Invaluable is committed to your privacy. This GDPR Addendum explains our collection, use, disclosure, retention, and protection of your personal information, as EU Data Subjects, in the manner compliant with the regulations set forth in the GDPR
Table of Contents
ScopeThis privacy notice applies to any Invaluable website, application, service, or tool (collectively "Services") where this privacy notice is referenced, regardless of how you access or use them, including through mobile devices.
Learn more: ScopeThis privacy notice applies to any Invaluable website, application, service, or tool (collectively "Services") where this privacy notice is referenced, regardless of how you access or use them, including through mobile devices.
This privacy notice also applies to the provision of Invaluable services through any Invaluable partner's website, application, service, or tool where it is referenced and where your listings and their content are published or advertised in accordance with the terms of this privacy notice.
We may amend this privacy notice at any time by posting the amended version on this site including the effective date of the amended version. We will announce any material changes to this privacy notice through the Invaluable Message Center and/or via email.
Lawful BasesRegarding the lawful bases required by article 5 and the specific bases considered lawful under article 6 of GDPR, two lawful bases apply depending on the data and its use:
Consent: The data subject has freely given consent for their information to be processed for a specific purpose.
For all processing involved with educating the consumer about what is available and what each might find of particular interest, and all data collection involved with improving the quality of our services and your experience with using them, commonly known as Marketing and User Experience, our lawful basis is consent, freely given, as defined by GDPR.
Legitimate Interest: processing is necessary for the purposes of the legitimate interests pursued by the controller
For the provision of a transaction marketplace, once a hopeful buyer starts the process that ultimately could lead to a purchase, that process is controlled by our Legitimate Interest in your data, all of which is used to manage the transactions and provide services for the buying process, and some of which are used in support of the contract entered into directly with the seller once the buying process is initiated. This would include the collection of data to fulfill the contract including address and credit card data. Legitimate Interest is the basis for processing and retaining data to facilitate authorization to bid, fraud detection, the provision of a a safe and secure marketplace including the open market processing itself, the placement of price offers through bidding or buy now, the completion of those purchases by both buyers and sellers, and the correct and lawful conclusion and accounting for those purchases. All this data collection and processing has its legal basis in article 6: Legitimate Interest.
Who Controls Your InformationRegardless of where you are in the world when you access our services, you are contracting with:
Invaluable LLC is your data controller, and is responsible for the collection, use, disclosure, retention and protection of your personal information in accordance with our global privacy standards, this privacy notice, as well as any applicable national laws.
Your data controller may transfer data to other members of the Invaluable, LLC. corporate family who have agreed to follow the policy set forth by Invaluable, LLC, as described in this privacy notice.
We may process and retain your personal information on our servers in the U.S. and elsewhere in the world where our data centers are located.
Where we have a legal obligation to do so, we have appointed data protection officers (DPOs) to be responsible for the privacy program at each of the respective data controllers.
Personal information we collect
What is personal information?Personal Information is information relating to an identified or identifiable natural person. An identifiable natural person is one who can be identified, directly or indirectly, by reference to an identifier such as a name, an identification number, location data, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
We do not consider personal information to include information that has been anonymized or aggregated so that it can no longer be used to identify a specific natural person, whether in combination with other information or otherwise.
We collect personal information from you when you use our Services.
Learn more: Personal information we collectWe collect personal information from you and any devices (including mobile devices) you use when you: use our Services, register for an account with us, provide us information on a web form, update or add information to your account, or when you otherwise correspond with us.
Some of this personal information, such as a verifiable way to identify you, is necessary to enter into our User Agreement. The provision of all other personal information is voluntary, but may be essential in order to use our Services, such as the bidding, buying or selling information needed to conclude a transaction.
We may also collect personal information from other sources, as described below.
Personal information you give us when you use our Services or register for an account with us
information we collect automatically when you use our Services or register for an account with us
Personal information we collect using cookies and similar technologies
Personal information collected from other sources
How we use your personal informationWe use your personal information to provide and improve our Services, provide you with a personalized experience on our sites, contact you about your account and our Services, provide you customer service, provide you with personalized advertising and marketing, to detect, prevent, mitigate, investigate and track fraudulent or illegal activities, and to track actions related to the exercise of contractual obligations between our marketplace buyers and sellers.
Learn more: How we use your personal informationWe use the personal information we collect from you for a range of different business purposes and according to different legal bases of processing. The following is a summary of how and according to which legal bases we use your personal information.
