Sedo Protecting Your Privacy changes — 20160202_rev01

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You will be notified when your personal information is collected by any third party that is not our agent/service provider so that you can make an informed choice as to whether or not to share your information with that party.

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Under some circumstances we may require some additional financial information, including, without limitation, your billing address, bank account information, a credit card number and expiration date, and tracking information from checks or money orders.

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We may automatically collect certain information based upon your behavior on the site. We use this information to do internal research on our users' demographics, interests, and behavior to serve our users better. This information may include the URL that you come from or go to (whether this URL is on the site or not), your computer browser information, and your IP address.

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This information includes internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and clickstream data. We use this information, which does not identify individual users, to analyze trends, to administer the site, to track users' movements around the site and to gather demographic information about our user base as a whole. We do not link this automatically-collected data to personally identifiable information.

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Technologies such as cookies, beacons, scripts and tags are used by Sedo.com LLC and our third party advertising company. These technologies are used in analyzing trends, administering the website, tracking users' movements around the site, and gathering demographic information about our user base as a whole. We may receive reports based on the use of these technologies by these companies on an individual and aggregated basis. Various browsers may offer their own management tools for removing these types of tracking technologies.

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Most cookies are "session cookies," meaning that they are automatically deleted from your hard drive at the end of a session. You are always free to decline our cookies if your browser permits, although in that case you may not be able to use certain features on the site and you may be required to re-enter your password or provide other information more frequently during a session.

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[www.macromedia.com/support/documentation/en/flashplayer/help/settings\_manager07.html](http://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager07.html)

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Some of our business partners (e.g., advertisers) may use "cookies" on our site. We have no access to or control over these "cookies." This privacy policy covers the use of "cookies" by Sedo only and does not cover the use of "cookies" by any advertisers.

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In addition, the use of clear gifs in our HTML-based emails let us know which emails the recipients have opened. This allows us to gauge the effectiveness of certain communications and the effectiveness of our marketing campaigns. If users would like to opt-out of these emails, please email us at [contact@sedo.com.](mailto:contact@sedo.com)

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We and or our third party advertising company employ a software technology called clear gifs (a.k.a. Web Beacons/Web Bugs), that help us better manage content on our site by informing us what content is effective. Clear gifs are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of Web users. The main difference between the two is that clear gifs are invisible on the page and are much smaller, about the size of the period at the end of this sentence. Clear gifs are not tied to users' personal information.

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This information includes internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and clickstream data. We use this information, which does not identify individual users, to analyze trends, to administer the site, to track users' movements around the site and to gather demographic information about our user base as a whole. We do not link this automatically-collected data to personally identifiable information.

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In addition, we use clear gifs in our HTML-based emails to let us know which emails have been opened by the recipients. This allows us to gauge the effectiveness of certain communications and the effectiveness of our marketing campaigns. If users would like to opt-out of these emails, please email us at contact@sedo.com.

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Most cookies are "session cookies," meaning that they are automatically deleted from your hard drive at the end of a session. You are always free to decline our cookies if your browser permits, although in that case you may not be able to use certain features on the site and you may be required to re-enter your password or provide other information more frequently during a session.

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Flash cookies are different from browser cookies because of the amount of, type of, and how data is stored. Cookie management tools provided by your browser will not remove Flash cookies. To learn how to manage privacy and storage settings for Flash cookies click here:

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[http://www.macromedia.com/support/documentation/en/flashplayer/help/settings\_manager.html#117118](http://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager.html)

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If you choose to make bids, buy or sell through the site, we may collect information about your bidding, buying and selling behavior and transactions. If you send us personal correspondence, such as emails or letters, or if other users or third parties send us correspondence about your activities on the site, we may collect such information into a file specific to you.

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We use your information and other information we obtain from your current and past activities on the site to resolve disputes, troubleshoot problems, collect fees owed, pay amounts due you, verify your account data, measure user interest in Sedo's products and services, inform you about online and offline offers, products, services, and updates, customize your experience, detect and protect us against error, fraud and other criminal activity, and enforce our User Agreement. At times, we may look across multiple users to identify problems or resolve disputes, and we may examine your information to identify users using multiple Login Names.

