At Treasure, the privacy of our clients and other website visitors is of the utmost importance. Treasure strives to gain and maintain the trust of our community of users, buyers and sellers by continually protecting identities and holding information in confidence. All information you provide us when using Treasure websites is held in confidence, except as herein noted. All terminology, terms, and conditions consistent with the Terms of Service, and the Terms of Service are thus incorporated into the privacy policy herein.
As we update and expand our services, this privacy policy may change to better serve everyone. Treasure does not typically send notifications of changes to our privacy policy, and thus users are responsible for checking back periodically for updates. Please feel free to contact us at any time with questions or suggestions regarding this policy.
Contents:
Who Is Responsible For Your Data?
The data controller is Treasure, its legal entity and affiliates as named in our site footers.
Please note that Treasure’s services do not include any outside platforms/providers that are connected with our operation. This can include financial transactions platforms such as Stripe, which is used in conjunction with making purchases on Treasure.
Individuals Under the Age of Majority
As per our Terms of Service, individuals under the age of majority in their respective jurisdiction are not permitted to use Treasure’s services. As such, we do not knowingly collect, use, or maintain any personal data from any minors, nor do we knowingly allow such persons to register for Treasure and its services.
What Personal Information Do We Collect, When, and Why?
When you visit Treasure Sites, we will not collect your name, address, telephone number or email address without your consent. We collect any and/or all of the following, and store the data at our data centers, including but not limited to those in the United States. Consult the glossary found later in this policy to learn more about terms used in this section.
EXAMPLES OF PERSONAL INFORMATION WE MAY COLLECT AND WHEN WE COLLECT IT
(THIS LIST IS NOT EXHAUSTIVE)
A. Our registration process collects some or all of your Name, Email Address, billing and/or shipping addresses, Telephone number(s), and payment details like Credit Card Number, eCheck, or other payment/validation method.
PURPOSE - To provide you with requested services to participate in auctions conducted by Treasure.
LEGAL BASIS FOR PROCEEDING - Performance of a contract, the Treasure Terms.
B. We collect any communications, content, and other information you provide when you use Treasure’s services, including comments responding to items listed/displayed on Treasure, emails to Treasure, information provided during signup, etc.
C. Our, or third party, credit application collects your Name, Home Address, Home Phone, Employment Information, IP address and References.
PURPOSE - To know our clients and prevent fraud.
LEGAL BASIS FOR PROCESSING - Legitimate Interests
D. Our surveys and contests collect your name, email address, address, telephone number, and information about your collecting and selling habits and interests.
PURPOSE - To monitor the performance of our website and make your user experience better.
PURPOSE - To deliver more appropriate advertisements on our website and other websites.
PURPOSE - To improve the navigation, functionality, and general service that our website provides.
PURPOSE - To monitor your use of our services, train our staff and improve your client or user experience.
PURPOSE - To provide you with details about upcoming auctions, events and other Treasure services that might interest you.
LEGAL BASIS FOR PROCESSING - Legitimate Interests
E. CCTV captures your images when you visit or conduct business at our premises or attend our events at various locations.
PURPOSE - To keep you, our staff, property we sell, property on our premises, and auction event premises secure.
LEGAL BASIS FOR PROCESSING - Legitimate Interests - Public Interest
F. Our automated and manual processes aggregate personally identifiable information related to your information you provided to us directly and through third-party vendors (such as name and address, wealth and creditworthiness), together with web activity history, transactional history, survey data, and other data sources.
PURPOSE - To improve our service, provide personalized experiences (through our sales staff, client services staff, accounting, shipping, as well as print and digital channels), focus our marketing efforts, manage our fraud risks, establish credit limits, and other similar goals to further our business.
LEGAL BASIS FOR PROCESSING - Legitimate Interests
By submitting personally identifiable information, you agree, without limitation or qualification, to this information being used exclusively by Treasure and its authorized dealers for business purposes only. If you opt not to provide us with personally identifiable information, you may be unable to receive specific communications on products and company information or make full use of Site features.
