Privacy Policy

1. INTRODUCTION & SCOPE

This Privacy Policy explains how Sell My Project ("SMP," "we," "our," or "us") collects, uses, stores, shares, protects, and processes personal information in connection with the Sell My Project website, applications, marketplace platform, Auctions, communication tools, and related services (collectively, the "Platform").

This Privacy Policy is intended to help users understand what information SMP collects, how information is used and shared, how SMP protects user information, what privacy rights users may have, and how users may contact SMP regarding privacy-related matters.

This Privacy Policy applies to personal information collected through the Platform, Auctions and marketplace activity, user accounts and Garage profiles, communications with SMP, payment and transaction activity, customer-support interactions, marketing communications, and related online and offline interactions connected to SMP services. This Privacy Policy applies to Buyers, Sellers, Garage accounts, builders, visitors, and other users interacting with the Platform.

By accessing or using the Platform, creating an account, participating in Auctions, submitting information, uploading content, or otherwise interacting with SMP services, users acknowledge that they have read and understood this Privacy Policy and consent to the collection, use, disclosure, and processing of information as described herein. If a user does not agree with this Privacy Policy, the user should discontinue use of the Platform.

This Privacy Policy is incorporated into and forms part of the SMP Terms of Service, Buyer Terms, Seller Terms, and related Platform policies. Capitalized terms not defined in this Privacy Policy shall have the meanings assigned in the applicable Terms of Service. In the event of a conflict between this Privacy Policy and the Terms of Service regarding privacy or data-processing matters, this Privacy Policy shall generally control with respect to those matters unless otherwise required by law.

SMP operates primarily as a United States-based online marketplace platform intended for users and vehicles located within the United States, unless otherwise approved by SMP.

Users accessing the Platform from outside the United States acknowledge that information may be collected, stored, processed, and transferred within the United States, privacy laws in the United States may differ from those in other jurisdictions, cross-border data transfers may occur in connection with Platform operations, and users remain responsible for compliance with local laws applicable to their use of the Platform.

SMP reserves the right to restrict or limit Platform access in certain jurisdictions where operational, legal, compliance, or regulatory concerns arise.

2. INFORMATION WE COLLECT

2.1 Information Users Provide Directly

SMP may collect information users voluntarily provide when creating accounts, participating in Auctions, communicating with other users, contacting customer support, completing transactions, uploading content, or otherwise interacting with the Platform.

Such information may include names, usernames, email addresses, phone numbers, mailing addresses, business information, social-media handles, profile details, Garage information, communications, uploaded content, and other information users choose to provide.

2.2 Account Registration Information

When users create accounts, SMP may collect registration and account-related information, including account credentials, login information, profile information, verification status, account preferences, notification settings, account history, and marketplace participation records. Users are responsible for ensuring that account information remains accurate and up to date.

2.3 Identity Verification & KYC Information

SMP and its service providers may collect identity verification and know your customer ("KYC") information for fraud prevention, payment processing, compliance, risk management, or marketplace security purposes.

Verification information may include government-issued identification, driver's license information, tax identification information, business registration records, banking information, proof of ownership documentation, selfie verification, address verification, and related compliance materials. SMP may utilize third-party verification providers to process or validate such information.

2.4 Vehicle, Listing & Garage Information

SMP may collect information relating to Projects, listings, Auctions, Garages, builds, restoration activity, and marketplace participation, including VIN information, title information, odometer disclosures, vehicle specifications, restoration details, build descriptions, pricing information, photos and videos, modification details, listing history, and related vehicle-sale information.

2.5 Payment & Transaction Information

SMP and its payment providers may collect payment and transaction-related information, including billing information, payment method details, transaction records, payout information, purchase history, Auction activity, Buyer Premium information, chargeback records, tax-related information, and payment-verification data. Payment-processing services may be provided through third-party providers such as Stripe and related financial institutions.

2.6 Communications & Support Requests

SMP may collect information contained in customer-support requests, emails, messages, dispute communications, feedback submissions, survey responses, moderation reports, verification inquiries, and communications conducted through the Platform. Such communications may be monitored, reviewed, stored, or retained for operational, training, fraud prevention, legal, compliance, or marketplace integrity purposes.

2.7 Auction & Marketplace Activity

SMP may collect information relating to user participation in Auctions and marketplace activity, including bid histories, Auction participation, Send It activations, Crew engagement, comments, watchlists, account interactions, Trust Score activity, transaction history, and marketplace behavior patterns. Marketplace activity may be publicly visible depending on Platform functionality and user participation settings.

2.8 User Content & Uploaded Materials

SMP may collect and store content users upload, publish, transmit, or otherwise provide through the Platform, including listing content, photos, videos, comments, build documentation, usernames, Garage profiles, messages, invoices, title documentation, and related marketplace materials. Users remain responsible for ensuring uploaded content complies with applicable laws and Platform policies.

2.9 Device, Usage & Technical Information

SMP may automatically collect device, technical, and usage-related information when users access or interact with the Platform, including IP addresses, browser type, device identifiers, operating systems, login activity, geolocation data, session information, referral URLs, clickstream data, crash reports, performance information, and Platform interaction data. This information may be used for analytics, security, fraud prevention, troubleshooting, and operational purposes.

2.10 Cookies & Tracking Technologies

SMP may use cookies, pixels, SDKs, analytics tools, session technologies, and similar tracking technologies to operate and secure the Platform, remember user preferences, authenticate accounts, analyze usage trends, improve functionality, personalize user experiences, and support advertising or marketing activities. Users may manage certain cookie preferences through browser settings or, where available, applicable consent-management tools.

2.11 Information from Third Parties

SMP may receive information from third parties, including payment processors, identity-verification providers, analytics providers, advertising partners, social-media platforms, fraud-prevention services, public databases, government agencies, service providers, and other users interacting with the Platform. Third-party information may be combined with information collected directly from users for operational, compliance, security, fraud-prevention, and marketplace improvement purposes.

