Gavel Privacy Policy

Welcome to the Gavel Privacy Policy ("Policy")! This explains how we collect, store, protect, and share your information, and with whom we share it. We suggest you read this in conjunction with our Terms of Service (http://gavelcorp.com/ToS/). While you're using the Gavel mobile application ("App"), we collect some information about you. In addition, you may choose to use App to share information with others using the App, including your friends and contacts ("Users"). We may also need to share your information sometimes.

By downloading and installing our App, you agree that we can collect, transfer, store, disclose and use your information as described in this Policy. Gavel is a global app, and your information will be sent to and used in the United States regardless of the country you reside in, and by downloading our App you consent to such transfer. PLEASE READ CAREFULLY!

If you have any questions or comments about this Policy, please feel free to contact us at legal@gavelcorp.com.

1. COLLECTION OF INFORMATION.

Registration Information

When you download the App and create an account ("Account"), we may collect certain information ("Registration Information") about you, such as:

● Name;

● Username;

● Email address;

● Gender;

● Date of birth;

● Nationality;

● Demographic Information

● Photographs;

● Location; and

● Login information and friend lists for social media accounts that you connect to your User Account (this could include, for example, your Google, YouTube, Facebook, Twitter, and Instagram accounts ("Social Media Accounts")).

You will also be required to create a username and password in connection with the registration of your Account. Once you register, you will be able to review and change this information at any time.

This information helps to enhance the App and verify our Users. Registration Information such as your name and username may be visible to the public on your profile page.

Additional Information

We may also collect additional information in connection with your use of the App, such as comments and posts, or if you use our electronic messaging function, or any purchase by a Buyer of a vehicle listed for sale on the Gavel Platform.

If you contact us, we will receive your email address, and may track your IP address as well as the information you send to us to help resolve your query. We will keep records of our communications with you, including any complaints that we receive from you about other Users (and from other Users about you).

We recommend and encourage you (and all our members) to think carefully about the information you disclose about yourself. We also do not recommend that you put email addresses, URLs, instant messaging details, phone numbers, full names or addresses, credit card details, national identity numbers, drivers' license details and other sensitive information on your profile which is open to abuse and misuse.

Please be careful about posting sensitive details about yourself on your profile such as your religious denomination and health details. While you may voluntarily provide this information to us when you create your profile, including your ethnic background, there is no requirement to do so. Please remember that photographs that you post on the Appl may reveal information about yourself as well. Where you do upload and choose to tell us sensitive information about yourself, you are explicitly consenting to our processing of your information and making this public to other Users.

When you post information about yourself or use the messaging function, the amount of personal information you share is at your own risk. Please see Section 4 below for more information on who can access what you post on the App. If you post anything that is inconsistent with our Terms of Service, we reserve the right to terminate your Account.

IF YOU PROVIDE A CELL PHONE NUMBER TO RECEIVE SMS MESSAGES FROM THE GAVEL APP, YOU EXPRESSLY CONSENT TO RECEIVING SMS MESSAGES FROM US PROMOTING OUR SERVICES AND PRODUCTS. ALTHOUGH THERE IS NO FEE ASSOCIATED WITH THIS SERVICE, YOUR CARRIER MAY CHARGE YOU FOR EACH MESSAGE YOU RECEIVE. YOU AGREE THAT WE ARE NOT RESPONSIBLE FOR SUCH CHARGES. IF YOU DO NOT WISH TO CONTINUE TO RECEIVE ANY MESSAGES VIA YOUR MOBILE DEVICE, YOU MAY OPT-OUT AT ANY TIME BY TEXTING "STOP" IN RESPONSE TO A MARKETING SMS MESSAGE.

Data Storage

By using Gavel, you agree and acknowledge that Gavel is a global app operating through servers located throughout the world. If you live in a country with data protection laws, the storage of your personal data may not provide you with the same protections as you enjoy in your country of residence. By submitting your personal information, or by choosing to upgrade the services you use, or by making use of the applications available on the App, you agree to the transfer of your personal information to, and storage and processing of your personal information in, any such countries and destinations.

Geolocation Information

If you turn these features on, we may collect your device's geolocation data and save your device's coordinates to offer certain features to you. We may also use your device's geolocation information to personalize the App and make it easier for you to interact with other Users. You can control your location information settings in your Account settings and switch them off if you choose. Even if you have disabled location services, we may still determine your city, state, and country location based on your IP address (but not your exact location).

