Privacy Policy

Classic Promenade, LLC & Classic Promenade Auctions, LLC

Privacy Notice

Last Updated: June 25, 2020

When you use or interact with a U.S. website, mobile app or other digital service (each a “Digital Service”) operated or owned by Classic Promenade LLC & Classic Promenade Auctions LLC CP & CPA (“CP & CPA”), we and third parties may obtain certain information about you. In this section, we provide an overview of our privacy practices related to the Digital Services.

What Information We Obtain

• Information you provide when you use the Digital Services, including when you sign up for newsletters, create an account, and list or place a bid on a listed vehicle or other products and services through the Digital Services. This may include your contact, payment or demographic information.
• Information you submit when you choose to participate in a survey, sweepstakes, contest, promotion, event or similar initiative.
• Information you give us about others, such as a friend’s contact information when you share our content.
• Information collected by automated means such as cookies or pixels. This may include information about your device and browser, including IP address or mobile device advertising identifiers, as well as information about how you and others use, interact with or respond to the Digital Services. This collection may take place while you are using a Digital Service or while the Digital Service is running in the background of your device.
• Precise location information associated with your device when location services are active.
• Information we obtain from other sources, such as business partners, data suppliers and social media platforms.

How We Use Information We Obtain

• To process your requests and provide you with the Digital Services, including to enable you to publish listings or participate in auctions, to connect you with the seller if your bid was successful and deliver customized content or recommendations. Note that we use your payment card information (such as your card number and expiration date) for limited purposes such as to process your transaction (including recurring payments, if applicable), to provide you with the requested products or services and to protect our rights or the rights of others.
• To learn about users of the Digital Services and analyze how you and others interact with and respond to the Digital Services.
• To communicate with you, including to send you marketing and promotional communications.
• For advertising and marketing purposes.
• To protect our rights and the rights of others.

How We Share Information

• With sellers and others with whom you engage as a result of your participation in auctions or other features made available on, or in connection with, the Digital Services.
• With service providers that perform services or handle transactions on our behalf.
• With advertisers, advertising- and marketing-related services providers and partners as well as companies that help us learn how you and others interact with our content.
• With social media platforms and similar services, including when you interact with our Digital Services that integrate tools and services provided by social medial platforms.
• With business partners, such as when we partner with a third party to offer products or services on a co-branded basis.
• Other parties when required by law or as necessary to protect our rights, and in the context of corporate transactions.
• With your consent or otherwise at your direction.

Your Choices, Including Marketing and Interest-Based Ads Opt-Outs

• You may take steps to limit the use of your information for interest-based advertising on your browser or mobile device. See section Interest-Based Ads Opt-Outs for more information.
• You may unsubscribe from our marketing or promotional emails by clicking the “Unsubscribe” link in our emails, or for certain Digital Services, by logging into your account and adjusting your preferences.

Additional Information

• We use a variety of security technologies and procedures to help protect information from unauthorized access, use or disclosure.
• The Digital Services are operated from the United States. Information may be processed and stored in the United States or other countries.
• The Digital Services are not intended for use by children under the age of 13.
• This Privacy Notice is part of the Terms and Conditions which govern your use of the Digital Services and any disputes related to your use of the Digital Services (including our use of your information) will be resolved per the dispute resolution provision in the Terms of Use.
• Additional disclosures and rights apply to California residents and European visitors. These are included at the end of this Privacy Notice in section N. Additional Information for California Residents and section O. Additional Information for European Visitors.

Contact Us

If you have questions about our Privacy Notice you can contact us by email at harry@classicpromenade.com. If you have any questions about your California Consumer Privacy Act of 2018 (CCPA) rights, please contact us at harry@classicpromenade.com.

1. INTRODUCTION

This Privacy Notice applies to the U.S. website, mobile application or other digital service (each a “Digital Service”) linking to this Privacy Notice and owned or operated by Classic Promenade LLC & Classic Promenade Auctions LLC (“we”, “us”, “our” or “CP & CPA”). This Privacy Notice describes the privacy practices of CP & CPA only and does not cover the practices of other users with whom you may engage through the Digital Services or other companies, including those that may advertise or sponsor content, products or services on the Digital Services.

