Protecting Your Privacy

DATED 2016-01-15 · VERSION 20161110_rev01 · COMPARED WITH 20160202_rev01 · ARCHIVE SNAPSHOT

Full text changes — 20160202_rev01 to 20161110_rev01

COLOUR MARKS THE SEVERITY OF A FLAGGED CLAUSE · + AND − MARK ADDED AND REMOVED

 Effective Date: 01/15/2016
 Posting Date: 01/15/2016
 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](https://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/us/about-us/policies/protecting-your-privacy/).
 Sedo.com LLC has received TRUSTE's Privacy Seal signifying that this Privacy Statement and our practices have been reviewed for compliance with the TRUSTe program. 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, [sedo.com](https://sedo.com/). In order to view our relationship with TRUSTe please visit the validation page visible by clicking on the TRUSTe Seal.
+[https://privacy.truste.com/privacy-seal/Sedo-com-LLC/validation?rid=fad2d4a5-2105-486c-8537-e8ceb33ec90b](https://privacy.truste.com/privacy-seal/Sedo-com-LLC/validation)
 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/)
 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 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.
+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/) (or if located in the European Union, click [here](http://www.youronlinechoices.eu/)). 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.
+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.
+_Affiliates for Our Operations._ We may use third parties ("affiliates") to facilitate or outsource one or more aspects of the services that we provide to you (e.g., domain name search technology, advertising provisions for parked domains, and other services) and therefore we may provide some of your information directly to these affiliates. These affiliates are subject to confidentiality agreements with us and other legal restrictions that prohibit their use of the information we provide them for any other purpose except to facilitate the specific outsourced service, unless you have explicitly agreed or given your prior permission to them for additional uses. In some instances, the affiliate may collect information directly from you. In these cases, you will be notified of the involvement of the affiliate, and all additional information you provide them and their additional uses will be up to you. It may be necessary to disclose your stored information, such as first and last name, company name, address, email and/or phone number, to relevant domain monetization advertising partners for the purpose of providing you such services.
+_
+Agents and Business Entities._ We share much of our data, including personal information about you, with our affiliates, subsidiaries, and joint ventures that are committed to serving your online needs and providing related services throughout the world. We use an outside credit card processing company to bill you for goods and services. These companies do not retain, share, store, or use personal information for any other purposes. To the extent that these entities have access to your information, they will treat it at least as protectively as they treat information they obtain from their other users. Our affiliates, subsidiaries, and joint ventures follow privacy practices no less protective of all users than our practices described in this document, to the extent allowed by applicable law.
+Affiliates for Our Operations. We may use third parties ("affiliates") to facilitate or outsource one or more aspects of the services that we provide to you (e.g., domain name search technology, advertising provisions for parked domains, and other services) and therefore we may provide some of your information directly to these affiliates. These affiliates are subject to confidentiality agreements with us and other legal restrictions that prohibit their use of the information we provide them for any other purpose except to facilitate the specific outsourced service, unless you have explicitly agreed or given your prior permission to them for additional uses. In some instances, the affiliate may collect information directly from you. In these cases, you will be notified of the involvement of the affiliate, and all additional information you provide them and their additional uses will be up to you. It may be necessary to disclose your stored information, such as first and last name, company name, address, email and/or phone number, to relevant domain monetization advertising partners for the purpose of providing you such services.
+Agents and Business Entities. We share much of our data, including personal information about you, with our affiliates, subsidiaries, and joint ventures that are committed to serving your online needs and providing related services throughout the world. We use an outside credit card processing company to bill you for goods and services. These companies do not retain, share, store, or use personal information for any other purposes. To the extent that these entities have access to your information, they will treat it at least as protectively as they treat information they obtain from their other users. Our affiliates, subsidiaries, and joint ventures follow privacy practices no less protective of all users than our practices described in this document, to the extent allowed by applicable law.
 Sedo, its affiliates, subsidiaries, joint ventures, or any combination of such, will share some or all of your information with another business entity should we plan to merge with, or be acquired by, that business entity. Should such a combination occur, we will require that the new combined entity follow this privacy policy with respect to your information. You will be notified via email and/or a prominent notice on our Web site of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.