3. HOW WE USE INFORMATION

3.1 Platform Operations & Marketplace Functionality

SMP uses collected information to operate, maintain, administer, improve, and provide the Platform and related marketplace services. This includes supporting core marketplace functionality such as account creation and management, Auctions and Send It activations, Project listings, Garage profiles, marketplace engagement, bid activity, user authentication, transaction coordination, and general Platform administration.

Information may also be used to personalize user experiences, improve listing visibility, organize marketplace content, support search and recommendation functionality, optimize Platform performance, maintain operational stability, and develop new marketplace features and services.

SMP may analyze marketplace activity, user interactions, and engagement patterns to understand better how users interact with the Platform and to improve overall marketplace functionality and user experience.

3.2 Account Administration

SMP uses information to create, verify, maintain, secure, administer, and manage user accounts and marketplace participation. This may include account setup, onboarding, login authentication, password management, identity verification, profile administration, Garage management, payout setup, notification management, Trust Score administration, account recovery procedures, moderation reviews, and enforcement of Platform policies and procedures.

SMP may also use account-related information to communicate with users, monitor account activity, investigate suspicious conduct, verify ownership or authority, respond to support requests, administer marketplace privileges, and maintain marketplace integrity and operational security. Users remain responsible for ensuring that account information is accurate, current, and complete.

3.3 Auction Operations & Transaction Processing

SMP uses information to facilitate Auctions, marketplace participation, and related transaction activity across the Platform. This includes processing bids and Send It activations, managing Auction timing and visibility, administering anti-sniping extensions, coordinating marketplace interactions, displaying bid histories and engagement activity, facilitating communications between Buyers and Sellers, processing payments and payouts, generating transaction records, administering Buyer Premiums and related fees, and supporting completed sales and marketplace operations.

Information may also be used to confirm transaction activity, verify payment status, monitor Auction integrity, support dispute resolution, investigate suspicious bidding behavior, maintain audit logs, and satisfy operational, accounting, legal, tax, or compliance obligations associated with marketplace transactions.

SMP may retain records relating to Auctions, bids, communications, payments, and marketplace activity for operational continuity, fraud prevention, evidentiary purposes, legal compliance, and enforcement of Platform policies.

3.4 Fraud Prevention & Security

SMP uses information to detect, investigate, prevent, monitor, and address fraud, suspicious activity, account compromise, payment abuse, chargebacks, Auction manipulation, unauthorized access, spam, security incidents, deceptive conduct, and other activity that may threaten the Platform, its users, or marketplace integrity.

To support security and risk management, SMP may utilize automated monitoring systems, behavioral analytics, moderation tools, fraud-detection software, audit logs, device-recognition technologies, IP analysis, identity-verification systems, payment-risk tools, Trust Score systems, and third-party fraud-prevention or compliance providers.

SMP may use collected information to investigate suspicious marketplace activity, verify account legitimacy, enforce Platform policies, detect duplicate or abusive accounts, prevent shill bidding, monitor high-risk transactions, preserve evidence, protect users from fraud or abuse, and maintain operational security across the Platform. Where reasonably necessary, SMP may also cooperate with payment providers, regulators, law enforcement agencies, fraud-prevention vendors, and other authorized third parties in connection with fraud investigations, security matters, compliance obligations, or enforcement activity.

3.5 Identity Verification & Compliance

SMP may use information to verify user identity, confirm ownership or authority, conduct know-your-customer ("KYC") reviews, satisfy compliance obligations, and reduce operational, legal, financial, or regulatory risk. Verification and compliance activities may include identity confirmation, sanctions screening, fraud reviews, payment verification, ownership validation, title-related verification, tax-related compliance, risk assessments, and compliance with applicable laws, regulations, payment-network requirements, or third-party provider obligations.

SMP may also utilize third-party identity verification, fraud prevention, or compliance providers to support marketplace security, operational integrity, and lawful Platform operations.

3.6 Payment Processing & Payouts

SMP and its payment providers use information to process payments, facilitate payouts, verify transactions, prevent payment fraud, manage chargebacks, process refunds or reversals, administer marketplace fees, and maintain transaction and accounting records.

Payment-processing activities may include billing verification, transaction authentication, payout administration, fraud screening, tax reporting, financial compliance reviews, and dispute management. Payment-processing services may be conducted through third-party providers such as Stripe and related financial institutions, which may independently collect, process, and retain financial information in accordance with their own policies and legal obligations.

SMP may also use payment-related information to monitor marketplace risk, investigate suspicious financial activity, and enforce Platform policies relating to transactions and marketplace participation.

3.7 Customer Support & Communications

SMP uses information to respond to support requests, communicate with users, provide transaction updates, send operational notices, resolve disputes, conduct investigations, and improve customer-support operations.

Communications may include account alerts, Auction notifications, payment confirmations, verification requests, dispute communications, technical support responses, moderation notices, security alerts, policy updates, marketplace announcements, and related operational or compliance communications.

SMP may also review, preserve, and analyze communications conducted through or relating to the Platform for training, quality assurance, fraud prevention, dispute resolution, legal compliance, enforcement, operational continuity, and marketplace-integrity purposes.

3.8 Marketing, Advertising & Promotions

SMP may use information for marketing, advertising, branding, promotional, editorial, analytics, and community-engagement purposes. This may include sending promotional communications, personalizing advertising, featuring listings or marketplace activity, conducting promotional campaigns, supporting social-media marketing, audience development, marketplace growth initiatives, content promotion, and measuring advertising or campaign effectiveness.

SMP may also use marketplace activity, engagement trends, browsing behavior, Garage participation, and Auction interactions to improve marketing strategies and personalize promotional experiences.

