Privacy Policy

Our Privacy Promise

Thank you for accessing the platform made available by Gauge Automotive, Inc. (“Company”, “we”, “us”, or “our”). We take your privacy very seriously. Our goal is to always be transparent and explain our privacy policy in the clearest way possible what personal information we collect, how we use it and what rights you have in relation to it.
All the personal information we have access to will be collected, processed and protected consistent with applicable data protection laws, and we never sell or broker protected or personally-identifiable information.
This Privacy Policy addresses what we do with your personal information as you access and use the auction tools and other items described as “Services” in our agreement with you.  It does not cover what our clients (who may be dealers) do with your personal information.  Those clients are subject to applicable laws and regulations, and they are responsible to act within the law and their own privacy policies.  We provide the Services to help our clients collect and process personal information about you and the vehicles you are selling, but our clients control the purposes and means of that collection and processing, so they must govern themselves according to applicable law, as well as by our contracts with them.
If you browse our website, we use Google Analytics to understand to improve the quality and relevance of the content on our website. This information does not reveal your specific identity (like your name or contact information).

Last Updated:  7/30/2020
DETAILS OF PRIVACY POLICY
A.  Who is Covered by this Privacy Policy
1. Individual employees and agents of our clients who administer the Services on behalf of our clients.
2. Sellers of vehicles who use our platform.
3. Individuals who access our website for purpose of browsing and information.

If you have any questions or concerns about this privacy policy, or our practices with regards to your personal information, please contact us at support@sellgauge.com.

B.  Services We Render Company allows our clients access to cutting edge software tools and services (“Services”) that allow licensed vehicle dealers and sellers to conveniently connect with each other.  Because of the nature of our Services, our clients require certain personal information from and about you and the vehicle you are selling using the Services, and that personal information is processed using our Services.  The personal information about you that we process may include contact information, information about title to your vehicle, the auction process, and other personal information about you, as well as usage or analytics information regarding how you access and use the Services.

1. OUR COLLECTION AND USE OF PERSONAL INFORMATION
When we use the term “personal information” in this Privacy Policy, we mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to you. It does not include aggregated or de-identified information that is maintained in a form that is not reasonably capable of being associated with or linked to you (“Anonymized Information”).  You agree that Anonymized Information belongs to us, subject to any provisions in our contracts with clients. 1. Personal Information that You Provide and that We Collect Automatically We collect personal information when you voluntarily submit information to us or visit our websites. We collect the following categories of personal information that provide in connection with our Services:
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- Contact Information. If you register for our Services or otherwise provide information to us through any paper or electronic applications or other forms, we will collect your name, phone number, and email address and possibly other demographic information.
- Vehicle information. When you use the Services, you may use the Services to process personal information regarding the vehicle you are attempting to sell, including vehicle identification numbers, year, make, condition, and other information related to that vehicle.  This information is made available to our buyers to enable them to make bids for the vehicles you list and to understand and improve their process related to their purchases.
- Bidding and Payment Information. When you use the Services, you will input information to allow us to conduct the auction for your vehicle and to make payment to you when a purchase occurs.  We use this information to manage the auction and to make those payments, but also to help us understand and improve how we do business.
- Usage Data. Usage Data consists of the following and similar information:
1. Information about your interactions with the Services, most commonly our website, which includes the date and time of any requests you make.  This also may include details of your use of third-party applications connected with the Services.
2. The timing of the information you post to the Services including messages you send and/or receive via the Services and your interactions with our customer service team.
3. Technical data which may include URL information, cookie data, your IP address, the types of devices you are using to access or connect to the Services, unique device IDs, device attributes, network connection type (e.g. WiFi, 4G, LTE, Bluetooth) and provider, network and device performance, browser type, language, information enabling digital rights management, operating system, and application version.

Like most companies, we use cookies and other data collection techniques to automatically collect information that helps us provide the Services effectively.  We and our service providers use cookies, pixels, scripts and similar technologies to manage the website and to collect information about you and your use of the website. These technologies help us customize or personalize your experience and analyze the use of our website to make them more useful to you. Most internet browsers allow you to remove or manage cookie functions and adjust your privacy and security preferences. For information on how to do this, access the “help” menu on your internet browser. For information about our and our third-party partners’ use of cookies and related technologies to collect information automatically, please contact us at info@sellgauge.com. When you visit our website, we also collect analytics data using third-party analytics tools such as Google Analytics, to help us measure traffic and usage trends for the website and to understand more about the demographics of our users. You can learn more about Google’s practices with Google Analytics by visiting Google’s privacy policy.

2. OUR USE OF PERSONAL INFORMATION
We use the personal information we collect:
- Communications.To contact you, such as in response to your inquiries, comments or orders, to provide technical or administrative support or to let you know about new products, Services or offers.
- Personalization. To remember you and provide personalized content, information and user experiences.
- Analyze and Improve Services. To monitor, enhance, and improve our Services, track our website usage, and monitor the effectiveness of our Service.
- Make Information Available to Buyers. In most cases, the information we collect about you is made available to buyers clients for processing pursuant to their agreements to purchase vehicles you list for sale.  Our lawful basis for providing this personal information to buyers is your consent, which you give when you list your vehicle for sale and when you use the Services.

