This Privacy Policy governs the website for Bid4Assets, Inc. (“Bid4Assets,” “we”, “us,” or “our”).  In using Bid4Assets’ website (the “Platform”), you agree to be bound by this Privacy Policy.  Your privacy is important to us, which is why we have developed this Privacy Policy to explain our practices regarding the use and disclosure of personally identifiable information we obtain online from users of our Platform.

If we decide to change our Privacy Policy, we will post those changes on this page so that you are always aware of what information we collect, how we use it and under what circumstances we disclose it.  If you do not agree to this Privacy Policy, or any changes we subsequently make, you should stop accessing the Platform. 

How We Collect Information About You

We generally collect information through the Sites in three ways:

1. We collect information that our customers or visitors (including you) supply to us.
2. We collect information from emails and other contacts sent to us by you, other customers and users of the Platform.
3. We collect information electronically on all customers and other users of the Sites by means of cookies.

Your Account Information

To participate in many of the services offered by Bid4Assets, you will need to register an account.  Registration of an account involves the selection of a username and a password, which will be provided to us.  You are entirely responsible for maintaining the confidentiality of your username and password. Furthermore, you are entirely responsible for any and all activity which occurs in connection with your account. You agree to immediately notify us of any unauthorized use of your account or any other breach of security known to you. Bid4Assets may terminate your account due to the misuse, improper use or unauthorized use of a username, password or the Platform. Bid4Assets will not be responsible and you will hold harmless Bid4Assets for any actual, special, consequential or incidental losses or damages arising from the misuse, improper use or unauthorized use of a username, password or this Platform.

We recommend the following guidelines for creating a password:

• DO NOT make your password the same as your username.
• The password should not be a word that appears in the dictionary.

The password must contain a minimum of eight characters, including one uppercase letter, one lowercase letter, one number and one symbol, such as an exclamation mark or number sign

Sharing and Disclosure of Information

We may disclose your personal information collected through your use of the Platform to: (a) our affiliates; (b) third parties to provide you with information or materials you specifically request; (c) our service providers and settlement companies providing services to us; (d) other Bid4Assets users who you engage in transactions with; or (e) as otherwise specifically permitted in this Privacy Policy.  We may also use and disclose your personal information collected through your use of the Platform to unrelated third parties: (a) to conform to legal requirements or to respond to a subpoena, search warrant or other legal process received by us; (b) to enforce our Terms and Conditions or to protect our rights; (c) to protect the safety of others, including other users of the Platform; or (d) with your consent in a particular instance. 

We reserve the right to transfer or disclose you information collected through the Platform, including your personal information, for other business reasons of ours (including in connection with an assignment of our rights covered under the paragraph below captioned “Assignment”).

We also reserve the right to change the manner of our use and disclosure in accordance with the “Changes in Our Privacy Policy” section below.

Children’s Privacy and Age Limitations for the Website

The Platform is intended for use by persons aged 18 or older, and by your use of this Platform you affirm that you are at least 18 years of age.  We do not knowingly collect personally identifiable information from children under the age of 18. If we discover or are made aware that we have received personally identifiable information from an individual who indicates that he or she is, or whom we otherwise have reason to believe is, under the age of 18, we will delete such information from our systems.  If you are a parent or guardian of a child under the age of 18 and believe he or she has disclosed personally identifiable information to us please contact us as provided below.  In any such event, a parent or guardian of a child under the age of 18 may review and request deletion of such child's personally identifiable information as well as prohibit the use thereof. 

Please also see the additional disclosures in the paragraphs below captioned “Additional Notices to California Residents -- Content Removal Requests for Users Under 18 Years Old”.

Use of Cookies

Cookies are small pieces of information that some websites store on your computer's hard drive when you visit them. Like many other websites, Bid4Assets uses cookies to identify account holders so they do not have to enter a username and password upon each visit. Most web browsers automatically accept cookies but allow you to modify security settings so you can approve or reject cookies on a case-by-case basis.