We use your personal information to fulfill a contract with you and provide you with our Services, to comply with our legal obligation, protect your vital interest, or as may be required for the public good. This includes:
We use your personal information to pursue our legitimate interests where your rights and freedoms do not outweigh these interests. We have implemented controls to balance our interests with your rights. This includes to:
With your consent, we may use your personal information to:
We may use technologies that could be considered automated decision making or profiling. We will not make automated decisions about you that would significantly affect you, unless such a decision is necessary as part of a contract we have with you or that we have with our sellers, we have your consent, or we are required by law to use such technology.
Your choices about how we use your personal informationYou have choices about how we use your personal information to communicate with you, to send you marketing information, how we provide you with customized and relevant advertising, and whether you want to stay signed into your account.
Learn more: Your choices about how we use your personal information
Communication preferencesYou can control your email communication preferences in the Communication Preference section within your My Invaluable. There, you can also choose which newsletters and promotions you want to receive.
MarketingIf you do not wish to receive marketing communications from us, you can unsubscribe via the link in an email you received, change your Communication Preferences within My Invaluable, indicate your communication preferences using the method described within the direct communication from us or contact us as described in the Contact Us section below. Keep in mind, we do not sell, rent, or otherwise disclose your personal information to third parties for their marketing purposes without your consent.
AdvertisingIf you do not wish to participate in our advertising personalization programs, you can opt-out by following the directions provided within the applicable advertisement, or through the programs described in our User Cookie Notice. The effect of an opt-out will be to stop personalized advertising, but it will still allow the collection of personal information as otherwise described in this privacy notice. We do not allow third parties to track or collect your personal information on our sites for their own advertising purposes, without your consent.
Staying Signed inWhen you sign in to your account on our Services, we give you the option to stay signed in to your account for certain amount of time. If you are using a public or shared computer, we encourage you not to choose to stay signed in. You or any other user of the computer/browser you signed in on will be able to view and access most parts of your account and take certain specific actions during this signed in period without any further authorization. The specific actions and account activities that you or any other user of this computer/browser may take include:
You can typically end your signed in session by either signing out and/or clearing your cookies. If you have certain browser privacy settings enabled, simply closing your browser may also end your signed in session. If you are using a public or shared computer, you should sign out and/or clear your cookies when you are done using our Services to protect your account and your personal information.
Ways you can access, control, and correct your personal informationWe respect your right to access, correct, request deletion or request restriction of our usage of your personal information as required by applicable law. We also take steps to ensure that the personal information we collect is accurate and up to date.
Learn more: Ways you can access, control, and correct your personal information
Access, correction, and deletion of your personal informationYou can see, review and change most of your personal information by signing in to your account. Please, update your personal information immediately if it changes or is inaccurate. Keep in mind, once you make a public posting, you may not be able to change or remove it.
We will honor any statutory right you might have to access, modify or erase your personal information. To request access and to find out whether any fees may apply, if permitted by applicable national laws, please contact us at [email protected]. Where you have a statutory right to request access or request the modification or erasure of your personal information, we can still withhold that access or decline to modify or erase your personal information in some cases in accordance with applicable national laws.
Upon your request, we will close your account and remove your personal information from view as soon as reasonably possible, based on your account activity and in accordance with applicable national laws.
How we might share your personal informationWe may disclose your personal information to other members of the Invaluable LLC corporate family, to sellers if you successfully complete a purchase, or to third parties. This disclosure may be required for us to provide you access to our Services, to comply with our legal obligations, to enforce our User Agreement, to facilitate our marketing and advertising activities, or to prevent, detect, mitigate, investigate and track prohibited, fraudulent or illegal activities related to our Services. We attempt to minimize the amount of personal information we disclose to what is directly relevant and necessary to accomplish the specified purpose. We do not sell, rent, or otherwise disclose your personal information to third parties for their marketing and advertising purposes without your consent.
Learn more: How we might share your personal informationWe may disclose your personal information to the following parties for the following purposes:
Invaluable LLC corporate family members, who may use it to:
Service Providers and financial institutions partners as follows:
Law enforcement, legal proceedings, and as authorized by law
Invaluable sellers as authorized by you, or essential to your use of our Services
Change of ownershipIf we are subject to a merger or acquisition with/by another company, we may share information with them in accordance with our global privacy standards. Should such an event occur, we will require that the new combined entity follow this privacy notice with respect to your personal information. If we intend to handle your personal information for any purposes not covered in this privacy notice, you will receive prior notification of the processing of your personal information for the new purposes.
