Thomas Auctions LLC Privacy Policy
Last updated: April 21, 2022
This privacy policy has been compiled to better serve those who are concerned with how their 'Personally Identifiable Information' (“PII”) is being used online. PII, as used in US privacy law and information security, is information that can be used on its own or with other information to identify, contact, or locate a single person, or to identify an individual in context. Please read our privacy policy carefully to get a clear understanding of how we collect, use, protect or otherwise handle your Personally Identifiable Information in accordance with our website.
1. What personal information do we collect from the people that visit our website?
When purchasing or registering on our site, as appropriate, you may be asked to enter your:
Name
Age
Postal and email address
Telephone number &/or fax number
Gender identity
Ethnicity and primary language
Veteran status
Current occupation
Level of completed education
IP address / email address
Physical location, which may be derived from your IP address or mobile device
Financial information (e.g., mortgage loan balance), when you choose to share it with us
Your real estate buying/selling interests, when you choose to share them with us
Your mobile device’s contacts, photos, and location, when you choose to share them with us
Photos
Your realtor license number
or other details to help you with your experience.
2. When do we collect information?
We collect information from you when you register on our site or enter information on our site.
3. How do we use your information?
We may use the information we collect from you when you register, make a purchase, sign up for our newsletter, respond to a survey or marketing communication, surf the website, or use certain other site features in the following ways:
To personalize user's experience and to allow us to deliver the type of content and product offerings in which you are most interested.
To improve our website in order to better serve you.
To allow us to better service you in responding to your customer service requests.
To send you marketing related emails with information about our services, new offerings & other related news.
To quickly process your transactions.
To send periodic emails regarding your purchases or other products and services.
To follow up with you after correspondence (live chat, email or phone inquiries)
4. How do we protect visitor information?
Our website is scanned on a regular basis for security holes and known vulnerabilities in order to make your visit to our site as safe as possible. Your personal information is contained behind secured networks and is only accessible by a limited number of persons who have special access rights to such systems, and are required to keep the information confidential. We implement a variety of security measures when a user places a bid, purchases, enters, submits, or accesses their information to maintain the safety of your personal information.
5. Do we use 'cookies'?
Yes. Cookies are small files that a site or its service provider transfers to your computer's hard drive through your Web browser (if you allow) that enables the site's or service provider's systems to recognize your browser and capture and remember certain information. For instance, we use cookies to help us remember and process your purchases. They are also used to help us understand your preferences based on previous or current site activity, which enables us to provide you with improved services. We also use cookies to help us compile aggregate data about site traffic and site interaction so that we can offer better site experiences and tools in the future.
We use cookies to:
Help remember and process your purchases.
Understand and save user's preferences for future visits.
Compile aggregate data about site traffic and site interactions in order to offer better site experiences and tools in the future. We may also use trusted third-party services that track this information on our behalf.
You can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies. You do this through your browser settings. Each browser is a little different, so look at your browser's Help menu to learn the correct way to modify your cookies.
If you disable cookies, some features will be disabled. It may affect your experience including tools that make our site experience more efficient and some of our services will not function properly.
6. Third-party disclosure
We do not sell, trade, or otherwise transfer to outside parties your personally identifiable information unless we provide users with advance notice. This does not include website hosting partners and other parties who assist us in operating our website, conducting our business, or serving our users, so long as those parties agree to keep this information confidential. We may also release information when its release is appropriate to comply with the law, enforce our site policies, or protect our or others' rights, property, or safety.
However, non-personally identifiable visitor information may be provided to other parties for marketing, advertising, or other uses.
7. Third-party links
Occasionally, at our discretion, we may include or offer third-party products or services on our website. These third-party sites have separate and independent privacy policies. We, therefore, have no responsibility or liability for the content and activities of these linked sites. Nonetheless, we seek to protect the integrity of our site and welcome any feedback about these sites.
8. Behavioral Re-marketing
We use re-marketing services to advertise on third-party websites to you after you visited our site. We and our third-party vendors use cookies to inform, optimize and serve ads based on your past visits to our site.
