Oct 12, 2021

Emerald Holdings LLC D.B.A. Emerald Direct Capital (“we” or “us”) consider the privacy and protection of our clients' data, both corporate and personal, to be of the utmost importance and we take robust measures across our business to protect the security and integrity of all such information.

However, the law requires us to take particular steps in relation to the processing and protection of personal data. To ensure that you feel confident about providing us with your personal information when communicating with us and using our services, we outline below our practices in relation to the collection and use of personal data. This policy (together with our terms of use and any other documents referred to on it) sets out the basis on which we will collect, use and process personal data. Please read this Privacy Policy carefully to ensure you understand how we handle your personal data; please also check this page from time to time as the Policy may be updated.

INFORMATION WE MAY COLLECT FROM YOU

We may collect and process the following information about you:

information you provide by filling in forms on our website (www.emeralddirectcapital.com); and information given in hard copy form or by any other means providing: your name; date of birth; address; interests; marketing preferences; when appropriate your credit information; and any other personal information relevant to the services we provide. This information may be provided when you are registering interest, transacting with us, subscribing to our services or for newsletters or requesting information;

correspondence or other contacts you may have with us;

details of transactions you carry out through our website, and any communications by telephone, in person or by any other means relating to those transactions. This may include recording certain telephone conversations, for example relating to live bidding;

details of your visits to our website including, but not limited to, traffic data, web logs or other communication data and the resources you access.

The information you provide to us will be used for processing transactions but may also be used for internal data processing, such as compiling statistical information about your interests and the use of www.emeralddirectcapital.com. As a service to you, we may also use this information to customize the content we offer on www.emeralddirectcapital.com.

SPECIFIC INFORMATION WE MAY COLLECT VIA

www.emeralddirectcapital.com

We may collect and process the following information obtained from your use of www.emeralddirectcapital.com

Cookies

A cookie is a simple text file that is stored on your computer or mobile device by a website’s server and only that server will be able to retrieve or read the contents of that cookie. Each cookie is unique to your web browser. It will contain some anonymous information such as a unique identifier and the site name and some digits and numbers. It allows a website to remember things like your preferences or what’s in your shopping basket. Using our website will result in us placing cookies on your computer in the 3 categories set out below.

Strictly necessary: These cookies are essential to enable you to move around the website and use its features, such as accessing secure areas of the website; many of the functions on our website will not work properly, or at all, if you do not allow these cookies to be used. We may therefore be unable to provide many of the services you may wish to request unless you accept the use of these cookies.

Performance: These cookies collect information about how visitors use a website, for instance which pages visitors go to most often. These cookies do not collect information that identifies a visitor: all information these cookies collect is aggregated and is therefore anonymous. The information is only used to improve how the website works.

Functionality: These cookies allow the website to remember choices you make (such as your user name, language or the region you are in) and provide enhanced, more personal features (for example, remembering changes you have made to text size and fonts).

If you reside outside the EU, we also use a fourth type of cookie for Targeting or Advertising:

Targeting or Advertising: We sometimes partner with third parties to deliver more relevant advertisements and to compile web statistics. These third parties may use cookies, web beacons and other tracking technology to monitor your visits to both Emerald Holdings LLC D.B.A Emerald Direct Capital and other websites. They monitor your online behavior and identify website usage, helping advertisers show you advertising and content that is more relevant to you. Some examples of what Targeting and Advertising Cookies do:

Provide advertisers with information about your visit to our websites so they can show you advertising that is relevant to you.

Limit the number of times you see an advertisement.

Help measure the effectiveness of an advertising campaign.

Don't worry - none of these cookies store personally identifiable information and we only use trusted advertising partners. Just so you know, these third parties will have their own privacy policies and they may be different from ours.

IP Address

We may collect information about your computer, including your internet address, operating system and browser type when you visit us. Your internet address is used to help identify and gather statistical or demographic information about our customers generally. We also use this information for internal system administration to help diagnose problems with our servers, to administer our website and the customer or user experience.

HOW IS THIS PERSONAL INFORMATION USED?

Emerald Holdings LLC will collect, record, store and use your personal data world-wide among the Emerald Holdings LLC companies for clearly specified purposes including but not limited to:

providing you with information, products or services that you request from us or which we believe would interest you in a way that is targeted and relevant. This could include but is not limited to auctions, private sales, storage services and transportation, valuations, real estate, education and insurance;

carrying out our obligations arising from any contracts entered into between you and us;

notifying you about changes to our products and services;

ensuring that our website is presented in the most effective manner for you and your computer

selling or purchasing property or services

(unless you object,) advising you of forthcoming sales, events and services.