How long we keep your personal informationWe retain your personal information for as long as necessary to provide the Services you have requested, or for other essential purposes such as complying with our legal obligations, resolving disputes, and enforcing our policies.
Learn more: How long we keep your personal informationHow long we retain personal information can vary significantly based on context of the Services we provide and on our legal obligations. The following factors typically influence retention periods:
How do we protect your personal informationWe protect your personal information using technical and administrative security measures to reduce the risks of loss, misuse, unauthorized access, disclosure and alteration. Some of the safeguards we use are firewalls and data encryption, physical access controls to our data centers, and information access authorization controls. Our systems and policies are compliant with PCI DSS 3.2, particularly relating to sensitive financial information.
Data Controllers and Data Protection OfficersLearn more about who is your data controller, and is responsible for the collection, use, disclosure, retention and protection of your personal information in accordance with our global privacy standards, this privacy notice, as well as any applicable national laws.
Learn more: Data Controllers and Data Protection OfficersRegardless of where you are in the world when you access our services, you are contracting with:
All applicable laws, including Privacy Laws, for that location apply, as well as additional National and International regulations.
We have appointed a Data Protection Officer (DPO - William Peverill) to be responsible for the privacy program at Invaluable. You can contact our DPO via [email protected], and he will respond within 30 days in compliance with the GDPR
Other important privacy informationThis section describes some additional privacy information related to your use of our Services that you may find important.
Learn more: Other important privacy information
Seller responsibilities over transactional information you receive through InvaluableWhen you transact with another user, we enable you to obtain or we may provide you with the personal information of the other user (such as their name, account ID, email address, contact details, shipping and billing address) to complete the transaction. Independent from us, you are the controller of such data and we encourage you to inform the other user about your privacy practices and respect their privacy. In all cases, you must comply with the applicable privacy laws, and must give the other user a chance to remove them from your database and them a chance to review what information you have collected about them.
You may use the personal information that you have access to only for Invaluable transaction-related purposes, or for other services offered through Invaluable (such as escrow, shipping, disputes or fraud complaints, and buyer-seller communications), and for purposes expressly consented by the user to whom the information relates. Using personal information of other users that you have access to for any other purpose constitutes a violation of our User Agreement and additional contracts we may have in place with sellers.
Unwanted or threatening emailWe do not tolerate abuse of our Services. You do not have permission to add other users to your mailing list (email or postal), call, or send him/her text messages for commercial purposes, even if this user purchased something from you, unless the user has given his/her explicit consent. Sending unwanted or threatening email and text messages is against our User Agreement. To report Invaluable-related spam or spoof emails please forward the email to [email protected] with any additional comments, questions or objections you may have.
Communication toolsWe may scan messages automatically and check for spam, viruses, phishing and other malicious activity, illegal or prohibited content or violations of our User Agreement, this privacy notice or our other policies.
Children's PrivacyOur Services are specifically intended only for people who, through age and competence, are able to enter into a contract. Use by all other individuals is specifically precluded. We do not knowingly collect personal information from users deemed to be children under their respective national laws.
Third Party Privacy PracticesThis privacy notice addresses only our use and handling of personal information we collect from you in connection with providing you our Services. If you disclose your information to a third party, or visit a third party website via a link from our Services, their privacy notices and practices will apply to any personal information you provide to them or they collect from you.
We cannot guarantee the privacy or security of your personal information once you provide it to a third party and we encourage you to evaluate the privacy and security policies of your trading partner before entering into a transaction and choosing to share your personal information. This is true even where the third parties to whom you disclose personal information are bidders, buyers or sellers on our site.
Contact UsIf you have a question or a complaint about this privacy notice, our global privacy standards, or our information handling practices:
You can reach the Global Privacy Office in writing at:
You can also email our Privacy team at [email protected]
Or you can call our global customer care team at the contact us number for your region, and thy may be able respond to complaints, to help you find answers, or to put you in touch with our Privacy Office.
Our Data Protection Officer is William Peverill
Your right to file complaints with a data protection supervisory authority is always available to you. If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at the Council of Better Business Bureaus
This policy document 3.00 was last revised effective May 25, 2018.