How Does Treasure Use Your Information?
Treasure may research our clients' usage patterns and demographics based on the information provided to us during their experiences on our website. We do this to better understand our clients' needs and enhance our service. This information is compiled and analyzed for internal use.
Registration qualifies a user as a Treasure client, and, regardless of any regulation to the contrary, the user agrees, until this consent is revoked in writing, that Treasure may from time to time contact the user concerning sale and purchase opportunities available through Treasure.
Treasure collects and stores any login information you create in order to allow you to access your account information and member features.
With Whom Does Treasure Share Your Information?
All information is held in confidence by Treasure. We do not trade, rent or sell your information, including email addresses or phone numbers, to third parties, nor do we provide it for any third party's general commercial usage. Any information disseminated to parties external to Treasure is anonymous in nature - for example: the prices realized for a particular item may include the price paid for a share.
We or you may disclose your personal data with our service providers to ensure the proper functioning of your requested services and Treasure business operations (for example, for authentication or to process transactions, we or our service provider may transmit your credit card information to a bank for enhanced data security and authentication). Before we do so, we shall take reasonable steps to ensure that your personal data will be given adequate protection, and our service providers will only use the information interacting with Treasure for purposes outlined in the “What personal information do we collect, when, and why?” section.
You agree to review and consent to the Privacy Policy of any outside service provider/platform you share your data with in your use of Treasure, such as financial transaction providers, and to hold such service producer exclusively responsible for their use of your data under their terms, policies and agreements with you. Important: we emphasize that such outside platforms are not part of the services provided by Treasure, and as such we are not liable for the actions/policies of such providers.
We reserve the right to share information, when we deem appropriate, with third parties that are acting on proper legal authority (e.g. subpoenas), including police and governmental agencies. We will also share your information with third-party companies or organizations if we have a good-faith belief that this is reasonably necessary to find or protect against security issues or fraud. We may respond to credit references initiated by you or in the trade. In such instances, we generally will verify whether you are a known client, the length of time you may have done business with us, and whether your account is in good standing.
What Are Cookies, and How Are They Used?
The Internet browser you use to view our site allows a small file called a "cookie" to be saved on your device. This cookie enables our Web server to recognize you as a first-time or repeat client, and may include information such as your User Name so you do not have to re-enter it every time you visit. We also use cookies to provide customized and personalized services to you. Your browser does allow you to turn off or warn you about cookies from our site and from any other websites. Cookies do not allow us to know anything about your surfing habits on other websites. They simply tell us about your surfing habits on our website. Treasure may allow certain third parties contracted by Treasure, such as analytics partners, advertising technology partners, and other partners, to use cookies and/or include web beacons on HA.com web pages for purposes related to those specific partner services. These cookies and web beacons may include your IP address, but do not include any Personally Identifiable Information (“PII”).
NOTE: Treasure operates under US law. As of this original writing, no US court has ruled that an IP address is PII. Therefore, as it relates to our data gathering and usage activities and the data gathering and usage activities of our third party partners, Treasure does not consider IP address to be personally identifiable information, as this data is not used in that context. We understand that some entities and individuals outside the US do consider IP address to be PII, and we therefore disclose these practices.
How Do We Ensure the Protection of Your Personal Information?
Treasure maintains reasonable physical, electronic, and procedural safeguards to protect the security and integrity of all Personal Information provided to us. Treasure limits access to personal information about you to those employees who we reasonably believe need to come into contact with that information to provide products or services to you in order to do their jobs.
In the interest of privacy and security, we automatically expire your session when a specific period goes by without activity.
Treasure takes reasonable precautions - including administrative, technical, and physical measures - to safeguard your personal information against loss, theft, and misuse, as well as unauthorized access, disclosure, alteration, and destruction.
How Long Will Your Personal Data Be Retained?
We will retain your personal information for as long as necessary to fulfill the purposes outlined in the “What personal information do we collect, when, and why?” section and to satisfy any legal, accounting, regulatory, or reporting requirements.