1. WHAT INFORMATION WE OBTAIN

When you use a Digital Service, we may obtain various types of information related to you and your use of the Digital Service. This may include information that directly identifies you such as your name, address, or contact information (this type of information may be called “personal information” or “personally identifiable information”). The information we obtain generally consists of information (1) you give us about yourself, (2) you give us about others, (3) automatically collected about your interactions with the Digital Services and our content or ads on third-party websites, apps or other media, and (4) we get from other sources.

1. Information you give us

We may ask you to provide information about yourself when you use the Digital Services. For example, to subscribe to one of our newsletters, you will need to give us an email address. You may not be able to use certain features if you choose not to submit the requested information.

The information you give us may include details such as:

• Contact information (e.g., name, mailing address, email address or phone number). This may be your personal or professional contact information if you are a dealer.
• Information you provide in auction listings, including vehicle year, make, model, geographic location, vehicle identification number (“VIN”) and other vehicle related information and/or information about any other products or services you may list or make available on, or in connection with, the Digital Services.
• Demographic, interests and household information (e.g., age, gender or education).
• Payment information for transactions made through the Digital Services (e.g., payment card number, expiration date and billing information).
• Comments, photos, videos and other content or information you choose to publish on the Digital Services or otherwise share with us, including photos of vehicles which may include license plate information.
• Information you provide when you choose to participate in surveys, polls, sweepstakes, contests or promotions (including information about your participation in activities that may generate loyalty or rewards points).
• Location information, which may include precise location information when you permit the Digital Services to access device location. To prevent the collection of precise location information, please refer to instructions provided by your mobile service provider or device manufacturer.
• Other information you may allow us to access through your device’s permissions settings, such as your contacts or address book.
• Transactional and activity information (e.g., data regarding listings, bids, requests and other transaction-based content that you generate or derived from your activities)).

2. Information you give us about others

You may give us information about other people, such as the name and email of a friend or contact with whom you want to share our content. Do not give us information about others unless you are authorized or have their consent to do so. We will use their information for the purposes described in this Privacy Notice.

3. Information automatically collected

The Digital Services automatically log certain information about visits to the Digital Services, such as the number and frequency of visitors, technical information about browsers and devices used to access the Digital Services, and information about crashes or other technical issues. In addition, we and third parties may automatically collect certain information through automated means about your activities over time across the Digital Services as well as across third-party sites, apps or other media. The tools that collect this information vary depending on the Digital Services and include technologies such as cookies, web beacons, tags, scripts, pixels, local shared objects (including HTML5 cookies) and software development kits (“SDKs”). These technologies may be included in our web pages, mobile apps, emails, and other digital content. The tools may assign or collect unique cookie IDs or other identifiers associated with your browser or device. The tools may collect information while you are using our Digital Services or while they are running in the background of your device.

The information automatically collected may include:

• Information about your computer, device, browser and operating system (e.g., type, model, or version).
• Internet protocol (IP) address, which may be used to derive your general geographic area (e.g., city and country).
• Device identifiers (e.g., mobile advertising IDs).
• Information about your interactions with the Digital Services, including browsing activities and clickstream data that reflect the content you have accessed, clicked on, or viewed.
• Information about how you accessed the Digital Services, including details about websites or apps visited immediately before or after accessing a Digital Service.
• Demographic, interests and household information.
• Information about your interactions with email messages and other communications, such as whether you opened or forwarded the email or clicked on links contained in the email.

4. Information we obtain from other sources

We receive information about you from other sources and it may be combined with other information about you. For example, we may obtain data from:

• Operators of third-party sites or apps, content distribution channels and platforms (e.g., Roku, Amazon Fire TV), voice-activated assistants (e.g., Amazon Alexa, Google Home) or other devices and technologies when you interact with our content, products, services or ads available on those channels and platforms. The information we receive may include information about the content you view or access as well as your demographic information and information about your interests.
• Third-party data suppliers such as data aggregators, data resellers, public databases and business partners. They may provide us with demographic information, information about your transactions, and other information that helps us learn about you and other users of the Digital Services.
• Social Media Platforms and similar services (“Social Media Platforms”). When you engage with our content or ads on Social Media Platforms, or interact with features on the Digital Services that contain content or features provided by Social Media Platforms (e.g., login or sign in features or tools that allow you to share our content with others on Social Media Platforms), we may obtain information from Social Media Platforms, including your username, user ID, demographic information and other information, subject to the settings and privacy practices of the relevant Social Media Platform. We may obtain this information directly from the Social Media Platform or through plug-ins, integrations or applications.

