Table of contents

• General
• What personal information do we collect
• How we use your personal information
• Transfers of your personal information to other jurisdictions
• Marketing Purposes
• Cookies
• Data subject rights – accessing, rectifying, changing and deleting your personal information, and withdrawing consent
• Protection and retention of your personal information
• Other Information

1. General

This Privacy Policy outlines how eBuy Artisan Network (EAN) collects, uses, stores, shares, and protects your personal information. It applies to our website, applications, services, and tools. By using our Services, you consent to the collection and use of your personal information as described in this Privacy Policy, Cookie Policy, and Terms of Use. We may update this policy periodically, and changes will be effective immediately after posting on our website. 

2. What personal information do we collect

You can visit our website without registering for an account. When you decide to provide us with your personal information, you agree that such information is sent to and stored on our servers. We collect the following types of personal information:

Information we collect automatically: When you visit our website, use our Services and or reply to ads or other content, we automatically collect the information sent to us by your computer, mobile device or other equipment that provides access. This information includes, but is not limited to:

• information from your interaction with our Website and Services, including, but not limited to, device ID, device type, general geo-location information derived from IP address, computer and connection information, statistics on page views, traffic to and from EAN, referring URL, ad data, IP address and standard web log information; and
• information we collect through cookies, web beacons and similar technologies. 

Information you provide to us: We collect and store any information you enter on our website or that you provide to us when you use our Services. This information includes, but is not limited to:

 Information that you provide to us when you register for an account or for the Services that you use, such as your full name and/or username, email address, social media links, address and profile photo. 

• additional information that you may provide to us through social media sites or third-party Services. 
• information provided in the context of dispute resolution, correspondence through our website or correspondence that is sent to us. 
• with your consent, information about your location and the location of your device, which is used to help you set your search area and provide you with other relevant information that relates to your location. You can adjust your location preferences at any time in your device settings, and 
• your resume if you choose to submit it to us for consideration through our careers page 

 Information from other sources: We may receive or collect additional information about you from third parties and add this to our account information. This information includes, but is not limited to demographic data, navigation data, additional contact data and additional data about you from other sources, such as public authorities, to the extent permitted by law.

 3. How we use your personal information

You agree that we may use your personal information for the following purposes:
 to provide you access to our Services and Customer Support by means of e-mail or telephone.

• to prevent, detect and investigate potentially prohibited or illegal activities, fraud and security breaches and to enforce our Terms of Use. 
• to personalize, measure and improve our Services, content and ads. 
• to contact you, by e-mail, push notification, text message (SMS) or by telephone, to inquire about our Services and the services of companies that are part of the EAN.
• to provide you with other services that you have requested, as described when we collected the information, 
• to administer contests, and 
• to consider you as a potential candidate if you choose to upload your resume through our careers page.

 Sharing information with and registration on social media sites: We offer sign-on services that allow you to access our website using your existing login credentials. You can also share information with third-party social media sites like Facebook through our services. If you grant us access to your personal information on these third-party sites, the scope of access will depend on your browser settings and your consent. By connecting your third-party account to your EAN account, you agree to our collection, use, and storage of your information in accordance with this Privacy Policy.

Transfer of your personal information to third parties: We may disclose your personal information to third parties in accordance with this Privacy Policy and applicable legislation and regulations. We will not disclose your personal information to third parties for their marketing purposes without your explicit consent. We may share your personal information with:

 Companies of the Classifieds Group to provide joint content and services (such as registration and customer support), to prevent, detect and investigate possible illegal activities, violations of our policy, fraud and/or data security breaches, and to support decision making on products, websites, applications, services, tools and communication. The Classifieds Group companies will use this information to send you marketing messages when you yourself have requested their services, and they will use your personal information in accordance with their respective privacy policy.

• service providers with whom we have entered into an agreement to help us provide our Services on the website, such as financial service providers, analytics service providers (including so that they might compare the data (e.g. email and phone number) in encrypted (or “hashed”) form with their own databases, to identify users who are known to both of us and the respective service provider, enabling us to display more targeted marketing on Google), marketing agencies and advertising-related service providers, and technical support. In such cases, the personal information shall remain under the control of EAN. If you are listing an ad, your listing or business address may be displayed on a map in your ads (including within the EAN mobile application) via Google Maps and therefore transferred to Google (refer to the Google Privacy Notice for more info). Your information may also be provided to Microsoft in connection with our use of Microsoft Advertising (refer to Microsoft’s Privacy Statement for more info).
• certain third parties (such as intellectual property rights holders, supervisory authorities, tax authorities, police and other regulatory authorities) if we are required to do so by law, or in accordance with our Privacy Policy. We may share your personal information:

1. to comply with legal obligations or a court order; or
2. if this is necessary for the prevention, detection or prosecution of criminal offenses, such as fraud, deceit or prosecution, or
3. if it is necessary to maintain our policies or to protect the rights and freedoms of others.

• other third parties to whom you have given consent to share your information via EAN, e.g. in the framework of an on-site integration. 
• companies that we intend to merge with in the context of a re-organisation or that acquire us; 
• an intellectual property owner if the owner of an intellectual property right or an intermediary in good faith believes that an advertisement violates the rights of the owner. Before personal information is provided, the IP owner will enter into an agreement that, inter alia, stipulates that information is only provided on the strict condition that it may only be used in the context of legal proceedings and/or obtaining legal advice and/or to answer questions from the relevant advertiser

Without limitation to the foregoing, we shall moreover – in our efforts to respect your privacy and to keep the website free of malicious persons or parties – not disclose your personal information to third parties without a court order or formal request from the government in accordance with applicable law, unless we believe in good faith that such disclosure is necessary to prevent impending injury or financial damages or to report alleged illegal activities, or is required by applicable law.