Bid4Assets uses cookies in a limited way. Cookies enable us to deliver content specific to your interests; they also tell us if you are using a browser that may not be compatible with our service.

1. Strictly necessary cookies. These are cookies that are required for the operation of the Platform. They include, for example, cookies that enable you to log into secure areas of the Platform, use a shopping cart or session tracking.
2. Analytical/performance cookies. They allow us to recognize and count the number of visitors and to see how visitors move around the Platform when they are using it. This helps us to improve the way the Platform works, for example, by ensuring that users are finding what they are looking for easily.  
3. Functionality cookies. These are used to recognize you when you return to the Platform. This enables us to personalize our content for you, greet you by name and remember your preferences. 

You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of the Platform and use the Services.  In addition, if you delete any Platform cookies on a given visit, you would need to block them again in subsequent visits to our Platform.

Links to Other Websites

The Platform may contain links to other websites, applications and services maintained by us, our affiliates and/or by third parties that may not follow the same privacy policies as applicable to the Platform. These other websites, applications and services may use cookies, collect data and use the data in ways that are different from the way in which we use the information collected through the Platform. When linking to another website, application or service, you should read the privacy policy of that other website, application or service. Our Privacy Policy only governs information collected on or through the Platform.

Opting Out of Marketing Communications

You may let us know at any time that you desire to opt out of emails and other electronic communications sent by us about marketing or promotional matters.  To opt out you should send us an email to [email protected] with the subject line “Please remove me from all Bid4Assets marketing emails” and we will then promptly remove you from such communications.  However, you may still receive emails and other electronic communications from us about non-marketing or non-promotional matters, such as information about your user account.  To opt out of Asset Hound email alerts, you must log in to your account and delete the rules.

Use of Google Analytics

We use Google Analytics, a web analytics service from Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA.

Google is certified under the Privacy Shield Agreement and thus warrants that it complies with applicable European privacy legislation. Google’s Privacy Shield status may be viewed here:

https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active .

Google Analytics uses cookies as well. The information about your use of the Platform generated by the cookie is usually sent to a Google server in the U.S., where it is saved. However, in the event that IP anonymization is activated on this Platform, Google will abbreviate your IP address in advance within member states of the European Union or in other countries within the European Economic Area that are party to the agreement. Only in exceptional cases is the full IP address sent to a Google server in the U.S. and abbreviated there. Google will use this information on our behalf to analyze your use of the Platform, compile reports on Platform activity and provide us with other services relating to the Platform, application and Internet use. The IP address provided by your browser for Google Analytics purposes is not merged with other data held by Google. You can prevent cookies from being stored by using the appropriate setting in your browser; however we would like to point out that if you block cookies it may mean that you are unable to benefit from the full range of functions offered by this Platform. You can also prevent collection of data generated by the cookie in reference to your Platform usage (including your IP address) by Google, and processing of this data by Google, by downloading the browser plug-in from the following link (http://tools.google.com/dlpage/gaoptout?hl=en) and installing it.

Please note that to ensure anonymous logging of IP addresses (so-called IP masking), on this Platform Google Analytics has been extended with the code ‘gat._anonymizeIp()’.

You can also prevent the collection of your data by Google Analytics by clicking on the following link:  https://tools.google.com/dlpage/gaoptout?hl=en.  An opt-out cookie can then be set which prevents further collection of your data through Google Analytics when you visit this Platform. This is particularly recommended when accessing our site via mobile devices.

Further information on terms of use and data protection can be found at the following web addresses: www.google.com/analytics/terms/en.html or  whttps://policies.google.com/privacy?hl=enl.

Changes in Our Privacy Policy

We reserve the right to modify this Privacy Policy at any time, and any modifications made will be effective immediately upon posting, so you should check this page for any changes.  We will post at the top of this Privacy Policy the date that modifications were last made, which should alert you to any changes since your last visit to the Platform.  Your continued use of the Platform is your agreement to the revised Privacy Policy. 

Governing Law

This Privacy Policy is governed by the laws of the State of Maryland. 