1. HOW WE USE INFORMATION WE OBTAIN

If you make a transaction using a Digital Service, we use your payment card information (e.g., your card number and expiration date) for limited purposes such as to process your transaction (including recurring payments, if applicable), to provide you with the requested products or services and for the purposes described under the section “To protect our rights or the rights of others” below.

Please note that if you successfully win a bid or complete a transaction with another user or third party that may be integrated with the Digital Services, we will provide the other user or third party, as appropriate, with your personal information to facilitate the transaction you requested (including, your name and contact information). Other users (including sellers) and third parties are independent from us and are responsible for the handling and use of your personal information, including personal information that we may provide to them. Sellers and third parties are responsible for compliance with applicable laws, including privacy laws, and rights that you may have with respect to your personal information that such users, sellers and third parties maintain. You should direct any questions or concerns with respect to your information directly to such users, sellers and third parties.

With respect to information other than your payment card information, we use that information:

1. To provide you with the Digital Services.This includes:

• Processing your requests regarding the Digital Services and our products or services, including listing or placing a bid or offer on a listed vehicle or any other products or services, or your participation in a survey, sweepstakes, contest, promotion, event or similar initiative. This also includes the publication and promotion of your listings and related content on other sites, apps or digital properties operated within our family of companies and/or cooperating with third party operators of sites, apps and other digital properties for such publication and promotion.
• Providing customer assistance or technical support and solving problems or disputes relating to auctions or fee claims.
• Customizing content, providing recommendations and enhancing the quality and your overall experience with the Digital Services, including by retaining your user preferences or presenting content in the most effective manner for the browser or device you use to access the Digital Services.
• Maintaining, operating, improving and developing the Digital Services and related content, products or services, including developing new products and features based on users’ interactions with the Digital Services.
• Learning about users of the Digital Services and analyzing how you and others interact with and respond to the Digital Services, including by measuring and optimizing usage, reliability and performance, conducting market research, analyzing trends, and supporting our operations (e.g., for accounting, auditing, financial, legal or other purposes).

2. To communicate with you.This includes:

• Sending you informational messages about the Digital Services (e.g., to confirm your listing or bid, and notify you of changes to a Digital Service).
• Delivering marketing or promotional communications, including offers or promotions about our or third parties’ products, services or other initiatives.
• Responding to your questions or addressing your requests.
• Communicating with you about surveys, sweepstakes, contests, promotions or events.

3. For advertising and marketing purposes, including interest-based advertising.This includes:

• Developing, managing and conducting advertising and marketing campaigns, promotions and offers, including about auctions, listings and our content, products and services or third parties’ products, services and other initiatives.
• Interest-based advertising (also known as targeted or personalized advertising or ads) is advertising based on your interests as inferred from your activities over time on the Digital Services and online services operated by third parties, as well as information from other sources, including information collected offline. Interest-based ads may consist of text ads, images, animations or videos and may be displayed to you based on various factors, including the context of the site or app in which they appear (e.g., sport or travel section), information you provided to the operator of the site or app (e.g., when you created an account), your activities on the site or app (e.g., pages viewed, searches performed or ads clicked), and information such as your demographic, interests and household information.
  • On the Digital Services and on third-party sites, apps or other media, we, our service providers and third parties may use automated means to (a) collect information for interest-based advertising purposes or (b) serve you interest-based ads. These automated means vary depending on the Digital Services and include technologies such as cookies, web beacons, tags, scripts, pixels, local shared objects (including HTML5 cookies) and SDKs. These technologies may use unique identifiers associated with your browser or device to support interest-based advertising.
  • We may use and/or combine online and offline information we obtain about you, including your personal information, for interest-based advertising purposes. We may aggregate the information we obtain to create audiences that are most likely to respond to ads based on demographic, interests or household information.
    Interest-based ads may be displayed to you by third parties, such as ad networks or exchanges.
  • There are steps you can take to limit the collection of your information for interest-based advertising purposes. These steps vary for the web and mobile app environments and are browser and device specific.
  • In serving interest-based ads, we adhere to the Self-Regulatory Principles for Online Behavioral Advertising developed by the Digital Advertising Alliance.
• Cross-device linking. If you access the Digital Services from multiple browsers or devices, we, our service providers and third parties may try to establish connections among and link the different browsers and devices you use to access the Digital Services and our content or ads published elsewhere. This helps us provide you with a seamless experience across the browsers and devices you use and serve you with more relevant content and ads (e.g., so that we don’t show you the same article twice).
• Analyzing and measuring the performance, effectiveness and reach of our advertising (including interest-based ads) and marketing efforts on the Digital Services and elsewhere.

