THE LEVEL MARKET (TLM) PRIVACY NOTICE

Last Updated: August 04, 2015

Scope and Consent

This Privacy Notice describes our collection, use, disclosure, retention, and protection of your personal information. It applies our website (www.thelevelmarket.com), and to any TLM application, service, or tool (collectively "Services") where this Privacy Notice is referenced, regardless of how you access or use them, including through mobile devices.

By using our Services and/or registering for an account with us, you are accepting the terms of this Privacy Notice and our User Agreement, and you are consenting to our collection, use, disclosure, retention, and protection of your personal information as described in this Privacy Notice.If you do not provide the information we require, we may not be able to provide all of our Services to you.Personal Information

"Personal information" is information that can be associated with a specific person and could be used to identify that specific person whether from that data or from that data and other information that TLM has or is likely to have access to. We do not consider personal information to include information that has been made anonymous or aggregated so that it can no longer be used to identify a specific person, whether in combination with other information or otherwise. Changes to this Notice

We may amend this Privacy Notice at any time by posting the amended terms on this site. All amended terms automatically take effect 30 days after they are posted.  Collection

We collect, process, and retain personal information from you and any devices (including mobile devices) you may use when you: use our Services, register for an account with us, provide us information on a web form, update or add information to your account, participate in community discussions, chats, or dispute resolution, or when you  otherwise correspond with us regarding our Services.The personal information we collect includes the followingPersonal information you give us when you use our Services or register for an account with us:

  • Identifying information such as your name, addresses, telephone numbers or email addresses when you register for an account with us
  • Bidding, buying, or selling information you provide during a transaction, or other transaction­-based content that you generate or that is connected to your account as a result of a transaction you are involved in
  • Other content that you generate, or that is connected to your account (such as adding items to your basket, adding items to your Watch List, creating collections, and following other collections and sellers)
  • Financial information (such as credit card or bank account numbers) in connection with a transaction
  • Postage, billing and other information used to purchase or post an item, as well as, where postal services are provided through one of our programs, information required  to clear customs (such as Tax ID or other identification numbers) and relevant postage information (such as tracking numbers and tracking updates).
  • In some instances, when you use our Services, you may provide age, gender, interests and favorites
  • You may also provide us other information through a web form, by updating or adding information to your account, through your participation in community discussions, chats, dispute resolution, or when you otherwise correspond with us regarding our Services
  • Additional information we are required or authorized by applicable national laws to collect and process in order to authenticate or identify you or to verify the information we have collected

Personal information we collect automatically when you use our Services or register for an account with us

  • We also collect information about your interaction with our Services, your advertising preferences, and your communications with us. This is information we receive from the devices (including mobile devices) you use when you use our Services, register for an account with us, provide us information on a web form, update or add information to your account, participate in community discussions, chats, or dispute resolution, or when you otherwise correspond with us regarding our Services. This information comprises the following: Device ID or unique identifier, device type, ID for advertising, and unique device token
  • Geo­‐location information, including location information from your mobile device. Keep in mind that most mobile devices allow you to control or disable the use of location services by any application on your mobile device in the device's settings' menu
  • Computer and connection information such as statistics on your page views, traffic to and from the sites, referral URL, ad data, your IP address, your browsing history, and your web log information

Personal information we collect using cookies, web beacons, and similar technologies

We may use cookies, web beacons, unique identifiers, and similar technologies to collect information about the pages you view, the links you click, and other actions you take on our Services, within our advertising or e­‐mail content. Personal information from other sources

  • We may supplement the information we collect with information from third parties and add it to your account information. For example, we may collect and use demographic information that is publicly available, additional contact information, credit check information, and information from credit bureaus, as allowed by applicable national laws.
  • We may allow you to share information with social media sites, or use social media sites to create your account or to connect your account with the respective social media site. Those social media sites may give us automatically access to certain personal information retained by them about you (e.g., content viewed by you, content liked by you, and information about the advertisements you have been shown or may have clicked on, etc.). If you provide us with access to any site with video content, then you agree that we may share your video viewing with, or obtain information about your video viewing from, third­‐party social media sites for at least two years or until you withdraw consent. You control the personal information you allow us to have access to through the privacy settings on the applicable social media site and the permissions you give us when you grant us access to your personal information retained by the respective social media site about you. By associating an account managed by a social media site with your account and authorizing us to have access to this information, you agree that we may collect, use and retain the information provided by these social media sites in accordance with this Privacy Notice
  • If you give us personal information about someone else, you must do so only with their explicit and prior consent. You have to inform them how we collect, use, disclose, and retain their personal information according to our Privacy Notice.
Use and Retention

