Privacy and Security

Posted: December 30, 2019

Effective: January 1, 2020

What This Privacy Policy Covers

This privacy policy covers the use of the web site located at https://www.goldbelly.com and the services provided by Goldbely, Inc. ("Goldbelly"), including how treats personal information that Goldbelly collects and receives. Pursuant to Goldbelly's Terms of Use, you must be 18 years and older to use this site or have permission from a legal guardian. Therefore, this policy makes no provision for individuals under 18 years old. This policy does not apply to the practices of third parties that Goldbelly does not own or control, or individuals that Goldbelly does not employ or manage. This policy is effective on January 1, 2012.

Information Collection and How it is Used General Information: Goldbelly will not sell or disclose your name or email address to third parties without your explicit consent, except as specified in this privacy policy. Goldbelly collects personal information when you register to use Goldbelly services or to post content on Goldbelly. At registration you are asked for your email address and possibly other optional information. If you would like to obtain a Seller account, Goldbelly will ask for your business address, phone number, and payment information. Goldbelly automatically receives and records information on our server logs from your browser, including your IP address, cookies, and the pages you request. Goldbelly uses information for the following general purposes: products and services provisioning, billing, identification and authentication, services improvement, contact, research, and anonymous reporting. IP addresses are automatically reported by your browser each time you view a web page. Your IP address is stored in Goldbelly's user registration databases when you register with Goldbelly. IP addresses may be used for various research purposes, and/or delivering unique functionality in the Goldbelly Marketplace.

Service Announcements

Goldbelly will send you a welcome email when you sign up for Goldbelly's services. Goldbelly will send you service announcements on occasions when it is necessary to do so.

You may not opt-out of service-related communications, which are not promotional in nature. If you do not wish to receive them, you have the option to deactivate your account by emailing support@goldbelly.com from the email address you signed up with.

Administrative Messages

Goldbelly may periodically email you with administrative messages. Goldbelly will not sell or rent your personal information to third parties for their marketing purposes without your explicit consent. Your information may be combined with information Goldbelly collects from other companies and used to improve and personalize services, content and advertising. If you don't wish to receive administrative messages or participate in these programs, simply opt-out by emailing support@goldbelly.com.

Choice/Opt-out

If you no longer wish to receive administrative messages, you may opt-out by emailing support@goldbelly.com. Please note that if you do not wish to receive administrative messages from us, those notices will still govern your use of the Goldbelly website and service, and you are responsible for reviewing such notices for changes.

Password: Keep your password secure. You are fully responsible for all activity, liability and damage resulting from your failure to maintain password confidentiality. You agree to immediately notify Goldbelly of any unauthorized use of your password or any breach of security. You also agree that Goldbelly cannot and will not be liable for any loss or damage arising from your failure to keep your password secure.

Account Information: You must keep your account information up-to-date and accurate at all times, including a valid email address.

Account Transfer: You may not transfer or sell your Goldbelly account and User ID to another party. If you are registering as a business entity, you personally guarantee that you have the authority to bind the entity to this Agreement.

Newsletter Emails

Goldbelly users are offered subscriptions to Goldbelly email newsletters. To opt-in, Goldbelly will ask for your email address. This email address will only be used for this feature. You may change your subscription or unsubscribe at any time by following the instructions contained in the email.

Friend Features

"Share with a Friend" allows members to share information about a seller or a specific item listed on Goldbelly by sending a personalized email message. If you choose to use Goldbelly's "Share with a Friend" feature, Goldbelly will ask for the information needed to send the message, such as your friend's email address. Goldbelly will then automatically send your friend an email, inviting your friend to visit the site. Goldbelly does not store "Share with a Friend" information on our servers.