Log and Usage Data

Our servers automatically record information ("Log and Usage Data") created by your use of the App, which again helps us to improve our service. Log and Usage Data may include information such as your IP address, browser type, the referring domain, pages visited, access times, your mobile carrier, search terms, interactions with other Users, and any purchase by a Buyer of a vehicle listed for sale on the Gavel Platform. Other actions, such as interactions with us and other Users and advertisements, may also be included in Log and Usage Data.

Device Information

We may collect information about your device when you use the App including the unique device identifier, device model, operating system, and MAC address. In addition, if you permit us to do so, the App may access your device's address book and contact lists in order to offer you certain features of our Services.

Links

We may keep track of how you interact with links available on the App including third party services and clients by redirecting clicks or through other means. We may share aggregate click statistics such as how many times a particular link was clicked on.

Cookies

These are small data files that are transferred to your computer's hard disk. Like many websites, we use "cookie" technology to collect additional website usage data and to improve the App, but we do not require cookies for many parts of our App such as searching and looking at public User profiles or lists.

The cookies we collect enable us to learn how people interact with us and other Users. Cookies store information about your website visits and can recognize you and your preferences each time you visit the App.

If for any reason you decide that you do not want all of your activities on the App to be stored you may set your browser and mobile settings to block cookies and local storage devices, but please remember that if you do so, you may not be able to access all of the features Gavel offers.

We use the following types of cookies:

Cookie Functions

Cookie Purposes

Analytics and Research

We collect information through the use of “cookies”, tracking pixels, and similar technologies to understand how you navigate through the Gavel App and interact with other Users, to learn what content is popular, and to save your preferences. Cookies are small text files that web servers place on your device; they are designed to store basic information and to help websites and apps recognize your browser. We may use both session cookies and persistent cookies. A session cookie disappears after you close your browser. A persistent cookie remains after you close your browser and may be accessed every time you use the Gavel Platform. You should consult your web browser(s) to modify your cookie settings. Please note that if you delete or choose not to accept cookies from us, you may be missing out on certain features of the Gavel Platform.

Authentication

These cookies help us identify our Users so that when you're logged in you can enjoy our offerings, experiences and various features, such as uploading photographs and chatting. You can even localize your experience, such as when you've requested to view the App in your local language or when you ask the App to 'remember me'. We also use cookies and other web technologies, such as CAPTCHAs, to help keep the Gavel Platform and our members safe and secure.

Security and Site Integrity

We may use persistent cookies, which will help us to ensure we have identified the same device is logging into the correct account. These cookies help with our anti-spam measures and may help us to prevent phishers, scammers, unauthorized log-in attempts to your Account and accessing any hacked accounts.

Site Features and Services

These cookies and local storage devices provide functionality such as uploading photographs, chat, instant messaging, and using your Account settings. They also help provide experiences, such as links to other social media sites, social plugins and video content, including making it easier for you to share content between Gavel and your other favorite social networks. In some cases, we may allow a third party to place cookies or save data to your local storage devices on your mobile device – this is where the Gavel Privacy Policy ends and theirs begin. The third party who places cookies on your device is responsible for how they process their data so you should read their privacy policies and make sure you're okay with them before you start sharing. Examples of such policies are available at the following links:

Twitter: https://twitter.com/privacy?lang=en .

Facebook: https://www.facebook.com/policy.php .

YouTube: http://www.google.co.uk/intl/en/policies/privacy/ .

Performance

We need to use certain cookies and save data to your local storage devices to ensure our members have the best possible experience. They assist with your navigation of the App, ensuring pages load quickly and respond promptly to your requests.

Our use of cookies and local storage devices, including the specific cookie names, may change over time, but will generally fall into the above categories. Please visit this page regularly so that you are aware of any changes.

2. USE OF INFORMATION.

Our main goal is to ensure you have an enjoyable experience while using Gavel. In order to deliver an enjoyable experience to you, we may use your Registration and other information to:

● offer you our services and features;

● contact you with information about Gavel (e.g., updates and new offerings);

● personalize your Account and the content we deliver to you;

● conduct research and analytics about how you use and interact with the Gavel Platform;

● any purchase of a vehicle listed for sale on the Gavel Platform;

● resolve disputes between you and other Users;

● resolve disputes between you and Us; and

● investigate fraud, protect our legal rights, and to enforce our Terms of Service.