Assignment

We may assign our rights and duties under this Privacy Policy, including, without limitation, our rights in information collected through the Platform, to any third party at any time without notice to you, and such assignment rights shall include the ability to make an assignment in connection with any sale, merger, acquisition, divestiture or liquidation of all or part of our business or assets related to the Platform, all or substantially all of our business or assets, or as part of any reorganization or restructuring of our business.

Your Questions and Concerns

If you have questions or concerns regarding this Privacy Policy or our privacy practices, please send us an email (writing “Privacy Policy” in the subject line) at [email protected]. We will use reasonable efforts to promptly investigate any concern.

ADDITIONAL NOTICES TO CALIFORNIA RESIDENTS

California Do-Not-Track Disclosure

At this time, the Platform is not set up to honor web browser do-not-track settings.  Do-not-track is a privacy preference that users can set in their web browsers. When a user activates the do-not-track settings in browsers that offer this setting, the browser sends a message to websites or applications requesting them not to track the user. For more information about do-not-track matters, please visit www.allaboutdnt.org.

Information on Marketing Disclosures

California Civil Code Section 1798.83 permits our users who are California residents to request and obtain from us once a year, free of charge, information about the personal information (if any) we disclosed to third parties for direct marketing purposes in the preceding calendar year. If applicable, this information would include a list of the categories of personal information that was shared and the names and addresses of all third parties with which we shared information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us at 6931 Arlington Road, Suite 460, Bethesda, MD 20814.

Content Removal Requests for Users Under 18 Years Old

If you are a user under 18 years of age and reside in California, you may request and obtain removal of, content or information that you have posted on the Platform.    You may send us any such requests by one of the following methods: (i) by email (writing “Privacy Policy – Removal Request” in the subject line) at [email protected]; or (ii) by writing to us at 6931 Arlington Road, Suite 460, Bethesda, MD 20814.  We will review the request and respond promptly.  You should be aware that a request to remove content or information posted by you on the Platform does not ensure or require complete or comprehensive removal of such content or information from our databases.

Complaints

If you have any complaint about use of the Platform, you may contact us by email at [email protected], or by postal mail at 6931 Arlington Road, Suite 460, Bethesda, MD 20814. In accordance with California Civil Code Section 1789.3 California residents may also file complaints with the Complaint Assistance Unit, Division of Consumer Services, California Department of Consumer Affairs by postal mail at 1625 North Market Road, Suite N112, Sacramento, CA 95834 or by telephone at 800-952-5210.

ADDITIONAL NOTICES TO EUROPEAN UNION RESIDENT AND OTHER DATA SUBJECTS

In addition to the information provided elsewhere in this Privacy Policy, persons who are residents of the member countries of the European Union (“EU”) or other data subjects covered by the EU’s General Data Protection Regulation, (EU) 2016/679 (the “GDPR”), have certain additional privacy rights under applicable law.  The following provisions of this Privacy Policy provide an overview of these additional rights and related information.

Our Commitment

Bid4Assets embraces the approach to privacy protection reflected in the GDPR, giving our clients, vendors, and users a greater say in what happens with their data. Please contact our data protection officer at [email protected] if you have any questions about any matters related to our GDPR compliance.

Legal Bases for Processing Personal Information of European Union Citizens or Other GDPR Data Subjects

When processing your personal information, Bid4Assets may rely on one or more of the following legal bases (or other available legal grounds), depending on the circumstances:

1. Legitimate Interests – Bid4Assets may process your personal information where Bid4Assets has a legitimate interest in such processing for managing, operating or promoting our business, and that legitimate interest is not overridden by your interests, fundamental rights or freedoms.
2. Consent – Bid4Assets may process your personal information where Bid4Assets has obtained your consent to the processing.
3. Contractual Necessity – Bid4Assets may process your personal information where such processing is necessary in connection with any contract that Bid4Assets has with you.
4. Legal Requirements – Bid4Assets may process your personal information where such processing is required by applicable law.