4. To protect our rights or the rights of others.This includes:

• Detecting, preventing and responding to fraud or potentially illegal activities, misuse of the Digital Services, intellectual property infringement or other violations of law, this Privacy Notice, our Terms of Use or other applicable policies.
• Performing audits, assessments and testing or troubleshooting activities.
  Backing up our systems (including for disaster recovery purposes) and enhancing the overall security of the Digital Services.
• Complying with and enforcing applicable industry and legal requirements (including legal process such as court orders, warrants or subpoenas) and fulfilling contractual obligations.

1. HOW WE SHARE INFORMATION

We may share the information we obtain with:

1. Sellers, Other Users and Third Parties.If you transact with another user or third party in connection with an auction or other feature made available on or in connection with the Digital Service (such as commenting), we share your personal information with the seller, other user(s) or third party to facilitate the transaction you requested. If there are subsequent issues with the transaction such as a dispute, we may also share your information to help resolve the issue.
2. Affiliates and Subsidiaries.We work closely with affiliates and subsidiaries within the Hearst family of companies with whom we share your information as necessary or appropriate to operate the Digital Services.
3. Service Providers.In connection with the operation and provision of the Digital Services, we engage various third parties to provide services or handle transactions on our behalf, such as payment card processing, email distribution, list processing, postal mailing, cloud computing, analytics, digital content performance measurement, ad serving and managing sweepstakes, contests, promotions or events. These service providers use the information we provide to them as necessary or appropriate for the performance of their services.
4. Advertisers, Advertising- and Marketing-Related Service Providers and Partners.We may provide your information to advertisers, advertising agencies, ad networks, ad exchanges, marketing businesses, technology vendors and other entities that create, deliver and assess advertising or marketing campaigns, including interest-based ads.
5. Content Measurement Companies.We and third parties seek to measure the performance of content across the internet, including on the Digital Services. We may include third-party measurement software in the Digital Services to enable market research or to measure digital and video content consumption.
6. Social Media Platforms. If you interact with social media widgets, share content using social media share buttons, or access features of the Digital Services that contain content or features provided by Social Media Platforms, the relevant Social Media Platforms may collect information. We encourage you to review the privacy policies of the Social Media Platforms that you engage with as we are not responsible for their privacy practices.
7. Business Partners.We may provide your information to business partners including, without limitation, joint marketing partners and content sponsors, for various purposes. For example, we may partner with a third party to offer products on a co-branded, co-sponsored or cross-promotional basis that involves the sharing of information. These initiatives may be offered on the Digital Services or on other media.
8. Other Parties When Required by Law or As Necessary to Protect Our Rights.We may share your information as we believe is necessary or appropriate to protect, enforce, or defend our legal rights, the privacy or safety of our employees, users of the Digital Services or other individuals and entities, or to comply with or enforce applicable industry standards, law or legal process, including responding to court orders, warrants, subpoenas and other requests from public and government authorities.
9. Corporate Transactions.We reserve the right to transfer any of the information we have about you to proceed with the consideration, negotiation, or completion of a sale or transfer of all or a portion of our business or assets to a third party, such as in the event of a merger, acquisition or other disposition, or in connection with a bankruptcy reorganization, dissolution, or liquidation.
10. With Your Consent or Otherwise at Your Direction.In addition, we may share your information with third parties when you consent to or request such sharing.
11. YOURS CHOICES, INCLUDING MARKETING AND INTEREST-BASED ADS OPT-OUTS

