Privacy Policy

Effective Date:

BESTONLINEAUCTION Inc. (“BestAuction,” “we,” or “us”) respects your privacy. Our digital platform is designed for individuals and businesses to manage the procurement process and help to buy and sell goods and services by facilitating the connection and digital collaboration with new suppliers and partners around the world. This Privacy Policy (“Policy”) describes how we collect, use, and disclose information about individuals and employees of businesses that use the platform, individuals and businesses that appear in tender, and other platform visitors in connection with our platform (“Users”) and the online services provided through us (collectively, the “Services”). This Policy does not apply to information that you submit directly to third parties, including the organizations and individuals with which you connect on the Services. This Privacy Policy should be read in accordance with the Terms of Use.

 

Data That We Collect

We collect Personal Information and Other Information about Users in connection with the Services. For the purposes of this Policy, “Personal Information” is any information provided to us or generated within BestAuction.com that personally identifies or could be used to identify an individual, such as name or email address, gender, identification number or other information which could be reasonably linked to such identifying information.

“Other Information” is any information we collect that is not Personal Information.

We may combine Personal Information with Other Information; in which case we will treat the combined information as Personal Information. We also may combine information that we have about you with additional information that we, or other third parties, collect in other contexts—such as our communications with you via email or phone, your responses to project screening questions, your customer service records, or any feedback provided by a User. In those circumstances, we will treat the combined information as Personal Information.

 

Information about Users

If you are a User, we may collect the following Personal Information about you:

• Phone number (if given);
• Username email address;
• First and Last name;
• Home Address; and

In addition, other Users may ask you to fill out screening or other questions relevant to the procurement or eAuction process. We may collect your answers to those questions and use that information as described in this Policy. We also collect messages you send to us through our “Contact Us” or other messaging features, as well as the messages that you send to other Users through our Services. In addition, we may ask you follow-up questions and collect your answers to such questions.

NOTE:  Please do not submit any Sensitive Information (defined below) to or through the Services in response to any question or request from another use.

 

Payment Information

When required, we will collect your credit card or other payment information. We use third-party payment service providers to process payments on our behalf, and as a result we do not ourselves store your credit card number or other payment information.

We are not responsible for the Privacy Policy of our third party payment providers, and encourage you to review this policies at their web sites.

 

Information about All Users 

We collect information about Users automatically through the Services. This may include information such as your IP address and domain name, your Internet service provider, the date and time of your visit, your use of the Services during your current session and over time (including the pages you view and the files you download), the URLs from the websites you visit before and after navigating to the Services, your computer’s operating system and browser type, your software and hardware attributes (such as device IDs, device OS, and device type), search keyword and search engine, and your general geographic location (e.g., your city, state, province, or metropolitan region). Such information may be considered Personal Information under certain applicable law. We collect such information using the following technologies:

 

• Server Logs. When you use the Services, we automatically receive and record certain information from your computer (or another device) and your browser. To obtain such information, we may use server logs or     applications that recognize your computer and gather information about its online activity.
• Cookies. We also use cookies. Cookies are small files that are stored on your computer (or other device) by your web browser. A cookie allows the Services to recognize whether you have visited the Website before and may store user preferences and information. If you are concerned about having cookies on your computer, you can set your browser to refuse all cookies or to indicate when a cookie is being set, allowing you to decide whether to accept it. You can also delete cookies from your computer.
• Collaboration with Third-Party Data Collectors. We may partner with certain third parties to collect, analyze, and use some of the information described above. For example, we may allow third parties to set cookies or use pixel tags or other tracking mechanisms (such as tags or scripts) on the Services or in email communications from us, or we may allow third parties to use an application software development kit (SDK) or a server-to-server connection to collect information, including device identifiers such as IDFA and Advertising ID. The information collected by third parties using these technologies may be used for a variety of purposes, including analytics, as described in the “Third-Party Analytics” section below.

 

How We Use Your Information

Information about Users

If you are a User, we use your information to:

• Provide the Services to you, administer your account, fulfill the terms of any agreement you have with us, evaluate you for qualification to be matched with Creators, or respond to your requests. Note that any information you submit may be used by us to evaluate you for qualification to match and to provide the Services.

