Privacy Policy - AuctionACCESS

AuctionACCESS Privacy Policy

Effective as of August 12, 2026

This Privacy Policy describes how AuctionACCESS, LLC (“AuctionACCESS”, “we”, “us” or “our”) collects, uses, and discloses your personal information if you use any of the following (collectively, the “Service”):

the AuctionACCESS dealer credentialing system,
the AuctionACCESS individual representative credentialing system,
the AuctionACCESS website at www.auctionaccess.com,
the mobile application AuctionACCESS Mobile, or
any of our other websites or online services on which we post or link to this Privacy Policy owned and operated by AuctionACCESS.

The Service is not intended for use by individuals for personal, family, household, or other consumer purposes, and the personal information covered by this Privacy Policy pertains to people acting in a business or commercial capacity.

In certain situations, we may inform you that our use of your personal information is subject to a different or supplemental privacy policy. For example, for information about how we process biometric data, please see our Biometric Data Policy.

California Privacy Rights: See the Information for California Residents section below for important information about rights you may have under California’s privacy law.

How to Reach Us

If you have any questions, please contact us at customerservice@auctionaccess.com

Personal Information We Collect

Information you provide to us. Personal information you may provide to us through the Service or otherwise includes:

Application and registration information. We collect information from you when you open a Service account or when we need to verify your account, such as your name, address, phone number, email address, profile picture, photo ID (such as driver’s license, passport, official identification card or voter registration card), live selfie, government-issued personal ID number, salesperson license (if required), preferred language, and date of birth, as well as details about the companies you are affiliated with.
Account information. We collect the username and password that you set to establish an account on the Service, as well as any account preferences that you set.
Biometric data. We, our service providers and our partners, such as Incode Technologies, Inc., may collect, store, process, and use your biometric data to help us verify your identity and prevent fraud. This biometric data includes your facial geometry extracted from the live selfie or government-issued ID that you upload. For more information, see our Biometric Data Policy.
Vehicle remarketing activity. Once you have opened a Service account, we collect and maintain updated information about your vehicle remarketing activity, such as your bank information and dealer licenses.
Customer content. Our Customers (defined below) may upload or otherwise provide to the Service content, documents, and other information, such as information about a dealer’s credit history. This content may contain personal information.
Feedback or correspondence. We may collect information you provide when you contact us with questions, feedback, customer support requests, or otherwise correspond with us.
Payment and transaction information. We may collect the bank account or payment card information that you use to purchase products or services from us or our customers, and transaction information relating to those purchases.
Service interaction information. We may collect information associated with content you upload to the Service or otherwise submit to us, and information you provide when you use any interactive features of the Service.
Marketing information. We may collect your preferences for receiving marketing communications, and details about how you engage with them.
Other information. We may collect other information which is not specifically listed here, but which we will use in accordance with this Privacy Policy or as otherwise disclosed at the time of collection.

Information we obtain from other third parties. We may also receive personal information about you from other third party sources, such as our corporate affiliates, other Customers, information services (such as services that provide us with information about our customers and prospective customers), auction insurers, our business contacts (who may share with us contact details about individuals in their network), and publicly available sources (such as public records, social media platforms, and other publicly available sources). We may combine this information with information we collect from you or the Services.

Information collected by automated means. We and our service providers may automatically log, monitor and record information about you, your computer or mobile device, and activity occurring on or through the Service and our communications. Such information may include:

Device data, such as your computer or mobile device operating system type and version number, manufacturer and model, device or other unique identifier, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), language settings, mobile device carrier, radio/network information (e.g., Wi-Fi, Bluetooth, LTE, 3G), IP address, and general location information such as city, state or geographic area that can be derived from your IP address.
Usage data, such as the website you visited before browsing to the Service, pages or screens you viewed and for how long, navigation paths between pages or screens, information about your activity on a page or screen, access times and duration of access, whether you have opened our emails or clicked links within them, and other functional information on Service performance (like diagnostics and crash logs).
Precise geolocation data. The GPS location of your device, when you grant access to it in your device’s settings. We use this information for the compliance and protection purposes described below.
Membership data, such as the membership number and QR code that we generate for you to access auctions.

We and our service providers may collect this type of information over time and across the Service and third party websites and online services.

