Privacy Policy

At Surpplax Asset Management we collect various categories of Personal Information about you. The specific information we collect may vary depending on your interactions with us and may not include all the examples listed below:

• Identifiers: This includes your name, address, email address, phone number, social security number, driver’s license number, and other similar identifiers you provide to us.
• Characteristics of protected classifications: We may collect information such as your age, date of birth, and gender.
• Commercial information: This includes records of products or services purchased, as well as other purchasing or consuming histories.
• Internet or electronic network activity information: We may collect data about your online activity, device information, browsing history, and interactions with our website or applications.
• Geolocation data: We may collect information about your location.
• Audio, electronic, visual, or similar information: We may collect certain types of sensory data.
• Professional or employment information: This includes your job title, company name, and other related details.
• Inferences: We may draw inferences about your preferences, characteristics, behaviors, and attitudes based on the collected information.
• Sensitive Personal Information: In certain cases, we may collect sensitive information such as Social Security numbers, financial account details, or precise geolocation.

For California residents:

If you are a California resident, we also collect Personal Information as described in Cal. Civ. Code § 1798.80(e), which includes various types of sensitive information.

We do not use or disclose Sensitive Personal Information for purposes restricted under the California Consumer Privacy Act (“CCPA”), which grants you the right to limit the use and disclosure of such information.

Please note that additional information may be requested from you depending on specific transactions or regulatory requirements. We will inform you of the information needed and how it will be used.

We value the information you provide and strive to ensure a seamless interaction. Here’s how we collect and handle your data:

1. Direct Information: When you register for an account or submit information through our websites (such as bids or inquiries), we collect the information you provide to us directly.
2. Automated Collection: We automatically gather technical information about your interactions with us, such as your IP address and browsing history. This helps us enhance your experience and improve our services.
3. Information from Public and Third-Party Sources: We also obtain information from public sources and third parties. This may include details shared by your employer or co-workers, data from service providers or content providers, credit reporting agencies, potential purchaser lists, and other entities collaborating with us.

By consolidating information from these diverse sources, including public and third-party channels, we can better serve you and achieve the purposes outlined below.

Rest assured, this Privacy Policy covers both online and offline interactions, ensuring the secure handling of your personal information.

We value your information and use it in the following ways:

1. Providing personalized services: We utilize your information to deliver exceptional services tailored to your needs. This includes facilitating transactions, managing your account, addressing inquiries or requests, and comprehending your preferences.
2. Enhancing our business operations: Your data helps us improve our websites, track and analyze website traffic, gain insights into customer demographics and interests, identify potential server issues, develop new features, products, and services, and safeguard our legitimate interests.
3. Ensuring legal compliance and safety: We adhere to legal obligations and prioritize safety and security. This involves complying with legal requirements, protecting the rights and safety of ourselves, our stakeholders, and others, and detecting, preventing, and responding to security incidents or unlawful activities.
4. Utilizing de-identified and aggregated data: We may convert your information into a de-identified, anonymized, or aggregated format, ensuring that it no longer identifies individuals. This anonymized information may be used for various purposes and shared with trusted third parties.
5. Marketing communications: With your consent, we may use your Personal Information to send you relevant e-mail alerts, newsletters, and updates about upcoming auctions, sales events, and information related to our products and services. We prioritize compliance with applicable data protection laws and seek your consent when necessary.
6. Other purposes with your consent: We respect your choices, and if you provide consent, we may utilize your information for additional purposes beyond those mentioned above.

Rest assured, your privacy and consent are paramount to us.

We prioritize the protection of your Personal Information and strive to maintain transparency in our data sharing practices. Here’s how we may share your Personal Information:

1. Liquidity Services Affiliates: We may share your Personal Information within the Liquidity Services group of business entities to enhance our services and provide a seamless customer experience.
2. Service Providers: To assist us in delivering our services and conducting business activities, we may share your Personal Information with external service providers. These providers, such as Salesforce, Oracle Eloqua, Amazon Web Services, and Microsoft Azure, support us in various operational aspects.
3. Service or Communication Providers: In order to fulfill your service requests or complete transactions, we may share your information with other Website users, vendors, third-party partners, subcontractors, or service providers.
4. Business Partners, Website Users, and Third Parties: We may share your Personal Information with our business partners, other Website users, or third parties for their own purposes, including marketing. Whenever required by law, we will seek your consent before engaging in such sharing.
5. Law Enforcement, Legal Institutions, and Government Entities: When faced with subpoenas, court orders, official requests, or to prevent illegal activities, fraud, or potential threats, we may share your Personal Information with law enforcement, legal institutions, or government entities. This is done to protect your safety, our safety, or the safety of others, and as permitted or required by law.
6. Sale or Merger Situations: As our business evolves, we may engage in asset sales or acquisitions. If another entity acquires or merges with us, your Personal Information may be disclosed to such entity. Similarly, if we sell a specific business division, your Personal Information associated with that division may be transferred to the purchasing third party.
7. Auditors: We may provide transaction-related information to government or private auditors to validate our business practices, accounting records, or financial reports. All information shared for auditing purposes will be subject to strict confidentiality restrictions.

