Privacy Policy

1. What information do we collect and when?

When you use our Website or any of our Services, we may ask you to provide us with certain "Personally Identifiable Information" that can be used to contact or identify you. Personally Identifiable Information may include, but is not limited to, your email address, name, phone number, postal address, driver’s license number or other government issued identification number, credit card or other payment information which could include first name, last name, credit card number or checking account information for payment, a user-specified password, mailing address, zip code and telephone number. We collect this Personally Identifiable Information for the purpose of providing Services, access to the Website, identifying and communicating with you, responding to your requests/inquiries, servicing your purchase orders, and improving our services.

We collect credit card, address, bank information, or similar information ("User Financial Information") only from those who choose to use the Services through our Website in order to buy or sell items. User Financial Information collected by us is used may be used to authenticate user accounts and will be used to bill a user for products and Services available through the Website. We will never store the sixteen-digit Primary Account Number ("PAN") or the three-digit Card Security Code ("CSC") on any of your credit card(s).

Your information is stored on your account with us and is accessible through the Website. You can be update, modify, correct, or delete your information at any time when you login to your account. Deleting your information will not delete historical account records of online transactions which we may be required save for a specified period of time by law. If you have questions or concerns about correction of modification of your information you may contact us as described in the "Contact Us" section of this Privacy Policy.

Specifically, we collect:

• Information you submit to us. You can submit information to us in the following ways:
• Through forms provided on the Website, including submissions for items for sale, requests for items, or any other content generated by you during your use of the Website or any of the services provided through the Website, including any use through mobile phone browsers or other applications;
• By sending us emails and text messages (SMS or MMS);
• By interacting with us on social media platforms (such as Facebook or Twitter);
• By speaking to us over the telephone; or
• By registering accounts on the Website (including through mobile phone applications or browsers), including setting up passwords and preferred user names, contact details, account details, and preferences.

We may not be able to provide you with the Services or respond to any questions or requests you submit to us unless you submit certain Personally Identifiable Information or User Financial Information.

• Categories of information we collect about you:
• Identifiers such as your name, address, email, billing information, username, phone numbers, security questions, and password.
• User Financial Information such as credit or debit card number, verification number, and expiration date, to process payments and information about your transactions and purchases with us.
• Sensory information such as audio recordings (if you call our customer service phone number) or volunteer this information as while using the Services.
• Commercial information, including records of the purchases you make on the Website, including the time and date of purchase, any relevant delivery address, and information related to your purchased Services.
• Internet activity, including information on what you search for, view, click on and access in and through the Website, including referral links in our marketing emails and text messages (SMS or MMS). This information may also include how you reached the Website, and where you went when you left it. We also track how often you visit and use the Website. Your Internet activity contains certain information that is not personally identifiable, such as your IP address, pages viewed, and length of time spent on the Website. We may combine this information with data collected from other users to produce anonymous, aggregated statistical information. We may also collect information such as your computer's Internet Protocol ("IP") address, browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages and other statistics.
• Inferences about personal preferences that may be collected through the use of cookies (see our Cookies Policy).
• Technical information about the devices you use to access the Website. We may collect each device’s unique identifying code (MAC address), relevant IP address, operating system and version, web browser and version, and other device information.
• Information from banking, credit card and credit reference agencies about your financial status so that we can reduce the risk of fraud and gain insight into your consumer behavior.
• Research information collected if you participate in surveys or other marketing questionnaires.
• Geolocation information such as your general geographic location when you use the Website or the Services.
• Social media information, which we may collect if you access the Website or the Services through a third-party social media platform. We may have access to any information you provide to that social network depending on your privacy settings.

We do not collect any information related to "protected classifications" about you, such as details about your race, ethnicity, or gender, religious beliefs, or political opinions. We do not collect any information about your health, genetics, or biometrics.

2. How do we use your information?

We will only use your information, including Personally Identifiable Information and User Financial Information, for the purposes and legal bases set out in the table below.