+_Legal Requests._ Sedo cooperates with law enforcement authorities, as well as with other third parties, to enforce laws, intellectual property rights, and to prevent fraud. In response to a verified request by law enforcement or other government officials relating to a criminal investigation or alleged illegal activity, we can, and you authorize us to, disclose your name, city, state, telephone number, email address, login name history, fraud complaints, and site use history, with or without a subpoena. Without limiting the above, we will not disclose your personal information to law enforcement or other government officials without a subpoena, court order or substantially similar legal procedure, except when we believe in good faith that the disclosure of information is necessary to protect our rights or to prevent imminent physical harm, financial loss or to report suspected past, present, or future illegal activity. Further, we can, and you authorize us to, disclose to a third party your information, including your name, street address, city, state, zip code, country, phone number, email, and company name, as we in our sole discretion believe necessary or appropriate in connection with an investigation of fraud, intellectual property infringement, piracy, or other unlawful activity.
+Legal Requests. Sedo cooperates with law enforcement authorities, as well as with other third parties, to enforce laws, intellectual property rights, and to prevent fraud. In response to a verified request by law enforcement or other government officials relating to a criminal investigation or alleged illegal activity, we can, and you authorize us to, disclose your name, city, state, telephone number, email address, login name history, fraud complaints, and site use history, with or without a subpoena. Without limiting the above, we will not disclose your personal information to law enforcement or other government officials without a subpoena, court order or substantially similar legal procedure, except when we believe in good faith that the disclosure of information is necessary to protect our rights or to prevent imminent physical harm, financial loss or to report suspected past, present, or future illegal activity. Further, we can, and you authorize us to, disclose to a third party your information, including your name, street address, city, state, zip code, country, phone number, email, and company name, as we in our sole discretion believe necessary or appropriate in connection with an investigation of fraud, intellectual property infringement, piracy, or other unlawful activity.
 ## Use of Other Users' Information
 In order to facilitate interaction among site users, our site may allow you limited access to other users' information. By entering into our User Agreement, you agree that, with respect to other users' personal information that you obtain through the site or through a communication or transaction facilitated by Sedo. Sedo hereby grants to you a limited, non-transferable, revocable license to use such information only for: (a) Sedo-related communications that are not unsolicited commercial messages, (b) using services offered through Sedo (e.g., escrow services and fraud complaints), and (c) any other purpose that a user expressly agrees to after you tell them the purpose you would like to use it for.
 In all cases, you must give users an opportunity to remove themselves from your database and a chance to review what information you have collected about them. In addition, under no circumstances, except as defined herein, can you disclose personal information about another site user to any third party without the written consent of Sedo and the written consent of that user, including, but not limited to, email correspondence with Sedo staff regarding Sedo users, whether in the course of providing Sedo services or otherwise. You agree that other users may use your personal information to communicate with you in accordance with this paragraph.
 ## Control of Your Login Name and Password
 You are responsible for all actions taken with your login name and password, including fees charged to your account and adherence to the Acceptable Use terms contained in the Sedo User Agreement. Your Sedo user password should be held in strict confidence and under no circumstances will Sedo personnel, its agents or affiliates ask you for your Sedo user password. If you lose control of your password, you may lose substantial control over your information and may be subject to legally binding actions taken on your behalf. Therefore, if your password has been compromised for any reason, you should immediately change your password as detailed in the paragraph below.
 ## Accessing, Deleting, Reviewing and Changing Your Personal Information
+We offer you the ability to review, delete and change the information you submit to us by logging into the site and entering in the new information yourself or by emailing us at contact@sedo.com. Once logged in as a registered user, you can change your Password, other personal, contact, and financial information, and user preferences by going to the applicable pages available under "My Sedo." You must promptly update your personal information if it changes or is inaccurate. Once posted, you may not be able to change or remove any bids or postings made on the site.
+We offer you the ability to review, delete and change the information you submit to us by logging into the site and entering in the new information yourself or by emailing us at [contact@sedo.com](mailto:contact@sedo.com). Once logged in as a registered user, you can change your Password, other personal, contact, and financial information, and user preferences by going to the applicable pages available under "My Sedo." You must promptly update your personal information if it changes or is inaccurate. Once posted, you may not be able to change or remove any bids or postings made on the site.
 Generally, we will not modify your personal information based on a request not submitted through the site because it can be difficult to authenticate your identity manually.
 Upon your request, we will deactivate and delete your account, contact information, billing information, shipping information, and financial information from our active databases. To make this request, email [contact@sedo.com](mailto:contact@sedo.com). Your account will be deactivated and deleted as soon as reasonably possible after we receive your request but no later than 30 days.
 Upon receipt of a deactivation request, we will retain some of your information in order to prevent fraud, collect fees owed, resolve disputes, troubleshoot problems, assist with any investigations, enforce our User Agreement, and comply with legal requirements. Therefore, you should not expect that all of your information will be completely removed from our databases in response to your requests. However, your information will be deactivated from our active, registered user database, and will only be available to select Sedo personnel.