Web technologies. We and our service providers use the following technologies to facilitate some of the automatic collection described above:

Cookies, which are text files that websites store on a visitor’s device to uniquely identify the visitor’s browser or to store information or settings in the browser for the purpose of tracking user activity and patterns, helping the visitor navigate between pages efficiently, remembering preferences and whether a visitor is logged in, and improving the visitor’s browsing experience. Some cookies store information only during a user session, others persist in your browser and collect data from multiple sessions. You can learn more about cookies and how to control them at www.allaboutcookies.org.
Pixels, also known as web beacons or clear GIFs. Pixels are embedded in software code or invisible as image files within webpages or HTML formatted emails and used to demonstrate that a webpage or email was accessed or opened, or that certain content was viewed or clicked, at a specific date and time using a particular device, typically to compile statistics about usage of websites and the success of marketing campaigns.
Software development kits, or SDKs, which are used to incorporate third party computer code into our mobile app that allows our third party service providers to collect data directly from one of our apps for a variety of purposes, including to provide us with analytics regarding use of our app, to integrate with social media, or add features or functionality to our app.

How we use your personal information

We use your personal information for the following purposes and as otherwise described in this Privacy Policy or at the time of collection:

To operate the Service. We use your personal information to provide, operate, and improve the Service, including to:

open and maintain your Service account
verify user identities and prevent fraud
enable Customers to verify auction participant identities and perform credit checks
process your payments
communicate with you about the Service, including by sending you announcements, updates, security alerts, and support and administrative messages
understand your needs and interests, and personalize your experience with the Service and our communications
provide support and maintenance for the Service
respond to your requests, questions and feedback

To operate our business. We use your personal information to operate and expand our business activities, which includes analyzing our performance, developing our workforce, and administering and maintaining our Service and IT systems.

For research and development. We may use your personal information for research and development purposes, including to analyze use of the Service, to improve the Service and to develop new products and services.

To send you marketing communications. We may use your personal information to send you marketing communications as permitted by law. You may opt-out of our marketing communications as described in the Opt out of marketing communications section below.

To comply with law. We may use and share your personal information as we believe necessary or appropriate to comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities.

For compliance, fraud prevention, and safety. We may use your personal information and disclose it to law enforcement, government authorities, and private parties as we believe necessary or appropriate to: (a) protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims); (b) audit our internal processes for compliance with legal and contractual requirements or our internal policies; (c) enforce the terms and conditions that govern the Service; and (d) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity, such as cyberattacks, identity theft, and unauthorized credential use and sharing.

With your consent. In some cases we may specifically ask for your consent to collect, use or share your personal information, such as when required by law.

To create aggregated, de-identified or anonymous data. We may create aggregated, de-identified or anonymous data from your personal information and other individuals whose personal information we collect. We make personal information into de-identified or anonymized data by removing information that makes the data personally identifiable to you. Where required by applicable law, we will maintain and use deidentified information in deidentified form and not attempt to reidentify it, except for purposes of testing to ensure that the information has been adequately deidentified. We may use this aggregated, de-identified, or otherwise anonymized data and share it with third parties for our lawful business purposes, including to analyze and improve the Service and promote our business.

How we share your personal information

We may share your personal information with the following categories of third parties and as otherwise described in this Privacy Policy or at the time of collection:

AuctionACCESS Customers. We share your personal information with other subscribing customers of the Service at which you or your dealership is registered to do business or to which you or any dealership you work for sends your AuctionACCESS number, such as businesses engaged in the automobile dealer or automobile auction industries, and other businesses providing goods or services to such industries (collectively, “Customers”) in accordance with your authorization. For example, we make this information (including information received from auto auction insurers) available to Customers so they can verify the identities of auction participants, perform credit checks on them, and maintain records of completed transactions .

Affiliates. We may share your personal information with our corporate parent, subsidiaries and other affiliates under the control of our corporate parent for purposes consistent with this Privacy Policy.

Service providers. We may share your personal information with third party companies and individuals that provide services on our behalf or help us operate the Service or our business (such as printing, mailing, customer support, hosting, analytics, email delivery, marketing, payment, order fulfillment, generative artificial intelligence, identity verification, and database management services). These third parties may use your personal information only as authorized under our contracts with them.

Identity verification providers. We may share your personal information withcompanies that help us verify your identity and AuctionACCESS credentials. These companies may extract biometric facial geometry from the live selfie and government-issued IDs that you upload, as well as other personal information, and analyze it to verify your identity and prevent fraud. These companies collect this biometric data directly from you and use and retain this biometric data and other personal information as described in their privacy policies. For example, you can review the Privacy Policy and Biometric Data Policy and Notice of Incode Technologies, Inc., one of the identity verification services we use, at https://www.incode.com/privacy-policy and https://www.incode.com/biometric-data-policy-and-notice, respectively.

Payment processors. We may share your personal information with third party payment processors that collect your payment and transaction information to process your payments for the Service. For example, we may accept payment card payments through Stripe. You can read Stripe’s privacy policy at https://stripe.com/privacy.

Professional advisors. We may disclose your personal information to professional advisors, such as lawyers, bankers, auditors and insurers, where necessary in the course of the professional services that they render to us.