Users may opt out of certain marketing communications through unsubscribe mechanisms, communication settings, or other controls described in this Privacy Policy. However, SMP may still send transactional, operational, security, or legally required communications where necessary.

3.9 Analytics, Research & Platform Improvement

SMP may use information to analyze marketplace trends, monitor Platform performance, conduct research, improve functionality, develop new features, optimize user experiences, and support operational and business activities.

Analytics and research activities may include usage analysis, engagement tracking, Auction Performance monitoring, debugging, testing, traffic analysis, reporting, forecasting, feature evaluation, and marketplace behavior analysis.

SMP may also use collected information to improve Platform reliability, personalize marketplace experiences, enhance operational efficiency, and better understand how users interact with Auctions, listings, Garage features, and other marketplace functionality. Aggregated, anonymized, or de-identified information may be used for analytics, benchmarking, research, reporting, and business-improvement purposes where permitted by applicable law.

3.10 Legal Compliance & Enforcement

SMP may use information to comply with applicable laws, regulations, legal obligations, court orders, governmental requests, tax requirements, arbitration procedures, and regulatory inquiries.

Information may also be used to enforce the Terms of Service and Platform policies, investigate violations, preserve records, respond to disputes, protect intellectual property rights, and cooperate with legal authorities where reasonably necessary.

3.11 Protection of Rights & Marketplace Integrity

SMP may use information to protect the Platform, marketplace integrity, user safety, operational stability, SMP's legal rights and property, transaction security, and the rights of Buyers, Sellers, and third parties.

This may include monitoring marketplace activity, enforcing Platform rules, restricting abusive conduct, preserving evidence, and taking enforcement action where necessary to maintain a safe and trustworthy marketplace environment.

4. LEGAL BASES FOR PROCESSING (GDPR)

4.1 Performance of a Contract

SMP may process personal information where necessary to provide the Platform and to perform contractual obligations relating to account creation and administration, Auctions and marketplace participation, transaction processing, payment and payout services, customer support, enforcement of Platform policies, and the operation of marketplace functionality requested by users. Processing for contractual purposes is necessary for users to access and use the Platform and related services.

4.2 Legitimate Interests

SMP may process personal information where reasonably necessary for legitimate business and operational interests, including operating and improving the Platform, fraud prevention and security, marketplace analytics, risk management, communications, service optimization, marketing and promotion, dispute resolution, enforcement of Platform rules, and protection of SMP, users, and third parties. Where required by law, SMP will balance its legitimate interests against applicable user privacy rights and interests.

4.3 Consent

SMP may process personal information based on user consent where required by applicable law, including for certain marketing communications, optional cookies or tracking technologies, promotional activities, location-based features, or other consent-based processing activities. Users may withdraw consent at any time where legally permitted, although doing so may affect certain Platform functionality or services.

4.4 Legal Obligations

SMP may process personal information where necessary to comply with applicable legal, regulatory, tax, compliance, law-enforcement, arbitration, or governmental obligations. This may include processing information for identity verification, sanctions screening, fraud investigations, tax reporting, court orders, subpoenas, regulatory inquiries, dispute resolution, and compliance with applicable laws and regulations.

4.5 Protection Against Fraud & Abuse

SMP may process personal information where necessary to detect, investigate, prevent, monitor, or address fraud, chargebacks, payment abuse, Auction manipulation, unauthorized access, account compromise, deceptive conduct, security incidents, or other activity that threatens marketplace integrity, operational stability, or user safety.

Such processing may involve automated systems, behavioral analytics, audit logs, identity-verification tools, moderation systems, and third-party fraud-prevention or risk-management providers.

5. HOW WE SHARE INFORMATION

5.1 Sharing Between Buyers & Sellers

SMP may share information between Buyers and Sellers where reasonably necessary to facilitate Auctions, transactions, communications, vehicle transfers, payment coordination, dispute resolution, and related marketplace activity.

Shared information may include usernames, contact information, transaction details, payment status, vehicle-related information, pickup or shipping coordination details, verification status, and communications relating to marketplace transactions. Buyers and Sellers are responsible for how they use information received through the Platform and must comply with applicable laws, these policies, and reasonable privacy and security expectations when handling user information obtained through marketplace interactions.

5.2 Public Marketplace Information

Certain marketplace information may be publicly visible on the Platform to support marketplace transparency, community engagement, and Auction functionality. Publicly visible information may include listings, photos and videos, Garage profiles, usernames, comments, bid activity, Auction results, Crew participation, Trust Scores, marketplace engagement indicators, and related marketplace interactions.

Users acknowledge that information shared publicly through the Platform may be viewed, copied, captured, indexed, archived, shared, reposted, or redistributed by third parties outside SMP's control. SMP cannot guarantee the complete removal of publicly shared content or prevent third parties from retaining or reproducing publicly available marketplace information.

5.3 Service Providers & Vendors

SMP may share information with third-party service providers, contractors, vendors, and operational partners that assist with Platform operations, hosting, customer support, identity verification, payment processing, fraud prevention, analytics, communications, moderation, cloud infrastructure, security, data storage, marketing, and related business functions.

Such providers may access, process, or store information only as reasonably necessary to perform services on SMP's behalf and are generally expected to maintain appropriate confidentiality, privacy, and security protections. SMP may also utilize third-party providers to support Auctions, payment administration, dispute management, operational continuity, compliance obligations, technical support, and marketplace integrity.

5.4 Payment Processors & Financial Institutions

SMP may share information with payment processors, financial institutions, banking partners, payout providers, and related financial-service providers in connection with payment processing, payouts, fraud prevention, chargeback management, transaction verification, identity verification, tax reporting, financial reviews, and compliance obligations.

Payment-processing services may be provided through Stripe and related third-party providers, which may independently collect, process, retain, and disclose financial information in accordance with their own privacy practices, regulatory obligations, and service terms. SMP may also share transaction records, billing details, payment status information, and related marketplace activity where reasonably necessary to support financial operations, dispute resolution, fraud investigations, or marketplace security.