3. DISCLOSURE OF INFORMATION.

Our policy is to not disclose your Registration Information, except in the limited circumstances described here:

Your Consent – If you consent, we may share or disclose your Registration Information, such as when you use a third party web client or application to access your Account.

Service Providers - We engage certain trusted third parties to perform functions and provide services to us. We may share your Registration Information with these third parties.

Law and Harm - For more information on this, please see our Terms of Service (http://gavelcorp.com/ToS/). We will cooperate with all third parties to enforce their intellectual property or other rights. We will also cooperate with law enforcement enquiries from within or outside your country of residence. This may include preserving or disclosing any of your information, including your Registration Information, if we believe in good faith that it is necessary to comply with a law or regulation, or when we believe that disclosure is necessary to comply with a judicial proceeding, court order, or legal request; to protect the safety of any person; to address fraud, security or technical issues; or to protect our rights or property or those of third parties. In such cases we may raise or waive any legal objection or right available to us.

Business Transfers - In the event that Gavel Technologies Corp or any of our affiliates are involved in a bankruptcy, merger, acquisition, reorganization or sale of assets, your information may be sold or transferred as part of that transaction.

Non-Private or Non-Personal Information - We may share or disclose your non-private, aggregated or otherwise non-personal information with third parties for industry analysis and demographic profiling and to deliver targeted advertising about other products and services and for marketing purposes. You may opt-out of receiving marketing messages by using the opt-out mechanisms and links provided in each email.

4. WHAT OTHERS MAY SEE ABOUT YOU.

The Gavel Platform is designed to make it easier for you to connect with other Users and to interact with them. If you register or login to the Gavel Platform using your Facebook, Google, or email account, you are authorizing us to access certain Facebook, Google, or email account information, including information you make available to the public via Facebook, Google, or email such as your friends list, relationship status, current location and those friends or connections you have in common with other Users. You also understand that your User profile and other information you make available via the Gavel Platform, including information you provide directly or indirectly through Facebook (i.e., your Facebook photos, your name, age, approximate location, friends you have in common with other Users and other profile information), Google, or email may be viewed and shared by Users with individuals who may or may not be Users or via third party applications in such Users’ discretion.

When using the Gavel Platform, you should assume that anything you post or submit on the App may be publicly-viewable and accessible, both by Users and non-Users. Before you post this information, be aware that this content may be searchable by search engines.

5. MODIFYING YOUR REGISTRATION INFORMATION.

You may access or modify the Registration Information you provided at any time or permanently delete your Account.

When your Account is deactivated, we take reasonable efforts to make sure it is no longer viewable. We are not responsible for any information, pictures, comments, or other content that is deleted from our systems resulting from the deactivation of your Account.

To prevent abuse and/or misuse by a User following termination or deletion of a profile/Account we shall retain such information as we deem in our sole discretion may be necessary to ensure that User does not breach our Terms of Service (http://gavelcorp.com/ToS/) and to ensure compliance with all laws and regulations.

Warning : Even after you remove information from your profile or delete your Account, copies of that information may still be viewable and/or accessed to the extent such information has been previously shared with others, or copied or stored by other Users or to the extent such information has been shared with search engines. We cannot control this, nor do we accept any liability for this. If you have given third party applications or websites access to your personal information they may retain such information to the extent permitted under their terms of service or privacy policies.

6. OUR POLICY TOWARDS AGE.

You have to be at least 18 years old to use Gavel.

Our policy is to not market to children, minors or anyone under the age of 18. If you are less than 18 years old, we request that you do not submit information to us. If we become aware that a child, minor or anyone under the age of 18 has registered with us and provided us with personal information, we will take steps to terminate that person's registration and delete their Registration Information. If we do delete a profile because you violated our no children rules, we may retain your email and IP address to ensure that you do not try to get around our rules by creating a new profile.

