Privacy Policy

SB Media USA Inc. Digital Automotive Marketplace – Privacy Policy

Last updated: 27 March, 2024

SB Media USA Inc. Digital Automotive Marketplace (“we”, “our”, “us”) is committed to protecting and respecting your privacy. We are a Delaware corporation with a registered office at 1531 14th Street Santa Monica, CA 90404, United States and registered company number 7426907, and for the purpose of applicable data protection laws, we are the data controller. Our representative in the European Economic Area and the UK is DataRep, who can be contacted at [email protected] or https://www.datarep.com/data-request/

This Privacy Policy sets out the basis on which we will process any personal data or usage information we collect from you, or that you provide to us, in connection with your use of our website at www.sbxcars.com (our “Website”) and any content, tools, features and functionality offered on or through our Website (collectively referred to as the “Services”).

Please read this Privacy Policy carefully so that you understand your rights in relation to your personal data, and how we will collect, use and process your personal data. This Privacy Policy supplements any other privacy related notices and policies we may provide to you from time to time, and is not intended to override them. If you do not agree with this Privacy Policy in general or any part of it, you should not access the Website, use our Services or otherwise provide your information to us.

Our Services are not intended for children under the age of 18, and we do not seek or knowingly collect data relating to children. If we become aware that we have unknowingly collected information about a child, in particular any child under 13 years of age, we will make commercially reasonable efforts to delete such information. If you are the parent or guardian of a child under 13 years of age who has provided us with their personal information, you may contact us using the below information to request that it be deleted.

1. CHANGES TO THIS PRIVACY notice

We change our Privacy Policy from time to time, in which case we will update the “Last updated” date and take any other steps required by applicable law. Please check the Website regularly for notices of changes to our Privacy Policy. If you do not agree with updates to this Privacy Policy, please do not access or continue to use the Services.

2. THE PERSONAL DATA WE COLLECT

Information you give to us or our processors

You may provide some or all of the following personal data to us or our processors when you create an account, use our Services or contact us via our Website, our Services or by telephone, email, social media, our “contact us” form on our Website, or otherwise: your full name, phone number, address, email address, password, government identification, profile photo, vehicle title and registration documents, vehicle information (vehicle identification number, specification, description, location, photos), payment card information, value added tax number, employer identification number, business name, content you create on our Website (such as comments you upload), and Website notification settings. This information is required to enable us to fulfill our contract with you. If you do not provide this information, we will not be able to provide you with our Services.

To the extent that you create or post content to the Website or Services, we or others may store, display, reproduce, publish or otherwise use such content, and may or may not attribute it to you. Others may also have access to such content and have the ability to share it with third parties. If you choose to submit content to any public area of the Services, your content will be considered “public” and will be accessible by anyone.

Information we collect automatically

When you visit our Website and use our Services we may automatically collect information sent to us by your computer, mobile phone or other device including through cookies. This information includes: your IP address, device information (including name and type of operating system), mobile network information, standard web information such as your browser type and the pages you access on our Website, transaction information (including device information, transaction details, and IP address, but not payment card or account details), and security information (including a list of certain installed software, device and internet connection information, and available space on the device).

Information we collect from third parties

We may obtain information about you from outside sources, including information that we collect directly from third parties and information from third parties that you choose to share with us. This includes vehicle information in relation to a vehicle you list on our Website from our vehicle identification search provider, Carfax, and details regarding your government identification documents from our identification verification provider, Yoti.

3. HOW we use your PERSONAL INFORMATION

provide you with our Services, other content and Website functionality;
register and maintain your account with us;
display any comments or photos you upload under the comments section of our Website;
display your profile picture;
run a search of any vehicle identification number provided to us;
customize your user experience based on your preferences; and
display vehicle information you provide.

sign you up for our newsletters or alerts;
personalize our services for you;
send you text messages, if you opted into receiving text message updates on auctions; and
communicate with you about products, services, marketing, promotions, events and other news and information we think will be of interest to you, including by email, telephone and text message.

administer the Website and Services, and for internal operations, in order to conduct troubleshooting, data analysis, testing, research, statistical and survey analysis;
maintain the safety and security of our users, the Website, our Services and business;
send you announcements in relation to security, privacy or administrative and technology support related communications (these communications are not marketing orientated, and we do not rely on consent, so you may not opt out);
personalize our Website and our Services to ensure content is presented in the most effective manner for you and your device;
send you user experience surveys; and
improve and develop our products.