Disclosures to Third Parties

Your personal information will not be disclosed to third parties except where it is necessary for fulfillment of Bid4Assets’s obligations to you or where Bid4Assets is obliged or permitted to do so by law (including, without limitation, through the terms of any agreement Bid4Assets may have with you), or where Bid4Assets makes disclosures that are otherwise consistent with the uses described in this Policy.

Bid4Assets may also disclose any information (including personal information) relating to you to law enforcement authorities or any regulatory or government authority in response to any request including requests in connection with the investigation of any suspected illegal activities.

Bid4Assets reserves the right to transfer any personal information Bid4Assets has about you in the event Bid4Assets sells or transfers all or a portion of our business or assets, or merges with another organization. Should such a sale, transfer or merger occur, Bid4Assets will use reasonable efforts seeking to require that the transferee uses personal information you have provided to Bid4Assets in a manner that is consistent with this Policy.

Bid4Assets will not sell, resell or lease your personal information to any third parties but Bid4Assets may, if required for the purpose(s) for which your personal information was collected and processed, share it with Bid4Assets partners and/or service providers to enable them to provide their services to Bid4Assets or to you, as applicable. The foregoing are in addition to the other uses described elsewhere in this Policy.

Security of Personal Information of European Citizens or Other GDPR Data Subjects

Bid4Assets has policies and technical and organizational measures in place which are intended to safeguard and protect your personal information against unauthorized access, accidental loss, improper use and disclosure. However, you should be aware that information transmitted over the internet is not completely secure because of the nature of the internet and that systems and measures used to secure information are not flawless. For these reasons, although Bid4Assets will use reasonable efforts to protect your personal information, Bid4Assets does not warrant the security of personal information transmitted to Bid4Assets or stored by Bid4Assets, and personal information that is transmitted to Bid4Assets by you electronically is done at your own risk.

Retention of Personal Information of European Citizens or Other GDPR Data Subjects

Bid4Assets’s policy is to retain your personal information only for as long as is necessary to fulfill the purposes for which Bid4Assets collected such personal information, including for the purposes of satisfying any professional, legal, accounting or reporting requirements to which Bid4Assets is subject. To determine the appropriate retention period for personal information, Bid4Assets considers the scope, nature and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of the personal information, the purposes for which Bid4Assets collected and processed your personal information and whether Bid4Assets can achieve those purposes through other means, and any applicable legal and professional requirements.

Your Rights as a European Resident or Other GDPR Data Subject

You have a number of rights concerning your personal information that Bid4Assets holds and uses, including the following:

1. Right of Access – You have the right to be informed about what personal information Bid4Assets holds about you and to a copy of this personal information.
2. Right to Rectification – You have the right to have any inaccurate personal information which Bid4Assets holds about you updated or corrected.
3. Right to Erasure – In certain circumstances you may request that Bid4Assets delete the personal information that Bid4Assets holds about you.
4. Right to Complain – You have the right to lodge a complaint regarding the processing of your personal information to an applicable governmental or supervisory authority in your country.
5. Right to Withdraw Consent – Where processing of personal information is based on your consent, you have the right to withdraw such consent at any time.
6. Right to Object – Where Bid4Assets relies on our legitimate interests to process your personal information, you have the right to object to such use and Bid4Assets is required to discontinue such processing unless Bid4Assets can demonstrate an overriding legitimate interest in such processing.
7. Right to Restriction – You have the right to request that Bid4Assets stop using your personal information in certain circumstances including if you believe that the personal information Bid4Assets holds about you is inaccurate or that Bid4Assets’s use of your personal information is unlawful. If you validly exercise this right, Bid4Assets will store your personal information and will not carry out any other processing until the issue is resolved.

You may exercise any of the above requests in writing to Bid4Assets, Attn: Data Protection Officer, 6931 Arlington Road, Suite 460, Bethesda, MD 20814 or at [email protected]. You are also free at any time to request that Bid4Assets stop using your personal information for marketing purposes by contacting us at Bid4Assets, Attn: Data Protection Officer, 6931 Arlington Road, Suite 460, Bethesda, MD 20814.