Privacy Policy

Last Updated: April 1, 2021

This Privacy Policy (“Policy”) of Auctane d/b/a Adber ("Adber") describes in greater detail the privacy practices of Adber and its corporate affiliates, meaning companies related by common ownership or control (“us,” “we,” “our”) responsible for collecting and maintaining certain information collected about you.

If you have questions or complaints regarding our Privacy Policy or practices, please contact us as detailed under the How to Contact Us heading below.

We take the privacy of our Customers and their downstream customers very seriously. We never share the information of our Customer’s customers under any circumstances, unless it is required to complete the transaction contracted with our Customer. In addition, we require our Customers, where applicable, to undertake to respect the European Union General Data Protection Regulation.

1. WHEN THIS PRIVACY POLICY APPLIES.

This Policy applies to our sites, products, and services (collectively, "Services") that link to this Policy. Adber is the controller of all Personal Information subject to this Policy for our Services. If a Service you use links to this Privacy Policy, this Policy applies to you.

2. WHAT WE DO WITH YOUR INFORMATION.

We want to be clear about what information we collect and how we use it to deliver our Services to you, operate our business, and make our Services work better for you. This Privacy Policy describes how we collect, use, share and secure the information that you provide which can be used to identify you and that is shared with us (“Personal Information”). It also describes your choices regarding use, access and correction of your Personal Information. We do not sell or share your Personal Information with third parties for their own commercial uses, if you have opted out of such sharing.

a) Types of Information We Collect. In connection with access to our Services, we may collect Personal Information, such as your name, shipping/billing address, email address, phone, credit card/bank account number, username and password.

We collect or otherwise receive information when you register or open an account, sign in, pay fees, purchase or otherwise use a Service, call us for support, or give us feedback. We may also obtain information from other companies or third parties, such as when you synchronize a third party account or service with your Adber Account, or when we may use service providers to supplement the Personal Information you give us (e.g., validate your mailing address) to help us maintain the accuracy of your data and provide you with better service. We may collect content or other information that you may provide or create when you interact with our Services.

We may automatically collect certain usage information when you access our Services ("Usage Data"), such as Internet Protocol (“IP”) addresses, log files, unique device identifiers, pages viewed, browser type, any links you click on to leave or interact with our Services, and other usage information collected from cookies and other tracking technologies. For example, we may collect IP addresses to track and aggregate retained in pseudonym form (replacing any directly identifying characteristics of personal information, to monitor the locations from which users navigate to our Services. We may also collect IP addresses from users when they log into the Services as part of our log-in and security features. We may also, when you enable location-based Services, collect Global Positioning System (GPS) location data and/or motion data.

Our Services may change over time and we may introduce new features that may collect new or different types of information.

b) How We Use Your Information. We may use your information, including your Personal Information, for the following purposes:

Account Registration. We may use your name, address, phone number, billing information, and email address to register your account for certain Services we provide and to communicate important information to you. We may obtain additional Personal Information about you, such as address change information, from commercially available sources, to keep our records current. If you establish an administrator account that may be accessed by people other than you, please note that they may see and have the ability to change or delete your Personal Information. Please be careful to whom you grant administrator access to, as you are responsible for their actions.

To Provide Our Services and Operate Our Business. We may use your information to operate our business, including providing Services you requested, provide you with support related to our Services, and to help us protect our Services, including to combat fraud and protect your information.

Customer Service and Technical Support. We may use your name, address, phone number, email address, how you interact with our Services, and information about your computer configuration to resolve questions you may have about our Services and to follow up with you about your experience. We also offer various Internet chat services, for example, to speak with a Adber customer support representative. Internet Chat transmissions are encrypted, but you should not supply more Personal Information than is required to address your specific issue. A transcript of the session may be retained to resolve questions or issues related to our Services.

Communicate with You and Tell You About Other Services. We may use your information to communicate with you about our Services and to give you offers for third party products and services that we think may be of use to you. Please see below under "What You Can Do to Manage Your Privacy" for the choices you have regarding these communications.