Why we use your information	What is our basis for doing so
To provide you the Services and the Website, which require a certain amount of information to be collected in order to work properly and in a secure manner.	To support our legitimate interests in managing our business, providing the Services, and providing the Website (provided such interests are not overridden by your interests and rights).
To enable you to order products from the Website, which requires a certain amount of personal data to be collected, including User Financial Information.	The processing is necessary to perform a contract or enter into a contract with you, including enforcing any debts which you may owe resulting from products or Services you order through the Website.
To enable us to make offers for which you have signed up, deliver other marketing communications to you or to contact you about our Services, the Website, new products, news, offers, and sponsored events.	Where you have given consent to the processing of your personal data for direct marketing – from which you may opt-out at any time.
To gather feedback from you about our Services and the Website. We may invite you to provide feedback on occasion. We may use independent research and feedback providers to do so on our behalf. This process may be by invitation, which you can decline.	To support our legitimate interests in managing our business, providing the Services, and providing the Website (provided such interests are not overridden by your interests and rights).
To respond to any questions, suggestions, issues or complaints you have raised with us, or to communicate with you about operations changes to the Website or the Services.	To support our legitimate interests in managing our business, providing the Services, and providing the Website (provided such interests are not overridden by your interests and rights).
To respond to any social media posts or other public comments you make where these are made to or about us, the Website, the Services or other activities.	To support our legitimate interests in managing our business, providing the Services, and providing the Website (provided such interests are not overridden by your interests and rights).
To gather statistics about how you and other users use the Website and Services, and to enable us to understand our customer and user base, including market research.	To support our legitimate interests in managing our business, providing the Services, and providing the Website (provided such interests are not overridden by your interests and rights).
To check that you have or are likely to have the means to pay us for any products you have ordered from the Website or through use of the Services.	To support our legitimate interests in managing our business, providing the Services, and providing the Website (provided such interests are not overridden by your interests and rights).
To protect you and our business against any other criminal behavior, including identity theft and fraud, including monitoring the Website for fraudulent or unauthorized activity.	To support our legitimate interests in managing our business, providing the Services, and providing the Website (provided such interests are not overridden by your interests and rights).
To enable us and our third-party service providers to plan and manage our business, the Website, and the Services as effectively as possible.	To support our legitimate interests in managing our business, providing the Services, and providing the Website (provided such interests are not overridden by your interests and rights).
To maintain administrative and legal records about our business, including anonymizing your information should you choose to ceases using the Website or Services.	To support our legitimate interests in managing our business, providing the Services, and providing the Website (provided such interests are not overridden by your interests and rights).
To test new systems and processes and to develop new Services.	To support our legitimate interests in managing our business, providing the Services, and providing the Website (provided such interests are not overridden by your interests and rights).
To analyze our advertising on trade publications and trade websites, online and in search engine optimization.	To support our legitimate interests in managing our business, providing the Services, and providing the Website (provided such interests are not overridden by your interests and rights).

3. Who do we share your information with?

We do not sell your personal information or the personal information of your end users. We also do not allow any personal information to be used by third parties for their own marketing purposes. However, we cannot provide the Services or the Website without involving third parties. Sometimes we pass your information to the third parties identified below, depending on the scenario. We only share your information where we can do so in accordance with our obligations under this Privacy Policy and applicable law.

• Subsidiaries and affiliates of My Little Salesman, Inc. We do so because we hope to have a relationship with you across our different brands and businesses, if not now, then in the future, and we want to be able to provide you with the same value and high quality of experience however you choose to interact with us.
• Other people and businesses who help us provide our website, and related services to you, for example, payment services companies, such as Stripe, who enable you to use payment cards with us.
• Analytics and search engine providers, such as Google Analytics, who assist us in the improvement and optimization of the Website. These third-party service providers have their own privacy policies addressing how they use such information.
• Our insurers and insurance brokers in order for us to be able to obtain insurance against risks we face in running our business. They may retain this information for the purpose of ongoing risk assessment and insurance broking and underwriting services.
• Banks and finance companies where we have allowed them to offer you the possibility of purchasing items listed for sale or lease on the Website on credit or through a loan. They may retain this information if you take any financial service or product they offer.
• Credit reference agencies who provide anti-fraud and credit score information to us, banks and finance companies who also provide anti-fraud services and customer insight companies, in each case as necessary in order to benefit from their services. Where we do so for anti-fraud purposes, the recipient organization may hold your information on file for the purpose of of providing their fraud prevention services in the future.
• Business partners, suppliers, service providers, contractors, and sub-contractors for the performance of any contract we enter into with you.
• The prospective buyer of any part of our business or assets that we may sell. These prospective buyers will always be bound by nondisclosure agreements before your information is shared.
• Our professional advisers, for example our lawyers, accountants and technology consultants when they need it to provide advice to us.
• The police, local authorities, the courts and any other central or local government bodies where they request it, and we may lawfully disclose it, for the prevention and detection of crime. We may also share the information we collect where we are legally obliged to do so, for example, to comply with a court order.

