Privacy Policy

Introduction

The Joopiter.com website (the “Website”) is owned and operated by Joopiter, Inc. (“Joopiter”, “we”, “us” or “our”). This Privacy Policy describes the personal information Joopiter collects and how that personal information may be used, maintained and shared. This Privacy Policy applies to all individuals who access the Website, engage the services of Joopiter (“Services”), or otherwise interact with Joopiter. By using or accessing the Website and/or Services, you acknowledge that you have read and understood this Privacy Policy.

Joopiter, Inc. is the “controller” and is responsible for deciding how personal information is used and processed in connection with the Website and Services. If you have any questions or concerns about the Privacy Policy, please contact Joopiter:

Joopiter, Inc. 15 E 26th Street New York, NY 10010 Concierge@joopiter.com

We may amend our Privacy Policy from time to time, at any time without notice to you, by posting such changes on the Website. You are responsible for periodically checking the Privacy Policy. You will know if the Privacy Policy has been updated since your last visit to the Website by referring to the “Last Modified” date at the bottom of this page. IF YOU DO NOT AGREE TO THE CURRENT VERSION OF THE PRIVACY POLICY, YOUR SOLE AND EXCLUSIVE REMEDY IS TO REFRAIN FROM ACCESSING OR OTHERWISE USING THE WEBSITE OR THE SERVICES.

Information We Collect About You

“Personal Information” includes any information that enables us to identify you, directly or indirectly, by reference to any identifiers such as name, identification number, location data, online identifier or one or more factors specific to you. It does not include information that is considered anonymous or aggregated by applicable law.

We collect Personal Information about you from a variety of sources, including information we collect from you directly, information we collect about you from other sources, and information we collect automatically from you.

Information You Provide to Us The types of information that we may collect directly from you includes information that you provide when you register on the Website or agree to use our Services, such as: personal details (e.g., name, date of birth), contact details (e.g., shipping/billing address, phone number, email address), transaction information (e.g., bidding or purchase records, shipping details, information about items you purchase or wish to consign), financial information, username and password, and identification information.

It is Joopiter’s policy to request a government issued identification containing a photograph, such as a passport, identity card or driver’s license when you register to bid. Joopiter will use this information to verify your identification and screen for regulatory and financial risk.

Information We Collect From Other Sources We may obtain personal information about you from publicly and commercially available sources, including social media sites, and from our service providers.

Information We Collect From Your Use of Our Website and Services As you interact with our Website, we collect information through cookies and other similar technologies. We may also receive information about you if you visit other websites employing our cookies. A cookie is a small text file that is sent by a website to your device where it is stored by your web browser in order to remember information about you, such as your login information and preferences. For more information on how we use cookies and the choices you may have, please see our Cookie Policy.

How We Use Your Personal Information

We use your Personal Information for the following purposes, as permitted by applicable law:

• To fulfill your orders and purchases, facilitate auctions, provide the Services and manage your account;
• To send you information about auctions that you may be interested in;
• To send you marketing communications and other materials or information that may interest you;
• To verify your identity;
• To protect against risk of fraud;
• To comply with legal obligations to which we are subject and cooperate with regulators and law enforcement bodies;
• For other purposes that we tell you about specifically when you register or provide information about yourself to us.

How We Disclose Your Personal Information

We may disclose your Personal Information to other companies or entities as follows:

• To business partners and vendors that work on our behalf to provide services such as item shipments, mailings, customer account and technology support, secure payment processing, identity verification, fraud prevention, digital marketing management, and data storage;
• To consignors and others as needed to facilitate a consignment or purchase;
• To meet certain legal compliance requirements, for example under anti-money laundering laws or customs laws and regulations;
• To law enforcement or other entities as required;
• As part of a sale, merger, liquidation, or transfer of our business assets.

Grounds for Processing Your Personal Information

We rely on the following legal grounds to process your Personal Information:

• We process your Personal Information with your consent (e.g., when you agree that we may place cookies, or if you ask us to send you information about upcoming auctions).
• We process your Personal Information when we need to do this to fulfill a contract with you (e.g., for billing purposes) or where we are required to do this by law (e.g., where we have to fulfill anti-money laundering requirements).
• We process your Personal Information when it is our legitimate interests to do this and when these interests are not overridden by your data protection rights, such as ensuring the security of our Services, developing new business opportunities, maintaining accurate business records, and ensuring that our Website operates effectively.

__Your Data Protection Rights __

You can control some of our use or collection of your Personal Information:

• Receiving marketing messages from us: You may also stop email marketing by using the “unsubscribe” mechanism at the bottom of our email marketing messages. Please note that even if you opt-out of receiving emails, you may still receive communications related to your interaction with us (such as confirmation of a registration, email communications regarding an auction or purchase receipts) or otherwise as required by law.
• Receiving SMS messages from us: You may opt in to receive SMS communications regarding the auctions bids. Please note that message and data rates may apply. You may stop SMS messages by texting “Stop” to the message.
• Whether your account is up to date: You may edit the Personal Information that is stored in your user account on our website (e.g., your passwords and other contact information) by contacting us at concierge@joopiter.com. We will endeavor to respond to your request as soon as practicable. Before we are able to provide you with any information, correct any inaccuracies, or delete any information, however, we may ask you to verify your identity and to provide other details to help us to respond to your request.