To Improve Services and Develop New Services. We will use your information to personalize or customize your experience and the Service, develop new features or services, and to improve the overall quality of Adber's Services.

Feedback. We may use any information you volunteer in surveys you answer for us and combine them with answers from other customers in order to better understand our Services and how we may improve them. Answering any survey is optional.

c) How We Share Your Personal Information. From time to time, we may need to share your Personal Information with others.

Third Party Service Providers. We may share your information, including Personal Information and Usage Data, with third party service providers who perform various functions to enable us to provide our Services and help us operate our business, such as website design, sending email communications, telephone communication, SMS (text messaging), advertising, fraud detection and prevention, customer care, third party surveys or performing analytics. These companies are authorized to use your personal information only as necessary to provide these services to us. Our contracts with these third parties require them to maintain the confidentiality of the Personal Information we provide to them, only act on our behalf and under our instructions, and not use Personal Information for purposes other than the product or service they're providing to us or on our behalf.

United States Postal Service (USPS). Adber is regulated by the USPS. As part of the regulatory relationship, Adber collects certain information about you on behalf of the USPS. The USPS also may send us tracking data from their scans of your mail and packages in the mailstream. Our uses for the data include informing you about the status of your mail and packages through options like USPS Tracking, fraud detection and aggregating the data to help the USPS and us provide you better service. To learn more about USPS postage technology and Adber’s relationship with the USPS, please visit the USPS Postage Solutions page. Information collected on behalf of USPS is used for the regulatory oversight function of USPS and is not used for other purposes.

As part of Adber providing services of the USPS, the USPS requires that you agree to the USPS Privacy Act Statement and to provide information about yourself that will be maintained in a Privacy Act System of Records by the Postal Service. Privacy Act Statement: Your information will be used to facilitate the purchase of USPS postage and fulfill transactional reporting requirements for USPS postage systems. Collection is authorized by 39 U.S.C. 401, 403, and 404. Providing the information is voluntary, but if not provided, your transaction may not be processed. The Postal Service does not disclose your information to third parties without your consent, except to facilitate the transaction, to act on your behalf or request, or as legally required. This includes the following limited circumstances: to a congressional office on your behalf; to financial entities regarding financial transaction issues; to a US Postal Service (USPS) auditor; to entities, including law enforcement, as required by law or in legal proceedings; and to contractors and other entities aiding us to fulfill the Service (service providers). For more information regarding our privacy policies, visit www.usps.com/privacypolicy.

For more information regarding other specific carriers you may use via our Services, please see the privacy policies provided by each specific carrier you select.

Use of carrier services via our platform is at your own risk. We are not responsible for your use of carrier services. Your use of carrier services is as a direct customer of the specific carrier of your choosing and you agree to be bound by the terms and conditions of that carrier for use of services. By providing information to certain carrier services, you understand and consent to the collection, use, processing disclosure and transfer of such information and which they may have different data protection practices. Your interactions with these service carriers are governed by each carrier’s privacy policy.

Response to Subpoenas and Other Legal Requests. We may share your information with courts, law enforcement agencies, or other government bodies when we have a good faith belief that we are required or permitted to do so by law, including to meet national security or law enforcement requirements, to protect our company, or to respond to a court order, subpoena, search warrant, or other law enforcement request. Please see our obligations as they relate to European Union data subjects, in our Privacy Shield certification (discussed below).

Protection of Adber and Others. We may share account information, Personal Information and Usage Data when we believe it is appropriate to enforce or apply our products' Terms of Service and other agreements; or protect the rights, property, or safety of Adber, our Services, our users, or others. For example, this includes exchanging information with other companies and organizations for fraud protection and credit risk reduction. This does not include selling, renting, sharing, or otherwise disclosing Personal Information of our customers for commercial purposes in violation of the commitments set forth in this Privacy Policy.

Information Sharing Between Adber Entities. We share your information, including your Personal Information, with and among our subsidiaries, except where prohibited by law. Subsidiaries means companies related by common ownership or control. The reasons why we share your information include for our everyday business purposes, such as to: process your transactions, maintain your accounts, operate our business, etc. We may also share information about your transactions and experience so that we can operate our business effectively, detect and prevent fraud, and improve our Services.