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We may compare and review your information for errors, omissions and for accuracy. You agree that we may use your information to contact you and deliver information to you that, in some cases, is targeted to your perceived interests, such as targeted banner advertisements, administrative notices, product offerings, and communications relevant to your use of the site. By accepting this Agreement, you expressly agree to receive this information.

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## Our Disclosure of Your Information

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We do not share, sell or rent any of your personal information to third parties without your explicit consent or in any way other than as outlined in this privacy policy. However, the following describes some of the ways that your personal information may be disclosed in the normal course of business as part of our services.

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_Advertisers._ We aggregate (gather up data across numerous registered user accounts) personal information and disclose such information in a non-personal manner to advertisers and other third parties for their marketing and promotional purposes. For such purposes, we do not disclose any information that could be used to identify Sedo users personally.

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We partner with a third party ad network to either display advertising on our Web site or to manage our advertising on other sites. Our ad network partner uses cookies and Web beacons to collect non-personal information about your activities on this and other Web sites to provide you targeted advertising based upon your interests. If you wish to not have this information used for the purpose of serving you targeted ads, you may opt-out by clicking [here](http://preferences-mgr.truste.com/). Please note this does not opt you out of being served advertising. You will continue to receive generic ads.

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We partner with a third party ad network to either display advertising on our Web site or to manage our advertising on other sites. Our ad network partner uses cookies and Web beacons to collect non-personal information about your activities on this and other Web sites to provide you targeted advertising based upon your interests. If you wish to not have this information used for the purpose of serving you targeted ads, you may opt-out by clicking [here](http://preferences-mgr.truste.com/) (or if located in the European Union, click [here](http://www.youronlinechoices.eu/)). Please note this does not opt you out of being served advertising. You will continue to receive generic ads.

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_Site._ Although our pages may be coded with robot exclusion headers, others may illegally attempt to automatically collect your email address from the site. If you are involved in a transaction, we have features that may allow other users to view your email address and obtain your contact and other information to help complete the transaction. Further, we may send out notices to you or other users regarding suspicious activity or policy violations on the site.

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_Affiliates for Our Operations._ We may use third parties ("affiliates") to facilitate or outsource one or more aspects of the services that we provide to you (e.g., domain name search technology, advertising provisions for parked domains, and other services) and therefore we may provide some of your information directly to these affiliates. These affiliates are subject to confidentiality agreements with us and other legal restrictions that prohibit their use of the information we provide them for any other purpose except to facilitate the specific outsourced service, unless you have explicitly agreed or given your prior permission to them for additional uses. In some instances, the affiliate may collect information directly from you. In these cases, you will be notified of the involvement of the affiliate, and all additional information you provide them and their additional uses will be up to you. It may be necessary to disclose your stored information, such as first and last name, company name, address, email and/or phone number, to relevant domain monetization advertising partners for the purpose of providing you such services.

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Agents and Business Entities._ We share much of our data, including personal information about you, with our affiliates, subsidiaries, and joint ventures that are committed to serving your online needs and providing related services throughout the world. We use an outside credit card processing company to bill you for goods and services. These companies do not retain, share, store, or use personal information for any other purposes. To the extent that these entities have access to your information, they will treat it at least as protectively as they treat information they obtain from their other users. Our affiliates, subsidiaries, and joint ventures follow privacy practices no less protective of all users than our practices described in this document, to the extent allowed by applicable law.

