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AUCTOGON

Bidder Privacy Policy

Effective Date: April 24, 2026

This Bidder Privacy Policy describes how Auctogon Holdings, Inc., a Delaware corporation ("Auctogon," "we," "us," or "our"), collects, uses, shares, and protects information about bidders and buyers who use the auction house websites and mobile applications powered by Auctogon (collectively, the "Bidder Services").

Auctogon powers the technology behind these sites, but the auctions themselves are run by independent auction houses (each, an "Auction House"). Both Auctogon and the Auction House may process your information — this policy explains how.

1. Who You're Sharing Information With

When you register to bid or use a bidder site, two parties may receive your information:

  • Auctogon — provides the technology, stores your account, processes bids, and secures the platform.
  • The Auction House — approves your registration, receives your bids, issues invoices, and processes payments, deliveries, and any related communications.

Both parties may be "controllers" of your personal information for different purposes (see Section 6). The Auction House may also have its own privacy policy that applies in addition to this one.

2. Information We Collect

2.1 You Give Us

  • Account and identity: name, email, phone, mailing address, date of birth (for age verification);
  • Verification: government-issued ID or other documents if the Auction House requires verification;
  • Payment: billing details, processed through third-party payment processors;
  • Bidding activity: bids placed, items watched, notes to the auctioneer, communications with Auction House staff.

2.2 We Collect Automatically

  • Device, browser, IP address, operating system;
  • Pages viewed, items viewed, time spent, clicks;
  • Date and time of access;
  • Cookies, local storage, and similar technologies.

2.3 We May Receive from Third Parties

  • Identity verification results from KYC/identity vendors;
  • Payment confirmations from payment processors;
  • Fraud-risk signals from anti-fraud vendors.

3. How We Use Your Information

We use your information to:

  • Register your account and approve you for specific auctions;
  • Accept and record bids, and resolve bidding disputes;
  • Issue invoices (via the Auction House), process payments, and support pickup or delivery;
  • Send auction-related messages (bid confirmations, outbid alerts, invoice notices, pickup information);
  • Detect and prevent fraud, shill bidding, account takeover, and platform abuse;
  • Comply with legal obligations (tax, auction licensing, AML, sanctions screening);
  • Improve the Bidder Services.

4. How We Share Your Information

We do not sell your personal information, and we do not share your personal information for cross-context behavioral advertising.

We may share your information with:

  • The Auction House you register with — they receive your registration, bids, invoice, and transaction information because they are the party running the auction;
  • Service providers (sub-processors) that help us deliver the platform, including hosting, payment processing, identity verification, email delivery, and analytics. A current list is at auctogon.com/subprocessors;
  • Messaging providers — we use Twilio to deliver SMS notifications you have opted in to receive. Twilio processes your phone number and message content solely to deliver messages on our behalf and is contractually prohibited from using this information for any other purpose;
  • Other parties where required by law — to comply with legal obligations, court orders, law-enforcement requests, or fraud investigations;
  • In a business transfer — if Auctogon is acquired or merged, information may transfer as part of that transaction;
  • With your consent — for any other purpose.

Note: Auction Houses may share invoicing and transaction data with lienholders, title agencies, shipping partners, and tax authorities as necessary for the auction. Those disclosures are governed by the Auction House's practices.

4.1 SMS / Text Message Communications

If you opt in to SMS notifications, we collect your mobile phone number and use it to send transactional and account-related messages — including auction-going-live reminders, outbid alerts, won-lot confirmations, invoice and payment reminders, settlement notifications, and account or security alerts.

No third-party sharing of mobile data. We do not sell, rent, share, or otherwise disclose your mobile phone number, SMS opt-in consent, or SMS message content to any third party or affiliate for their marketing or promotional purposes. Mobile information is used solely by Auctogon and the Auction House with which you have registered, and is shared only with our messaging service provider (Twilio) strictly to deliver the messages you have requested.

Message frequency varies based on your activity and the auctions you participate in. Message and data rates may apply. You may opt out at any time by replying STOP to any message, by toggling SMS notifications off in your account settings, or by emailing privacy@auctogon.com. Reply HELP to any message for support information.

5. AI Features and Automated Decisions

The Bidder Services may use AI or automated processes (for example, fraud scoring, ID verification automation, or automatic bidder approval).