In addition, we will use some or all of the above information to comply with any applicable legal obligations, to enforce any applicable terms and conditions and/or terms of service, and to protect or defend the Services, our rights, the rights of our users, or others.

4. COOKIES

We use cookies and other similar technologies to collect information about your browsing activities over time and across different websites following your use of our Services. Cookies are used for fraud prevention, to allow us to recognize returning Website users across sessions, and analyze how long users spend on our Website. This helps us to improve our Services and the way our Website works. You can find more information about cookies and how to manage them here.

For more information, please refer to our Cookies Policy https://sbxcars.com/cookie-declaration

Your browser settings may allow you to transmit a “do not track” signal or other mechanism for exercising your choice regarding the collection of your information when you visit various websites. Like many websites, our Website is not designed to respond to such signals.

5. HOW WE SHARE YOUR personal data

With service providers and vendors. Such third parties include security vendors, payment processors, CRM providers, email communication providers and website hosting and data storage vendors. These third parties assist us with many different functions and tasks in connection with the Services, such as providing data storage and communicating with you.
When you request us to share certain information with third parties, with consent or to perform a contract with you. With your permission or direction, we will disclose your personal data to relevant third parties including: (i) Carfax, for the purpose of vehicle identification number searches; (ii) Stripe, for assisting with transactions on our Services; and (iii) third party providers who arrange vehicle photography services.
With professional advisors, in our legitimate interests or as required by law. As necessary, we will share your personal data with professional advisors such as auditors, law firms, or accounting firms.
For legal and security reasons and to protect our services and business, in our legitimate interests or as required by law. We will share your personal data with regulators, law enforcement agencies, public authorities, or any other relevant organisations: (i) in response to a legal obligation; (ii) if we have determined that it is necessary to share your personal data to comply with applicable law or any obligations thereunder, including cooperation with law enforcement, judicial orders, and regulatory inquiries; (iii) to protect the interests of, and ensure the safety and security, of us, our users, a third party or the public; (iv) to exercise or defend legal claims; and (v) to enforce our terms and conditions, other applicable terms of service, or other agreements.
With our affiliates, in our legitimate interests. We may share your personal data with companies within our corporate family.
In connection with an asset sale or purchase, a share sale, purchase or merger, bankruptcy, or other business transaction or re-organization, in our legitimate interests. We will share your personal data with a prospective buyer, seller, new owner, or other relevant third party as necessary while negotiating or in relation to a change of corporate control such as a restructuring, merger, or sale of our assets.
In any other circumstances, as notified to you in advance.

6. WHERE WE STORE YOUR personal data

The personal data collected by us or our processors from you may be transferred to, stored at and processed in countries outside the country in which you are located, by us and our third party service providers or partners. We will take all steps reasonably necessary to ensure that your personal data is treated securely and in accordance with this Privacy Policy.

When we transfer data outside the EEA or the UK, the data transfer will be under the European Commission’s standard contractual clauses for the transfer of personal data to third countries (specifically, module one (controller to controller transfer), module three (processor to processor transfer), module four (processor to controller transfer), as relevant), or the UK Information Commissioner’s international data transfer addendum to the EU standard contractual clauses, as relevant, unless the data transfer is to a country that has been determined by the European Commission or the relevant UK authorities, as applicable, to provide an adequate level of protection for individuals’ rights and freedoms for their personal data. Please contact us at [email protected] should you wish to examine a copy of the EU standard contractual clauses or UK international data transfer addendum.

7. HOW LONG WE RETAIN YOUR PERSONAL data

We will retain your personal data for as long as you keep your account open or as needed to provide you with our Services.

