reviewed by TRUSTe for compliance with [TRUSTe's program requirements](http://www.truste.com/privacy_seals_and_services/consumer_privacy/privacy-programs-requirements.html) including transparency, accountability and choice regarding the collection and use of your personal information. The TRUSTe program does not cover information that may be collected through downloadable software. The TRUSTe program covers only information that is collected through this Web site, [https://sedo.com](https://sedo.com/).
 TRUSTe's mission, as an independent third party, is to accelerate online trust among consumers and organizations globally through its leading privacy Trustmark and innovative trust solutions. If you have questions or complaints regarding our privacy policy or practices, please contact us at Sedo's Privacy Department by emailing [privacy@sedo.com](mailto:privacy@sedo.com), calling 617-499-7200, or writing Sedo.com, LLC, 161 First Street, Fourth Floor, Cambridge, MA 02142. If you are not satisfied with our response you can contact [TRUSTe here](https://feedback-form.truste.com/watchdog/request).
 Sedo.com LLC complies with the U.S. - E.U. Safe Harbor framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal data from European Union member countries.
 Sedo.com LLC has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, and to view Sedo.com LLC's certification, please visit [http://www.export.gov/safeharbor/](http://www.export.gov/safeharbor/)
 ## Overview
 The privacy practices of this statement apply to the services provided by Sedo available under the domain and subdomains of www.sedo.com (the "Site") and apply generally to our affiliates. By visiting this website you agree to be bound by the terms and conditions of this Privacy Policy. If you do not agree please do not use or access our site.
 This Privacy Policy describes the information we collect from you and what may happen to that information as part of the normal operation of our services. Sedo strives to provide a consistent set of privacy practices across an international community, and as such, all of our affiliates operate under similar privacy practices as described in this Privacy Policy, subject to the requirements of applicable law.
+By accepting the Privacy Policy and the User Agreement at the point of registration, you expressly consent to Sedo's use and disclosure of your personal information in accordance with this Privacy Policy. This Privacy Policy is incorporated into and subject to the terms of the Sedo User Agreement. This Privacy Policy is effective upon acceptance in registration for new registering users, and is otherwise effective on February 1, 2013.
+By accepting the Privacy Policy and the User Agreement at the point of registration, you expressly consent to Sedo's use and disclosure of your personal information in accordance with this Privacy Policy. This Privacy Policy is incorporated into and subject to the terms of the Sedo User Agreement. This Privacy Policy is effective upon acceptance in registration for new registering users, and is otherwise effective on August 7, 2014.
 ## Information from Children
 If you are under the age of 18, you may only use this site in conjunction with and under the supervision of your parents or guardians, and with express permission from Sedo. For this reason, we ask that children do not submit any personal information to Sedo.
 ## Information We Collect
 You will be notified when your personal information is collected by any third party that is not our agent/service provider so that you can make an informed choice as to whether or not to share your information with that party.
 Under some circumstances we may require some additional financial information, including, without limitation, your billing address, bank account information, a credit card number and expiration date, and tracking information from checks or money orders.
 We may automatically collect certain information based upon your behavior on the site. We use this information to do internal research on our users' demographics, interests, and behavior to serve our users better. This information may include the URL that you come from or go to (whether this URL is on the site or not), your computer browser information, and your IP address.
+This information includes internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and clickstream data. We use this information, which does not identify individual users, to analyze trends, to administer the site, to track users' movements around the site and to gather demographic information about our user base as a whole. We do not link this automatically-collected data to personally identifiable information.
 Most cookies are "session cookies," meaning that they are automatically deleted from your hard drive at the end of a session. You are always free to decline our cookies if your browser permits, although in that case you may not be able to use certain features on the site and you may be required to re-enter your password or provide other information more frequently during a session.
 Some of our business partners (e.g., advertisers) may use "cookies" on our site. We have no access to or control over these "cookies." This privacy policy covers the use of "cookies" by Sedo only and does not cover the use of "cookies" by any advertisers.
+We employ or our third party advertising company employs a software technology called clear gifs (a.k.a. Web Beacons/Web Bugs), that help us better manage content on our site by informing us what content is effective. Clear gifs are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of Web users. The main difference between the two is that clear gifs are invisible on the page and are much smaller, about the size of the period at the end of this sentence. Clear gifs are not tied to users' personal information.
+We and or our third party advertising company employ a software technology called clear gifs (a.k.a. Web Beacons/Web Bugs), that help us better manage content on our site by informing us what content is effective. Clear gifs are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of Web users. The main difference between the two is that clear gifs are invisible on the page and are much smaller, about the size of the period at the end of this sentence. Clear gifs are not tied to users' personal information.
