Last Updated: September 30, 2019
COMPLIANCE WITH THE EU-U.S. PRIVACY SHIELD FRAMEWORK
We collect or receive information in a few different ways. Often you may choose what information to provide, but in other instances we require you to provide certain information to use the Site or our Services.
Ecomdash will collect any comments you may send to ecomdash and any information you may post to the Site.
Ecomdash collects personally identifiable information when you: (1) register with ecomdash and create an account with us, (2) become an ecomdash Client, (3) participate in the purchase/auction for a product listed by an ecomdash Client, (4) complete a checkout page for a product purchased from an ecomdash Client, (5) provide comments or submit a problem to ecomdash or an ecomdash Client, (6) request information from ecomdash and provide your name or return contact information, or (7) respond to special offers, contests or surveys.
Buyers and ecomdash Clients. If you are using the online services of ecomdash, including ecomdash’s public Application Program Interface (“API”) (collectively, the “Services”), or the Site, ecomdash may collect personally identifiable information about you including email, billing and shipping addresses, credit card or bank account numbers, purchasing information, product information and product order information. In addition, ecomdash may also collect information about your bidding, buying and selling history as well as third party comments regarding your bidding, buying and selling behavior. Bidding and buying history may specifically include your history with respect to any failure to complete sales on winning bids. As part of the registration or checkout process, you may be asked to provide contact and billing information and other personally identifiable information. Providing some of the requested information is optional and ecomdash will indicate what information is required and what information is optional. You can always choose not to provide information even though it may be needed to make a purchase from an ecomdash Client or take advantage of ecomdash Services or features.
- Social Media Cookies: These cookies are used to integrate the Site with popular social media sites (Facebook, Twitter, etc.). Social Media cookies allow visitors to share content quickly and easily with their social networks.
- Analytics Cookies: These cookies are used to measure website traffic and activity.
- Advertising Cookies:These cookies help correlate online advertising to a visitor’s interests by displaying marketing messages that are relevant to a user based on a user’s browsing history and preferences.
Information from Third Parties. Some Users may connect to ecomdash or register to ecomdash using an external third-party application, such as Facebook, or an app developed using the ecomdash API. Ecomdash may receive information from those connected third-party applications. Connecting your ecomdash account to those third-party applications is optional. If you connect your account to a third-party application, we may receive your information from that application and we may use that information to provide the Services to you.
HOW WE SHARE YOUR INFORMATION
Ecomdash Users. If you are an ecomdash Client or a Buyer, ecomdash shares personally identifiable information it collects, as further described below under “Bidding and Buying Process” under “HOW WE USE PERSONALLY IDENTIFIABLE INFORMATION”.
Third Party Service Providers. Ecomdash shares personally identifiable information with our third-party service providers who help provide the Site and the Services, including our website host provider, online marketplace support provider, web analytics provider, and payment processor. Such third-party providers must agree to use such personally identifiable information only for the purposes for which they have been engaged by us.
Anonymous Use and Sharing. Ecomdash may share with third parties anonymized information in the performance of the Services, including evaluating market trends and/or under a joint marketing agreement to provide the Services. Such information will not include personally identifiable information.
Lawful Requests. Ecomdash may disclose a User’s personally identifiable information if required to do so by law and in response to lawful requests by public authorities, including to meet national security or law enforcement requirements, or if ecomdash has a good faith belief that such disclosure is necessary to protect and/or defend the rights and interests of ecomdash or others. Ecomdash may, as permitted by applicable law, disclose your personally identifiable information to ecomdash Clients, other ecomdash users or third parties in connection with an investigation of fraud, infringement, piracy or other unlawful activity and you expressly authorize ecomdash to make such disclosures.
Change of Ownership. We reserve the right to transfer any information we have about you in connection with a sale, merger, consolidation, change in control, transfer of assets, reorganization or liquidation of our business.
HOW WE USE PERSONALLY IDENTIFIABLE INFORMATION
We generally use information we collect to communicate with you, including to respond to your questions or comments, to provide the Site and the Services, to improve the Site and Services, to notify you about changes to the Site or the Services, to provide you with the products or services you have requested or purchased, to provide you with information about the services that we offer (including details of any products which we believe may be of interest to you) in accordance with your preferences, including any marketing preferences, to audit, monitor and administer the Site, to comply with any legal or regulatory obligations and to protect and enforce our legal rights.