 

• Allow other User’s to consider and select Users for the purposes of procurement or auction. We may share with any User any information that we have about you, including but not limited to your project scope; city, state, province, and country; contact information, including any associated websites; and responses to screening criteria.
• Send you administrative communications related to the Services, including communications about projects for which you have applied or have been selected.
• Send you marketing communications, in a manner consistent with your marketing preferences and applicable laws. If you wish to opt out of receiving promotional emails at any time, please click the “unsubscribe” link at the bottom of the email. Please note that if you unsubscribe from promotional emails, you will continue to receive non-promotional administrative emails with information relevant to your account and the operation of the Services.
• Analyze use of the Services and analyze our User demographics and other information.
• Improve our existing products and services or create new products and services.
• Personalize your experience on our website.
• Engage in analytics as described in the “Third-Party Analytics” section below.
• Comply with legal and/or regulatory requirements or protect our rights and interests.
• Facilitate the processing of payments (if applicable).

 

How We Share Your Information

We may share your information with the following third parties:

• Third-party service providers. We use third-party service providers to help us provide, manage, and improve the Services. These service providers may collect and/or use your information to assist us in achieving the purposes discussed in this Policy. We do not exercise control over any other sites that may be linked to or accessed through the Platform or our website. We have no responsibility for the privacy practices of third-parties, including any technology or software providers, which are used within the Services. You should review the policies of any third-party sites before providing personal information to these sites.

• Affiliates. We may share information with our corporate affiliates for the purposes described in this Policy.

• Other Users of the Services. We may share your information with other Users of the Services as described above in the section titled “How We Use Your Information.”

• Your direct sharing of information through the Services. The Services may enable you to share information, including Personal Information and Sensitive Information, directly through the Services. For example, the Services may contain messaging features that enable you to interact with or share content with other Users of the Services. The Website may include links to other Users’ websites, plug-ins, services, or applications. Clicking on those links or enabling those connections may allow the User to collect or share data about you. If you follow a link to a User website or engage a third-party plugin, please note that these Users may have their own privacy policies and we do not accept any responsibility or liability for these policies. We do not control how Users manage your personal information, and we encourage you to use discretion in sharing content with Users of the Services.

• Analytics. We may share your information with third parties to research and analyze our Users, and to seek to broaden our User base.

• Third-party plugins and integrations The Services may integrate certain third-party plugins, widgets, or integrations (such as social media plugins). Even if you do not click on these plugins, widgets, or     integrations, they may collect information about you, such as your IP address and the pages that you view. They also may set and/or access a cookie or other tracking mechanism. Each plugin, widget, and integration is governed by the privacy policy of the company providing it, and not this Policy.

• Legal purposes. The information we process, and store may be disclosed by us to legal authorities if we are required to do so by law. We may also disclose, at our discretion, some information we collect and store where we have reason to believe that disclosing this information is necessary to identify, contact or bring legal action against someone who may be causing interference with the rights, property, or rules of the Users, or someone who may cause or be at risk of imminent bodily harm, or someone who may be violating the Terms of Use of our Services. In such cases, the User in question will be informed.

• Financing, business transfers, and similar transactions. As we develop our business, we might sell or buy businesses or assets. In the event of a sale, merger, reorganization, dissolution, or similar event relating to all or a portion of our business or assets, your information may be part of the transferred assets. In accordance with applicable law, to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of BestAuction ‘s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by BestAuction about our customers and users is among the assets transferred.

• De-identified or aggregated information. We may also share de-identified and aggregated information about Services Users, such as by publishing a report on trends in the usage of the Services or sharing aggregated information about historical survey matching results.

 

Sensitive Information

 

Personal or Other Information related to your racial or ethnic origin, political opinions, religion or other beliefs, health or sex life, criminal background or trade union membership, and other similar information may be considered “Sensitive Information” under certain applicable law. We sometimes collect Sensitive Information when you create an account in the Services. By entering such information, you consent and agree that we may use such information in accordance with this Policy.

If you are a User, please do not submit Sensitive Information to or through the Services in response to any question or request from another User.

