Privacy Policy & Notice of Collection

About Our Online Platform & Users

Our Online Platform provides a trusted marketplace where buyers can access and purchase pre-owned agricultural equipment and related machinery offered by the Company. Through our Online Platform, you can browse and participate in auctions for a wide selection of competitively priced equipment, including tractors, combines, sprayers, and more from top brands such as John Deere, Case IH, and Brent, as well as apply for financing to assist with your purchase (the "Platform Services"). Your visit to our Online Platform is generally done in your capacity as an "Auctioneer Participant" who is using our Online Platform to browse equipment listings, bid in auctions, apply for financing, and purchase equipment. With this in mind, when you visit our Online Platform to access or use the Platform Services as an Auctioneer Participant, we are generally the controller of information and data we collect (if such information can identify you), and we will use and process it in accordance with this Privacy Policy and our separate Terms of Use, available at [link] (our "Terms of Use").

1. Information We Collect About You

As you access and interact with our Online Platform, we may collect (i) personal information or data that can potentially identify you, as described in more detail below, and (ii) other non-personal information or publicly available data that does not identify you, such as such as information related to auction listings, bid history, comments, or other user-generated content that is shared within the Online Platform or derived from publicly accessible sources such as articles, other marketplaces we partner with, media coverage, or published works.

With respect to information of Auctioneer Participants, we may collect the following information or data about you when you access and register to use our Platform Services and voluntarily create your unique profile:

• Common Identifiers. First name, last name, birth date, your profile name or nicknames for auction participation, email address, mailing address, phone number, and profile photo.
• Approximate Location. In your use of the Online Platform as an end user, we may also gather information through Tracking Technologies concerning your approximate location if location services are turned on through your device or browser settings.
• Payment Card Information. If you use our online payment system to process payments for any winning bids, we may use our third-party processors to collect your payment details and information.

In general, we collect this information above directly from you when you visit the Online Platform and voluntarily complete the registration process to use the Platform Services, or as you engage in bidding and auction-related activities. We may also periodically obtain both personal and non-personal information about you from lawful online gathering activities (such as publicly-available web scraping data) and through affiliates, business partners and partner associations who offer similar auction sites, ad services, and other third parties when those parties lawfully share the information with us.

WE GENERALLY DO NOT COLLECT INFORMATION THAT IS CONSIDERED SENSITIVE OR HIGHLY PROTECTED UNDER DATA PROTECTION LAWS (and even then, only with your consent by you affirmatively uploading that information to your profile).

2. Use of Tracking Technologies (Cookies)

In addition to our direct collection efforts described above, we may use, in our reasonable discretion, various tracking technologies, collection systems, and cookies or Google Analytics (collectively, "Tracking Technologies") to collect personal and non-personal information from your device based on your activity on our Online Platform, doing so according to this Privacy Policy.

As you may already know, Tracking Technologies retain information about your activity on our Online Platform and other online locations to disclose that information to us or the owner of the applicable webpage or mobile application. When you access our Online Platform, we may use Tracking Technologies to follow your usage of our Online Platform and the information you review or bid on. The information we obtain in this manner enables us to customize the Online Platform, to understand the markets and items you bid on for the Platform Services, and to measure the overall effectiveness of our online presence. We may also allow third parties, API-integrated parties, and ad networks to display advertisements on our Online Platform from time to time, some of which may include links to those third parties' own sites. These companies may also use Tracking Technologies to collect information about users viewing or interacting with their advertisements. These third-party sites have separate and independent privacy policies, notices of collection, and terms of use. We do not assume responsibility or liability for the content and activities of these linked sites, and we encourage you to directly review the policies and privacy practices on those sites.

You may choose to opt out of certain Tracking Technologies by modifying your browser and device settings. If you do so, however, some of the information or content on our Online Platform may be inaccessible. WE RECOMMEND YOU REVIEW YOUR DEVICE SETTINGS TO CONFIRM IF TRACKING TECHNOLOGIES, INCLUDING GEOLOCATION TRACKING, HAVE BEEN PROPERLY DISABLED OR CONFIGURED TO YOUR PREFERENCE.