For California Residents: We disclose the above categories of Personal Information to our service providers and contractors for various business or commercial purposes, including ensuring security and integrity, debugging, short-term use, performing services, advertising and marketing, research, quality assurance, and detecting or protecting against malicious activities. We do not sell Personal Information in exchange for monetary compensation, but we may share certain categories of Personal Information with third parties for cross-context behavioral advertising.

Note: We prioritize the privacy of consumers under the age of 16 and do not knowingly sell or share their Personal Information.

In order to process your Personal Information, we adhere to data protection laws that require a specific lawful basis for such processing. Here’s an overview of the bases we rely on:

1. Legitimate Interests: When you provide Personal Information for an inquiry, we process it based on our legitimate interest as a business to respond to your inquiry. However, in jurisdictions where legitimate interest is not a permissible basis, we rely on your consent instead.
2. Performance of a Contract: When entering into a business relationship with you, we process your Personal Information based on the legal basis of performing a contract. This allows us to process your information to fulfill our contractual obligations and complete transactions.
3. Marketing Communications: For the purpose of sending you marketing communications, such as buy alert emails, information on upcoming sales events, and special announcements, we rely on the legal bases of legitimate interests and/or consent (if required and obtained). You have the right to withdraw your consent at any time, and if consent is the sole basis for processing, we will cease processing your data upon withdrawal.
4. Enhancing Features, Products, and Services: When we use your Personal Information to enhance or develop our features, products, and services, we rely on the legal basis of legitimate interest. This is necessary for our business to provide a responsive service and ensure customer satisfaction. In jurisdictions where legitimate interest is not a permissible basis, we will obtain your consent.
5. Legal and Regulatory Obligations: To comply with our legal and regulatory obligations, we process your Personal Information based on the legal basis that such processing is required to fulfill a legal obligation.

If we intend to change the purpose for using any Personal Information you have provided, we will notify you in advance and ensure compliance with applicable data protection laws. In cases where necessary, we will obtain your consent before using your Personal Information in a new way. Please note that in Canada, the basis for processing Personal Information is consent.

We strive to maintain transparency and uphold your data protection rights throughout our processing activities.

We may store and process your Personal Information in the United States, and it may also be stored and processed in other countries where we or our affiliates or approved partners have facilities or operations. These countries may include but are not limited to, the UK, Hong Kong, and China. It’s important to note that information processed in another country may be subject to access requests from governments, courts, or law enforcement agencies in those jurisdictions, in accordance with their respective laws.

From time to time, transfers of Personal Information may occur between members of our group of business entities, both within and outside the European Economic Area (EEA).

For all cross-border transfers of Personal Information, we take necessary steps to ensure appropriate security measures and legal safeguards are in place to protect your information.

For EU Residents:

If your Personal Information is transferred from the EEA to a country outside the EEA, including the United States, we ensure that the transfer is carried out in compliance with applicable data protection laws. This includes implementing security measures and adequate safeguards to protect the transferred Personal Information. If you would like to learn more about the safeguards we have in place or request a copy of such safeguards, please contact us using the details provided in the “Contact Us” section below.

For PRC Residents:

If your Personal Information is transferred from mainland China to a country outside mainland China, including the United States, we ensure that the transfer complies with applicable data protection laws. This involves implementing security measures, adequate safeguards, and necessary approval procedures (if applicable) to protect the transferred Personal Information.

We retain the categories of Personal Information mentioned above for as long as necessary to fulfill the purposes outlined in this Notice or as authorized by applicable law. Generally, this means we keep the information for one or more of the following reasons:

1. Operational and Relationship Management: We retain your Personal Information as long as it is reasonably necessary to manage our operations, maintain your relationship with us, or fulfill another purpose for which the information was collected.
2. Compatibility and Disclosed Purposes: We keep your Personal Information for a reasonable duration if it is reasonably necessary to carry out a disclosed purpose that is compatible with the context in which the information was collected.
3. Rights and Property Protection: Your information may be retained if it is reasonably required to protect or defend our rights or property in accordance with applicable laws, which may include limitations on actions in specific cases.
4. Legal and Regulatory Obligations: We retain your information if we are required or permitted to do so by applicable laws or regulations.

We do not keep your Personal Information for longer than necessary for the purposes it was collected, as stated in this Policy. When determining the appropriate retention periods, we consider various factors, including:

• Contractual obligations to you
• Legal obligations under applicable law that specify a certain data retention period
• Statutes of limitations under applicable law
• (Potential) disputes or legal claims
• Compliance, regulatory, and auditing requirements
• Guidelines provided by relevant national data protection regulators

Once your Personal Information is no longer required, we securely anonymize or erase it. For more information about the specific retention periods for your Personal Information, please reach out to us using the contact details provided in the “Contact Us” section below.