Cookies

A cookie is a small amount of data, which often includes an anonymous unique identifier, that is sent to your browser from a web site's computers and stored on your computer's hard drive. You can configure your browser to accept all cookies, reject all cookies, or notify you when a cookie is set. If you reject all cookies, you may not be able to take full advantage of the Goldbelly service. Goldbelly uses its own cookies for a number of purposes, including to: Access your information when you "sign in"; keep track of preferences you specify while you are using Goldbelly's services; display local product offerings; estimate and report Goldbelly's total audience size and traffic; conduct research to improve Goldbelly's content and services. Goldbelly cookies do not collect personal information, and Goldbelly does not combine information collected through cookies with other personal information to tell us who you are or what your username or email address is.

Information Sharing and Disclosure

When you post a message, your Goldbelly ID or alias is visible to other users. If you post personal information online that is accessible to the public, you may receive unsolicited messages from other parties in return. Goldbelly may be required to disclose personally identifiable information under special circumstances, such as to comply with subpoenas or when your actions violate the Goldbelly Terms of Use. Goldbelly may disclose personally identifiable information to parties in compliance with Goldbelly's Copyright and Intellectual Property Policy, as Goldbelly in Goldbelly's sole discretion believes necessary or appropriate in connection with an investigation of fraud, intellectual property infringement, piracy, or other unlawful activity. In such events, Goldbelly may disclose name, street address, city, state, zip code, country, phone number, email address and company name. Goldbelly may share aggregated demographic information with business partners.

Goldbelly is affiliated with a variety of businesses and works closely with them. These businesses may operate stores on the Goldbelly website or sell items to you from the Goldbelly website. Goldbelly may also provide services or sell products jointly with affiliated businesses. Due to the nature of Goldbelly's business model, when an affiliated business is associated with your transaction, you will share customer information that is related to such transaction with that affiliated business.

Goldbelly employs other companies and people to perform tasks on our behalf and needs to share your information with them to provide products and services to you. Examples include but are not limited to fulfilling orders, handling billing disputes, analyzing data, providing marketing assistance and providing customer service.

Goldbelly will not rent, sell, or share personal information about you with nonaffiliated parties except as specified in this Privacy Policy to provide products or services you have requested or when Goldbelly has your permission. It may be necessary to share information in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of Goldbelly's Terms of Use, as specified in this Privacy Policy or as otherwise required by law. In some cases, Goldbelly may choose to buy or sell assets. In these types of transactions, customer information is typically one of the business assets that is transferred. Goldbelly will transfer information about you if Goldbelly is acquired by or merged with another company. In this event, Goldbelly will notify you by email or by putting a prominent notice on the Goldbelly web site before information about you is transferred and becomes subject to a different privacy policy.

As part of the buying and selling process, you may obtain another Goldbelly user's email address, shipping address and/or other information. Pursuant to Goldbelly's Terms of Use, you have a limited license to use this information. This information should only be used for Goldbelly-related communications or for Goldbelly-facilitated transactions. Goldbelly has not granted you a license to use the information for unsolicited commercial messages. Without limiting the foregoing, without express consent from the user, you are not licensed to add any Goldbelly user to your email or physical mail list.

Third Parties

Except as otherwise expressly included in this Privacy Policy, this document addresses only the use and disclosure of information Goldbelly collects from you. If you disclose your information to others, whether they are buyers or sellers on Goldbelly or throughout the internet, different rules may apply to their use or disclosure of the information you disclose to them. Goldbelly does not control the privacy policies of third parties, and you are subject to the privacy policies of those third parties where applicable. Goldbelly is not responsible for the privacy or security practices of other websites on the Internet, even those linked to or from the Goldbelly site. Goldbelly encourages you to ask questions before you disclose your personal information to others.

Personal Information we collect (and why)

User Data

This is the personal data that is provided by you or collected by us to enable you to sign up for and use the Goldbelly service. This may include your username, email address, phone number, birth date, street address, and country.

Some of the personal data we will ask you to provide is required in order to create your account. You may also have the option to provide us with additional personal data in order to make your account more personalized.

Usage Data

This is the personal data that is collected about you when you’re accessing and/or using the Goldbelly service, including:

Information about your interactions with the Goldbelly service such as your search queries (including the date and time of any requests you make), purchase history, and your product browsing history. It can also be inferences drawn about your interests and preferences based on your usage of the Goldbelly service.