Google Ads (AdWords)
Google Ads (AdWords) re-marketing service is provided by Google Inc.
You can opt-out of Google Analytics for Display Advertising and customize the Google Display Network ads by visiting the Google Ads Settings page: http://www.google.com/settings/ads
Google also recommends installing the Google Analytics Opt-out Browser Add-on - https://tools.google.com/dlpage/gaoptout - for your web browser. Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics.
For more information on the privacy practices of Google, please visit the Google Privacy Terms web page: https://policies.google.com/privacy?hl=en
Facebook re-marketing service is provided by Facebook Inc. (owned by Meta Inc.)
You can learn more about interest-based advertising from Facebook by visiting the facebook.com website
To opt-out from Facebook's interest-based ads, follow these instructions from Facebook: https://www.facebook.com/help/568137493302217
Facebook adheres to the Self-Regulatory Principles for Online Behavioral Advertising established by the Digital Advertising Alliance. You can also opt-out from Facebook and other participating companies through the Digital Advertising Alliance in the USA http://www.aboutads.info/choices/, the Digital Advertising Alliance of Canada in Canada http://youradchoices.ca/ or the European Interactive Digital Advertising Alliance in Europe http://www.youronlinechoices.eu/, or opt-out using your mobile device settings.
For more information on the privacy practices of Facebook, please visit Facebook's Data Policy: https://www.facebook.com/privacy/explanation
9. Payments
We use third-party services for payment processing (e.g. payment processors). That information is provided directly to our third-party payment processors whose use of your personal information is governed by their Privacy Policy.
10. California Online Privacy Protection Act (CalOPPA)
According to CalOPPA we agree to the following:
Users can visit our site anonymously.
Once this privacy policy is created, we will add a link to it on our home page or as a minimum on the first significant page after entering our website.
Our Privacy Policy link includes the word 'Privacy' and can be easily be found on the page specified above.
Users will be notified of any privacy policy changes:
On our Privacy Policy Page
Users are able to change their personal information:
By logging in to their account and accessing their personal information through their customer profile.
11. How does our site handle "do not track" signals?
We honor "do not track" signals and do not track, plant cookies, or use advertising when a Do Not Track (DNT) browser mechanism is in place.
If you enable "do not track", some features will be disabled. It may affect the user's experience that makes your site experience more efficient and some of our services will not function properly.
12. Children Online Privacy Protection Act (COPPA)
When it comes to the collection of personal information from children under 13, the Children's Online Privacy Protection Act (COPPA) puts parents in control. The Federal Trade Commission, the nation's consumer protection agency, enforces the COPPA Rule, which spells out what operators of websites and online services must do to protect children's privacy and safety online.
We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your child has provided us with Personally Identifiable Information, please contact us. If we become aware that we have collected Personally Identifiable Information from children without verification of parental consent, we take steps to remove that information from our servers.
13. California Shine the Light Law
Subject to certain limitations, California residents may ask us to provide them with (1) a list of certain categories of personal information that we have disclosed to third parties for their direct marketing purposes during the immediately preceding year, and (2) the identity of those third parties. To make this request, California residents may contact us through the Contacting Us section below. For such requests, indicate "California Shine the Light Request" in the communication with our office.
14. California Residents, California Consumer Privacy Act of 2018 (CCPA), California Consumer Privacy Action Notice (CCPA Notice)
Pursuant to the CCPA, we are providing this CCPA Notice. This CCPA Notice applies solely to California consumers, effective January 1, 2020. Terms used but not defined shall have the same meaning ascribed to them in the CCPA. This CCPA Notice does not apply to personal information that we collect from job applicants, contractors, or employees.
You have the Right to Know. You may request that we disclose to you what personal information we have collected, used, shared, or sold about you, and why we collected, used, shared, or sold that information. Other than noted in this privacy policy, we do not otherwise collect, use, share, or sell information about you. You may specifically request this disclosure by contacting us by the methods at the bottom of this privacy policy. We will provide this information to you free of charge within 45 calendar days of your request.