Customer Support. Contact information provided by a Buyer to ecomdash in connection with problems, comments or requests about our Site or the Services is used only to respond to those problems, comments or requests and may be provided to ecomdash Clients or third parties as necessary to respond to the comment, problem or request.
Marketing/Special Offers/Solicitation from Ecomdash. Ecomdash may use a Buyer’s information to provide updates and other business purposes related to making available the features and functions of the Services. Ecomdash also may use information a Buyer provides to make a Buyer aware of new products or special offers or promotions. Ecomdash will abide by requests from you to discontinue such use. As a Buyer, if you receive communications directly from an ecomdash Client, you should contact the ecomdash Client directly concerning such communications and review their privacy policies. A Buyer will receive such information as described in this Section unless a Buyer has opted out of receiving such information from ecomdash as part of the checkout process. Outside of the checkout process, Buyers may also opt out of receiving such information (if you have not already opted out of receiving it) by sending a request as described below in “Your Choices; Access to, Review of and Modifications to Your Personally Identifiable Information”.
Providing Ecomdash Buyer Information to Third Parties for Marketing/Solicitation (for ecomdash Buyers only). If you are a Buyer, ecomdash does not sell your personally identifiable information to third parties for purposes of marketing or soliciting you, provided however, we may share personally identifiable information, including credit or debit account information, with a third party upon your prior consent (opt-out). To the extent that ecomdash Clients (for example, a seller of an item you purchased) have access to your personally identifiable information as a result of your bidding or buying, where ecomdash provides your information to ecomdash Clients as part of a transaction you may be involved in with such ecomdash Client, these entities may solicit or market to you in accordance with their policies. As a Buyer, you are encouraged to review the privacy policies of the ecomdash Clients that provide the products or services related to your bid or purchase. You should contact ecomdash Clients directly and review their privacy policies should you have questions concerning their use of your personally identifiable information such as, for example, communications you may or may not wish to receive.
Providing Ecomdash Client Information to Third Parties for Marketing/Solicitation (for ecomdash Clients only). If you are an ecomdash Client, ecomdash may provide certain of your registration information to third parties for use in marketing and in designing or providing their own services, to send you information about its products and to notify you if you win a contest. As an ecomdash Client, you may opt-out of ecomdash providing such information to third parties at any time by updating your Personal Account Settings or by contacting ecomdash. You should contact the third party directly who may already be sending you messages in order to request these communications stop, and to review their privacy policies.
Bidding, Buying, Selling History. Ecomdash may use any information collected related to a Buyer or ecomdash Client’s bidding, buying or selling history to generate recommendations and predictions related to likelihood of your willingness to complete a bid and may submit such history and recommendations to ecomdash Clients.
YOUR CHOICES; ACCESS TO, REVIEW OF AND MODIFICATIONS TO YOUR PERSONALLY IDENTIFIABLE INFORMATION
Data Integrity; Choice. Ecomdash will use personally identifiable information only in ways that are compatible with the purposes for which it was collected or subsequently authorized by a User. Ecomdash will take reasonable steps to ensure that such information is relevant to its intended use, accurate, complete and current. Ecomdash will offer Users the opportunity to choose (opt-out) whether their personally identifiable information is to be disclosed to a third party or used for a purpose other than the purpose for which it was originally collected or subsequently authorized by the User.
You may access, modify, remove, correct or update personally identifiable information by contacting ecomdash (see “How To Contact Us” section below). To protect your privacy and security, we will also take reasonable steps to verify your identity before granting access or making corrections. Please note that we may not be able to correct or update your personally identifiable information previously provided to us by third parties.
If you receive any promotional email communication from us, you will be given the option to “unsubscribe” from receiving further email communications from us at any time. Your option not to receive promotional and marketing material from us will not preclude us from corresponding with you, by email or otherwise, regarding your existing or past business relationship with us. Ecomdash may retain transactional history in order to document a transaction you may have had with an ecomdash Client. You should contact the ecomdash Client (for example, the seller of an item you have purchased) directly in order to access, modify or update your personally identifiable information with them.
LINKS TO OTHER SITES
DO-NOT-TRACK; THIRD PARTY TRACKING
Unless your browser settings are configured to make your online activities and publicly available information about your online activities invisible to usage analytics tools, we do not presently have the capability to omit you from usage analytics to the extent your browser only sends us a “do not track” message and does not otherwise screen you from tracking without any action on our part. To learn more about browser tracking signals and “do not track”, visit http://allaboutdnt.org. Third parties, other than our service providers, do not have our permission to track which websites you visit prior to and/or after visiting our Site. That said, we cannot control all third-party tracking, and there may be third-party tracking without our knowledge or consent.