Direct Marketing Opt-Outs

1. Email marketing. You may opt out of receiving marketing or promotional emails from us by clicking on the “unsubscribe” link contained in such emails. Depending on the Digital Service you use, you also may be able to opt out of marketing or promotional emails by logging into your account and managing your email preferences. Please keep in mind that if you opt out of receiving marketing or promotional emails, we may still send you transactional emails or other communications relating to your use of the Digital Services (e.g., to confirm your bids, to inform you of changes to a Digital Service or in response to your password recovery request).
2. Text message marketing. If you choose to participate in a text message marketing campaign or promotion offered in connection with a Digital Service, you may opt out of receiving marketing texts from us by following the instructions contained in those messages (e.g., texting the word STOP) or provided to you when you elected to receive text message marketing.
3. Co-Branded, Co-Sponsored or Cross-Promotional Offerings. If you choose to participate in a co-branded, co-sponsored or cross-promotional offering, the brand, sponsor or other third party involved in that offering may use your information for its own purposes, including advertising and marketing purposes. You must contact the relevant third party directly to exercise your opt out choices with respect to such party’s use of your information.

Interest-Based Ads Opt-Outs

This means that these ads are customized based on the information we and others obtain about you. We describe below steps you can take to limit tracking of your activities and the delivery of interest-based ads in browsers and mobile apps you use to access the Digital Services. Please keep in mind that if you opt out of interest-based ads, you will still see ads, but these ads will not be based on your inferred interests. In addition, if you take the steps described below, some automated means may still be used to collect information about your interactions with the Digital Services for the other purposes described in this Privacy Notice (e.g., to remember user preferences or enable specific functionality).
The technologies used to deliver ads on websites and mobile apps differ. Please also remember that opt-outs are browser and device-specific.

Website (Browser) Opt-Out

1. Disabling Cookies.Most browsers accept cookies by default. You may be able to change the settings to have your browser refuse certain cookies or notify you before accepting cookies.

• If you choose to disable the use of cookies in your web browser, some features of the Digital Services may become difficult to use or unavailable.

2. Opt-out Cookies.You can follow the instructions provided by the Digital Advertising Alliance (“DAA”) hereand/or the Network Advertising Initiative (“NAI”) here to place an opt-out cookie on your browser. These opt-out cookies enable you to block participating companies from installing future cookies on your computer or browser.

• If you place opt-out cookies but subsequently clear or delete cookies on your computer or device browser, your opt-out cookies may be deleted and you may have to renew your opt-out choices for that specific browser.
• The opt-out mechanisms offered by the DAA and NAI are provided by third parties. CP & CPA does not control or operate these mechanisms or the choices provided through these mechanisms.

Mobile App Opt-Out

1. Device Settings.To limit interest-based advertising on your mobile device, you can review and adjust the settings provided by your device manufacturer, such as “Limit Ad Tracking” for iOSor “Opt-out of interest-based ads ” for Android.
2. AppChoices Application.You can download the “AppChoices” application provided by the DAA from your app store. AppChoices offers a mechanism to limit the collection of app data used for interest-based ads by participating companies. See the AppChoices provided by the DAAfor more.

Please keep in mind that as the mobile environment continues to evolve, additional opt-out mechanisms or privacy settings may become available to you. We encourage you to review the information on opt-outs and settings that device manufacturers, technology companies and industry associations make available to you.

Do Not Track

CP & CPA does not currently take steps to respond to browsers “Do Not Track” signals as no uniform standard to respond to such signals has been developed at this time.

Additional Choices

1. User account.If you have created an account on a Digital Service, you may be able to review some of your information for that account by logging in and updating your information or user preferences.
2. Device Settings.For relevant Digital Services, you may be able to review and adjust your preferences by updating the settings on your device (e.g., permitting us to collect precise location information).
3. Push Notifications.If a Digital Service enables push notifications on your device, you may review and update your push notification preferences by adjusting the settings on your device. For example, you can select the relevant app from “Notifications” (for iOS devices) or “App notifications” (for Android devices) and turn off alerts accordingly.
4. HOW WE PROTECT YOUR INFORMATION

We use a variety of security technologies and procedures to help protect information from unauthorized access, use or disclosure. However, no method of transmission over the internet, or method of electronic storage, is 100% secure. Therefore, while we make reasonable efforts to protect your personal information, we cannot guarantee its absolute security.

1. NON-U.S. VISITORS

We operate the Digital Services from the United States. Any information we obtain about you in connection with your use of the Digital Services may be processed and stored in the United States or other countries.

1. CHILDREN’S PRIVACY RIGHTS

The Digital Services are not intended for use by children, especially those under the age of 13, and we do not knowingly collect personal information from children under the age of 13.

