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AUCTOGON

Privacy Policy

Effective Date: April 15, 2026

This Privacy Policy describes how Auctogon Holdings, Inc., a Delaware corporation ("Auctogon," "we," "us," or "our"), collects, uses, discloses, and protects information in connection with our website at auctogon.com and any related software platform, services, and applications (collectively, the "Services"). By accessing or using the Services, you agree to this Privacy Policy.

Entity Change Notice. Effective April 15, 2026, Auctogon Holdings, Inc. succeeds Boundless Holdings, LLC as the service provider for the Auctogon platform. References in prior versions of this Privacy Policy to "Boundless Holdings, LLC" or "Auctogon (a product of Boundless Holdings, LLC)" are deemed references to Auctogon Holdings, Inc.

This Privacy Policy applies to the operator and administrator side of the Services used by auction house staff. Bidders and buyers using tenant-branded bidder sites (for example, yourauctionhouse.auctogon.com) should refer to the Bidder Privacy Policy.

1. Information We Collect

1.1 Information You Provide

We collect information you provide directly, including: name, email address, phone number, mailing address, company name, auctioneer license information, payment and billing details (processed through our third-party payment processors), auction listing data (lot descriptions, photographs, seller information, reserve prices), bidder registration information, and any communications you send us (e.g., support requests, feedback).

1.2 Information Collected Automatically

When you use the Services, we automatically collect certain information, including: device and browser type, IP address, operating system, referring URLs, pages viewed and interactions within the Services, date and time of access, and cookies and similar tracking technologies (see Section 6).

1.3 Information from Third Parties

We may receive information from third-party services you connect to Auctogon, such as payment processors, accounting systems, and CRM integrations. We may also receive information from publicly available sources relevant to auction settlement processes, including UCC filings and lien searches.

1.4 Categories of Personal Information (CCPA/CPRA)

For California residents, the categories of personal information we have collected in the preceding twelve (12) months include: identifiers (name, email, IP address); customer records (mailing address, phone, billing details); commercial information (transactions, subscription history); internet or network activity (usage logs); professional or employment information (auctioneer license, company role); geolocation (general, from IP); and inferences drawn from the above.

2. How We Use Your Information

We use the information we collect to:

  • Provide, maintain, secure, and improve the Services;
  • Process auction transactions, settlements, and payments;
  • Manage user accounts and tenant configurations;
  • Communicate with you about services, updates, and support;
  • Comply with legal obligations, including UCC lien search requirements and fiduciary reporting;
  • Detect and prevent fraud, abuse, and security incidents;
  • Conduct analytics to improve platform performance and user experience;
  • Fulfill any other purpose described at the time of collection or with your consent.

3. AI Features and Automated Decision-Making

Some Services use artificial intelligence, machine learning, or automated decision-making features — for example, to generate catalog descriptions, suggest bidder approvals, flag potentially fraudulent activity, or estimate valuations. When you interact with these features:

  • Your inputs and the resulting outputs are processed solely to deliver the requested feature;
  • Auctogon does not use Your Data to train, fine-tune, or otherwise improve any generative AI or machine-learning model shared across customers or sold to third parties, without your express consent;
  • Where the Services include AI features, those features operate on Your Data for your benefit only;
  • You retain the right to request human review of any automated decision that produces legal or similarly significant effects, where required by applicable law.

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 information in the following circumstances:

With Auction House Operators. If you are a bidder or buyer, the auction house operating the auction may receive your registration and transaction information as necessary to conduct the auction and complete the sale.

With Service Providers (Sub-Processors). We share information with third-party vendors who perform services on our behalf, including payment processing, hosting, authentication, analytics, and customer support. These providers are contractually obligated to use your information only to provide services to us. A current list of sub-processors is available at auctogon.com/subprocessors.

For Legal Compliance. We may disclose information to comply with applicable laws, regulations, legal processes, or government requests, including UCC searches and lien-related fiduciary obligations.

Business Transfers. In connection with a merger, acquisition, reorganization, or sale of assets, your information may be transferred as part of that transaction. We will notify you of any such change.

With Your Consent. We may share information for other purposes with your explicit consent.