5.5 Analytics, Hosting & Infrastructure Providers

SMP may share information with analytics providers, hosting providers, cloud service providers, infrastructure vendors, performance monitoring services, communication providers, and related operational partners that support the operation, maintenance, security, reliability, and improvement of the Platform.

Such providers may process technical information, device information, usage activity, transaction-related data, communications, and marketplace interactions for analytics, troubleshooting, hosting, operational support, performance optimization, security monitoring, and infrastructure-management purposes. SMP may also utilize third-party providers to support data storage, system administration, backup services, operational continuity, scalability, and technical maintenance of the Platform.

5.6 Advertising & Marketing Partners

SMP may share information with advertising, marketing, analytics, social media, audience development, promotional, and campaign management partners to support advertising campaigns, audience measurement, promotional activities, social media engagement, retargeting, analytics, and marketing optimization. Information shared for marketing purposes may include engagement activity, browsing behavior, marketplace interactions, advertising performance metrics, and related analytics data.

Certain advertising, analytics, or social media technologies may use cookies, pixels, SDKs, web beacons, or similar tracking technologies as described in this Privacy Policy and the Cookie Policy. Users may manage certain marketing preferences or opt out of certain advertising activities through applicable communication settings, browser controls, or third-party opt-out mechanisms where available.

5.7 Law Enforcement & Government Requests

SMP may disclose information to law enforcement agencies, regulators, courts, governmental authorities, payment providers, or other authorized third parties where SMP reasonably believes disclosure is necessary to comply with applicable law, respond to subpoenas, court orders, arbitration demands, or governmental requests, cooperate with investigations, prevent fraud or unlawful activity, protect user safety, enforce Platform policies, or protect SMP's rights, property, operations, or marketplace integrity.

SMP may also preserve records, communications, transaction data, audit logs, payment information, and marketplace activity for legal, compliance, investigative, fraud-prevention, operational, or evidentiary purposes. Where permitted by law, SMP may also respond to consumer-protection inquiries, intellectual property disputes, regulatory investigations, security matters, or requests relating to suspicious marketplace activity or financial misconduct.

5.8 Business Transfers & Corporate Transactions

Information may be disclosed, transferred, preserved, or made available in connection with mergers, acquisitions, financing transactions, due diligence reviews, corporate restructuring, bankruptcy proceedings, sale of assets, operational transitions, or other business-transfer transactions involving SMP or its marketplace operations. In such circumstances, user information may be transferred as part of the associated business assets, operational infrastructure, transaction records, or corporate transition process.

SMP may also retain or disclose information where reasonably necessary to support continuity of services, legal compliance, enforcement of Platform policies, risk management, or protection of marketplace integrity during or following a corporate transaction.

5.9 Professional Advisors & Legal Compliance

SMP may share information with legal counsel, auditors, accountants, insurers, consultants, compliance advisors, payment-risk advisors, and other professional service providers where reasonably necessary for legal compliance, dispute resolution, fraud prevention, audits, investigations, tax matters, operational reviews, risk management, enforcement of Platform policies, regulatory matters, or protection of SMP's legal, financial, and business interests.

Such advisors may access information only as is reasonably necessary to perform professional services or to support SMP's compliance with, or operational, enforcement, or legal obligations.

5.10 With User Consent or Direction

SMP may share information with third parties where users request or authorize disclosure, direct SMP to share information, connect third-party integrations, participate in optional promotional activities, or otherwise provide consent for specific sharing activities.

Users may be able to manage certain sharing preferences through account settings or applicable consent-management tools, where available.

6. PUBLIC MARKETPLACE & COMMUNITY FEATURES

6.1 Public Listings & Auction Activity

The Platform is designed to support public marketplace participation, Auction visibility, and community engagement. Certain information relating to listings, Auctions, Projects, and marketplace activity may be publicly visible through the Platform to users, visitors, and third parties.

Publicly visible information may include Project listings, photos and videos, Auction activity, bid histories, Auction results, pricing information, timestamps, usernames, comments, engagement indicators, and related marketplace interactions.

Users acknowledge that publicly available marketplace information may remain visible after transactions conclude, listings are removed, accounts are modified, or marketplace activity has ended. Publicly accessible information may also be copied, indexed, archived, captured, shared, or redistributed by third parties outside SMP's control.

6.2 Usernames, Garage Profiles & Crew Participation

Usernames, Garage profiles, Crew participation, profile activity, and related community features may be publicly visible to other users and visitors of the Platform. Public profile information may include usernames, Garage names, profile photos, account activity, community engagement, comments, participation history, featured Projects, marketplace reputation indicators, Trust Scores, Crew affiliations, and related marketplace activity.

Users are solely responsible for determining what information they choose to display publicly through the Platform and acknowledge that publicly visible profile information may be accessible, indexed, archived, or shared by third parties outside SMP's control.

6.3 Comments, Engagement & Community Content

Users may participate in community discussions, leave comments and reactions, engage with engagement features, ask questions in public listing Q&A, and communicate through Messages for marketplace listings and related Platform features. Content submitted through community features may become publicly accessible and may be viewed by other users, indexed by search engines, shared on social media, copied or reposted by third parties, or retained in marketplace records, moderation systems, backups, or archives.

SMP may moderate, organize, remove, preserve, or review community content for operational, moderation, fraud prevention, legal compliance, or marketplace integrity purposes. Users remain solely responsible for the content they choose to publish, communicate, upload, or otherwise make publicly available through the Platform.

6.4 Marketplace Transparency Features

To support marketplace transparency, user trust, and Auction integrity, SMP may display certain marketplace activity and engagement indicators publicly through the Platform.

