This policy governs only Truffles FZCO (hereinafter may referred to as «We» or «Us») use and disclosure of information We collect when users elect to use the Truffle.bid system (located on Our web site https://truffle.bid, also referred to as the «Site») or use Truffle services, or view advertisements We serve.

This policy does not otherwise apply to the practices of other web sites, third-party advertisers or advertising networks, or other services or companies that we do not own, manage or control. We do not control the privacy practices of such third parties, and you are subject to the privacy policies of those third parties when you use their services.

We may collect information about You through the following means:

• when you complete a Truffle registration of a personal account as a publisher or an advertiser, to render or acquire services from Us,
• when you visit Our web site, use Our widgets, visit a third-parties web site using Truffle services, or respond to advertisements served by Us or on Our behalf.

Types of information about You We collect:

Personal data (provided solely by publishers and advertisers when registering an account): Your first name and last name, Your company name, Your e-mail address, phone number, credit card number and billing address, registered office address.

Content interaction data: information gathered by using cookie files, providing Us with data on Your use of the Truffle system or its’ widget, You visiting a web site that includes the Truffle widget or uses Truffle, Your clicks and views of advertisements We serve on Truffle.

This information includes:

• general click stream behavior such as web pages viewed (including the URL addresses of such pages),
• search queries from which users are directed to a page, navigation from page to page through Our services,
• Your IP address,
• information about Your geographic location derived from Your IP address,
• domain name of Your Internet service provider,
• information about Your interactions with the Truffle system (clicks on links, visited pages, interactions with banners, icons, etc.),

A cookie is a small file containing a string of characters that is sent to your computer and stored on your hard drive when you visit a website; each website can send its own cookies to your browser. A persistent cookie is the type of cookies to remain on your hard drive after you close your browser. Persistent cookies may be used by your browser on subsequent visits to the site. Persistent cookies can be removed by following your web browser's directions. A session cookie is temporary and disappears after you close your browser. You can reset your web browser to refuse all cookies or to indicate when a cookie is being sent. However, some features of the Service may not function properly if the ability to accept cookies is disabled.

How We use gathered data:

We use Your Personal data to enable You to create an account to receive or render advertisement services to Us, store log-in credentials, and customize Your Truffle services, to provide feedback on Your queries, to fulfill requests you may make to Us, and use Your data to conduct research on use of Our services, facilitate payments to You for services rendered to Us, or receive payments for services rendered to You.

We use Your Personal data to enable You to create an account to receive or render advertisement services to Us, store log-in credentials, and customize Your Truffle services, to provide feedback on Your queries, to fulfill requests you may make to Us, and use Your data to conduct research on use of Our services, facilitate payments to You for services rendered to Us, or receive payments for services rendered to You.

We use Your Content interaction data to customize the advertisements displayed to You on Our Site to provide you with information and offers from Us or third parties that We believe you may find useful or interesting, including newsletters, marketing or promotional materials and other information on services and products offered by Us or third parties. We use cookies to uniquely identify a browser, which gives advertisers the ability to show targeted ads that are relevant to You. If you would prefer Us not to store a unique cookie in your browser, you may opt out. Note that by opting out, You still will receive advertising from Truffle when You visit Our Site – it just will not be targeted to You. Also, Content interactions data is used to provide Us data for internal analysis of the market (described below in Analytics Information subsection).

Analytics Information:

We use the Content interaction data We collect and information collected from our third-party partners to assemble a non-personal, demographic and behavioral information to group users that share a common interest into what we call "Audience Segments." These Audience Segments do not contain personally identifiable information; for example, these segments may disclose that a user located in a geographic area may be interested in cars, but this information does not identify or include the name, e-mail address, phone number, mailing address, or user name of any specific individual.

We will use these Audience Segments

(a) to match advertisements that may be of interest to our users that fall within that segment and

(b) to assist our advertisers, ad networks, and publisher web sites to deliver advertisements and offers that may be of interest to users within a given segment.

We use gathered data internally for purposes such as analyzing how the Truffle service is used, diagnosing service or technical problems or maintaining security, to operate, maintain, and provide to you the features and functionality of Truffle service. By using Our services, or providing us with any information, you consent to the collection, processing, maintenance and transfer of your data.