  • Auctogon does not use your information to train, fine-tune, or improve any generative AI or machine-learning model shared across customers, without your express consent.
  • You may request human review of any automated decision that produces legal or similarly significant effects (such as a denied registration), where required by applicable law.

6. Joint Controllership with the Auction House

Auctogon and the Auction House are joint controllers of some of your personal information:

  • Auctogon is responsible for: the technical platform, account security, encryption, access controls, platform-level fraud detection, and responding to privacy requests about platform data.
  • The Auction House is responsible for: registration approval, invoicing, payment collection, delivery, auction-specific communications, retention of auction records under their own license requirements, and responding to privacy requests about auction-specific activity.

If you have a privacy question about a specific auction, invoice, or Auction House communication, contact the Auction House first. For platform-level questions, contact Auctogon.

7. Cookies, Tracking, and Global Privacy Control

We use cookies and similar technologies to keep you logged in, remember your preferences, power the Bidder Services, and understand usage. You can control cookies in your browser settings; disabling some cookies may limit functionality.

Global Privacy Control (GPC). We respect Global Privacy Control signals. If your browser sends a valid GPC signal, we treat it as an opt-out of any sale or sharing of your personal information for cross-context behavioral advertising, where those rights apply.

8. International Data Transfers

Auctogon is headquartered in the United States, and your information may be processed in the United States. If you are accessing the Bidder Services from outside the U.S., you acknowledge that your information may be transferred to jurisdictions with different data-protection laws. For EEA, UK, or Swiss transfers, we rely on Standard Contractual Clauses and, where applicable, the EU-U.S. Data Privacy Framework.

9. Data Security

We use commercially reasonable safeguards, including encryption in transit and at rest, tenant isolation, role-based access controls, and regular security reviews. No system is perfectly secure — if we ever detect a breach affecting your information, we will notify you in accordance with applicable law.

10. Data Retention

We keep your information for as long as needed to operate your account, complete auction transactions, comply with legal record-keeping (auction records and tax records may require multi-year retention), resolve disputes, and enforce our agreements. Auction Houses may retain records under their own policies.

11. Your Rights

Depending on where you live, you may have the right to:

  • Access a copy of your information;
  • Correct inaccurate information;
  • Delete your information, subject to legal exceptions;
  • Port your information in a portable format;
  • Opt out of sale, sharing, or targeted advertising (we do not sell or share for behavioral advertising);
  • Limit use of sensitive personal information;
  • Request human review of automated decisions with significant effects;
  • Withdraw consent where processing is based on consent.

To exercise these rights, email privacy@auctogon.com. We will verify your identity before responding. If we deny your request, you may appeal by replying to the decision.

11.1 California (CCPA/CPRA)

California residents have the rights above plus the right to limit use of sensitive personal information. We do not sell or share personal information for cross-context behavioral advertising, and we have not done so in the preceding 12 months.

11.2 Other U.S. States

If you are a resident of Virginia, Colorado, Connecticut, Utah, Texas, Oregon, Delaware, Iowa, Montana, Tennessee, Indiana, Nebraska, New Hampshire, New Jersey, Minnesota, Maryland, Rhode Island, or any other state with comprehensive consumer privacy rights, you have substantially the same rights as California residents, subject to state-specific variations.

11.3 EEA, UK, and Switzerland (GDPR / UK GDPR)

We process your information as a controller (or joint controller with the Auction House). Our legal bases include performance of a contract, legitimate interests, consent, and legal obligations. You have rights of access, rectification, erasure, restriction, portability, objection, and the right to lodge a complaint with a supervisory authority.

12. Children

The Bidder Services are not intended for anyone under 18. We do not knowingly collect personal information from children under 13. Where state law requires, we also do not knowingly sell or share personal information of users under 16. If you believe a child has provided us information, email privacy@auctogon.com and we will delete it.

13. Third-Party Links

The Bidder Services may include links to third-party sites or tools. This policy does not apply to those third parties. Review their privacy policies separately.

14. Changes

We may update this Bidder Privacy Policy from time to time. Material changes will be posted here with an updated Effective Date and, where practicable, sent by email.

15. Contact

Auctogon Holdings, Inc.
1440 Broadway, Ste 200 #135
Oakland, CA 94612
Email: privacy@auctogon.com
Website: https://auctogon.com

For privacy questions about a specific auction or Auction House, contact the Auction House directly.