Transparency features may include bid visibility, Auction countdowns, transaction status, Trust Scores, verification badges, engagement metrics, Crew activity, and completed Auction information. SMP reserves the right to modify, limit, organize, remove, or expand transparency features and publicly visible marketplace information at any time.

6.5 Risks of Publicly Shared Information

Users acknowledge that information shared publicly through the Platform may be accessible to other users, search engines, advertisers, data aggregators, social-media platforms, and third parties outside SMP's control. Publicly shared information may be copied, reposted, archived, captured, indexed, or redistributed without SMP's involvement. SMP cannot guarantee the complete removal of publicly shared content or prevent third parties from accessing or retaining publicly available information.

7. COOKIES & TRACKING TECHNOLOGIES

7.1 Use of Cookies

SMP may use cookies, pixels, tags, SDKs, local storage, session technologies, and similar tracking technologies to operate, secure, and improve the Platform.

These technologies may be used to remember user preferences, authenticate accounts, maintain login sessions, support marketplace functionality, personalize user experiences, measure Platform performance, prevent fraud and abuse, and support analytics, advertising, and marketing activities.

Cookies may be temporary session cookies or persistent cookies that remain on a user's device after the browsing session ends.

7.2 Analytics Technologies

SMP may use analytics tools and technologies from third-party vendors to better understand Platform usage, user engagement, Auction activity, performance trends, technical issues, and marketplace behavior.

Analytics providers may collect information such as IP addresses, browser type, device identifiers, operating system information, referral URLs, session activity, and interaction data. Analytics information may be used to improve Platform functionality, optimize user experiences, troubleshoot issues, and support business operations.

7.3 Advertising & Retargeting Technologies

SMP and its advertising or marketing partners may use tracking technologies to personalize advertising, measure campaign performance, deliver promotional content, support retargeting campaigns, analyze audience engagement, and improve marketing effectiveness.

Advertising technologies may track interactions with listings, Auctions, Garage profiles, promotional campaigns, emails, advertisements, and related marketplace activity. Third-party advertising providers may use their own cookies or tracking technologies, subject to their respective privacy policies and practices.

7.4 Session Management & Authentication

Tracking technologies may be used to support account authentication, session management, login security, fraud prevention, account verification, device recognition, and operational security measures.

These technologies help maintain secure user sessions and protect the Platform from unauthorized access, account compromise, and suspicious activity.

7.5 Browser Controls & Cookie Preferences

Users may manage certain cookie settings and tracking preferences through browser settings, device settings, cookie consent tools, advertising preferences, or third-party opt-out mechanisms, where available. Users who disable cookies or tracking technologies may experience reduced functionality, limited marketplace features, authentication issues, or interruptions in Platform performance.

7.6 Do Not Track Signals

Some web browsers and devices may transmit "Do Not Track" ("DNT") signals. Because there is currently no universally accepted standard governing DNT signals, SMP may not respond to or alter data-collection practices when such signals are received unless otherwise required by applicable law.

8. COMMUNICATIONS & MARKETING

SMP may send transactional, operational, and service-related communications necessary to provide the Platform and marketplace services.

Such communications may include account notifications, Auction updates, bid confirmations, payment confirmations, payout notifications, verification requests, dispute communications, policy updates, security alerts, and customer-support responses. Users acknowledge that certain transactional communications are necessary for the operation of the Platform and may not be subject to general marketing opt-out preferences.

SMP may provide notifications and alerts relating to Auction activity, Send It activations, outbid notices, countdown reminders, listing updates, transaction status, Crew activity, account activity, and related marketplace events. Notifications may be delivered through email, SMS, push notifications, in-platform messaging, or other electronic communication methods supported by the Platform.

SMP may send marketing, promotional, editorial, advertising, and community-engagement communications relating to marketplace activity, featured Projects, Auctions, Garage content, promotions, events, surveys, newsletters, and new Platform features or services. Marketing communications may be personalized based on user activity, preferences, marketplace participation, or interactions with the Platform.

Users may opt out of certain marketing or promotional communications by using unsubscribe links, adjusting account communication settings, disabling device notifications, or following applicable opt-out instructions provided by SMP. Opting out of marketing communications does not prevent SMP from sending transactional, legal, compliance-related, security, or operational communications necessary for the operation of the Platform or enforcement of marketplace policies.

9. SMS COMMUNICATIONS

By providing your mobile number and opting in, you consent to receive SMS messages from Sell My Project regarding account notifications, authentication codes, project updates, auction activity, bidding notifications, customer support communications, and other service-related messages.

Message frequency may vary.

Message and data rates may apply.

You may opt out at any time by replying STOP. For assistance, reply HELP.

Mobile information will not be shared with third parties or affiliates for marketing or promotional purposes. All categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties.

10. PAYMENT PROCESSING & FINANCIAL INFORMATION

SMP may utilize Stripe and other third-party payment providers to facilitate payment processing, Buyer Premium collection, Seller payouts, billing operations, refunds, chargeback handling, and related financial transactions.

Payment providers may independently collect, process, store, and verify financial information in accordance with their own privacy policies, terms, and compliance obligations. SMP does not operate as a bank, escrow service, money transmitter, or financial institution. SMP and its payment providers may use payment and financial information to verify transactions, authenticate payment methods, prevent fraud, conduct risk assessments, monitor suspicious activity, detect chargeback abuse, review payout eligibility, and protect marketplace integrity.

Verification and fraud-screening activities may involve identity verification, billing verification, transaction monitoring, sanctions screening, behavioral analysis, device analysis, and third-party fraud-detection tools. Transactions may be delayed, reviewed, restricted, frozen, or declined where fraud-prevention, security, or compliance concerns arise.

SMP may collect, retain, review, and disclose transaction records, payment data, audit logs, bid histories, electronic consent records, communications, and related information in connection with chargebacks, payment disputes, fraud investigations, collection activities, or legal or compliance matters.