+Effective Date: 08/07/2014
+Posting Date: 08/07/2014
+Effective Date: 01/15/2016
+Posting Date: 01/15/2016
 Protecting your privacy and the personal information you provide us is a top priority at Sedo.com LLC ("Sedo"). For this reason, Sedo does not sell or rent your personal information to third parties without your explicit consent or in way other than as outlined in this privacy policy. At Sedo, we want our users to fully understand what information we collect, how we use this information, and the steps we take to protect your personal information.
 Please read this Privacy Policy to learn more about the policies and procedures Sedo has put in place to achieve this goal. In addition, Sedo wants our users to feel comfortable that we take all necessary steps to protect personal information. For this reason, we have created a webpage where users can learn how to report a [Privacy Complaint](https://sedo.com/about/policy.php).
+Sedo.com LLC has been awarded TRUSTe's Privacy Seal signifying that this privacy policy and practices have been reviewed by TRUSTe for compliance with [TRUSTe's program requirements](http://www.truste.com/privacy_seals_and_services/consumer_privacy/privacy-programs-requirements.html) including transparency, accountability and choice regarding the collection and use of your personal information. The TRUSTe program does not cover information that may be collected through downloadable software. The TRUSTe program covers only information that is collected through this Web site, [https://sedo.com](https://sedo.com/).
+Sedo.com LLC has received TRUSTE's Privacy Seal signifying that this Privacy Statement and our practices have been reviewed for compliance with the TRUSTe program. The TRUSTe program does not cover information that may be collected through downloadable software. The TRUSTe program covers only information that is collected through this Web site, [sedo.com](https://sedo.com/). In order to view our relationship with TRUSTe please visit the validation page visible by clicking on the TRUSTe Seal.
+TRUSTe's mission, as an independent third party, is to accelerate online trust among consumers and organizations globally through its leading privacy Trustmark and innovative trust solutions. If you have questions or complaints regarding our privacy policy or practices, please contact us at Sedo's Privacy Department by emailing [privacy@sedo.com](mailto:privacy@sedo.com), calling 617-499-7200, or writing Sedo.com, LLC, 161 First Street, Fourth Floor, Cambridge, MA 02142. If you are not satisfied with our response you can contact [TRUSTe here](https://feedback-form.truste.com/watchdog/request).
+If you have questions or complaints regarding our privacy policy or practices, please contact us at Sedo's Privacy Department by emailing [privacy@sedo.com](mailto:privacy@sedo.com), calling 617-499-7200, or writing Sedo.com, LLC, 161 First Street, Fourth Floor, Cambridge, MA 02142. If you are not satisfied with our response you can contact [TRUSTe here](https://feedback-form.truste.com/watchdog/request).
 Sedo.com LLC complies with the U.S. - E.U. Safe Harbor framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal data from European Union member countries.
 Sedo.com LLC has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, and to view Sedo.com LLC's certification, please visit [http://www.export.gov/safeharbor/](http://www.export.gov/safeharbor/)
 ## Overview
+The privacy practices of this statement apply to the services provided by Sedo available under the domain and subdomains of www.sedo.com (the "Site") and apply generally to our affiliates. By visiting this website you agree to be bound by the terms and conditions of this Privacy Policy. If you do not agree please do not use or access our site.
+The privacy practices of this policy apply to the services provided by Sedo available under the domain and subdomains of www.sedo.com (the "Site") and apply generally to our affiliates. By visiting this website you agree to be bound by the terms and conditions of this Privacy Policy. If you do not agree please do not use or access our site.
 This Privacy Policy describes the information we collect from you and what may happen to that information as part of the normal operation of our services. Sedo strives to provide a consistent set of privacy practices across an international community, and as such, all of our affiliates operate under similar privacy practices as described in this Privacy Policy, subject to the requirements of applicable law.
+By accepting the Privacy Policy and the User Agreement at the point of registration, you expressly consent to Sedo's use and disclosure of your personal information in accordance with this Privacy Policy. This Privacy Policy is incorporated into and subject to the terms of the Sedo User Agreement. This Privacy Policy is effective upon acceptance in registration for new registering users, and is otherwise effective on August 7, 2014.
+By accepting the Privacy Policy and the User Agreement at the point of registration, you expressly consent to Sedo's use and disclosure of your personal information in accordance with this Privacy Policy. This Privacy Policy is incorporated into and subject to the terms of the Sedo User Agreement.
 ## Information from Children
 If you are under the age of 18, you may only use this site in conjunction with and under the supervision of your parents or guardians, and with express permission from Sedo. For this reason, we ask that children do not submit any personal information to Sedo.
 ## Information We Collect
 You will be notified when your personal information is collected by any third party that is not our agent/service provider so that you can make an informed choice as to whether or not to share your information with that party.
 Under some circumstances we may require some additional financial information, including, without limitation, your billing address, bank account information, a credit card number and expiration date, and tracking information from checks or money orders.
