PRIVACY POLICY
PRIVACY POLICY

Vonality respects the right of privacy of all of its visitors, users, clients and customers and is committed to protecting such privacy in accordance with this Privacy Policy. The following details our treatment of your personally identifiable information collected in connection with your activities on, or related to our website, or to any auction or e-commerce sites we are managing.

Please read this Privacy Policy carefully and check back periodically as this Privacy Policy may change from time to time. Please note that this Privacy Policy does not apply to the practices of companies or websites which are not owned or controlled by Vonality.

In order to operate Vonality services, a bidder qualification service may be performed to reduce the risk of fraud. Vonality ("Vonality" or "we") must ask you to provide information about yourself and your credit card and/or bank account. This Privacy Policy describes the information we collect and how we use that information.

Vonality takes the privacy of your personal information very seriously and will use your information only in accordance with the terms of this Privacy Policy. We will not sell or rent your personally identifiable information or a list of our customers to third parties. However, as described in more detail below, there are limited circumstances in which some of your information will be shared with third parties, under strict restrictions, so it is important for you to review this Privacy Policy.

This Privacy Policy applies to all services that are hosted on vonality.com, Vonality, bidqualify, addlivevoice or any website or micro site managed by vonality which may not be disclosed whether the services are offered by Vonality, or by its subsidiaries.

By accepting the Privacy Policy and User Agreement in registration, you expressly consent to our use and disclosure of your personal information in the manner described in this Privacy Policy. This Privacy Policy is incorporated into and subject to the terms of the Vonality User Agreement.

Please note that your personal information will be stored and processed on our computers in the United States and Canada. The laws on holding personal data in United States and/or Canada may be more or less stringent than the laws of your country but Vonality will hold and transmit your personal information in a safe, confidential and secure environment. If you object to your personal information being transferred or used as described in this Privacy Policy, please do not register or use any of Vonality services, websites or parts of its website where you are requested to provide personal information.

Notification of Changes
This policy may be revised over time as new features are added to the Vonality service or as we incorporate suggestions from our customers. If we are going to use or disclose your personally identifiable information in a manner materially different from that stated at the time we collected the information, you will have a choice as to whether or not we use or disclose your information in this new manner. Any material changes will be effective only after we provide you by e-mail with at least 30 day's notice.

We will post the amended Privacy Policy prominently on our Web site so that you can always review what information we gather, how we might use that information, and whether we will disclose it to anyone. Please check the Vonality Web site at Vonality.com at any time for the most current version of our Privacy Policy.

Vonality and other pages on the Vonality Web site include links to third party Web sites. These sites are governed by their own privacy statements, and Vonality is not responsible for their operations, including but not limited to their information practices. Users submitting information to or through these third party Web sites should review the privacy statement of these sites before providing them with personally identifiable information.

Internal Uses
We collect, store and process your personal information on servers located in the United States and Canada. We use the information we collect about you in order 1) to provide our services and process your transactions, 2) to provide customer service, 3) to determine your eligibility to bid, and 4) to improve our products and services.

We work with third party merchants to enable them to accept payments from you. Merchants who offer this service will share personally identifiable information you provide to them with Vonality to validate the status of your ability to pay with Vonality or the existence of your account. You permit Vonality to return verification results of the validity of the personally identifiable information passed to Vonality.

Vonality does not store the personally identifiable information provided by these merchants to validate the existence of your account.

Disclosure to Third Parties Other Than Vonality Customers
Vonality will not sell or rent any of your personally identifiable information to third parties. Vonality will not share any of your personally identifiable information with third parties except in the limited circumstances described below, or with your expressed permission (and with other Vonality customers as described above). These third parties are limited by law or by contract from using the information for secondary purposes beyond the purposes for which the information is shared.

1. We share information with companies that help us process the transactions you request and protect our customer's transactions from fraud, such as sharing your credit card number with a service that screens for lost and stolen card numbers. We may disclose the information we collect from you to companies that market Vonality-related products and services on our behalf. Additionally, if you go into a negative balance and owe us money, we may share information with processing companies including collection agencies.

2. We disclose information that we in good faith believe is appropriate to cooperate in investigations of fraud or other illegal activity, or to conduct investigations of violations of our User Agreement. For example, this means that if we conduct a fraud investigation and conclude that one side has engaged in deceptive practices, we can give that person or entity's contact information (but not bank account or credit card information) to victims who request it.

3. We disclose information in response to a subpoena, warrant, court order, levy, attachment, order of a court-appointed receiver or other comparable legal process, including subpoenas from private parties in a civil action.

4. We share aggregated statistical data with our business partners or for public relations. For example, we may disclose that a specific percentage of our users live in Toronto. However, this aggregated information is not tied to personally identifiable information.

5. As with any other business, it is possible that Vonality in the future could merge with or be acquired by another company. If such an acquisition occurs, the successor company would have access to the information maintained by Vonality, including customer account information, but would continue to be bound by this Privacy Policy unless and until it is amended as described above.

6. We share your information with our parent companies, affiliates, subsidiaries and joint ventures to help coordinate the services we provide to you, enforce our terms and conditions, and promote trust and safety.

Our Contacts with Vonality Customers
We communicate with users on a regular basis via e-mail to provide requested services, and we also communicate by phone to resolve customer complaints or investigate suspicious transactions. We use your e-mail address and or bidder registration information to provide information and to send information about important changes to our products and services, market new auctions or services to you and to send notices and other disclosures required by law. Generally, users will have the option to opt out of these communications.

We also use your e-mail address to send you other types of communications that you can control, including the Vonality Periodical newsletter, auction tips, customer surveys, auction notifications, and notice of special third-party promotions or auctions.

Internet Address Information
We use IP addresses, browser types and access times to analyze trends, administer the site, improve site performance and gather broad demographic information for aggregate use.

Information Security
Vonality is committed to handling your customer information with high standards of information security. Your credit card and bank account information are stored only in encrypted form on computers that are not connected to the Internet. We restrict access to your personally identifiable information to employees who need to know that information in order to provide products or services to you. We maintain physical, electronic and procedural safeguards that comply with federal regulations to guard your nonpublic personal information. We test our security systems regularly and also contract with outside companies to audit our security systems and processes. The security of your Personal Information is important to us. Vonality takes technical, contractual, administrative, and physical security steps to protect Personal Information that you provide to us. We instruct our employees with access to your Personal Information that it is to be used only in adherence with the principles set forth in this Privacy Policy and the laws applicable to each specific business.

In certain areas, such as when you provide credit card information to us, we work to help protect the security of your credit card information during transmission by using industry standard Secure Sockets Layer (SSL) encryption technology.

Any e-mail or other communication requesting confidential information or asking you to provide sensitive account information via email, or linking to a website with a URL that does not begin with https://www.vonality.com should be treated as unauthorized and suspicious and should be reported to Vonality immediately by forwarding it to spoof@vonality.com.

QUESTIONS, COMMENTS OR SUGGESTIONS

If you have questions, comments or suggestions about this Privacy Policy or our privacy practices that were not answered here; send our Privacy Manager an e-mail at privacy@vonality.com.

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