1. Scope and Updates This notice governs your use of Promo LLC's AUCTION WALK website, apps, payment services, products and tools (the "Services"), however accessed (including partner sites). We may revise it at any time by posting a new version with an updated effective date. Substantial changes will be announced via My Messages or email. 2. Data Controller The Promo LLC AUCTION WALK entity responsible for your data depends on your location and the Services you use. In the U.S., that's Promo LLC, Sheridan, Wyoming— for both general Services and sellers' payment services. 3. Data Protection Officer and Contact We've appointed data protection officers worldwide. Their names and contacts appear in our Promo LLC Privacy Center. You may also reach out anytime to our global Privacy Team or the controller handling your data. 4. Data We Collect 4.1 Data You Provide • Identity and contact details (name, address, email, phone, username, tax ID) • Seller payment info (SSN, DOB, bank details, VAT) • Transaction data (bids, purchases, sales, shipping, customs) • Messages, survey responses, community posts, customer-service call recordings • Optional demographic or preference data (age, gender, interests) 4.2 Automatic Data Collection • Transaction metadata (amounts, times, locations) • Site and app activity (cart, watch list, searches, ad interactions) • Device and connection info (IP address, browser, OS, data traffic, referral URL) • Location data (general via IP; precise with your permission) 4.3 Cookies & Similar Technologies We use cookies, beacons and SDKs to track page views, ad exposures and engagement, device IDs, and user segments. Manage settings via our Cookie Policy. 4.4 Third-Party Data Sources We enrich our records with data from public sources, credit bureaus, ID-verification and risk-modeling vendors, and other Promo LLC Inc. affiliates, always ensuring lawful disclosure. 5. How We Use Your Data 5.1 Providing Our Services To register and manage your account, execute transactions, display history and ratings, process payments, ship items, handle disputes, and provide support and notifications. We share data with buyers, sellers, logistics firms, payment processors, corporate affiliates, and enforcement partners under strict confidentiality. 5.2 Legal Compliance To meet court orders, regulatory inquiries, anti-fraud, anti-money-laundering and data-security requirements; data may go to law enforcement, tax authorities, courts and credit bureaus. 8. Your Privacy Rights As a data subject, you have the right to: • Access your personal data and know what we're processing • Correct inaccurate or incomplete information • Request deletion of your data (subject to legal restrictions) • Restrict or object to our processing of your data • Port your data to another service • Withdraw your consent at any time • File a complaint with your local data protection authority 9. Cookies & Similar Technologies We and select partners use cookies for: • Core functionality (e.g., login, navigation) • Performance monitoring (e.g., load times, errors) • User experience (e.g., preferences, form data) • Personalized advertising and marketing