We use the personal information we collect to: provide and improve our Services, to provide you with a personalized experience on our sites (especially, by offering you services and items that you may like), to contact you about your account and our Services, to provide you customer service, to provide you with personalized advertising and marketing, and to detect, prevent, mitigate and in vestigate fraudulent or illegal activities. We may use and retain your personal information as follows:

Provide, improve, and personalize our Services

  • Provide access to and use of our Services.
  • Offer you site content that includes items and services that you may like.
  • Keep track of your preferences and the other parties with whom you have communicated.
  • Give you access to your purchase history, scores, bids, internal messages and other feature
  • Customize, measure, and improve our Services
  • Provide other services requested by you as described when we collect the information
  • We may use geo­‐location information to provide you with location based services (such as advertising, search results, and other personalized content)

Contact you about your account and provide you customer service

  • Contact you to notify you regarding your account, to troubleshoot problems with your account, to resolve a dispute, to collect fees or monies owed, to poll your opinions through surveysor questionnaires, or as otherwise necessary to provide you customer service.
  • Contact you as necessary to enforce our User Agreement, applicable national laws, and any agreement we may have with you.
  • For these purposes we may contact you via email, telephone, text messages, and postal mail. When contacting you via telephone, to ensure efficiency, we may use autodialed or pre­‐recorded calls and text messages as described in our User Agreement.

Personalize our advertising and marketing communications

  • Personalize, measure, and improve our advertising based on your advertising customization preferences
  • Contact you, either via email, telephone, text messages, and postal mail in order to: offer you coupons, discounts and special promotions, and inform you about our Services and those of our TLM corporate family. We will use the contact information you have provided to contact you by e­‐mail, SMS text and/or telephone if you have consented to such contact.
  • Deliver targeted marketing, service updates, and promotional offers based on your communication preferences.

Prevent, detect, mitigate, and investigate fraudulent or illegal activities

  • Prevent, detect, mitigate, and investigate fraud, security breaches, potentially prohibited or illegal activities
  • Enforce our Privacy Notice, our User Agreement or other policies
We retain your personal information as long as it is necessary and relevant for our operations. In addition, we may retain personal information from closed accounts to comply with national laws, prevent fraud, collect any fees owed, resolve disputes, troubleshoot problems, assist with any investigation, enforce our User Agreement and take other actions permitted or required by applicable national laws. After it is no longer necessary for us to retain your personal information, we dispose of it in a secure manner according to our data retention and deletion policies.

Access

We take steps to ensure that the personal information we collect is accurate and up to date, and that you have the ability to access and make corrections to it. This includes the following:

  • You can see, review and change your personal information by signing in to your account. Please update your personal information immediately if it changes or is inaccurate
  • Once you make a public posting, you may not be able to change or remove it. Upon your request, we will close your account and remove your personal information from view as soon as reasonably possible, based on your account activity and in accordance with applicable national laws
  • We will honor any statutory right you might have to access, modify or erase your personal information.
  • To request access and to find out whether any fees may apply, if permitted by applicable national laws, please contact us following the instructions in the Contact Us section below.
  • Where you have a statutory right to request access or request the modification or erasure of your personal information, we can still withhold that access or decline to modify or erase your personal information in some cases in accordance with applicable national laws, but will give you reasons if we do so

Disclosure

We may disclose your personal information to other members of the TLM corporate family or to third parties. This disclosure may be required for us to provide you access to our Services, to comply with our legal obligations, to enforce our User Agreement, to facilitate our marketing and advertising activities, or to prevent, detect, mitigate, and investigate fraudulent or illegal activities related to our Services. We minimize the amount of personal information we disclose to what is directly relevant and necessary to accomplish the specified purpose. As stated above, we do not disclose your personal information to third parties for their marketing and advertising purposes without your explicit consent. We may disclose your personal information to third parties for the following purposes:

  • provide joint content and services (like registration, transactions, and customer support)
  • help detect and prevent potentially fraudulent and illegal acts, violations of our User Agreement, and data security breaches
  • provide you personalized advertising
  • guide decisions about products, sites, applications, services, tools, and marketing communications. TLM will use your personal information to send you marketing communications.