1. LINKS TO THIRD-PARTY WEBSITES, MOBILE APPS OR OTHER SERVICES

The Digital Services may contain links to websites, mobile apps or other services operated by companies not affiliated with CP & CPA. In addition, the Digital Services may be made available to you through third-party platforms (such as app stores or Social Media Platforms) or other channels. We are not responsible for the privacy practices of any non-CP & CPA operated websites, mobile apps or other services and channels, and we encourage you to review the privacy policies or notices published by relevant third parties.

1. CAREERS/JOB OPPORTUNITIES

This Privacy Notice does not apply to web pages hosting our careers or job opportunities. Any information obtained through such pages is governed by the privacy notice published thereon.

1. DISPUTE RESOLUTION/TERMS

Any dispute concerning the Digital Services (including our use of your personal information) will be resolved per the dispute resolution provision in the Terms of Use which govern your use of the Digital Services. Please take a few minutes to read the Terms of Use before using the Digital Services.

1. CHANGES TO THIS PRIVACY NOTICE

We may update this Privacy Notice from time to time to reflect changes in our privacy practices or applicable laws. In accordance with applicable law, we may make such changes without prior notice. We will publish the updated version on the relevant Digital Services and indicate at the top of the Privacy Notice when it was most recently updated. Your use of the Digital Services will be governed by the then-current version of the Privacy Notice.

1. CONTACT US

If you have any questions about this Privacy Notice, please contact us by email at harry@classicpromenade.com. For questions related to and to exercise your California Consumer Privacy Act of 2018 (CCPA) rights, please contact us by email at harry@classicpromenade.com.

1. ADDITIONAL INFORMATION FOR CALIFORNIA RESIDENTS

Under California law, specific disclosures are required and California residents have additional rights regarding their personal information. Please review this section to learn more.

Your California Consumer Privacy Act of 2018 (CCPA) Rights

Categories of Personal Information We Collect

The California Consumer Privacy Act of 2018, as amended from time to time (“CCPA”) requires specific disclosures for each category of personal information that we collect. The table below summarizes our general data handling practices which are more fully described in Sections B, C and D of this Privacy Notice.

Your California Consumer Privacy Act of 2018 (CCPA) Privacy Rights
Residents of California may have the following rights:

1. Right to know and access your personal information. Under CCPA, you have the right to:

• Know the categories of personal information we collect and the categories of sources from which we got the information;
• Know the business or commercial purposes for which we collect and share personal information;
• Know the categories of third parties and other entities with whom we share personal information; and
• Access the specific pieces of personal information we have collected about you.

To do so, please email us at harry@classicpromenade.com and include your name, email address and California postal address. Please specify the CCPA right you wish to exercise at this time.

2. Right to deletion. In some circumstances, you may ask us to delete your personal information. To do so, please email us at harry@classicpromenade.com  and include your name, email address and California postal address. Please specify the CCPA right you wish to exercise at this time.
3. Right to opt out of sales. We may share your personal information with third parties in ways that may constitute a “sale” under CCPA. You may request that we not “sell” your personal information on a going forward basis. To do so, please email us at harry@classicpromenade.com and include your name, email address and California postal address. Please specify the CCPA right you wish to exercise at this time. If you reengage with us after opting out of the “sale” of your personal information, such as by submitting a bid, signing up for a newsletter and/or entering a sweepstakes or contest your personal information will be collected and used in accordance with this Privacy Notice.
4. Right to be free from discrimination. You may exercise any of the above rights without fear of being discriminated against. We are permitted to provide a different price or rate to you if the difference is directly related to the value provided to you by your data.

For any of the above mentioned rights, you may designate an authorized agent to make a request on your behalf. In the request, you or your authorized agent must provide including information sufficient for us to confirm the identity of an authorized agent. We are required to verify that your agent has been properly authorized to request information on your behalf and this may take additional time to fulfill your request.

We will use the information you provide to make your CCPA rights requests to verify your identity, identify the personal information we may hold about you and act upon your request. We strongly recommend that you submit the email and postal address that you used when you created accounts, listed or placed a bid on a listed vehicle or other products and services, or signed up for a newsletter. After you submit a CCPA rights requests , we may ask you to verify your identity and/or access to the email address you submitted. You are required to verify your identity and/or email in order for us to proceed with your CCPA rights requests. Please check your spam or junk folder in case you can’t see the verification email in your inbox. If you are a California resident and have any questions regarding your CCPA rights under this Privacy Notice, please contact us at harry@classicpromenade.com. 