Should we share or disclose any of your information to any third party for any business purpose, including any business partner, supplier, service provider, contractor, or sub-contractor, we shall enter into an agreement with such third party that:

• Specifies we disclose your information only for limited and specific purposes, namely, for the performance of any contract we enter into with you;
• Requires the third party to comply with applicable privacy and consumer protection laws, including the California Consumer Privacy Act ("CCPA") and the California Privacy Rights Act ("CPRA");
• Grants us the right to take reasonable and appropriate steps to help ensure that such third party complies with such applicable privacy and consumer protection laws, including the CCPA and CPRA;
• Requires the third party to notify us should it determine that it can no longer meet its obligations under any applicable privacy and consumer protection laws, including the CCPA and CPRA; and
• Grants us the right, upon the third party’s receipt of our notice, to take reasonable and appropriate steps to stop and remediate any unauthorized use of your information, including under any circumstance in which the third party has notified us that it can no longer meet its obligations under any applicable privacy or consumer protection law.

4. Social media, blogs, reviews, and similar services

Any posts or comments you make to our accounts on third party social media platforms (for example, Facebook or Twitter) will be shared under the terms of the relevant social media platform on which they are made and could be made public by that platform. These platforms are controlled by third parties, not us, so we are not responsible for this sharing. You should review the terms and conditions and privacy policies of the social media platforms you use to ensure you understand how they will use your information and what information relating to you they will make publicly available.

If the Website provides any blog, review system, or other interactive board system that allows you to make posts or comments about us, the Website, or our Services, your submitted information will be shared with all users of that portion of the Website and, if made on a publicly available portion of the Website, with the public. You should ensure that any comments you make on these services are fit to be read by third parties and are not offensive or defamatory.

5. Security of your information

Information provided through the Website is stored on our secure servers (or on those of any third party we engage to provide our information technology platform or the Website) and is encrypted using standard technology.

Where we have given you, or you have chosen, a password which enables you to access your account or certain parts of the Website, you are responsible for keeping the password confidential and must not share it with anyone. You are responsible for any actions carried out using your password except where there has been fraud.

In the event of a data breach involving your Personally Identifiable Information or User Financial Information, we shall notify you as quickly as possible (but in no case shall you be notified later than sixty (60) days after the date of the breach). We may be required to report certain data breaches to relevant government authorities depending on the extent of the data breach.

6. How long do we keep your information?

In accordance with our legal data protection and privacy obligations, we will only retain your information, including Personally Identifiable Information and User Financial Information, for as long as we need it to achieve the purpose(s) for which we obtained it. If you notify us that you intend to close your account with us, and that you will cease to use the Website, we will stop processing your Personally Identifiable Information and User Financial Information on the date you close your account. Not later than thirty (30) days after you close your account, we will delete your Personally Identifiable Information from our systems unless retention of your Personally Identifiable Information is required by law or regulation or is necessary for us to comply with law or regulation. We shall also notify any third parties who may process your Personally Identifiable Information on our behalf that you are closing your account. Some information related to your account that is not "Personally Identifiable Information" or "User Financial Information," such as a history of use of the Website, may be retained for our internal purposes.

7. Managing your information

It is very important to us that all the information we hold about you remains accurate and up to date to reduce the risk of errors in providing the Services or access to the WebsiteIf you have an online account with us, please ensure that the information you provide to us remains accurate and up to date.

Depending on your residence or domicile, you may have rights in relation to your information, including your Personally Identifiable information and User Financial Information, under applicable law, which may be subject to certain limitations and restrictions. We will honor all such legal rights.

We may request proof of identification to verify your identify should you submit requests to us. We reserve the right not to comply with any requests we receive where we may lawfully do so, for example, if we reasonably believe a request to be malicious, technically very onerous, to involve disproportionate effort or harmful to the rights of others.

If you wish to exercise any of these rights, inquire about your rights, or if you would like to make a request for data deletion, please contact us as described in the "Contact Us" section of this Privacy Policy.

If you have any questions or complaints about our use of your information, please contact us as described in the "Contact Us" section of this Privacy Policy. We will do our very best to answer any questions and resolve any complaints to your satisfaction.

8. Third party links

Our website may contain links to our website of third parties. If you follow a link to any third-party website, please note that these websites will have their own privacy policies and we do not accept any responsibility or liability for any use of such third-party websites.