Authorities and others. We may share your personal information with law enforcement, government authorities, and private parties, as we believe to be necessary or appropriate to comply with law or for compliance, fraud prevention and safety purposes, as described above in the section titled How we use your personal information.

Business transfers. We may sell, transfer or otherwise share some or all of our business or assets, including your personal information with parties (and their advisors), in connection with a business transaction (or negotiations of or due diligence for such potential business transaction) such as a corporate divestiture, merger, consolidation, acquisition, reorganization, sale or other disposition of all or any portion of the business or assets of, or equity interests in, AuctionACCESS or our affiliates (including in the event of bankruptcy or other similar dissolution proceedings).

Other parties with your consent or at your direction. We may share your personal information for other purposes to you at the time we collect the information pursuant to your consent or direction.

Your choices

California privacy rights. California residents can exercise privacy rights with respect to the personal information we process, as described in the Information for California residents section below.

Access or update your information. If you have registered for a Service account, you may review and update certain personal information in your account profile. If you identify an inaccuracy in your information or other records in the Services, or you need to make a change to your information, please update it via the Service or contact us at customerservice@auctionaccess.com or (205) 414-2739.

Opt out of marketing communications. You may opt out of marketing-related emails by following the opt out or unsubscribe instructions at the bottom of the email, or by contacting us at customerservice@auctionaccess.com You may continue to receive service-related and other non- marketing emails.

Cookies. Most browsers let you remove or reject cookies. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. Please note that if you set your browser to disable cookies, the Service may not work properly. For more information about cookies, including how to see what cookies have been set on your computer or mobile device and how to manage and delete them, visit www.allaboutcookies.org. You can learn more about Google Analytics, one of the analytics services we use, and how to opt-out of being tracked by Google Analytics here: https://tools.google.com/dlpage/gaoptout.

Pixels. Most browsers and devices allow you to configure your device to prevent pixel images from loading. To do this, follow the instructions in your browser or device settings.

Mobile location data. You can disable our access to your device’s precise geolocation in your mobile device settings.

Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.

Choosing not to share your personal information. Where we are required by law to collect your personal information, or where we need your personal information in order to provide the Service to you, if you do not provide this information when requested (or you later ask to delete it), we may not be able to provide you with our services. We will tell you what information you must provide to receive the Service.

Delete your account. You may request account deletion of your Service account and associated information by contacting us at privacyrequests@auctionaccess.com

The Service may contain links to other websites, mobile applications and other online services operated by third parties. These links are not an endorsement of, or representation that we are affiliated with, any third party. In addition, our content may be included on web pages or other online services that are not associated with us. We do not control third party websites, mobile applications or other online services operated by third parties, and we are not responsible for their actions. We encourage you to read the privacy policies of the other websites, mobile applications and online services you use.

Security and Retention

The security of your personal information is important to us. We employ a number of organizational, technical and physical safeguards designed to protect the personal information we collect. However, security risk is inherent in all internet and information technologies and we cannot guarantee the security of your personal information.

We retain personal information for as long as necessary to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish or defend legal claims, and to comply with law or for compliance, fraud prevention and safety purposes, as described above. Factors determining the appropriate retention period for personal information include the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of personal information, the purposes for which we process the personal information, whether we can achieve those purposes through other means, and the applicable legal requirements. When we no longer require the personal information we have collected about you, we will either delete or anonymize it (so that it is no longer personally identifiable with you)

International data transfers

We are headquartered in the United States, and we and our service providers may process personal information in the United States and in other countries. These countries may have data protection laws that are not as protective as those where you live.

Children

The Service is not intended for children under 18 years old, they should not use the Service, and we do not knowingly collect personal information from them. If we learn that we have collected personal information of a child under 18 without the consent of the child’s parent or guardian required by law, we will delete it.

Changes to this Privacy Policy

We may modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the effective date of this Privacy Policy and posting the modified Privacy Policy on the Service.

Any modifications to this Privacy Policy will be effective when posted (or as otherwise indicated at the time of posting). In all cases, your continued use of the Service after the posting of any modified Privacy Policy indicates your acceptance that the modified Privacy Policy applies to your use of the Service and interaction with our business.

Information for California residents

This section describes how we collect, use and disclose the personal information of California residents in our capacity as a “business” under the California Consumer Privacy Act (“CCPA”), and the rights that you have with respect to your personal information if you are a California resident. For purposes of this notice, “personal information” has the meaning given in the CCPA, but does not include information excluded from the scope of the CCPA.

YOUR CCPA RIGHTS

If you are a California resident, you have the following rights. However these rights are not absolute, and, in certain cases, we may decline your request as permitted by law.