You have the Right to Delete. You may request that we delete personal information from you and to tell our service providers to do the same. In some situations, we are not able to delete your personal information if we need that information to complete your transaction, provide a reasonably anticipated product or service, for certain reasonable consumer expectations, to comply with legal obligations, or certain CCPA provided exceptions. You may specifically request this deletion by contacting us by the methods at the bottom of this privacy policy. We will honor this request within 45 calendar days.
You have the Right to Opt-Out. We do not sell personal information. We do share information with service providers as provided in this privacy policy for transactional and marketing purposes.
You have the Right to Non-Discrimination. We do not and will not deny goods or services, charge you a different price, or provide a different level or quality of goods or services because you exercised your rights under the CCPA. If you refuse to provide your personal information to us or ask us to delete it, and that personal information is necessary for us to provide you with goods or services, we may not be able to complete the transaction.
15. Fair Information Practices
The Fair Information Practices Principles form the backbone of privacy law in the United States and the concepts they include have played a significant role in the development of data protection laws around the globe. Understanding the Fair Information Practice Principles and how they should be implemented is critical to comply with the various privacy laws that protect personal information.
In order to be in line with Fair Information Practices we will take the following responsive action, should a data breach occur:
We will notify the users via email
Within 1 business day
We will notify the users via in-site notification
Within 1 business day
We also agree to the Individual Redress Principle, which requires that individuals have a right to pursue legally enforceable rights against data collectors and processors who fail to adhere to the law. This principle requires not only that individuals have enforceable rights against data users, but also that individuals have recourse to courts or government agencies to investigate and/or prosecute non-compliance by data processors.
16. CAN-SPAM Act
The CAN-SPAM Act is a law that sets the rules for commercial email, establishes requirements for commercial messages, gives recipients the right to have emails stopped from being sent to them, and spells out tough penalties for violations.
We collect your email address in order to:
Send information, respond to inquiries, and/or other requests or questions.
Process purchases and to send information and updates pertaining to purchases.
We may also send you additional information related to your purchases, interests, and/or our services.
Market to our mailing list or continue to send emails to our clients after the original transaction has occurred.
To be in accordance with CAN-SPAM we agree to the following:
NOT use false or misleading subjects or email addresses.
Identify the message as an advertisement in some reasonable way.
Include the physical address of our business or site headquarters.
Monitor third-party email marketing services for compliance, if one is used.
Honor opt-out/unsubscribe requests quickly.
Allow users to unsubscribe by using the link at the bottom of each email.
If at any time you would like to unsubscribe from receiving future emails, you can follow the instructions at the bottom of each email and we will promptly remove you from ALL correspondence.
17. Legal Disclosure of Data
We also use and disclose your Personal Information as necessary or appropriate, in particular when we have a legal obligation or legitimate interest to do so:
To comply with applicable law and regulations.
This may include laws outside your country of residence.
To cooperate with public and government authorities.
To respond to a request or to provide information we believe is important.
These can include authorities outside your country of residence.
To cooperate with law enforcement.
For example, when we respond to law enforcement requests and orders or provide information we believe is necessary or appropriate.
For other legal reasons.
To enforce our terms and conditions; and
To protect our rights, privacy, safety or property, and/or that of our affiliates, you or others.
In connection with a sale or business transaction.
We have a legitimate interest in disclosing or transferring your Personal Information to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets (including in connection with any bankruptcy or similar proceedings).
Other Uses & Disclosures:
Collection of other information:
Through your use of our App
When you download and use our App, we and our service providers may track and collect App usage data, such as the date and time the App on your device accesses our servers and what information and files have been downloaded to the App based on your device number.
18. Contacting Us
If there are any questions regarding this privacy policy, you may contact us using the information below.
Thomas Auctions LLC, Attn: Thomas Seaman
℅ KWGM
29225 Chagrin Blvd. #105
Pepper Pike, OH., 44122
(216) 469-7081