9. Google API services disclosure

Our use and transfer of information received from Google APIs to any other system will adhere to Google API Services User Data Policy, including the Limited Use requirements.

10. Changes to this Privacy Policy

We shall update this Privacy Policy at least annually and reserve the right to update this Privacy Policy from time to time. The date on which any updated version of this Privacy Policy is effective will be marked by the "Last Updated" date on this Privacy Policy. Please review the Privacy Notice whenever you access or use this Website.

11. Contact Us

You may contact us by emailing us at the address privacy@mlsinc.com or by calling our toll-free number (844) 325-3818. We may require that you supply Personally Identifiable Information in order to verify your identity in order to process any requests you submit.

Please contact us if:

• you have any inquiries about this Privacy Policy,
• you no longer want to participate in our services,
• you would like to make a request for data deletion, or
• you wish to opt out of receiving further information.

12. Cookies Policy

Cookies are files with a small amount of data, which may include an anonymous unique identifier. Cookies are sent to your browser from the Website and stored on your computing device. We use cookies to collect information to improve our services and the Website. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. The "Help" feature on most browsers provides information on how to accept cookies, disable cookies, or to notify you when receiving a new cookie. If you do not accept cookies, you may not be able to use some features of the Website. At no time do we share information from cookies with third parties.

If you create an account with us then we will use cookies for the management of your signup process and general administration of your account. These cookies will usually be deleted when you log out of the Website; however, in some cases they may remain stored on your computing device to remember your preferences for using the Website. We use cookies when you are logged into the Website so that you are not required to log in every time you visit a new page on the Website; these cookies are typically removed or cleared when you log out to ensure that you can only access restricted features and areas when you are logged into the Website. We may use cookies to process orders, to facilitate e-commerce transactions, and for payment processing. It's important for us to understand statistics about purchases made via the Website and cookies may track this kind of data.

We may also use cookies provided by trusted third parties. The Website uses Google Analytics, one of the most widespread and trusted analytics solutions on the Internet, for helping us to understand how you use the Website and to determine ways that we can improve your experience. Google Analytics cookies may track information such as how long you spend on the Website and the pages you visit so we can continue to produce engaging content. For more information on Google Analytics cookies, see the official Google Analytics page at the URL https://analytics.withgoogle.com/. We use the Google AdSense service to serve advertising on the Website; Google AdSense uses a DoubleClick cookie to serve more relevant ads on the Website and limits the number of times that a given ad is shown to you. For more information on Google AdSense, see the official Google AdSense website at the URL https://www.google.com/adsense/start/. Several partners may advertise on our behalf and affiliate tracking cookies would allow us to see if our customers have come to the Website through one of our partner sites so that we can credit them appropriately and, where applicable, allow our affiliate partners to provide any bonus related to purchases. We may also use social media buttons and/or plugins on this site that allow you to interact between the Website and your accounts with social media providers, such as for registration or login purposes. For these interactions to operate, the social media providers (such as Facebook) will use cookies in conjunction with our Website. These cookies may contain your information for various purposes outlined in their privacy policies of these social media providers.

Finally, we may use cookies to understand our users’ behavior and use of the Website. Cookies may be used on an aggregate basis to track navigation of the Website by users but this information is not traceable to an individual user.

13. California Users

Users located in California may have additional rights under the California Consumer Protection Act ("CCPA"). This section describes certain rights you have under the CCPA and how you may exercise them.

Under the CCPA, you have five (5) primary consumer rights:

• The right to know what personal information we collect.
• The right to know if we sell or share your personal information, and to whom.
• The right to object to the sale of personal data.
• The right to access your personal information.
• The right to equal service and price, even if you exercise your rights under the CCPA.

Access to Specific Information and Data Portability Rights

Under the CCPA, you have the right to request that we disclose information to you pertaining to our collection and use of your "personal information," as defined under the CCPA (the definition of which may include certain of your "Personally Identifiable Information"), over the past twelve (12) months. You may make this request for free two (2) times each year. You may make this request as described in the "Contact Us" section of this Privacy Policy.

Once we receive and confirm your request, we will acknowledge receipt of this request within ten (10) business days, and within forty-five (45) days of the request, we will disclose to you, in a portable and easily accessible format:

• The categories of personal information we collected about you.
• The categories of sources for the personal information we collected about you.
• Our business or commercial purpose for collecting (or selling) that personal information.
• The categories of third parties with whom we share that personal information.
• The specific piece of personal information we collected about you.
• If we sold or disclosed your personal information for a business purpose, two lists disclosing the sales and the business purpose (which will identify the personal information categories that each category of recipient purchased or obtained).