Service Providers and financial institutions partners

  • Third party service providers who help us to provide our Services, payment processing services, assist us in providing customized advertising, assist us with the prevention, detection, mitigation, and investigation of potentially illegal acts, violations of our User Agreement, fraud and/or security breaches and other business operations
Law enforcement, legal proceedings, and as authorized by Law

  • to comply with our legal requirements, enforce our User Agreement, respond to claims that a listing or other content violates the rights of others, or protect any one's rights, property or safety.
  • to law enforcement or governmental agencies, or authorized third­‐parties, in response to a verified request relating to a criminal investigation or alleged or suspected illegal activity or any other activity that may expose us, you, or any other of our users to legal liability. We will only disclose information we deem relevant to the investigation or inquiry, such as name, city, state, postcode, telephone number, email address, User ID history, IP address, fraud complaints, bidding and listing history
  • to credit agencies or bureaus as authorized by applicable national laws (e.g. information on late or missed payments or other defaults on your account that may be reflected in your credit report or file)
  • to third parties involved in a legal proceeding, if they provide us with a subpoena, court order or substantially similar legal procedure, or we otherwise believe in goodfaith that the disclosure of information is necessary to prevent imminent physical harm or financial loss or to report suspected illegal activity

Other TLM users as authorized by you or your use of our Services.

When transacting with another user, the other user may request and we may provide him/her with information about you necessary to complete the transaction, such as your name, account ID, email address, contact details, shipping and billing address, or other information from you needed to promote the reliability and security of the transaction. If a transaction is held, fails, or is later invalidated, we may also provide the other user with details of the unsuccessful transaction. The other user receiving your information is not allowed to use this information for purposes unrelated to the transaction, such as to contact you for marketing purposes, unless you have express consented to it. Contacting users with unwanted or threatening messages is a violation of our User Agreement.Data disclosure to PayPal Inc. and its corporate family

We may disclose your personal information to PayPal Inc. and its corporate family for the following purposes:

  • to prevent, detect, mitigate, and investigate potentially illegal acts, fraud and/or security breaches, and to assess and manage risk, including to alert you if fraudulent activities have been detected on your TLM or PayPal accounts
  • to provide customer services, including to help service your account or resolve disputes (e.g., billing or transactional disputes)
  • to facilitate the processing of payment cards when you pay within our Services with a payment card and we use PayPal to process your payment
  • to facilitate shipping and related services for purchases you made using PayPal

Change of Ownership

If we were to merge with or be acquired by another company, we may share information with them in accordance with our global privacy standards. Should such an event occur, we will require that the new combined entity follow this Privacy Notice with respect to your personal information. If your personal information will be collected, used, disclosed, or retained for any purposes not covered in this Privacy Notice, you will receive prior notification of the processing of your personal information for the new purposes.Security

We protect your information using technical and administrative security measures to reduce the risks of loss, misuse, unauthorized access, disclosure and alteration. Some of the safeguards we use are firewalls and data encryption, physical access controls to our data centers, and information access authorization controls.

Important Information

This section describes some additional important information related to your use of our Services. There are just a few more pieces of important privacy information related to your use of our Services that we need to cover:When you share your personal information on our sites or applications – what happens?

Other users have access to the information you share on TLM. For example, other users may be able to see your bids, purchases, items for sale, the sellers and productsyou follow, Feedback, ratings and associated comments. Other users can also see any information you chose to share in your profile.

To help protect your privacy, we allow only limited access to other users' contact, shipping and financial information as necessary to facilitate your transactions and collect payments. However, when users are involved in a transaction, they have access to each other's name, User ID, email address and other contact and shipping information [Is this true?].

How you should use the information you receive on TLM

When you are in a transaction with another user, we enable you to obtain or we may provide you with the personal information of the other user (such as his/her name, account ID, email address, contact details, shipping and billing address) to complete the transaction. We encourage you to inform the other user about your privacy practices and respect his/her privacy. In all cases, you must give the other user a chance to remove himself/herself from your database and give him/her a chance to review what information you have collected about them.

You may use the personal information that you have access to only for TLM transaction­‐related purposes, or for other services offered through TLM, and for purposes expressly consented by the user to whom the information relates. Using personal information of other users that you have access to for any other purpose constitutes a violation of our User Agreement.

Unwanted or threatening email

We do not tolerate abuse of our Services. You do not have permission to add other users to your mailing list (email or postal), call, or send him/her text messages for commercial purposes, even if this user purchased something from you, unless the user has given his/her explicit consent. Sending unwanted or threatening email and text messages is against our User Agreement. To report TLM-­related spam or spoof emails please forward the email to info@thelevelmarket.com.Children's Privacy

Our websites are general audience websites, and our Services are not intended for children under the age of 13. We do not knowingly collect personal information from users in this age group.Third Party Privacy Practices

This Privacy Notice addresses only the use and disclosure of personal information we collect from you. If you disclose your information to others, or if you are directed to a third party website, their privacy notices and practices will apply.We cannot guarantee the privacy or security of your information once you provide it to a third party and we encourage you to evaluate the privacy and security policies of your trading partner before entering into a transaction and choosing to share your information.This is true even where the third parties to whom you disclose personal information are bidders, buyers or sellers on our site.

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