1. ADDITIONAL INFORMATION FOR EUROPEAN VISITORS

In order to address our legal obligations in Europe (including the UK), CP & CPA provides the following additional information for Europe-based visitors to CP & CPA’s U.S. Digital Services.

Who is Responsible for Your Information?

If you use or interact with a CP & CPA U.S. Digital Service then the data controller will be Classic Promenade LLC & Classic Promenade Auctions LLC. The contact details for this entity are provided in the “Contact Us” section above.

Legal Bases for Using Your Information

We process personal information for different purposes (as described in the “How We Use Information We Obtain” section, above) on the following legal bases:

To perform our contractual obligations to you. We and our service providers process your information to perform our contractual obligations to you when we use your information to provide you with the Digital Services and related content, products or services and to communicate with you. For example, when you list or successfully bid on a vehicle or other products and services through the Digital Services, we process your payment and contact information as necessary to collect the fees charged by us and to facilitate your transaction with the seller. We process your contact information and other details to provide you with support services you request. We also send you informational communications on this basis, including to confirm a listing or to notify you of a change to a Digital Service. Failure to provide requested information could prevent or delay the fulfilment of our contractual obligations.

• To pursue our legitimate interests. We process your information to meet our legitimate interests when we use your information to provide you with the Digital Services and related content, products or services, to communicate with you and for our advertising and marketing purposes. For example, our legitimate interests include making improvements to, customizing and understanding how you interact with the Digital Services and related content, products or services, and sending you communications about products and services we think may be of interest to you. To accomplish our legitimate interests, we may share your information with our affiliates and subsidiaries, service providers and business partners (including for our advertising and marketing purposes) and in the context of a corporate transaction. We maintain safeguards to protect the information we process to pursue our legitimate interests.
• To comply with our legal obligations. We process and share your information as necessary to comply with our legal obligations when we use your information to protect our rights or the rights of others and when we share your information with other parties where required by law or as necessary to protect our rights. For example, we may be required to collect certain information from you when processing your payment for tax or financial reporting reasons.
• With your consent. We obtain your consent to process your information when we are required to do so by law. If consent is the legal basis on which we process your personal information, you can withdraw your consent at any time by contacting us using the information provided in the “Contact Us” section above.

Your Rights Over Your Information

In certain circumstances, you have a right to access or object to the use of personal information held about you (including in relation to direct marketing). You can also ask us to rectify, update, erase, restrict or to share your information in a usable format with another company. Such requests are subject to applicable law.
We encourage you to contact us to update or correct your information if it changes or if the personal information we hold about you is inaccurate.
If you would like to discuss or exercise such rights, please contact us at harry@classicpromenade.com. We will contact you if we need additional information from you in order to honor your requests.

Storing Your Information

We will keep your personal information for as long as we have a relationship with you. Once our relationship with you has come to an end, we will retain your personal information for a period of time that enables us to:

• Maintain business records for analysis, understanding market trends and/or audit purposes and to improve the Digital Services.
• Comply with record retention requirements under applicable laws or other relevant legal or regulatory requirements.
• Defend, establish, exercise or bring any existing or potential legal claims.
• Carry out fraud detection and prevention.
• Deal with any complaints regarding the Digital Services, our products and services.

We will delete your personal information when it is no longer required for these purposes. If there is any information that we are unable, for technical reasons, to delete from our systems, we will put in place appropriate measures to prevent any further processing or use of the data.

International Data Transfers

Information collected through the Digital Services will be processed in and subject to the laws of the United States, which may not provide the same level of protection for your personal information as your home country. If we transfer personal data from the European Economic Area, United Kingdom and Switzerland we put in place safeguards.

Changes to the Privacy Notice

Where changes to this Privacy Notice have a fundamental impact on the nature of the processing or otherwise have a substantial impact on you, we will give you advanced notice so that you have the opportunity to exercise your rights (e.g. to object to the processing).

Privacy Officer and Complaints

Our Privacy Officer can be contacted at harry@classicpromenade.com
We are committed to working with you to obtain a fair resolution in the event you have a complaint or concern about privacy. If, however, you believe that we have not been able to assist with your complaint or concern, you have the right to make a complaint to a data protection authority.