Reviewing and Changing Your Information?
Treasure has safeguards in place to keep your personal information accurate, complete, and up-to-date for the purposes for which it is used. Naturally, you always have the right to access and correct the personal information you have provided. You can help us ensure that your contact information and preferences are accurate, complete, and up-to-date by going to your Profile page.
For any personally identifiable information that cannot be updated via your Profile page, please make a request to have it changed, if needed, using the contact information listed later in this policy.
“Do Not Track” Notice and Disclosure
Treasure does not currently respond to Web browser “do not track” signals and similar signals as providers of these signals do not currently operate according to common, industry-accepted standards. However, as stated earlier in this policy, your browser provides tools to allow you to change your privacy and security settings. For instructions, consult your browser’s Help menu.
Treasure does not knowingly allow other parties to collect personally identifiable information about an individual consumer’s online activities over time and across different websites when a consumer uses our websites and services.
For more information on Do Not Track, visit allaboutdnt.com.
Additional Information for European Union Residents Who Use Treasure Sites and Apps
Subject Access Requests
If you are a resident of the European Union, you have the right to make a “subject access request” You can request that Treasure provide a copy of the information we hold about you, correct it, erase it, object or restrict the processing of it, and transfer it to another organization. You also have the right to object to direct marketing.
If you want to exercise any of the above rights with respect to your personal data, please make your request using the contact information listed later in this policy.
Treasure will always verify the identity of anyone making a subject access request before handing over any information. In the event Treasure refuses your request under rights of access, we will provide you with a reason as to why, which you have the right to legally challenge.
Transfer of Information to the United States
Treasure is based in the United States and, under normal business operations, your data will reside on servers located in the United States.
Additional Information for California Residents Who Use Treasure Sites and Apps
If you are resident of California, you have the right to request, update, or delete certain personal information from a business with whom you have an established business relationship. This includes personal information the business shares with third parties for direct marketing purposes by such third party and the identities of the third parties with whom the business has shared such information during the immediately preceding calendar year.
If you want to exercise these rights with respect to your personal data, please make your request using the contact information listed later in this policy.
Treasure will always verify the identity of anyone making a subject access request before handing over any information. In the event Treasure refuses your request under rights of access, we will provide you with a reason as to why, which you have the right to legally challenge.
Under the California Consumer Privacy Act, Treasure may not:
Notice Regarding Account Deletion Requests
Treasure may not be able to completely delete information relating to your account and may need to retain information consistent with legitimate business purposes, to comply with applicable laws and regulations, or because of an active or potential legal dispute. Where information for a deleted account is retained, only necessary account information is retained and only for the limited purposes of compliance with the reasons described herein. Such information is retained subject to and consistent with applicable data privacy laws for your region.
Questions, Concerns, and Complaints
If you have any questions, concerns, or complaints relating to the processing of your personal data, please contact us through our site or by writing us at Treasure’s corporate address:
You may raise a complaint with the relevant supervisory authority if you believe Treasure infringed applicable data privacy laws when processing your personal data. This right is without prejudice to any other administrative or judicial remedy you might have.
Glossary:
• Data Controller: The person or entity who determines the purposes for which and the manner in which any personal data are, or are to be, processed.
• Legitimate Interests: Processing is necessary for our or a third party’s legitimate interests in carrying on, managing, and administering our respective businesses effectively and properly (except where our or the third party’s interests are overridden by your own interests, rights, and freedoms).
• Performance of a contract: A lawful basis where processing of data is necessary for the performance of a contract to which you are a
party, or in order to take steps at your request to entering into a
contract.
• Personal Data: Any data relating to an identified or identifiable
individual; an identifiable person is one who can be identified, directly or indirectly. This can include names, email addresses, home address, credit applications, user account information, and correspondence to and from an individual.
• Processing: Any operation performed on personal data, such as collection, recording, storage and retrieval, use, combining it with other data, transmission, disclosure, or deletion.
Privacy policy last updated on and effective as of May 29th, 2023.
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