 In addition, we use clear gifs in our HTML-based emails to let us know which emails have been opened by the recipients. This allows us to gauge the effectiveness of certain communications and the effectiveness of our marketing campaigns. If users would like to opt-out of these emails, please email us at contact@sedo.com.
 Flash cookies are different from browser cookies because of the amount of, type of, and how data is stored. Cookie management tools provided by your browser will not remove Flash cookies. To learn how to manage privacy and storage settings for Flash cookies click here:
 [http://www.macromedia.com/support/documentation/en/flashplayer/help/settings\_manager.html#117118](http://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager.html)
+If you choose to make bids, buy or sell through the site, we may collect information about your bidding, buying and selling behavior and transactions.
+If you send us personal correspondence, such as emails or letters, or if other users or third parties send us correspondence about your activities on the site, we may collect such information into a file specific to you.
+If you choose to make bids, buy or sell through the site, we may collect information about your bidding, buying and selling behavior and transactions. If you send us personal correspondence, such as emails or letters, or if other users or third parties send us correspondence about your activities on the site, we may collect such information into a file specific to you.
 We use your information and other information we obtain from your current and past activities on the site to resolve disputes, troubleshoot problems, collect fees owed, pay amounts due you, verify your account data, measure user interest in Sedo's products and services, inform you about online and offline offers, products, services, and updates, customize your experience, detect and protect us against error, fraud and other criminal activity, and enforce our User Agreement. At times, we may look across multiple users to identify problems or resolve disputes, and we may examine your information to identify users using multiple Login Names.
+We may compare and review your information for errors, omissions and for accuracy.
+You agree that we may use your information to contact you and deliver information to you that, in some cases, is targeted to your perceived interests, such as targeted banner advertisements, administrative notices, product offerings, and communications relevant to your use of the site. By accepting this Agreement, you expressly agree to receive this information.
+We may compare and review your information for errors, omissions and for accuracy. You agree that we may use your information to contact you and deliver information to you that, in some cases, is targeted to your perceived interests, such as targeted banner advertisements, administrative notices, product offerings, and communications relevant to your use of the site. By accepting this Agreement, you expressly agree to receive this information.
 ## Our Disclosure of Your Information
+We do not sell or rent any of your personal information to third parties without your explicit consent or in any way other than as outlined in this privacy policy. However, the following describes some of the ways that your personal information may be disclosed in the normal course of business as part of our services.
+We do not share, sell or rent any of your personal information to third parties without your explicit consent or in any way other than as outlined in this privacy policy. However, the following describes some of the ways that your personal information may be disclosed in the normal course of business as part of our services.
 _Advertisers._ We aggregate (gather up data across numerous registered user accounts) personal information and disclose such information in a non-personal manner to advertisers and other third parties for their marketing and promotional purposes. For such purposes, we do not disclose any information that could be used to identify Sedo users personally.
 We partner with a third party ad network to either display advertising on our Web site or to manage our advertising on other sites. Our ad network partner uses cookies and Web beacons to collect non-personal information about your activities on this and other Web sites to provide you targeted advertising based upon your interests. If you wish to not have this information used for the purpose of serving you targeted ads, you may opt-out by clicking [here](http://preferences-mgr.truste.com/). Please note this does not opt you out of being served advertising. You will continue to receive generic ads.
 _Site._ Although our pages may be coded with robot exclusion headers, others may illegally attempt to automatically collect your email address from the site. If you are involved in a transaction, we have features that may allow other users to view your email address and obtain your contact and other information to help complete the transaction. Further, we may send out notices to you or other users regarding suspicious activity or policy violations on the site.
 If you have any questions about security on our web site, you can email us at [privacy@sedo.com](mailto:privacy@sedo.com).
 ## Social Media Widgets
 Our Web site includes Social Media Features, such as the Facebook Like and Recommend buttons, the Twitter Share button, other widgets that use the ShareThis button, and interactive mini-programs that run on our site. These Features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the Feature to function properly. Social Media Features and Widgets are either hosted by a third party or hosted directly on our Site. Your interactions with these Features are governed by the privacy policy of the company providing it.
+## Links to 3rd Party Sites
+Our Site includes links to other Web sites whose privacy practices may differ from those of Sedo. If you submit personal information to any of those sites, your information is governed by their privacy policies. We encourage you to carefully read the privacy policy of any Web site you visit.
 ## Testimonials
 We display personal testimonials of satisfied customers on our site in addition to other endorsements. With your consent we may post your testimonial along with your name.
 ## Notice and Modification

Protecting Your Privacy

Full text changes — 20140703_rev01 to 20150121_rev01