Users remain responsible for legitimate payment obligations associated with marketplace activity, including Auctions, listings, Buyer Premiums, and related fees. Improper chargebacks or fraudulent payment disputes may result in account suspension, payout restrictions, collection activity, recovery of losses and fees, permanent marketplace bans, or legal enforcement action.

SMP and its payment providers may process and retain financial information to comply with tax-reporting obligations, anti-fraud requirements, anti-money laundering obligations, sanctions compliance, payment-network rules, financial regulations, court orders, governmental requests, and related legal or compliance obligations.

Users acknowledge that financial information may be disclosed to payment providers, financial institutions, regulators, law enforcement agencies, or governmental authorities where reasonably necessary to comply with applicable laws or protect the Platform and its users.

11. DATA RETENTION

SMP retains personal information for as long as reasonably necessary to provide the Platform and marketplace services, maintain user accounts, process transactions, resolve disputes, enforce Platform policies, comply with legal obligations, and protect marketplace integrity and security. Retention periods may vary depending on the nature of the information, applicable legal requirements, operational needs, and risk-management considerations.

SMP may retain records relating to Auctions, bids, Send It activations, listings, transactions, payment activity, communications, dispute history, account activity, and marketplace participation. Transaction and Auction records may be retained for operational continuity, accounting purposes, fraud prevention, dispute resolution, legal compliance, marketplace integrity, or evidentiary purposes.

SMP may retain information relating to fraud prevention, security monitoring, investigations, moderation activity, account restrictions, suspicious conduct, audit logs, device information, and enforcement actions for as long as reasonably necessary to detect and prevent fraud, investigate abuse, maintain Platform security, enforce marketplace rules, and protect SMP, users, and third parties.

Certain security and fraud-prevention records may be retained even after account closure or deletion requests where permitted by law.

SMP may retain information as required or permitted by applicable tax laws, financial regulations, payment-network rules, arbitration procedures, court orders, governmental requests, compliance obligations, and legal recordkeeping requirements. This may include retention of payment records, tax documentation, identity-verification materials, transaction histories, communications, and compliance-related records.

Information may remain in backup systems, archived records, disaster-recovery storage, audit logs, moderation systems, or historical databases for a period after deletion requests, account closures, or removal from public display.

SMP may retain backup or archived information where reasonably necessary for operational continuity, security, fraud prevention, legal compliance, dispute resolution, or preservation of marketplace records.

12. DATA SECURITY

SMP maintains administrative, technical, physical, and operational safeguards designed to protect personal information against unauthorized access, disclosure, misuse, alteration, loss, or destruction.

Security measures may include account authentication controls, encryption technologies, access restrictions, monitoring systems, fraud-detection tools, audit logs, network-security measures, secure payment-processing integrations, and operational security procedures. SMP regularly reviews and updates security practices as reasonably necessary to support Platform security and marketplace integrity.

Users are responsible for maintaining the confidentiality and security of their account credentials, passwords, authentication methods, devices, payout accounts, and login information. Users remain responsible for activity conducted through their accounts and must promptly notify SMP of suspected unauthorized access, account compromise, fraudulent activity, phishing attempts, or other security concerns relating to their accounts or marketplace activity.

Although SMP implements security measures intended to protect information, no method of electronic storage, transmission, or online security is completely secure or guaranteed against unauthorized access, cyberattacks, security breaches, technical failures, or other risks. Users acknowledge that use of online marketplaces and electronic communications involves inherent security risks, and SMP cannot guarantee absolute security of information transmitted to, stored by, or processed through the Platform.

SMP may investigate, respond to, mitigate, document, and take appropriate action regarding suspected or actual security incidents, data breaches, fraud, unauthorized access, or other security-related concerns affecting the Platform or its users.

Where required by applicable law, SMP may provide notifications relating to certain security incidents or unauthorized disclosures of personal information. SMP also reserves the right to cooperate with law enforcement agencies, regulators, payment providers, security consultants, and other third parties in connection with security investigations or incident-response efforts.

13. USER RIGHTS & PRIVACY CHOICES

13.1 Access Rights

Subject to applicable law, users may request access to personal information SMP maintains about them, including information relating to account activity, marketplace participation, Auctions, transactions, communications, payment activity, and related data-processing activities.

SMP may request identity verification before responding to access requests and may deny or limit requests where permitted by applicable law, security requirements, legal obligations, the protection of third-party rights, fraud-prevention concerns, or operational considerations. SMP may also retain records relating to access requests for compliance, security, and recordkeeping purposes.

13.2 Correction & Update Rights

Users may request correction, modification, or updating of inaccurate, incomplete, or outdated personal information maintained by SMP. Certain account-, profile-, Garage-, payout-, communication-, and marketplace-related information may also be updated directly through user account settings or applicable Platform functionality.

SMP may request verification or supporting documentation before processing correction requests where reasonably necessary to protect marketplace integrity, prevent fraud, maintain operational accuracy, or comply with legal obligations.

13.3 Deletion Requests

Subject to applicable law, users may request deletion of certain personal information maintained by SMP. SMP may retain information where reasonably necessary for completed transactions, fraud prevention, dispute resolution, legal compliance, payment processing, accounting obligations, security monitoring, operational continuity, enforcement of Platform policies, marketplace integrity, evidentiary preservation, or other lawful business purposes.

Deletion of information may not result in complete removal from backup systems, archived records, audit logs, moderation systems, transaction histories, or historical marketplace records. Certain publicly visible marketplace information, Auction activity, comments, or transaction-related records may also remain accessible where necessary for operational, legal, compliance, or marketplace-integrity purposes.

13.4 Data Portability Rights

Where required by applicable law, users may request a copy of certain personal information in a portable and commonly used electronic format. Data portability rights may apply only to information processed by automated means and based on consent or contractual necessity.