We may need to keep Personal Information we have collected about you to respect your decision to opt-out, for record-keeping and other purposes.

How We Protect Your Personal Information

We protect your information using commercially reasonable physical, technical, and administrative security measures designed to comply with applicable legal requirements and safeguard the Personal Information we collect. No security measures are perfect or impenetrable and we cannot guarantee the absolute security of your Personal Information. You remain responsible for protecting your username and password and for the security of information you transmit to us over the Internet.

We Do Retain Your Personal Information for a Limited Amount of Time

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 and/or audit purposes.
• Comply with record retention requirements under the law or other relevant legal or regulatory requirements.
• Defend or bring any existing or potential legal claims.
• Deal with any complaints regarding the services.

We will delete your Personal Information when it is no longer required for these purposes.

International Transfers Your Personal Information will be stored and processed by us and our subcontractors in jurisdictions, including the United States, where laws regarding data protection may be less stringent than the laws in your country. By using this Website and by providing any Personal Information, all users, including without limitation users in Canada, the UK and the European Union, acknowledge our collection and processing of such Personal Information in such jurisdictions.

• Children’s Privacy

Our Website is not directed at children under the age of 13 and we do not knowingly collect data about children.

Additional Information and Rights for EEA, UK and Swiss Residents

Under European data protection law, in certain circumstances, you have the right to:

• Request access to any Personal Information we hold about you as well as related information, including the purposes for processing the Personal Information, the recipients or categories of recipients with whom the Personal Information has been shared, where possible, the period for which the Personal Information will be stored, the source of the Personal Information, and the existence of any automated decision making.
• Obtain without undue delay the rectification of any inaccurate Personal Information we hold about you.
• Request that Personal Information held about you is deleted.
• Prevent or restrict processing of your Personal Information.
• Request transfer of Personal Information directly to a third party where this is technically feasible. Also, where you believe that Joopiter has not complied with its obligation under this Privacy Policy or European law, you have the right to make a complaint to an EU Data Protection Authority or the UK Information Commissioner’s Office. You can exercise any of these rights by contacting us at concierge@joopiter.com.

Additional Information and Rights For California Residents

Under the California Consumer Privacy Rights Act (“CCPA”), California residents have the right to:

• Request and receive disclosure of our Personal Information collection practices during the prior 12 months, including the categories of Personal Information we collect, the categories of sources of such information, our business purpose for collecting or sharing such information, and the categories of third parties with whom we share such information;
• Request and receive a copy of the Personal Information we have collected about them during the prior 12 months;
• Request and receive disclosure of our information sharing practices during the prior 12 months, including a list of the categories of Personal Information sold with the category of third party recipients and a list of the categories of Personal Information that we disclosed for a business purpose;
• Request that we not sell Personal Information about them;
• Request that we delete (and direct our service providers to delete) their Personal Information subject to certain exceptions.

For purposes of the CCPA, “Personal Information” means information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident or household.

To exercise the access, portability and/or deletion rights described above, please submit a verifiable consumer request to us by either calling us at 310-340-1923 or emailing us at concierge@joopiter.com. Please note that we may request specific information from you in order to verify your identity, and there may be circumstances where we will not be able to honor your request. For example, if you request deletion, we may need to retain certain Personal Information to comply with our legal obligations or other permitted purposes. We will only use Personal Information provided in a verifiable consumer request to verify your identity or authority to make the request.

For requests for deletion of your information please understand that California law permits us to retain certain information and not to delete it under certain circumstances. By way of example, we are not required to comply with a request to delete information if the information is necessary for us to complete a transaction for you or otherwise perform a contract; to detect, protect against, or prosecute security incidents, fraud or illegal activity; to use the information only internally in ways reasonably aligned with your expectations as our customer (such as maintaining sales records), and to comply with legal obligations. If we receive such a request from you we will notify any service providers we have engaged to delete your information as well. We will not discriminate against you as a result of your exercise of any of these rights.

Selling information We do not sell your information for monetary consideration, and we do not disclose your information for other valuable consideration.

We do share your information for the following business purposes:

• To obtain services such as item shipments, mailings, customer account and technology support, secure payment processing, identification verification, fraud prevention and data storage;
• For legal and compliance purposes and to cooperate with law enforcement or other reasonable requests for information; and
• To support potential sales, mergers, liquidations, or transfers of our business assets.

We disclose all of the categories of Personal Information noted below with service providers that process Personal Information on our behalf (e.g., data storage providers, email services, Internet service providers, and research firms), business partners (e.g., professional advisors and consultants), government and law enforcement entities, and advertising and marketing companies.

We may disclose the following categories of information to the third parties listed below:

• General

As this Privacy Policy is part of our Website Terms and Conditions (“Terms”), any disputes between us that relate to privacy or the use of your information, and that arise out of or are related to this Privacy Policy, the Website or our Services, will be subject to our Terms, including any provisions regarding the limitation of damages and liability, governing law and jurisdiction.

Last Modified: October 25, 2022