3. OUR DISCLOSURE OF PERSONAL INFORMATION
We disclose personal information in the following ways:
- Company.We disclose personal information within Company for purposes and uses that are consistent with this Privacy Policy.
- Service Providers. We disclose personal information with our third-party vendors, consultants and other service providers that perform services on our behalf, which may include hosting services, administrative or business management services, analytics services, technology services (including web and mobile platforms, and email communications providers and data storage providers).
- Buyers. We disclose personal information with the purchasers of vehicles who use our Services.  We never provide personal information about you to buyers providers, except as required for us to perform the Services.
- Business Transaction or Reorganization. If Company or some or all of our assets are acquired or otherwise transferred, or in the unlikely event that we go out of business or enter bankruptcy, the personal information of our users may be transferred to or acquired by a third party.
- Legal Obligations and Rights. We may disclose personal information to third-parties, such as legal advisors and law enforcement to:satisfy any applicable law, regulation, subpoena/court order, legal process or other government request;enforce our Terms of Service, including the investigation of potential violations thereof;investigate and defend ourselves against any third-party claims or allegations;protect against harm to the rights, property or safety of Company, our users or the public as required or permitted by law; anddetect, prevent or otherwise address criminal (including fraud), security or technical issues.Consent. We may disclose personal information about you to certain other third-parties, but only when you specifically give us your consent.

4. CHILDREN'S PERSONAL INFORMATION
We do not knowingly solicit data from or market to children under 18 years of age. If you become aware of any data we may have collected from children under age 18, please contact us at support@sellgauge.com.

5. CONTROL OVER YOUR PERSONAL INFORMATION
You have some choices regarding how we use your personal information, including the following: Communications Preferences You can stop receiving promotional email communications from us by clicking on the “unsubscribe link” provided in such communications. You may not opt out of Service-related communications (e.g., account verification, transactional communications, changes/updates to features of the Service, technical and security notices)

6. THIRD-PARTY WEBSITES AND SERVICES
The Services may contain links to and from third-party websites of our business partners, as well as to advertisers and social media sites, and our users may sometimes post links to third-party websites. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for their policies. We strongly recommend that you read their privacy policies and terms and conditions of use to understand how they collect, use, and share information. We are not responsible for the privacy practices or the content on the websites of third-party sites.

7. SECURITY
The security of your Data is important to us. We use commercially reasonable efforts to store and maintain your Data in a secure environment. We take technical, contractual, administrative, and physical security steps designed to protect Data that you provide to us. We have implemented procedures designed to limit the dissemination of your Data to only such designated staff as are reasonably necessary to carry out the stated purposes we have communicated to you.

8. RETENTION
We will keep your information for as long as it remains necessary for the identified purpose or as required by law, which may extend beyond the termination of our relationship with you. We may retain certain data as necessary to prevent fraud or future abuse, or for legitimate business purposes, such as analysis of aggregated, non-personally-identifiable data, account recovery, or if required by law. All retained information will remain subject to the terms of this Privacy Policy. Please note that if you request that your information be removed from our databases, it may not be possible to completely delete all of your information due to technological and legal constraints. As we have mentioned before, our buyers are generally required or allowed to collect and keep personal information about you in order to consummate your vehicle sale.  In addition, certain personal information is excepted from the obligations imposed by applicable law to delete that personal information.  Therefore, when you request that we remove personal information about you from our records and the Services, we will make commercially reasonable efforts to comply with your request in keeping with applicable law.  In any event, we will not use or process your personal information in any manner beyond what has been disclosed in this Privacy Policy.

9. UPDATES TO THIS POLICY
Please note that this Privacy Policy does not apply to our processing of information about our employees or contractors. We may provide additional privacy policies where the scope of our processing of your personal information falls outside the scope of this Privacy Policy. In such cases, the additional privacy policy will govern how we may process the information you provide at that time. We may update this Policy from time to time. If we make any changes to this Policy, we will change the “Last Updated” date at the top of the Policy and will post the updated Policy on this page. If we make material changes to this Policy, we will notify you by email to your registered email address, by prominent posting on this website or our online services, or through other appropriate communication channels. All changes shall be effective from the date of publication unless otherwise provided.

10. CONTACT US
If you have any questions about this Policy, please contact us at support@sellgauge.com or by writing to us at: Gauge Automotive, Inc.
Attn: Privacy Officer
Salt Lake City, UT 84111
REGION SPECIFIC DISCLOSURES

We may choose or be required by law to provide different or additional disclosures relating to the processing of personal information about residents of certain countries, regions or states. Please refer below for disclosures that may be applicable to you:



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