13.5 Restriction & Objection Rights

Subject to applicable law, users may request restriction of certain processing activities or object to processing based on legitimate interests, direct marketing, profiling, or related data-processing activities.

SMP may continue processing information where permitted or required by law, including for legal compliance, fraud prevention, security, dispute resolution, or enforcement purposes.

13.6 Withdrawal of Consent

Where processing is based on consent, users may withdraw consent at any time by adjusting account settings, updating communication preferences, disabling certain cookies or tracking technologies, or contacting SMP.

Withdrawal of consent does not affect the lawfulness of processing conducted prior to withdrawal and may limit certain Platform functionality or services.

13.7 Appeal & Complaint Rights

Users who believe SMP has improperly handled a privacy request or violated applicable privacy laws may contact SMP to request further review or, where permitted by law, an appeal.

Users may also have the right to submit complaints to data protection authorities, consumer protection agencies, attorneys general, regulatory bodies, or other governmental authorities with jurisdiction over privacy-related matters.

14. CALIFORNIA PRIVACY RIGHTS (CCPA/CPRA)

If you are a California resident, you may have certain privacy rights under the California Consumer Privacy Act ("CCPA"), as amended by the California Privacy Rights Act ("CPRA"), subject to applicable legal exceptions and limitations.

Depending on applicable law and the nature of your relationship with SMP, California residents may have the right to request access to categories and specific pieces of personal information collected by SMP, request correction of inaccurate personal information, request deletion of certain personal information, request portability of certain personal information, request information regarding categories of personal information collected, disclosed, sold, or shared, limit certain uses or disclosures of sensitive personal information where applicable, opt out of certain data-sharing or targeted advertising activities, receive notice regarding SMP's data practices, and exercise privacy rights without unlawful discrimination or retaliation.

SMP may collect, use, disclose, retain, and process personal information for business and commercial purposes described in this Privacy Policy, including operating the marketplace, facilitating Auctions and transactions, payment processing, fraud prevention, analytics, advertising, customer support, legal compliance, and protection of marketplace integrity and operational security.

California residents may submit privacy rights requests using the contact methods identified in this Privacy Policy. SMP may require identity verification before processing requests and may request additional information reasonably necessary to verify the identity or authority of the requesting party.

In certain circumstances, SMP may deny, limit, or defer requests, as permitted by applicable law, including when retention of information is necessary for completed transactions, fraud prevention, security purposes, legal compliance, dispute resolution, enforcement of Platform policies, protection of legal rights, or other lawful business purposes.

SMP does not unlawfully discriminate against users for exercising applicable California privacy rights. However, certain Platform functionality, marketplace participation, communications, or services may be limited where information processing is necessary for the operation of the Platform or completion of marketplace transactions.

California residents may also designate an authorized agent to submit certain privacy-rights requests on their behalf, subject to applicable verification and authorization requirements.

15. GDPR & EEA PRIVACY RIGHTS

Users located in the European Economic Area ("EEA"), the United Kingdom, Switzerland, or other jurisdictions with similar data-protection laws may have certain rights under applicable privacy and data-protection legislation, including the General Data Protection Regulation ("GDPR").

Subject to applicable law and certain legal limitations or exceptions, eligible users may have the right to access personal information maintained by SMP, request correction of inaccurate or incomplete information, request deletion of personal information, restrict or object to certain processing activities, request portability of certain personal information, withdraw consent where processing is based on consent, object to direct marketing or profiling activities, and request review of certain automated processing activities where applicable.

SMP may process personal information under several legal bases described in this Privacy Policy, including performance of a contract, legitimate business interests, legal obligations, fraud prevention and security purposes, and user consent where required.

Users may submit GDPR or privacy-rights requests using the contact methods identified in this Privacy Policy. SMP may require identity verification before processing requests and may request additional supporting information where reasonably necessary to confirm identity, authority, or the scope of the request.

In certain circumstances, SMP may deny, limit, or defer requests where permitted by applicable law, including where processing or retention of information is necessary for legal compliance, fraud prevention, dispute resolution, enforcement of Platform policies, protection of legal rights, operational continuity, public-interest obligations, or other lawful business purposes.

Users located in the EEA, the United Kingdom, or similar jurisdictions may also have the right to lodge complaints with the applicable supervisory authorities, data protection regulators, or governmental privacy agencies if they believe their personal information has been processed in violation of applicable law.

Where required by applicable law, SMP may implement contractual, technical, organizational, or operational safeguards designed to support lawful international transfers of personal information and protection of user privacy rights.

16. INTERNATIONAL DATA TRANSFERS

SMP operates primarily within the United States, and personal information collected through the Platform may be processed, stored, transferred, or accessed within the United States or other jurisdictions where SMP, its service providers, or operational partners maintain facilities or operations.

Users acknowledge that privacy and data-protection laws in the United States may differ from those in their home jurisdiction.

By accessing or using the Platform, users acknowledge and consent to the transfer of personal information across national borders where reasonably necessary for Platform operations, Auctions and marketplace activity, payment processing, customer support, hosting and cloud services, fraud prevention, analytics, communications, legal compliance, and related business operations.

Cross-border transfers may involve transfers to jurisdictions that may not provide the same level of data-protection rights or legal safeguards as the user's home jurisdiction.

Where required by applicable law, SMP may implement reasonable safeguards designed to support lawful international data transfers, including contractual protections, data-processing agreements, security measures, compliance procedures, and other transfer mechanisms recognized under applicable privacy laws. Despite such safeguards, users acknowledge that international data transfers may involve inherent legal, operational, and security risks beyond SMP's direct control.

17. CHILDREN'S PRIVACY

The Platform is intended solely for individuals who are at least eighteen (18) years old or the age of majority in their jurisdiction. SMP does not knowingly permit minors to create accounts, participate in Auctions, submit bids, activate Send It Auctions, list Projects, complete transactions, engage in marketplace activity, or otherwise use the Platform. By accessing or using the Platform, users represent and warrant that they meet the applicable age requirements, have the legal capacity to enter into binding agreements, and are not prohibited from using the Platform under applicable law.

