Effective Date: 09/01/2005
Posting Date: 08/01/2005
Protecting your privacy and the personal information you
provide us is a top priority at Sedo. For this reason, Sedo does not sell
or rent your personal information to third parties for their marketing purposes
without your explicit consent. 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 their personal information.
For this reason, we have created a webpage where users can learn how to report
a privacy complaint.
Sedo is a licensee of the TRUSTe Privacy Program. TRUSTe is
an independent, non-profit organization whose mission is to build users'
trust and confidence in the Internet by promoting the use of fair information
practices. This privacy statement covers the site www.sedo.com. Because Sedo
wants to demonstrate our commitment to your privacy, we have agreed to disclose
our information practices and have our privacy practices reviewed for compliance
by TRUSTe.
If you have questions or concerns regarding this statement,
you should first contact Sedo's Privacy Department by emailing
[email protected],
calling +49 221.34030.230, or writing Sedo GmbH, Im Mediapark 6,
50670 Cologne, Germany. If you do not receive acknowledgement of your inquiry
or your inquiry has not been satisfactorily addressed, you should then contact
TRUSTe at http://www.truste.org/consumers/watchdog_complaint.php.
TRUSTe will then serve as a liason with the Web site to resolve your concerns.
For more information on TRUSTe, please go to www.truste.org.
This site complies with the EU Safe Harbor framework as set
forth by the Department of Commerce regarding the collection, use, and retention
of data from the European Union.
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 August 1, 2005
for all users.
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
Sedo only collects personal information about users that we
consider necessary for providing our services in an efficient, customized, and
user-friendly manner, including your name, address, phone number and email address.
Our Use of Your Information
In general, you can browse a large portion of the site
without telling us who you are or revealing any personal information about
yourself. Once you give us your personal information, you are not anonymous
to us. If you choose to use our services, we may require you to provide
contact and identity information, billing information, and other personal
information as indicated on the forms throughout the site. You always have
the option not to provide information by choosing not to use a particular
service or feature.
We provide you the opportunity to opt-out of having your
personally identifiable information used for certain purposes when we ask
for this information. For example, if you register for a user account but
do not wish to receive any additional marketing material from us you can
indicate your preference on the registration form. If you no longer wish
to receive our newsletter and promotional communications you may opt-out
of receiving them by following the instructions included in each newsletter
or communication or by emailing us at [email protected].
In addition, we offer an opportunity to opt-out of receiving our newsletter
on your account data page, or you may call us at +49 221.34030.230.
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.
We use data collection devices such as "cookies" on certain pages
of the site to help analyze our web page flow, measure promotional effectiveness,
and promote trust and safety. "Cookies" are small files placed on your hard
drive that assist us in providing our services. We may offer certain features
that are only available through the use of a "cookie." We also use cookies
to allow you to enter your password less frequently during a session. Cookies
can also help us provide information targeted to your interests. Personally
identifiable information you have submitted while on our site is linked with
information gathered from our use of cookies in the form of log files. 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
statement covers the use of "cookies" by Sedo only and does not cover the use
of "cookies" by any advertisers.
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.
Our Disclosure of Your Information
We do not sell or rent any of your personal information
to third parties for their marketing purposes without your explicit consent.
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-personally identifiable 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.
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, 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.
Agents and Business Entities. We share much of our data,
including personal information about you, with our affiliates, subsidiaries,
and joint venturers 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 personally identifiable 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 venturers 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 venturers, 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.
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.
Your 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 Sedo-related communication
or Sedo-facilitated transaction, 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, Reviewing and Changing Your
Personal Information
We offer you the ability to review and change the information
you submit to us by logging into the site and entering in the new information
yourself. 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 [email protected].
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.
Discussion Boards
If you use the discussion boards located on our site you
should be aware that any personally identifiable information you submit can
be read, collected, or used by other users of these forums, and could be
used to send you unsolicited messages. Sedo is not responsible for the personally
identifiable information you choose to submit in these forums.
Other Information Collectors
Except as otherwise expressly included in this Privacy
Policy, this document only addresses the use and disclosure of information
we collect from you. To the extent that you disclose your information to
other parties, whether they are bidders, buyers or sellers on our site or
other sites throughout the Internet, different rules may apply to their use
or disclosure of the information you disclose to them. Sedo does not control
the privacy policies of third parties.
Security
Sedo follows generally accepted industry standards to protect
the personal information submitted to us, both during transmission and once
we receive it. No method of transmission over the Internet, or method of
electronic storage, is 100% secure, however. Therefore, while we strive to
use commercially acceptable means to protect your personal information, we
cannot guarantee its absolute security.
Your information is stored on Sedo's servers located in the
United States and in European Union countries. When you enter sensitive information
(such as credit card or bank information) on our registration or order forms,
we encrypt that information using secure socket layer technology (SSL).
We treat data as an asset that must be protected against loss and unauthorized
access. We employ many different security techniques to protect such data
from unauthorized access by users inside and outside the company, but "perfect
security "does not exist on the Internet or with any data, digital or physical.
Sedo personnel receive training on complying with our privacy
practices and the importance of protecting your information. Disciplinary
procedures are in place in should a Sedo employee violate our Privacy Policy.
If you have any questions about security on our web site, you
can email us at [email protected].
Notice, Modification
If we decide to change our Privacy Policy we will post those
changes to this privacy statement, the homepage, and other places we deem
them appropriate so that you are aware of what information we collect, how
we use it, and under what circumstances, if any, we disclose it.
We reserve the right to make changes to this Privacy Policy at any time by
posting the amended terms on the site, so please check it frequently. If
we make material changes to this Policy, all amended terms shall automatically
be effective 30 days after they are initially posted on the site.
How to Contact Sedo
| Mail: |
Sedo, GmbH
Im Mediapark 6
50670 Cologne
Germany |
| Telephone: |
+49 221.34030.230 |
| Facsimile: |
+49 221.34030.102 |
| Email: |
[email protected] |