 We may automatically collect certain information based upon your behavior on the site. We use this information to do internal research on our users' demographics, interests, and behavior to serve our users better. This information may include the URL that you come from or go to (whether this URL is on the site or not), your computer browser information, and your IP address.
+This information includes internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and clickstream data. We use this information, which does not identify individual users, to analyze trends, to administer the site, to track users' movements around the site and to gather demographic information about our user base as a whole. We do not link this automatically-collected data to personally identifiable information.
+Technologies such as cookies, beacons, scripts and tags are used by Sedo.com LLC and our third party advertising company. These technologies are used in analyzing trends, administering the website, tracking users' movements around the site, and gathering demographic information about our user base as a whole. We may receive reports based on the use of these technologies by these companies on an individual and aggregated basis. Various browsers may offer their own management tools for removing these types of tracking technologies.
+Most cookies are "session cookies," meaning that they are automatically deleted from your hard drive at the end of a session. You are always free to decline our cookies if your browser permits, although in that case you may not be able to use certain features on the site and you may be required to re-enter your password or provide other information more frequently during a session.
+[www.macromedia.com/support/documentation/en/flashplayer/help/settings\_manager07.html](http://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager07.html)
+Some of our business partners (e.g., advertisers) may use "cookies" on our site. We have no access to or control over these "cookies." This privacy policy covers the use of "cookies" by Sedo only and does not cover the use of "cookies" by any advertisers.
+In addition, the use of clear gifs in our HTML-based emails let us know which emails the recipients have opened. This allows us to gauge the effectiveness of certain communications and the effectiveness of our marketing campaigns. If users would like to opt-out of these emails, please email us at [contact@sedo.com.](mailto:contact@sedo.com)
+We and or our third party advertising company employ a software technology called clear gifs (a.k.a. Web Beacons/Web Bugs), that help us better manage content on our site by informing us what content is effective. Clear gifs are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of Web users. The main difference between the two is that clear gifs are invisible on the page and are much smaller, about the size of the period at the end of this sentence. Clear gifs are not tied to users' personal information.
+This information includes internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and clickstream data. We use this information, which does not identify individual users, to analyze trends, to administer the site, to track users' movements around the site and to gather demographic information about our user base as a whole. We do not link this automatically-collected data to personally identifiable information.
+In addition, we use clear gifs in our HTML-based emails to let us know which emails have been opened by the recipients. This allows us to gauge the effectiveness of certain communications and the effectiveness of our marketing campaigns. If users would like to opt-out of these emails, please email us at contact@sedo.com.
+Most cookies are "session cookies," meaning that they are automatically deleted from your hard drive at the end of a session. You are always free to decline our cookies if your browser permits, although in that case you may not be able to use certain features on the site and you may be required to re-enter your password or provide other information more frequently during a session.
+Flash cookies are different from browser cookies because of the amount of, type of, and how data is stored. Cookie management tools provided by your browser will not remove Flash cookies. To learn how to manage privacy and storage settings for Flash cookies click here:
+[http://www.macromedia.com/support/documentation/en/flashplayer/help/settings\_manager.html#117118](http://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager.html)
 If you choose to make bids, buy or sell through the site, we may collect information about your bidding, buying and selling behavior and transactions. If you send us personal correspondence, such as emails or letters, or if other users or third parties send us correspondence about your activities on the site, we may collect such information into a file specific to you.
 We use your information and other information we obtain from your current and past activities on the site to resolve disputes, troubleshoot problems, collect fees owed, pay amounts due you, verify your account data, measure user interest in Sedo's products and services, inform you about online and offline offers, products, services, and updates, customize your experience, detect and protect us against error, fraud and other criminal activity, and enforce our User Agreement. At times, we may look across multiple users to identify problems or resolve disputes, and we may examine your information to identify users using multiple Login Names.
 We may compare and review your information for errors, omissions and for accuracy. You agree that we may use your information to contact you and deliver information to you that, in some cases, is targeted to your perceived interests, such as targeted banner advertisements, administrative notices, product offerings, and communications relevant to your use of the site. By accepting this Agreement, you expressly agree to receive this information.