Non-Discrimination

We will not discriminate against you for exercising any of your rights under the CCPA. Unless otherwise permitted by the CCPA, we will not:

• Deny you Services available through the Website.
• Charge you different prices or rates for Services available through the Website, including through imposing penalties or granting discounts or benefits.
• Provide you with, or suggest that you may receive, a different level or quality of the Services available through the Website.
• Threaten you with any of the foregoing.

We may, during our normal course of business, offer you certain incentives that are permitted under the CCPA that may result in different prices or quality of the Services available through the Website.

Right to Deletion

You have the right under the CCPA to request two (2) times per year that we delete your personal information. This right does not apply if we need to retain your personal information in order to:

• Ensure data security, including detecting or resolving data security issues.
• Debug the Website or our information technology systems.
• Comply with the CCPA or other relevant law.
• Complete any outstanding contract for Services with you.
• Carry out internal processes that you, as a consumer, would reasonably expect.

To exercise your deletion right, please contact us as described in the "Contact Us" section of this Privacy Policy. Sales of Personal Information

The Company does not sell any personal information of its users and has not sold any personal information of its users during the past twelve (12) months.

Categories of Activities and Categories of Your Personal Information

In summary, we share the categories your information with third parties based on these categories of business purposes:

Category of Business Purpose	Category of Personal Information
Auditing	Identifiers; User Financial Information; Commercial information; Internet activity; Inferences about personal preferences
Security	Identifiers; User Financial Information; Sensory information; Inferences about personal preferences; Technical information about the devices you use; Information from banking, credit card and credit reference agencies
Debugging	Sensory information; Internet activity; Inferences about personal preferences; Technical information about the devices you use; Research information; Geolocation information
Short-term Uses	Identifiers; User Financial Information; Sensory information
Performing Services	Identifiers; User Financial Information; Sensory information; Commercial information; Internet activity; Inferences about personal preferences; Technical information about the devices you use; Information from banking, credit card and credit reference agencies; Research information; Geolocation information; Social media information
Internal research	Identifiers; User Financial Information; Sensory information; Commercial information; Internet activity; Inferences about personal preferences; Technical information about the devices you use; Research information; Geolocation information; Social media information
Testing or improvement of our Service	Internet activity; Inferences about personal preferences; Technical information about the devices you use; Research information; Geolocation information; Social media information

14. European Users

This Section shall apply to you if you are a resident or national of the European Union (the "EU"). If you are a resident or national of the EU, then you have certain rights under the General Data Protection Regulation ("GDPR") enacted by the EU.

For purposes of this section:

• You, as individual resident or national of the EU, will be considered a "data subject" as defined in the GDPR.
• We, as an organization that collects data from data subjects, will be considered a "data controller" as defined in the GDPR.
• All information related to your activities related to the Services or the Website will be considered "personal data" as defined in the GDPR. Your "personal data" includes your Personally Identifiable Information and User Financial Information.
• We do not collect "special category data" as defined in the GDPR.
• When we collect, store, use, and dispose of your personal data, we are engaging in "processing" as defined in the GDPR.

We seek to adhere to the principles of Article 6 of the GDPR, which states that we should only collect your personal data:

• If you have given consent to the processing of your personal data
• If we require it to fulfill our contractual obligations to you regarding the Services or the Website
• To company with our legal obligations
• To protect the vital interests of you and our other users
• To perform tasks in the public interest
• For our other legitimate interests unless they are overridden by your interests or rights

The GDPR sets forth your eight (8) rights you have regarding our processing of your personal data. These rights are:

• Your right to be informed regarding how we process your personal data
• Your right of access to your personal data
• Your right to rectify or correct your personal data
• Your right to request erasure of your personal data
• Your right to restrict processing of your personal data
• Your right to portability of your personal data
• Your right to object how we process your personal data
• Rights related to automated decision-making and profiling

Should you wish to exercise any of these rights, please contact us as described in the "Contact Us" section of this Privacy Policy.

You also have the right under the GDPR to submit complaints or concerns to the National Data Protection Authority of the country in which you reside or your country of national origin. For a list of the National Data Protection Authorities in the EU, you may visit this website:

https://edpb.europa.eu/about-edpb/about-edpb/members_en