Sharing with Third Parties Generally. Adber may share certain information with carefully selected third parties that will allow them to mail you promotional materials about quality goods and services (including special offers and promotions) that may be of interest to you. The information shared will not include your e-mail address; your phone number; any information related to your postage, mailing activity or postage meter license; or any information related to your customers or address lists. You may contact Adber at any time to request that your information not be shared with such third parties, or when you register with Adber, or by accessing the opt-out link in any email communication from Adber or by clicking here.

Information about European Union data subjects will not be shared unless they have opted-in to such sharing.

Sale of Our Business. If we sell, merge, or transfer any part of our business, we may be required to share your information. If so, you will be asked if you wish to stop receiving promotional information following any change of control.

With your Consent. Other than as set out above, we will provide you with notice and the opportunity to choose when your Personal Information may be shared with other third parties.

d) Syncing, Linking, Connecting Other Third Party Services with Your Adber Service.

We work with other companies or developers to offer you products and services and you may choose to sync, link or connect other third party services with your Adber Service. Sometimes Adber may let you know about the service or product, or another company may let you know about a Adber service or product. If you choose to accept these services, providing your consent to either the third party or to us, we may exchange your information, including your Personal Information, as well as information about how you interact with each provider’s service or product. This exchange of information is necessary to maintain business operations and to provide the ongoing service that you have requested. By requesting or accepting these products or services, you are permitting us to provide your information, including your Personal Information, to the other party. Prior consent from European Union data subjects would be required prior to offering any information discussed in this section.

3. WHAT YOU CAN DO TO MANAGE YOUR PRIVACY.

You can view and edit information that identifies you online through your Adber Service. How you can access and control information that identifies you will depend on which Services you use. You have a choice about the use of information that identifies you, marketing communications you receive from us, and our use of cookies and other tracking technologies.

a) Updating Your Personal Information. In connection with your right to manage your Personal Information you provide to us, you may access, update, change, correct or request deletion of your information either through the Service or through our customer support. You can reach our customer support by using the contact information provided in the "How to Contact Us" section of this Policy. We will respond to your request within a reasonable timeframe.

b) Managing Marketing Communications From Us. We will honor your choices when it comes to receiving marketing communications from us.

You have the following choices if you have been receiving marketing communications from us that you no longer wish to receive:

• You may contact Adber at any time to request that your information not be shared with third parties (other than the USPS) or set preferences when you register with Adber.

• Access the opt-out link in any email communication from Adber or by clicking here.

• Remember that even if you choose not to receive marketing communications from us, we will continue to send you mandatory service or transactional communications.

European Union data subjects will only receive marketing communications from Adber or Third Parties, if they affirmatively opt-in to such communication, upon initiating service or at another time.

c) Cookies and Other Tracking Technologies. Generally we use these tracking technologies to:

• Fulfill your requests for products and services, and improve our services.

• Remind us of who you are on return visits in order to deliver to you a better and more personalized service. This cookie is set when you first visit the Adber Site.

• Estimate our audience size and measure traffic patterns regarding usage of Adber’s network of Sites. Each browser accessing Adber is given a unique cookie which is then used to determine the extent of repeat usage and usage by a registered user versus by an unregistered user.

• Track the number of entries in our promotions.

• Customize the advertising and content you see.

If you are uncomfortable having a cookie placed on your system, you may elect to turn off the cookie or delete existing cookies in your browser. If you turn off or delete the Adber cookie, you may not be able to receive special offers or personalized content from Adber.

Technologies such as cookies, or similar technologies, are used by Adber and our partners (e.g. network advertising partners), affiliates, or analytics or service providers (e.g. online customer support providers). These technologies are used in analyzing trends, administering the site, tracking user movements around the site and to gather 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 as well as aggregated basis.