7. CHANGES TO THIS POLICY.

As the Gavel Platform evolves, we may revise this Privacy Policy from time to time. The most current version of the policy will govern our use of your information. If we make a change to this policy that, in our sole discretion, is material, we will notify you, for example, via an email to the email associated with your Account or by posting a notice within the Gavel Platform or on this page. By continuing to access or use Gavel after those changes become effective, you agree to be bound by the revised Privacy Policy.

8. SECURITY.

We take commercially reasonable security measures to help protect your information against loss, misuse and unauthorized access, or disclosure. We use reasonable security measures to safeguard the confidentiality of your personal information such as secured servers using firewalls.

Unfortunately, no website or Internet transmission is ever completely 100% secure and even we cannot guarantee that unauthorized access, hacking, data loss or other breaches will never occur, but here are some handy tips to help keep your data secure:

1. Please make sure you log out of your Account after use.

2. Please don't share your social media password with anyone else!

3. Change your social media password periodically.

If you ever think someone has had access to your social media password, please report it to the relevant social media platform and change your password immediately. We cannot guarantee the security of your personal data while it is being transmitted to our site and any transmission is at your own risk.

WE EXPRESSLY DISCLAIM ANY REPRESENTATION OR WARRANTY, WHETHER EXPRESS OR IMPLIED, WITH RESPECT TO ANY BREACHES OF SECURITY, DAMAGE TO YOUR DEVICE, OR ANY LOSS OR UNAUTHORIZED USE OF YOUR REGISTRATION INFORMATION OR OTHER DATA.

9. THIRD PARTY ACCOUNTS.

If you have registered using a third party social media platform, your User profile will be available to all Users whether via our App or our partners' websites.

Remember that when you register with a third party, you are also giving them personal information, so we recommend that you read their privacy policies as we do not control how they use their information.

If you have registered on one of these third party websites, such as Facebook, or you have verified your Account via a third party website, we may connect your User profile with your profile on such website. We may do this by way of new products and applications which we introduce from time to time, including new products powered by our group companies.

If you have created a User profile through a third party website and you do not want to link your User profile to your profile on the third party website, we cannot amend these settings. Please visit the application settings on your third party website profile and follow the instructions to remove the App’s access permissions.

We only use the APIs, OAuth Tokens, Widgets, or other means provided by the applicable Social Media Account to integrate your Social Media Account with our Platform. As such, we only receive the limited information that each Social Media Account permits to be transferred.

10. YOUR CALIFORNIA PRIVACY RIGHTS.

California's "Shine the Light" law, Civil Code section 1798.83, requires certain businesses to respond to requests from California customers asking about the businesses' practices related to disclosing personal information to third parties for the third parties' direct marketing purposes. If you wish to find out about any rights you may have under California Civil Code section 1798.83, you can write to us at legal@gavelcorp.com.

From time to time we may disclose your contact information to third parties to allow them to market their products or services to you or for other marketing purposes. This may be information we received from you offline and online. If you want us to stop further sharing your email contact information with third parties (if we have your email contact information), you may notify us at legal@gavelcorp.com. Please follow the instructions provided to you by third parties to unsubscribe from their messages. If you have opted-out as described above, and thereafter you chose to use a service or promotion that requires us to contact you or share your information with a third party, then your previous opt-out preferences will not apply to such service.

In addition, under California law, operators of online services are required to disclose how they respond to "do not track" signals or other similar mechanisms that provide consumers the ability to exercise choice regarding the collection of personal information of a consumer over time and across third party online services, to the extent the operator engages in that collection. At this time, we do not track our Users' personal information over time and across third-party online services. This law also requires operators of online services to disclose whether third parties may collect personal information about their users' online activities over time and across different online services when the users use the operator's service. We do not knowingly permit third parties to collect personal information about an individual User's online activities over time and across different online services when using the App.

11. ABOUT US.

Your access to the Gavel Platform, as well as this Privacy Policy are governed and interpreted by the laws of the State of California, other than such laws, rules, regulations and case law that would result in the application of the laws of a jurisdiction other than the State of California. By using the Gavel Platform, you are consenting to the exclusive jurisdiction of the courts of the United States and the State of California. You agree that such courts shall have in personam jurisdiction and venue and waive any objection based on inconvenient forum. You agree that you will not file or participate in a class action against us. In the event there is a discrepancy between this English language version and any translated copies of the Policy, the English version shall prevail.

Effective date

This Privacy Policy was last updated on April 4, 2017.