We will also retain and use your personal data to the extent necessary based on certain criteria, including if we need the data to continue providing the Services, comply with our legal obligations, resolve disputes and enforce our terms and conditions, other applicable terms of service, and our policies, promote safety, security and integrity, or to defend the Services, our rights, the rights of our users or others. If you stop using our Services or if you delete your account with us, we will store your information in an aggregated and anonymized format; we may use this information indefinitely without further notice to you.

8. SECURITY

Despite our reasonable efforts to protect your personal data, no security measures are impenetrable and we cannot guarantee “perfect security”. Any information you send electronically, including through the Services or over email, telephone or text/SMS, is sent at your own risk.

9. YOUR RIGHTS

Access: You may have the right to access the personal data we hold about you, including details relating to how we use it, and who we share it with.
Correction: You may have the right to request that we correct personal data we hold that is inaccurate.
Deletion/Erasure: You may have the right to request that we delete the personal data we hold about you.
Portability: You may have the right to receive a copy of the personal data we hold about you and to request that we transfer it to a third party, in certain circumstances and with certain exceptions.
Restriction of processing: You may have the right to ask us to stop processing the personal data we hold about you, other than for storage purposes, in certain circumstances.
Objection: You may have the right to object to our processing of your personal data.
Opt-out of marketing: You may opt-out of marketing emails at any time, by using the unsubscribe/opt-out function displayed in our communications to you or in your profile settings https://sbxcars.com/my-settings
Withdrawal of consent: Where we rely on consent to process your personal data, you may have the right to withdraw this consent at any time by clicking on the relevant opt-out toggle, in your user profile settings or emailing us at [email protected].

Please note that a number of these rights only apply in certain circumstances, and all of these rights may be limited by law. We will not discriminate against you for exercising any of these rights.

To exercise any of these rights, you can contact [email protected]. Further information may be needed to verify your identity before exercising these rights, such as your email address or government issued ID. Depending on where you reside, you may designate, in writing or through a power of attorney document, an authorized agent to make requests on your behalf to exercise your rights. Before accepting such a request from an agent, we will require that the agent provide proof you have authorized them to act on your behalf, and we may need you to verify your identity directly with us. If we deny your request, you may appeal our decision by contacting us through the methods described in the Contact section below.

10. SOCIAL FEATURES

Certain features of the Services allow you to initiate interactions between the Services and third party services or platforms, such as social networks (“Social Features”). Social Features include features that allow you to access our pages on third party platforms, and from there “like” or “share” our content. Use of Social Features may allow a third party to collect and/or use your information. If you use Social Features, information you post or make accessible may be publicly displayed by the third party. Both we and the third party may have access to information about you and your use of both the Services and the third party service. For more information, see the section below, Third Party Links and Materials.

11. THIRD PARTY LINKS and materials

Our Website may contain links to other online platforms, plug-ins or other applications operated by, or make available content or information from third parties. We do not control such other sites, applications or third parties, and are not responsible for their content, their privacy policies, or their use of your information. Information you provide on public or semi-public venues, including information you share on third party social networking platforms, may also be viewable by other users of the Website and/or users of those third party online platforms without limitation as to its use by us or by a third party. Our inclusion of such links does not, by itself, imply any endorsement of the content on such platforms or of their owners or operators except as disclosed on the Website. We expressly disclaim any and all liability for the actions of third parties, including but without limitation to actions relating to the use and/or disclosure of personal data by third parties. Any information submitted by you directly to these third parties is subject to that third party’s privacy policy.

12. COMPLAINTS

If you have complaints about how we process your personal data, please contact us at [email protected] and we will respond to your request as soon as possible.

If you think we have infringed data protection laws, you may have the right to file a claim with the regulator or data protection supervisory authority in the country in which you live or work or where you think we have infringed data protection laws.

13. CONTACT

We welcome your questions, comments, and concerns about this Privacy Policy or your personal data. Please send us any feedback to [email protected].

14. LANGUAGE

Except as otherwise prescribed by applicable law, in the event of any inconsistency between the English language version and local language version of this Privacy Policy, the English language version will prevail.