Please note that even if you opt-out of such Cookies or otherwise opt-out of interest based advertising, you will still receive advertisements, they just will not be tailored to your interests. Also, if you opt-out and later delete your Cookies, use a different browser, or buy a new computer, you may need to renew your opt-out choices.

d) Social Media Features. Our Services may use social media features, such as Facebook sharing ("Social Media Features"). These features may collect your IP address and which page you are visiting within our Service, and may set a cookie to enable the feature to function properly. Social Media Features are either hosted by a third party or hosted directly on our Services. Your interactions with these features are governed by the privacy policy of the company providing the relevant Social Media Features.

4. DATA RETENTION AND YOUR ACCESS RIGHTS

a) Data Retention. In accordance with and as permitted by applicable law and regulations, we will retain your information as long as necessary to serve you, to maintain your account for as long as your account is active, or as otherwise needed to operate our business. When you close your account, we may continue to communicate with you about our Services, give you important business updates that may affect you, and let you know about products and services that may interest you, unless you have opted out of receiving marketing communications. We may also continue to use some of your information for business purposes and to improve our offerings or in some cases to develop new ones. We will retain and use your information as required by applicable regulations and Adber's records and information management policies to comply with our legal and reporting obligations, resolve disputes, enforce our agreements, complete any outstanding transactions and for the detection and prevention of fraud.

b) Your Access Rights. Upon request and as required by applicable law, you may contact Adber to confirm whether we maintain, or process on behalf of a third party, and of your Personal Information and to review it in order to verify its accuracy and the lawfulness of our processing of such Personal Information. Where you have determined that the Personal Information we collected about you is inaccurate or processed in violation of applicable law you may also request that your Personal Information be corrected, amended, or deleted. Requests for access to your Personal Information and to have it corrected, amended, or deleted should be sent to [email protected] or to the mailing address provided under "How to Contact Us."

EU data subjects have certain rights to access Personal Information about them, and to limit use and disclosure of their Personal Information. With our Privacy Shield certification (discussed below in Section 7), Adber has committed to respect those rights. If you wish to request access, to limit use, or to limit disclosure, please contact us at privacy@Adber.com or the mailing address provided under "How to Contact Us" and please provide the name of the Adber customer who submitted your Personal Information to our services.

5. SECURITY OF YOUR INFORMATION.

Keeping your Information safe is important to us. You can find out more about keeping your personal information safe while on line from the U.S. government here. We provide reasonable and appropriate security measures in connection with securing Personal Information we collect. Though no method of transmission over the Internet, or method of electronic storage, is 100% secure.

For example, we:

• Consistently work to update our security practices to implement accepted best methods to protect your Personal Information, and review our security procedures carefully.

• Comply with applicable laws and security standards.

• Securely transmit your sensitive Personal Information.

• Train our staff and require them to safeguard your data. Limit the staff with access to your Personal Information.

• Transmit, store, protect, and access all cardholder information in compliance with the Payment Card Industry's Data Security Standards.

6. INTERNATIONAL DATA TRANSFERS.

In accordance with and as permitted by applicable law and regulations, we reserve the right to transfer your information, process and store it outside your country of residence to wherever we or our third party service providers operate. At this time United States person’s data shall be stored and kept within the United States. European Union data subjects may have their data stored in the European Union or the United States, and such data may be transferred to the United States to allow for completion of the Services required. All data stored and transferred would be done so subject to the E.U. – U.S. Privacy Shield Framework.

7. HOW TO CONTACT US.

If you have questions or comments about this Privacy Policy, please contact us. We want your feedback and comments.

a) Via Email. If you have questions or complaints regarding our Privacy Policy or practices, please contact us by email at support@Adber.com.

8. CHANGES TO OUR PRIVACY POLICY.

From time to time we may change or update our Privacy Policy. We reserve the right to make changes or updates at any time. More information about how we will notify you is below.

If we make material changes to the way we process your Personal Information, we will provide you notice via our Service or by other communication channels, such as by email or posting on our Site prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices. Please review any changes carefully. If you object to any of the changes and no longer wish to use our Services, you may close your account(s). All changes are effective immediately upon posting and your use of our Service after a notice of material change or posting of an updated Privacy Policy shall constitute your consent to all changes.