5. Joint Controllership with Auction House Operators

When an auction house ("Tenant") uses the Services to operate its auctions, both Auctogon and the Tenant may jointly determine purposes and means of processing certain personal information (including bidder registration data, bid history, and transaction records). In that arrangement:

  • Auctogon is responsible for the platform's technical infrastructure, security, access controls, and platform-level privacy rights requests.
  • The Tenant is responsible for the lawfulness of auction-specific data use, including registration criteria, invoicing, collections, and the enforcement of the Tenant's own privacy policy.

If you are a bidder or buyer, please direct auction-specific privacy rights requests (for example, questions about a specific invoice, registration decision, or communication you received from the auction house) to the relevant Tenant.

6. Cookies, Tracking Technologies, and Global Privacy Control

We use cookies, local storage, and similar technologies to operate the Services, remember your preferences, authenticate sessions, detect fraud, and understand how the Services are used. You may control cookies through your browser settings, though disabling cookies may limit functionality of the Services.

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

7. International Data Transfers

Auctogon is headquartered in the United States, and your information may be transferred to, stored in, and processed in the United States. If you access the Services from outside the United States, you acknowledge that your information may be transferred to jurisdictions with different data-protection laws.

For transfers from the European Economic Area, United Kingdom, or Switzerland, we rely on Standard Contractual Clauses ("SCCs") approved by the European Commission and, where applicable, the EU-U.S. Data Privacy Framework, UK Extension, and Swiss-U.S. Data Privacy Framework.

8. Data Security

We implement commercially reasonable administrative, technical, and physical safeguards to protect your information, including encryption of data in transit and at rest, role-based access controls, tenant isolation, and regular security assessments. However, no method of transmission or storage is completely secure, and we cannot guarantee absolute security.

9. Data Retention

We retain your information for as long as your account is active, as needed to provide the Services, to comply with legal obligations (including record-keeping requirements applicable to auction transactions), to resolve disputes, and to enforce our agreements. Auction transaction records may be retained for extended periods as required by applicable law.

10. Your Rights and Choices

Depending on your jurisdiction, you may have certain rights regarding your personal information, including:

  • Access — confirm whether we process your personal information and receive a copy;
  • Correction — correct inaccurate information;
  • Deletion — request deletion of your information, subject to legal exceptions;
  • Portability — receive your information in a portable format;
  • Opt-out — of sale, sharing, or targeted advertising (Auctogon does not sell or share for cross-context behavioral advertising);
  • Restriction and Objection — to certain processing;
  • Human review of automated decisions with significant effects;
  • Withdrawal of consent where processing is based on consent.

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

10.1 California Residents (CCPA/CPRA)

If you are a California resident, you have the rights listed above, plus the right to limit the use and disclosure of sensitive personal information. We do not sell or share personal information (including for cross-context behavioral advertising) and have not done so in the preceding twelve (12) months. We do not knowingly sell or share the personal information of consumers under the age of 16.

10.2 Residents of 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 described above, subject to state-specific variations. Email privacy@auctogon.com to exercise these rights.

10.3 EEA, UK, and Switzerland Residents (GDPR / UK GDPR)

If you are located in the EEA, UK, or Switzerland, we process personal information as a data controller. Our legal bases for processing include: performance of a contract, legitimate interests (providing and improving the Services, fraud prevention, security), compliance with legal obligations, and consent where required. You have rights of access, rectification, erasure, restriction, portability, objection, and the right to lodge a complaint with a supervisory authority.

11. Children's Privacy

The Services are intended for adult business users and are not directed to children. We do not knowingly collect personal information from children under the age of 13. If we learn that we have collected personal information from a child under 13, we will delete it promptly. Where state law requires, we also do not knowingly sell or share the personal information of consumers under the age of 16.

12. Third-Party Links and Services

The Services may contain links to third-party websites or integrate with third-party services. This Privacy Policy does not apply to those third parties. We encourage you to review the privacy policies of any third-party services you access through or in connection with the Services.

13. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of material changes by posting the updated policy on our website and updating the "Effective Date" above. Your continued use of the Services after any changes constitutes your acceptance of the updated policy.

14. Contact Us

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