Information you share on EAN: When using our website, you can share information with other users, including advertisements and contact details. Be cautious about sharing personal information, as you’re responsible for what you share. We can’t guarantee the privacy or security of information shared with others, or how they’ll use it. For shared computers or public internet access, log off after each session and consider clearing cookies and browsing history to protect your credentials.

4. Transfers of your personal information to other jurisdictions

We may transfer your personal information to recipients in other countries, which may have different data protection laws. In such cases, foreign governments or agencies may access your information under local laws. However, we’ll protect your personal information according to this Privacy Policy, even when transferring it to other countries or corporate affiliates, who may process data on servers worldwide.

5. Marketing Purposes

We’ll use your information to send you offers and contact you about EAN’s products and services, as well as those from our affiliates. We won’t sell or rent your personal information to third parties for marketing without your consent. We may combine your information with data from other sources to enhance our services and personalize your experience. You can manage your marketing preferences in your EAN account or unsubscribe via the link in our messages.

6. Cookies

We and our service providers use cookies, web beacons, and similar technologies to identify users, enhance website experiences, measure promotional effectiveness, and ensure trust and safety, as further detailed in our Policy on Cookies, Web Beacons, and Similar Technologies 

7. Data subject rights – accessing, rectifying, changing and deleting your personal information, and withdrawing consent

 Accessing or obtaining a copy of your personal information: You may access your personal information or account information by logging into your EAN account. Alternatively, you can also contact Customer Support by selecting Privacy – Access Information to access or obtain a copy of your personal information stored by us (including information that is not directly accessible on EAN), unless we are not required to provide access or a copy under applicable law. We may charge a fee to compensate costs; however, the fee shall not exceed the amount permitted by law. 

Correcting your personal information: If your information is factually incorrect or incomplete or irrelevant for the purposes for which we process your information, you may request that we rectify your information by contacting Customer Support and selecting Privacy – Rectify Information. Such requests will be handled in accordance with applicable law. 

Changing your personal information: We cannot modify your personal information or account information. You can modify your own information by logging into your EAN account. When you place a classified ad, you may not be able to change your listing or delete your message. 

Deleting your personal information: If you want to close your account (where applicable) with us and/or delete your personal information, please send us a request by contacting Customer Support and selecting Privacy – Delete Information. You may also initiate a request via the EAN web/app. We will process your request within a reasonable period and in accordance with applicable law. Please note we may not delete information which we are required or permitted to retain under the applicable law. 

Withdrawing Consent: You have the right to object and opt-out of certain uses and disclosures of your personal information and may withdraw your consent to our processing of your personal information at any time by contacting us. Please note that even if you opt-out, we may still collect and use non-personal information regarding your activities on our website.  Please note that our processing of these requests are subject to certain exceptions, and therefore may not be applicable in instances where we need to retain the information (i) under applicable law or to preserve our rights, (ii) as required to deter and identify potential fraud, spam, criminal activity or other suspicious behaviours, (iii) as reasonably required to keep records of your request, (iv) if related to previously deleted ads or replies (which information, subject to (i)-(iii), may still be in the process of being deleted). You may also contact us concerning any of the above requests by writing to EAN management.

8. Protection and retention of your personal information

We protect your personal information by using technical and administrative security measures (such as firewalls, data encryption, and physical and administrative access controls to the data and servers) that limit the risk of loss, abuse, and unauthorised access, disclosure, and alteration. Nevertheless, if you believe your account or information has been abused, please contact us.

We use the reCAPTCHA Enterprise tool on our website to help detect and prevent fraud, spam and abuse. This tool collects information about your hardware and software (such as device or application data) and sends it to Google to run and improve the tool, as well as for general security purposes. Please note that your use of reCAPTCHA Enterprise is subject to Google’s Terms of Service and Privacy Policy.  We retain personal information if is legally permissible and delete personal information when it is no longer necessary for the purposes as described above.

 9. Other information

 Abuse and unsolicited commercial communications (“spam”): We do not tolerate abuse of our website. You do not have permission to add other EAN users to your mailing list (e-mail or postal) for commercial purposes, even if a user has purchased something from you, unless the user has given his explicit consent. If you notice that someone is abusing our website (spam or spoof emails), please notify us. It is not allowed to use our member-to-member communication resources to send spam or content that violates our Terms of Use in any other way. For your security, we may scan messages automatically and check for spam, viruses, phishing and other malicious activity or illegal or prohibited content. We do not permanently store messages sent through these resources.
Third Parties: Unless explicitly provided otherwise in this Privacy Policy, this Privacy Policy applies only to the use and transfer of information we collect from you. EAN has no control over the privacy policies of third parties that may apply to you. When we work with third parties or use third party tools to provide certain services, we will explicitly indicate which privacy policy applies to you. We therefore encourage you to ask questions and review third party privacy policies before you disclose your personal information to others.

Contact: If you have any questions about this Privacy Policy or our processing of your personal information, please contact us by writing to EAN management.