 ## Our Disclosure of Your Information
 We do not share, sell or rent any of your personal information to third parties without your explicit consent or in any way other than as outlined in this privacy policy. However, the following describes some of the ways that your personal information may be disclosed in the normal course of business as part of our services.
 _Advertisers._ We aggregate (gather up data across numerous registered user accounts) personal information and disclose such information in a non-personal manner to advertisers and other third parties for their marketing and promotional purposes. For such purposes, we do not disclose any information that could be used to identify Sedo users personally.
+We partner with a third party ad network to either display advertising on our Web site or to manage our advertising on other sites. Our ad network partner uses cookies and Web beacons to collect non-personal information about your activities on this and other Web sites to provide you targeted advertising based upon your interests. If you wish to not have this information used for the purpose of serving you targeted ads, you may opt-out by clicking [here](http://preferences-mgr.truste.com/). Please note this does not opt you out of being served advertising. You will continue to receive generic ads.
+We partner with a third party ad network to either display advertising on our Web site or to manage our advertising on other sites. Our ad network partner uses cookies and Web beacons to collect non-personal information about your activities on this and other Web sites to provide you targeted advertising based upon your interests. If you wish to not have this information used for the purpose of serving you targeted ads, you may opt-out by clicking [here](http://preferences-mgr.truste.com/) (or if located in the European Union, click [here](http://www.youronlinechoices.eu/)). Please note this does not opt you out of being served advertising. You will continue to receive generic ads.
 _Site._ Although our pages may be coded with robot exclusion headers, others may illegally attempt to automatically collect your email address from the site. If you are involved in a transaction, we have features that may allow other users to view your email address and obtain your contact and other information to help complete the transaction. Further, we may send out notices to you or other users regarding suspicious activity or policy violations on the site.
 _Affiliates for Our Operations._ We may use third parties ("affiliates") to facilitate or outsource one or more aspects of the services that we provide to you (e.g., domain name search technology, advertising provisions for parked domains, and other services) and therefore we may provide some of your information directly to these affiliates. These affiliates are subject to confidentiality agreements with us and other legal restrictions that prohibit their use of the information we provide them for any other purpose except to facilitate the specific outsourced service, unless you have explicitly agreed or given your prior permission to them for additional uses. In some instances, the affiliate may collect information directly from you. In these cases, you will be notified of the involvement of the affiliate, and all additional information you provide them and their additional uses will be up to you. It may be necessary to disclose your stored information, such as first and last name, company name, address, email and/or phone number, to relevant domain monetization advertising partners for the purpose of providing you such services.
+_
 Agents and Business Entities._ We share much of our data, including personal information about you, with our affiliates, subsidiaries, and joint ventures that are committed to serving your online needs and providing related services throughout the world. We use an outside credit card processing company to bill you for goods and services. These companies do not retain, share, store, or use personal information for any other purposes. To the extent that these entities have access to your information, they will treat it at least as protectively as they treat information they obtain from their other users. Our affiliates, subsidiaries, and joint ventures follow privacy practices no less protective of all users than our practices described in this document, to the extent allowed by applicable law.
 ## Links to 3rd Party Sites
 Our Site includes links to other Web sites whose privacy practices may differ from those of Sedo. If you submit personal information to any of those sites, your information is governed by their privacy policies. We encourage you to carefully read the privacy policy of any Web site you visit.
 ## Testimonials
+We display personal testimonials of satisfied customers on our site in addition to other endorsements. With your consent we may post your testimonial along with your name.
+We display personal testimonials of satisfied customers on our site in addition to other endorsements. With your consent we may post your testimonial along with your name. If you wish to update or delete your testimonial, you can contact us at privacy@sedo.com.
 ## Notice and Modification
 If we decide to change our Privacy Policy we will post those changes to this privacy policy, the homepage, and other places we deem them appropriate so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it.
 We reserve the right to make changes to this Privacy Policy at any time by posting the amended terms on the site, so please check it frequently. If we make material changes to this Policy, we will notify you by email, sent to the e-mail address specified in your account, or by means of a notice on this Site prior to the change becoming effective. All amended terms shall automatically be effective 30 days after they are initially posted on the site.

Protecting Your Privacy

Full text changes — 20150121_rev01 to 20160202_rev01