We use both our and third-party analytics tools to help us measure traffic and usage trends for the Truffle service. These tools collect information sent by your browser as part of a web page request, including the web pages you visit, your browser add-ons, your browser's width and height, and other information that assists us in improving the Truffle service. We collect and use this analytics information in aggregate form such that it cannot reasonably be manipulated to identify any particular individual user.

Log File Information:

Log file information is automatically reported by your browser each time you access a web page. When you use Our service, Our servers automatically record certain log file information. These server logs may include anonymous information such as your web request, Internet Protocol ("IP") address, browser type, referring / exit pages and URLs, number of clicks and how you interact with links on the service, domain names, landing pages, pages viewed, and other such information.

Sharing Your information:

We will not rent or sell your personally identifiable information to third parties outside Truffles FZCO and its controlled subsidiaries and affiliates without your consent, except as noted below:

• Who We may share Your information with:

We may share your non-personally identifiable information with third-party business partners for the purpose of providing the Truffle service to you. Those business partners will be given limited access to such information that is reasonably necessary to provide services, and We will require that such third parties comply with this Privacy Policy.

• Instances where We are required to share your personally identifiable information

We will disclose personally identifiable information where required to do so by law, or if we reasonably believe that such action is necessary to:

(a) comply with the law and the reasonable requests of law enforcement;

(b) to protect the security or integrity of Our service; and/or

(c) to exercise or protect the rights, property, or personal safety of Truffles FZCO, Truffle, our users or others.

We may share non-personally identifiable information, including information obtained through tools such as cookies, log files, device identifiers, location data (such as anonymous usage data, referring/exit pages and URLs, platform types, number of clicks, etc.):

• in any manner permitted for personally identifiable information; and
• with Our third-party business partners for the purposes described in the section above.

We may also aggregate or otherwise strip data of all personally identifying characteristics and may share that aggregated, anonymized data with third parties. We may share non-aggregate, non-personally identifiable usage information, including audience segments, with third party advertisers and publishers to assist us and them in delivering relevant, targeted advertising that is aligned with user interests. For example, these companies may use such information (e.g., click stream information, time and date, subject of advertisements clicked or scrolled over) in order to provide advertisements about goods and services likely to be of greater interest to you. Your preferences collected through this process may be used to influence which types of marketing messages you receive across sites that we work with.

We may also share aggregate statistical information about Our services with advertisers and publishers. We do not provide any personally identifiable information to these third parties.

Sharing Your data for Ads on Truffle

We may also share certain information such as your location, browser and cookie data and other data relating to your use of our Service with our business partners to deliver advertisements ("ads") that may be of interest to you. We may allow third-party ad servers or ad networks to serve advertisements on the Truffle service. These third-party ad servers or ad networks use technology to send, directly to your browser or mobile device, the ads and ad links that appear on the Truffle service, and will automatically receive your IP address when they do so. They may also use other technologies (such as cookies, JavaScript, device identifiers, location data, and clear gifs, see above) to compile information about your browser's or device's visits and usage patterns on the service, and to measure the effectiveness of their ads and to personalize the advertising content.

We do not sell, rent, or share the information we collect directly from you or about you from third parties with these third-party ad servers or ad networks for such parties' own marketing purposes.

Please note that our counterparty, a third-party advertiser, may ask Truffle to show an ad to a certain audience of users (e.g., based on demographics or other interests). In that situation, Truffle determines the target audience and Truffle serves the advertising to that audience and only provides anonymous aggregated data to the advertiser. If you respond to such an ad, the advertiser or ad server may conclude that you fit the description of the audience they are trying to reach.

Please note that our counterparty, a third-party advertiser, may ask Truffle to show an ad to a certain audience of users (e.g., based on demographics or other interests). In that situation, Truffle determines the target audience and Truffle serves the advertising to that audience and only provides anonymous aggregated data to the advertiser. If you respond to such an ad, the advertiser or ad server may conclude that you fit the description of the audience they are trying to reach.

The Truffle Privacy Policy does not apply to, and we cannot control the activities of, third-party advertisers. Please consult the respective privacy policies of such advertisers or contact such advertisers for more information.

Changing or Deleting Your Information

If you choose to opt out entirely, then your account may become deactivated and you will need to re-register should you decide to opt-in again. To delete your information, please contact Us via info@truffle.bid.