YOUR CALIFORNIA PRIVACY RIGHTS
Pursuant to Section 1798.83 of the California Civil Code, California residents have the right to request from a business with whom the California resident has an established business relationship: (1) What types of personally identifiable information, if any, of the California resident the business shares with third parties for direct marketing purposes of those third parties; and (2) the identities of the third parties with whom the business has shared such information in the immediately preceding calendar year.
Ecomdash does not knowingly, and uses reasonable efforts not to, collect, use or disclose personally identifiable information from children under the age of 13. If we learn we have collected or received personally identifiable information from children under 13, we will take steps to delete the information as soon as possible. The Services are not targeted at children, and individuals under 18 years of age, or the age of majority in their jurisdiction of residence if higher, may not register for any of the Services.
Domestic and International Use. All personally identifying information collected by ecomdash may be used in the United States or if the Services are undertaken by ecomdash for a foreign ecomdash Client, such information may be transferred to the United States for use of the Services by an ecomdash Client, or such information may be transferred to that ecomdash Client outside of the United States and you consent to any such transfer of information outside of your country, including countries that have different data protection rules than your country. We do not represent that the Site or Services are appropriate or available in any particular jurisdiction.
Notice to Residents of Countries Outside the United States. Ecomdash is hosted in and intended for use in the United States by U.S. residents. If you are located in the European Union, please see the “PRIVACY SHIELD PROVISIONS” for more information about transfers from the EU to the U.S.
PRIVACY SHIELD PROVISIONS
Right of Access. If you are an EU individual, you have the right to access the personally identifiable information we hold about you. If such information is inaccurate or processed in violation of the Privacy Shield Principles, you may also request that such information be corrected, amended or deleted. See “YOUR CHOICES; ACCESS TO, REVIEW OF AND MODIFICATIONS TO YOUR PERSONALLY IDENTIFIABLE INFORMATION” section above and “HOW TO CONTACT US” below for information on how to exercise this right.
Choice. If you are an EU individual, you have the right to opt out of (i) disclosures of your personally identifiable information to third parties not identified at the time of collection or subsequently authorized and (ii) uses of personally identifiable information for purposes materially different from those disclosed at the time of collection or subsequently authorized. See “YOUR CHOICES; ACCESS TO, REVIEW OF AND MODIFICATIONS TO YOUR PERSONALLY IDENTIFIABLE INFORMATION” section above and “HOW TO CONTACT US” below for information on how to exercise this right.
Onward Transfers. If ecomdash receives personally identifiable information subject to our certification under the Privacy Shield and then transfers such information to a third-party service provider acting as an agent on our behalf, we have certain liability under the Privacy Shield if the agent processes such information in a manner inconsistent with the Privacy Shield except when we are not responsible for the event giving rise to the damage.
Ecomdash Internal Recourse Mechanism. In compliance with the Privacy Shield Principles, ecomdash commits to resolve complaints about our collection or use of your personally identifiable information. EU individuals with inquiries or complaints should first contact ecomdash at: firstname.lastname@example.org or at ecomdash, Attn: CEO/Nick Maglosky, 10 Corporate Drive., Burlington, MA 01803 or by phone at 781.852.3200. We will respond to your request within a reasonable timeframe, but in no event less than 45 days after receipt of your complaint.
Independent Recourse Mechanism. If a complaint cannot be resolved through ecomdash’s internal process, ecomdash commits to cooperate with the panel established by the EU data protection authorities (DPAs) and comply with the advice given by the panel with regard to personally identifiable information transferred from the EU. Such individuals may direct complaints about their personally identifying information to their respective DPA.
Binding Arbitration. You have the possibility, under certain conditions, to invoke binding arbitration for complaints regarding Privacy Shield compliance not resolved by any of the other Privacy Shield mechanisms pursuant to the Privacy Shield’s Recourse, Enforcement and Liability Principle and Annex I of the Privacy Shield.
Regulatory Oversight. The Federal Trade Commission has jurisdiction over ecomdash’s compliance with the Privacy Shield.
How To Contact Us
10 Corporate Drive
Burlington, MA 01803
You may also use the above contact information if you think any information about you is inaccurate, incomplete, or if you want to change the sort of information about you that ecomdash may have collected.