3. Purposes for Which We May Use the Information We Collect

We collect, use, and process your personal and non-personal information to pursue our legitimate business interests in promoting an auction marketplace for pre-owned agricultural equipment, performing our ongoing contractual obligations with you on the Online Platform (according to our separate Terms of Use), and marketing information concerning the Company and our Platform Services. In furtherance of those purposes, we may use the information that we collect about you to:

• Operate, maintain, and provide features of the Online Platform. For example, we may use your profile information, bidding history, or preferences to facilitate your participation in auctions, help you discover relevant equipment listings, provide customer support, recommend auctions that may be of interest, and enable secure transactions
• Perform research and analysis about our Platform Services.
• Perform our contractual obligations according to the provisions of our Terms of Use.
• Contact users of the Online Platform to provide support after such users voluntarily contact us.
• Contact users through their voluntarily disclosed phone numbers, email addresses, or other contact information, including, without limitation, (a) to inform them of platform-related updates, new features, marketing communications, auction results, payment or shipping notifications, financing or account-related matters, and feedback requests, and (b) to communicate special offers or promotions from the Company or its affiliates regarding equipment, services, or financing options.
• Conduct surveys for our own internal or marketing purposes.
• Aggregate information and end user reports to more effectively offer and develop the Online Platform and Platform Services.
• Comply with legal obligations and prevent illegal activity, fraud, or abuse.
• Enforce or defend the intellectual property and other rights underlying our Online Platform and Platform Services if we detect misuse of those rights.
• Use the information as otherwise described to you in our Terms of Use or other published policies.

4. How and With Whom We May Share Your Information

4.1 With Other Users or Online Viewers

By design, information you upload or share on the Online Platform, such as bidding activity, may be visible to other users and auction participants. As the moderator of our Online Platform, we may share (or review) your information when you engage in these types of activities.

4.2 With our Service Providers and Marketing Partners

We may share your information, profile, and data, including contact information, with our support personnel and contractors who need such information to authenticate your log-in to the Online Platform and send you informational updates (so long as you have not opted out of such messaging in accordance with our Terms of Use). We may share your personal information for commercial purposes with others, such as our subsidiaries or affiliates, contractors, IP partners, service providers (including third party marketing partners or ad agencies), developers, and other third parties we use to support our Online Platform and Platform Services so long as those parties are bound by contractual or fiduciary obligations to keep your personal information secure and to use it only for the purposes for which we disclose it to them (e.g., in support of our Online Platform or API integration with our Platform Services).

4.3 For Aggregated Statistical Purposes

In maintaining our Online Platform, we may also use, process, or sell aggregate information that does not identify you, such as survey responses, aggregated reports and user engagement details on prediction markets, and other statistical information, for any purpose permissible under applicable data and consumer privacy laws.

4.4 For Legal Purposes and to Defend our Rights

We may also share personal information if we believe in good faith that doing so is required by law or is otherwise required to exercise or defend legal rights, take precautions against liability, protect the rights of any individual, protect the integrity and proprietary rights of the Online Platform, protect the Platform Services or others from fraudulent or unlawful activity, or defend against third party claims (including claims under our Terms of Use).

4.5 In Connection with a Sale of the Company

We may also share your personal information and data as part of a sale, merger or change in control, or in preparation for any of these events that impact the Company or our affiliates. Any other entity that acquires the Company or part of our business will have the right to continue to use your information and data available on the Online Platform, but only in the manner set out in this Privacy Policy unless you agree otherwise.