We may contact you for the above purposes by telephone call, email, text or SMS messaging and other means.

SHARING INFORMATION

We will not share your personal data with anyone outside the Emerald Holdings LLC group of companies other than in accordance with the law and as stated in this Policy. Each of the countries in which we operate has different privacy laws. Our Privacy Policy will reflect those.

We may from time to time however need to disclose your personal data to certain third parties.

Agents or Contractors of Emerald Holdings LLC

We may need to disclose certain personal information to our Agents or Contractors to enable Emerald Holdings LLC to process transactions or communicate with you. Where we do so it will be on the basis that these agents/contractors are required to keep the information confidential and secure, and will not use the information for any other purpose than to carry out the services they are performing for Emerald Holdings LLC.

Anti-Money Laundering and Regulatory Authorities

We may need to retain and disclose certain information about you to regulatory authorities and to appropriate agencies to conduct anti-money laundering and trade sanction checks and to assist with fraud prevention, in particular, in compliance with our AML obligations and in relation to trade sanctions. We will disclose this information as is required by law.

Credit Agencies

We may need to disclose certain personal information about you to credit agencies to conduct appropriate checks when you are transacting with us.

Legal Disclosures

While we will not voluntarily disclose your personal data we may disclose such information if we are required to do so by a valid Court Order, if we are lawfully requested by government or law enforcement authorities, if we are required to do so pursuant to other legal processes, or if it becomes necessary to protect the rights or property of Emerald Holdings LLC.

Worldwide Transfers and Processing

As a global organization, Emerald Holdings LLC may process your personal information as described above in countries outside of the EEA. Each of these countries has differing privacy laws offering different levels of protection for your personal information. Our Privacy Policy reflects these varying practices and we will act in accordance with this Policy in all jurisdictions we operate in. By providing your personal information to Emerald Holdings LLC, you consent to us processing your personal information in any jurisdiction, in accordance with this Policy.

Contacting You

In order to provide you with marketing information about our products and services, we may contact you by email, text, SMS or any other messaging service, telephone, fax and by post. At the bottom of any marketing emails you will have a clearly marked unsubscribe option from future mailings. In addition, you may at any time send an email to support@emeraldholdingsllc.com asking for your name to be removed from our lists.

Your Rights

You have the legal right to a copy of the information which we hold about you, including information on how this will be used and to ensure this information is accurate. You also have the right to ask us not to process your personal data for marketing purposes - you can exercise this right by checking certain boxes on the forms we use to collect data or at any time by contacting us at support@emeralddirectcapital.com

Security

We will take all reasonable and appropriate steps to protect the security and integrity of all personal information provided to our website, or by any other means electronic or otherwise.

We will ensure that your personal data within Emerald Holdings LLC is suitably protected against both unauthorized physical and electronic access. These measures include an electronic firewall and various other protection measures that involve virus scanning, installation of security patches, vulnerability testing, backup and recovery planning, employee training, security audits and other steps designed constantly to improve the data protection posture. However, we cannot guarantee that information during transmission through the internet or any computer network is entirely safe from unauthorized intrusion, access or manipulation. We will have no liability for disclosure of information due to errors or unauthorized acts of third parties. In any event, where we believe personal data has been compromised, we will notify you of this.

Third-Party Websites

Emerald Holdings LLC sites contain links to other websites which are not operated by Emerald Holdings LLC. The information you provide to us will not be transmitted to other websites. However, these websites may collect personal information about you in accordance with their own privacy policies. Emerald Holdings LLC is not responsible for the privacy practices or the content of such websites.

How long will Emerald Holdings LLC keep my personal information?

We will hold your information on our systems for as long as is necessary for the relevant activity, or for as long as is specified in any agreement between you and us.

Changes to this Policy

We reserve the right to amend or update this Privacy Policy and any of our privacy practices at any time. We will notify users of this website by posting any updated policy on this page and such changes will be effective immediately and without further notice. Where appropriate, we may notify you directly of changes to the Privacy Policy either through email or a prominent notice on our website.

Contact

If you have any queries in relation to the use and protection of your personal data please contact us at support@emeralddirectcapital.com