Information. To request that we disclose the following information about our collection and use of your personal information during the past 12 months:
- The categories of personal information that we have collected.The categories of sources from which we collected the personal information.The categories of external parties with whom we share the personal information.The categories of personal information that we sold or disclosed for a business purpose.The categories of external parties to whom the personal information was sold or disclosed for a business purpose.
- The business or commercial purpose for collecting, sharing and/or selling Personal Information.
Access. To request a copy of the personal information that we have collected about you during the past 12 months.
Deletion. To request that we delete personal information about you that we have collected from you.
Correction. To request that we correct inaccurate personal information that we have collected about you.
Opt-out.
- “Selling” or “sharing” of personal information. You can opt-out of the “sharing” of your personal information for interest-based advertising purposes and/or from the “sale” of your personal information for monetary or other valuable consideration (as applicable). We do not “sell” or “share” your personal information as those terms are defined in the CCPA.
- Use of “automated decisionmaking technologies.” You can request to opt-out of “automated decisionmaking technologies,” as defined by the CCPA, that are used to make significant decisions. We do not use automated decisionmaking technologies as that term is defined in the CCPA in a manner subject to the right to opt out under the CCPA.
Sensitive personal information. We do not process sensitive personal information for the purpose of inferring characteristics about consumers under the CCPA.
Nondiscrimination. To exercise your rights described above free from discrimination or retaliation as prohibited by the CCPA.

You may exercise the information, access, correction and deletion rights described above by:

calling us at (205) 414-2739
emailing privacyrequests@auctionaccess.com

Identity Verification. You may be required to submit information sufficient in our reasonable discretion for us to verify your identity so we can process your requests to exercise your rights to know, access, deletion, and correction, and we reserve the right to confirm your California residency. To verify your identity, we may require you to provide personal identifiers we can match against information we may have previously collected from you, confirm your request using contact details used to make the request, provide government-issued identification, or provide a declaration under penalty of perjury, where permitted by law

Authorized agents. If you are submitting a request as an authorized agent of another person, you may be required to take additional steps permitted by law based on the nature of your request to verify that your request is authorized.

Consumers under 16. We do not have actual knowledge that we “sell” or “share” the personal information of consumers under 16 years of age.

PERSONAL INFORMATION THAT WE COLLECT, USE AND DISCLOSE

The chart below summarizes the personal information we collect and may disclose to external parties by reference below to both the categories defined in the Personal information we collect section of this Privacy Policy above and the categories of personal information specified in the CCPA. This describes our current practices and during the 12 months preceding the last update of this Privacy Policy. Information you voluntarily provide to us, such as in free-form webforms, may contain other categories of personal information not described below. We may also disclose personal information to professional advisors, law enforcement and government authorities, and business transferees, as described above in the How we share your personal information section.

Personal information we collect	CCPA statutory category	Categories of external parties to whom we may “disclose” personal information for a business purpose
Registration information	– Identifiers – California customer records – Commercial information – Professional information	– AuctionACCESS Customers – Affiliates – Service providers – Identity verification providers
Biometric data	– Biometric Information	– Service providers – Identity verification providers
Account information	– Identifiers- – California customer records – Commercial information – Professional information	– AuctionACCESS Customers – Affiliates – Service providers
Vehicle remarketing activity	– Identifiers – California customer records – Professional information	– AuctionACCESS Customers – Affiliates – Service providers
Feedback or correspondence	– Identifiers – Commercial information – California consumer records – Professional information	– Affiliates – Service providers
Payment and transaction information	– Identifiers – Commercial information – California customer records	– Affiliates – Service providers – Payment processors
Service interaction information	– Identifiers – California customer records – Commercial information – Professional information	– AuctionACCESS Customers – Affiliates – Service providers
Marketing information	– Identifiers – Commercial information – California customer records – Internet or network information	– Affiliates – Service providers
Device data	– Identifiers – California consumer records – Internet or network information	– Affiliates – Service providers – Identity verification providers
Usage data	– Identifiers – Commercial information – Internet or network information	– Affiliates – Service providers – Identity verification providers
Precise geolocation data	– Geolocation data	– Affiliates – Service providers
Membership data	– Identifiers – California consumer records	– Affiliates – Service providers
Data derived from the above	– Inferences	– Affiliates – Service providers – Identity verification providers
Sensitive personal information Account informationPrecise geolocation dataBiometric dataPayment and transaction information		– AuctionACCESS Customers – Affiliates – Service providers – Identity verification providers – Payment processors

As described above in Personal Information We Collect, we collect this personal information from you, our corporate affiliates, business partners, other Customers, information services, auction insurers, consumer reporting agencies, our business contacts, and publicly available sources. In addition, as described above in How We Use Your Personal Information, we may use this Personal Information to operate the Service and our business, for research and development, to send marketing communications, to comply with law, for compliance, fraud prevention and safety, with your consent, and to create aggregated, de-identified or anonymous data.