 

Third- Party Analytics

We may partner with certain third parties to collect the information discussed above and to engage in analytics, auditing, research, and reporting. These third parties may use web logs, pixel tags, or other technologies, and they may set and access cookies on your computer or other device.

In particular, the Website uses Google Analytics to help collect and analyze certain information for the purposes discussed above. To opt out of Google Analytics, click here: https://tools.google.com/dlpage/gaoptout

For more information about how these third parties collect and use your information, please see their privacy policies.

 

Third-Party Links, Websites, Apps, and Communication Technologies

Our website and the Services may contain links to and from websites and apps of other third parties. If you follow a link to any of these websites or apps, please note that these websites and apps, and any services that may be accessible through them, are operated and controlled by third parties and have their own privacy policies. A link to any third-party site does not imply that we endorse or accept any responsibility for the content or use of such site. We encourage our Users to be aware when they leave the Services and to read the privacy policies applicable to such third-party websites and apps. Similarly, Users may survey or otherwise communicate with other Users via phone, email, video-conferencing, or other communication methods not provided, facilitated, or endorsed by us. These technologies have their own privacy policies and are not covered by this Policy.

 

Security

We use commercially reasonable physical, electronic, and procedural safeguards to protect your information against loss or unauthorized access, use, modification, or deletion. However, no security program is 100% secure, and thus we cannot guarantee the absolute security of your Personal or Other Information.

 

Data Retention

We retain information for as long as reasonably necessary to deliver our Services to you or to fulfill the purposes described in this Policy or as required by law. For example, we may retain your information for as long as you maintain your User. If you are a User and deactivate your account, we will delete your Personal Information after 90 days. However, we reserve the right to retain any information required under applicable law.

 

Your Choices and Access to Information

You have the right and ability to access and edit your account information on our Services at any time by logging into and updating your account information. You may access, amend, and/or request deletion of certain information to the extent permitted under applicable law. To make such requests and/or inquire about such rights you may either do so by accessing your account through BestAuction.com or by sending us an email at [email protected].

For your protection, we may only implement requests with respect to the information associated with the particular email address you use to send us your request, and we may need to verify your identity before implementing your request. We will attempt to comply with any reasonable requests for accessing, amending, or deleting your information.

 

Children’s Privacy

We do not knowingly collect information from children under the age of 18 and do not target our Services to children under 18. If you are under 18, please do not use the Services. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce this prohibition. If you have reason to believe that a child under the age of 18 has provided information to us, please contact us, and we will endeavor to delete that information from our databases.

 

Governing Law

We have taken commercially reasonable steps to ensure your data is protected in accordance with the Personal Information and Electronic Documents Act (“PIPEDA”), including leveraging the cyber security services, firewalls, as well as other security measures embedded within FORPSI.com and AZURE cloud by Microsoft. From time to time, your Personal Information may be accessed by BestAuction-authorized services or staff in another country where BestAuction or authorized third parties operate. We implement measures to protect your information and to ensure compliance with applicable laws.

All issues and questions concerning the application, construction, validity, interpretation and enforcement of this Privacy Policy shall be governed by and construed in accordance with the laws of the Province of Ontario, and the federal laws of Canada applicable therein.

To inquire about or exercise your rights in accordance with applicable law, please contact us at [email protected]

 

Your Acknowledgments

By signing up, you agree to the terms and conditions of this Privacy Policy. You also agree that you assume all risks regarding your use of the Services, transmissions made over the Internet generally, and your sharing of your Personal or Other Information.

By using our Services, you grant us and all other persons or entities involved in the operation of our Services the right to receive, transmit, monitor, retrieve, store and use your Personal or Other Information, including information that may be privileged or confidential under applicable laws, in connection with the operation of our Services and our maintenance of your Personal or Other Information, as described in this Privacy Policy.

 

Policy Changes

We may make changes to this Policy from time to time. We will post the revised Policy on the website with an “effective date” that indicates when the revised Policy will take effect. We encourage you to review this page periodically to note any changes.

 

Questions or Comments

If you have any questions or comments regarding our privacy practices or this Privacy Policy, please send us an email at [email protected]