SMP does not knowingly collect, solicit, process, or maintain personal information from children under the age of thirteen (13) or other minimum age thresholds established under applicable privacy or consumer-protection laws. The Platform is not directed toward children, and SMP does not intentionally design marketplace services, Auctions, advertising, or community features to target minors.

If SMP becomes aware or reasonably believes that personal information has been collected from a child in violation of applicable law, SMP may take actions reasonably necessary to protect privacy and comply with legal obligations. Such actions may include removing or restricting access to the information, terminating associated accounts, disabling marketplace participation, restricting Platform access, preserving records for legal-compliance purposes, or taking other operational or protective measures deemed appropriate by SMP.

Parents or legal guardians who believe that a child may have provided personal information to SMP may contact SMP using the contact methods identified in this Privacy Policy to request review, investigation, or deletion of the applicable information. SMP may require reasonable verification before responding to such requests and may retain certain records where required or permitted by applicable law, fraud-prevention obligations, dispute-resolution requirements, or security-related purposes.

18. THIRD-PARTY LINKS & SERVICES

The Platform may contain links to third-party websites, applications, services, tools, integrations, advertisements, social-media platforms, payment providers, shipping providers, or other external resources not owned or controlled by SMP.

User interactions with third-party services may be subject to separate terms, policies, and privacy practices established by those third parties. SMP does not control and is not responsible for the availability, content, functionality, security, or practices of third-party websites or services. Third-party providers connected to the Platform may independently collect, process, store, or share personal information in accordance with their own privacy policies and legal obligations.

This may include payment processors, analytics providers, advertising partners, hosting providers, authentication services, social-media platforms, and embedded third-party technologies. Users are encouraged to review the privacy policies and terms applicable to any third-party services they access through or in connection with the Platform.

The Platform may include embedded content, social-media features, sharing tools, videos, widgets, plugins, or integrations provided by third-party platforms or services. These features may collect IP addresses, device information, browsing activity, cookie data, interaction information, and related technical or usage data.

Interactions with social media platforms and embedded third-party content are governed by the privacy practices and policies of the applicable third-party providers, rather than by SMP.

19. BUSINESS TRANSFERS & CORPORATE CHANGES

SMP may transfer, disclose, or make available personal information in connection with mergers, acquisitions, financing transactions, due diligence reviews, sale of assets, corporate restructuring, or other business-transfer transactions involving SMP or its operations. User information may be transferred as part of the associated business assets, operational transition, or corporate transaction process.

In the event of bankruptcy, insolvency, receivership, reorganization, liquidation, or similar corporate proceedings, personal information may be transferred, disclosed, sold, or otherwise processed as part of the applicable legal or operational process.

SMP reserves the right to retain, preserve, or transfer records where reasonably necessary for legal compliance, operational continuity, protection of marketplace integrity, enforcement of rights and obligations, or administration of corporate or legal proceedings.

20. CHANGES TO THIS PRIVACY POLICY

SMP reserves the right to update, revise, modify, or replace this Privacy Policy at any time to reflect changes in Platform functionality, marketplace operations, legal or regulatory requirements, business practices, security measures, or data-processing activities. Updated versions of this Privacy Policy become effective upon posting or other notice provided by SMP unless otherwise required by applicable law.

Where required by applicable law or where SMP determines it appropriate, SMP may provide notice of material changes to the Privacy Policy through email communications, Platform notifications, account alerts, updated effective dates, or other reasonable communication methods. Users are responsible for reviewing the Privacy Policy periodically to remain informed about SMP's privacy practices and policy updates.

Continued access to or use of the Platform following the effective date of the updated Privacy Policy terms constitutes acknowledgment and acceptance of the revised Privacy Policy to the fullest extent permitted by law. If a user does not agree with the updated Privacy Policy terms, the user should discontinue use of the Platform.

21. CONTACT INFORMATION

Users may contact SMP with questions, concerns, or requests regarding this Privacy Policy, personal information, data-processing practices, marketplace privacy matters, or related compliance issues, using the contact methods designated by SMP.

Privacy-related communications may include account privacy inquiries, data-access requests, correction requests, deletion requests, marketing preferences, and general privacy concerns. SMP reserves the right to update contact methods, communication procedures, or support channels at any time.

Users may submit requests regarding applicable privacy rights, including requests for access to personal information, correction of inaccurate data, deletion of personal information, restriction of processing, portability, withdrawal of consent, or objection to certain processing activities. SMP may require identity verification before responding to privacy-rights requests and may, where permitted by applicable law, deny such requests.

Copyright-infringement notices and intellectual property complaints may be submitted to SMP in accordance with applicable DMCA procedures and Platform policies.

Complaints should generally include:

• identification of the protected work;
• identification of the allegedly infringing material;
• sufficient information to locate the material;
• contact information of the complaining party;
• a good-faith statement regarding unauthorized use;
• a statement made under penalty of perjury regarding accuracy and authority; and
• a physical or electronic signature of the rights holder or authorized representative.

SMP reserves the right to remove allegedly infringing material, disable access to disputed content, preserve records, cooperate with legal authorities, or, where appropriate, terminate repeat infringers.

Government agencies, regulators, law enforcement authorities, consumer-protection agencies, courts, and authorized legal authorities may contact SMP regarding compliance inquiries, subpoenas, court orders, investigations, fraud-prevention matters, intellectual property claims, consumer complaints, or other legal or regulatory matters.

SMP reserves the right to cooperate with lawful governmental requests, preserve records, disclose information where legally required or reasonably necessary, and respond to regulatory inquiries consistent with applicable law and Platform policies.