5. Your Rights Concerning Your Personal Information

5.1 U.S. Consumer Rights

Pursuant to applicable U.S. data protection and consumer privacy laws, you may contact us to request the exercise of certain rights concerning your personal information, including the right to: (i) request that we disclose the categories and specific pieces of personal information we have collected and disclosed about you; (ii) confirm and know whether we have processed or sold your personal information; (iii) request information about the Company's disclosure of personal information to our affiliates or service providers (including for their marketing purposes); (iv) opt-out of the Company sharing your personal information with third parties and our service providers; (v) request that we provide a copy of your personal information to you (data portability); (vi) request that we update your personal information or correct any inaccuracies you have detected through your use of the Online Platform; (vii) opt-out of any direct or indirect profiling or targeted advertising we may engage in based on your use of the Online Platform and our Tracking Technologies; or (viii) request that we otherwise delete your personal information. You also have the right to lodge a complaint with a supervisory authority if you believe we have breached the terms of this Privacy Policy with respect to your personal information. Depending on where you are located, some of these rights may not apply or may be subject to limitations. For example, we may limit the number of requests you make or charge reasonable fees as legally permitted. YOU WILL NOT FACE DISCRIMINATION FOR EXERCISING YOUR RIGHTS WITH RESPECT TO YOUR PERSONAL INFORMATION. Notwithstanding anything else herein to the contrary and except as required by applicable law or regulation, while your content remains active in an open marketplace or event, the rights and license you have granted to the Company and our partners pursuant to this Privacy Policy or the Terms of Use will remain in full force and effect.

5.2 Exercising Your Rights

You or your authorized representative may contact us (at the contact information below) to exercise these rights set out above. Your request must provide sufficient information that allows us to reasonably verify you are the data subject about whom the request is made and describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

5.3 Opt-out Instructions

If you wish to opt-out of certain features of the Online Platform or our Tracking Technologies, please contact us at the information set out below and we will provide instructions or clarify whether such request is within the scope of our current features.

6. Age Restrictions

Our Online Platform (and the Platform Services) are not generally intended for persons under 18 years of age or under the age of legal majority in their jurisdiction of residence, whichever is higher. If you are under the age of 18 or the applicable age of majority, please do not provide any personal information to the Company through the Online Platform or access the Platform Services. We do not knowingly collect personal information from anyone under 18 or under the age of majority without appropriate parental or legal guardian consent. If you believe we may have collected information from or about a person under 18 or the age of majority without proper consent, please notify us immediately at the support email listed below in Section 10.

7. Visiting Our Online Platform from Outside the United States

Please be aware that if you visit our Online Platform from any jurisdiction outside of the United States, your information may be transferred, stored, and processed in the United States—which primarily serves as the main location of our data servers. Data protection and other consumer laws in the United States might not align with those in your jurisdiction, even in light of the consumer rights we have disclosed above. By accessing the information on our Online Platform, you understand that your personal information and data may be transferred to our facilities and to those third parties with whom we share the information, as we've previously explained in this Privacy Policy.

8. Data Retention Period & Security Measures

We retain your personal information for a reasonable period to fulfill the purposes for which we collected it (as outlined in this Privacy Policy), including to defend our rights under the Online Platform and the Platform Services. If we no longer reasonably need personal information for such purposes, we will, at our election and in accordance with applicable data protection laws, delete it from our records, anonymize the personal information, or archive the personal information in a manner consistent with industry standards for protection and retention of personal information, unless applicable law or legal considerations necessitate a longer retention period (as the case may be). If you elect to suspend or close your access to the Platform Services, we may retain your information and keep your profile log stored in our records for a reasonable time period, unless you affirmatively close and delete your account.

We strive to use technical and organizational measures to protect personal information against loss, misuse, and unauthorized access, use, or alteration. However, we cannot guarantee the complete security of these measures, so please exercise caution when submitting personal information online, including through our Online Platform. The Company is not responsible for the individual actions of any users who take publicly posted information and use it for their own purposes.

9. Changes to This Privacy Policy

We may update or change this Privacy Policy from time to time based on modifications in law or internal review of our policies and procedures. When we perform an update, we will amend the "last updated" date above and notify you if such changes materially affect your rights or our obligations under this Privacy Policy. If you continue using our Online Platform after the Privacy Policy has been updated, you will be considered to have accepted the new terms.

10. How to Contact Us

If you have any questions, comments, or complaints about this Privacy Policy or our practices under applicable date protection and privacy laws, or if you have any requests in regard to your personal information, please contact: [insert email].