Following termination or deactivation of your Truffle account, We may retain your profile information and user content for a commercially reasonable time for backup, archival, or audit purposes. We reserves the right, but have no obligation, to monitor the content you post on the service. We reserve the right to remove any such information or material for any reason or no reason, including without limitation if in our sole opinion such information or material violates, or may violate, any applicable law or our Terms of Service, or to protect or defend our rights or property or those of any third party. We also reserve the right to remove information upon the request of any third party.

Security

We are very concerned with safeguarding your information. We use commercially reasonable safeguards to preserve the integrity and security of all information collected through the Truffle service. To protect your privacy and security, we take reasonable steps (such as requesting a unique password) to verify your identity before granting you access to your account. You are responsible for maintaining the secrecy of your unique password and account information, and for controlling access to your email communications from Truffle, at all times. Notwithstanding the foregoing measures, We cannot ensure or warrant the security of any information you transmit to Truffle or guarantee that information on the Truffle may not be accessed, disclosed, altered, or destroyed. We are not responsible for the functionality or security measures of any third party.

Policy Towards Children

This Site is not directed to children under 16. We do not knowingly collect or solicit personal information from children under 16 or knowingly allow such persons to register for an account. If you are under 16, please do not send any information about yourself to us, including your name, address, telephone number, or email address. No one under age 16 is allowed to provide any personal information to or on Truffle. In the event that We learn that We have collected personal information from a child under age 16 without verification of parental consent, We will delete that information as quickly as possible. If you believe that We might have any information from or about a child under 16, please contact us at support@truffle.bid.

Information Regarding Your Data Protection Rights Under General Data Protection Regulation (GDPR)

For the purpose of this Policy, We are a Data Processor of Your personal information, processing Your data on servers located in Germany.

If You are from the European Economic Area (EEA), Our legal basis for collecting and using Your personal information, as described in the Policy, depends on the information We collect and the specific context in which We collect it. We may process Your personal information because:

• We need to perform a contract with You, when You use the Site
• You have given Us permission to do so;
• The processing is in Our legitimate interests and it's not overridden by Your rights;
• To comply with the applicable law;

If You are a resident of the European Economic Area (EEA), You have certain data protection rights. In certain circumstances, You have the following data protection rights:

• The right to access, update or to delete the personal information we have on You;
• The right of rectification;
• The right to object;
• The right of restriction;
• The right to data portability;
• The right to withdraw consent;

Please note that We may ask You to verify Your identity before responding to such requests.

Please note that We may ask You to verify Your identity before responding to such requests. You have the right to complain to a Data Protection Authority about Our collection and use of Your personal information. For more information, please contact Your local data protection authority in the European Economic Area (EEA).

Privacy Policy Changes. Applicable Law

We may amend this Privacy policy from time to time. The revised Policy takes effect from the date of its posting, unless otherwise provided in the new version of the Policy. The Policy and the relationship between the You and the Company are subject to the laws of Estonia.

Links to Other Web Sites

We are not responsible for the practices employed by websites linked to or from the Truffle service, nor the information or content contained therein. Please remember that when you use a link to go from the Truffle service to another website, our Privacy Policy is no longer in effect. Your browsing and interaction on any other website, including those that have a link on Our Site, is subject to that website's own rules and policies. Please read over those rules and policies before proceeding.

Updates to the Policy

We may, in our sole discretion, modify or update this Privacy Policy from time to time, and so you should review this page periodically. When we change the policy, we will update the 'last modified' date at the bottom of this page. Your continued use of the Site following the posting of any changes to this policy means you accept such changes. We reserve the right to transfer your personal information in the event of a transfer of ownership of Truffles FZCO, such as acquisition by or merger with another company.

From time to time we may update this Privacy Policy. You should visit this page periodically to review any such changes to the privacy policy. In such cases, your continued use of Our Site or Our service means that the provision of personally identifiable information to us after such material changes will be subject to the new terms. If We make material changes to this Privacy Policy that expand our rights to use your personal information that We have collected, We will notify you to seek your consent through email or a prominent posting on the site.

You always have the option to cancel your account with us at any time. Simply de-install the widget from your site. If you have any questions or need some clarification on our privacy policy, please do not hesitate to email us at info@truffle.bid.

OUR DETAILS:

Truffles FZCO

info@truffle.bid.