Certain technical data, which may include:

• URL information;
• online identifiers including cookie data and IP addresses;
• information about the types of devices you are using such as network connection type (e.g. wifi, 3G, LTE), provider, network and device performance, browser type, language, and operating system;
• your non-precise location, which may be derived or inferred from certain technical data (e.g., your IP address, language setting of your device, or payment currency), to monitor for unusual/suspicious account activity, and deliver personalized content and advertising to you.

Payment and Purchase Data

We may collect certain personal data if you make a purchase through the Goldbelly service. The exact personal data collected will vary depending on the payment method (e.g. credit card or PayPal) but will include information such as:

• Name;
• Date of birth;
• Credit or debit card type, expiration date, and certain digits of your card number;
• Postal code;
• Mailing address;
• Mobile phone number; and
• Details of your purchase and payment history.

Third Party Sources

Authentication partners: If you register for or log into our services using third party credentials (e.g. Facebook), we will import your information from such third party to help create your account with us.

Technical service partners: We work with technical service partners that provide us with certain data, such as mapping IP addresses to non-precise location data (e.g., city, state), to enable us to provide the Goldbelly service, content, and features.

Payment partners: If you choose to pay for a service or feature by invoice, we may receive data from our payment partners to enable us to send you invoices, process your payment and provide you with what you’ve purchased.

Advertisers and other advertising partners: We may obtain certain data about you, such as cookie id, mobile device id, or email address, and inferences about your interests and preferences from certain advertisers and advertising partners that allow us to deliver more relevant ads and measure their effectiveness.

What we use Personal Information for

• To provide and personalize the Goldbelly service.
• To understand, diagnose, troubleshoot, and fix issues for the Goldbelly service.
• To evaluate and develop new features, technologies, and improvements to the Goldbelly service.
• To comply with legal obligations and law enforcement requests.
• To conduct business planning, reporting, and forecasting.
• To process your payment.
• To detect fraud, including fraudulent payments and fraudulent use of the Goldbelly service.
• To conduct research, contests, surveys, and sweepstakes.

Requesting, Editing, and Deleting Account and Personal Information

You can change your Goldbelly Account Information (except your username), at any time. Goldbelly may send you certain communications relating to the Goldbelly service, such as service announcements and administrative messages that are considered part of your Goldbelly account.

Goldbelly limits access to personal information about you to employees who Goldbelly believes reasonably need to come into contact with that information to provide products or services to you or in order to do their jobs. Your Goldbelly Account Information is password-protected.

If your personally identifiable information changes you may correct or update it by making the change on your Goldbelly account page. You may delete or deactivate your account by emailing Customer Support at account_removal@goldbelly.com. For your security, you must send the account deletion request from the same email address that you use to log into your account. Goldbelly will respond to your request within 10-20 business days. Please note that your identification, billing and contact information may remain in Goldbelly's records for some period.

Security

The security of your personal information is important to us. Your Goldbelly account information is protected by a password for your privacy and security. You need to work to protect against unauthorized access to your password and to your computer by signing off once you have finished using a shared computer. When you enter sensitive information (such as credit card number) for registration Goldbelly encrypts that information using Transport Layer Security technology (TLS). Goldbelly follows generally accepted industry standards to protect the personal information submitted to us, both during transmission and once Goldbelly receives it. No method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, while Goldbelly strives to use commercially acceptable means to protect your personal information, Goldbelly cannot guarantee its absolute security. If you have any questions about security on Goldbelly's Web site, you can email Goldbelly at account_removal@goldbelly.com.

Changes to this Privacy Policy

If this privacy policy is changed, Goldbelly will post changes so that you are aware of those changes. Goldbelly reserves the right to modify this privacy statement at any time, so please review it frequently. If Goldbelly makes material changes to this policy you will be notified here, by email, or other places Goldbelly deems appropriate.

Questions

If you have questions or suggestions you can submit them to support@goldbelly.com or by postal mail to Goldbelly Attn: Customer Support; 27 Union Sq W Ste 500, New York, NY 10003