A. UK and EEA Rights

You possess various rights concerning your Personal Information. For further information and guidance on your rights, please consult the data protection regulator in your country of residence. To exercise any of these rights, please reach out to us via the email address provided in the “Contact Us” section below.

1. The Right to be Informed: You have the right to receive clear, transparent, and easily understandable information about how we use your information and the rights available to you. This Policy serves the purpose of providing you with such information.
2. The Right of Access: You have the right to request access to your information, including confirmation of whether we are processing it and certain other details similar to those outlined in this Policy. You can make this request by contacting us via email at the address provided below.
3. The Right to Rectification: If your information is inaccurate or incomplete, you can request its correction. Please contact us via email at the address provided below to request rectification of any errors in the personal information we hold.
4. The Right to Erasure: This right enables you to request the deletion or removal of your information when there is no compelling reason for us to continue using it. It is important to note that this is not an absolute right, and certain exceptions may apply.
5. The Right to Restrict Processing: You have the right to request the restriction of further use of your information. While your information may still be stored, it will not be processed further.
6. The Right to Data Portability: You have the right to obtain and reuse your personal data for your own purposes across different services. This allows you to transfer your information easily and securely between our IT systems and those of another provider, without impacting its usability. However, please note that this is not a general right and certain exceptions may apply.
7. The Right to Object to Processing: You have the right to object to certain types of processing, including processing for direct marketing purposes. If you wish to change your preferences regarding email communications or opt out of specific types of processing, please contact us.
8. The Right to Lodge a Complaint: You have the right to lodge a complaint with your national data protection regulator regarding the handling or processing of your personal data.
9. The Right to Withdraw Consent: If you have provided consent for any processing activities involving your Personal Information, you have the right to withdraw your consent at any time. Please note that withdrawing consent does not invalidate any processing that occurred before the withdrawal.

We strive to address requests and provide information free of charge. However, in cases of baseless, excessive, or repeated requests, or for additional copies of the same information, we may charge a reasonable fee to cover administrative costs. We may also refuse requests in certain circumstances. Before submitting your request, please consider it responsibly. We will respond as promptly as possible, generally within one month. If more time is required to process your request, we will notify you accordingly.

B. California Rights

If you are a resident of California, you have specific rights concerning your Personal Information. To exercise these rights, please submit a request through our email at legal@surpplax.com.br. Please be aware that certain requests may require us to verify your identity and locate you in our records. You may also designate an authorized agent to make requests on your behalf, subject to identity verification.

1. Right to Know: You have the right to know what Personal Information we have collected about you, including the categories of information, sources, business purposes, recipients, and specific pieces of information collected.
2. Right to Delete Your Personal Information: You have the right to request the deletion of Personal Information we have collected from you, subject to exceptions under the law.
3. Right to Correct Inaccurate Information: If you believe the Personal Information we hold about you is inaccurate, you can request its correction.
4. Right to Opt-Out of Sales and Sharing of Personal Information: You have the right to opt out of the sale of your Personal Information and request that we do not share it for cross-context behavioral advertising. To exercise this right, please manage your Cookie preference settings when accessing our websites.
5. Rights Related to Automated Decision-Making: You have the right to opt out of automated decision-making processes, including profiling, that evaluates personal aspects related to your work performance, economic situation, health, personal preferences, interests, reliability, behavior, location, or movements.
6. Right to Non-Discrimination: If you exercise your privacy rights under the CCPA, you have the right not to receive discriminatory treatment.C. PRC Rights

   You possess various rights concerning your Personal Information. To exercise any of these rights, don’t hesitate to get in touch with us via email at the address provided in the “Contact Us” section below.

   1. The Right to be Informed: You have the right to receive clear, transparent, and easily understandable information about how we use your information and your rights. This Policy serves the purpose of providing you with such information.
   2. The Right of Access: You have the right to request access to your information, including confirmation of whether we are processing it and similar details provided in this Policy. Please contact us via email at the address below to exercise this right.
   3. The Right to Rectification: If your information is inaccurate or incomplete, you can request its correction. Please write to us at the email address below to request rectification of any errors in our personal information.
   4. The Right to Delete: You have the right to request the deletion of your information under certain circumstances, such as when the purpose of processing has been achieved or cannot be achieved when the information is no longer necessary when we cease to provide the service or the retention period has expired, when you withdraw your consent (if processing is based on consent), or when we process your information in violation of laws, regulations, or agreements.
   5. The Right to Restrict Processing: You have the right to request the restriction of further use of your information. While your information may still be stored, it will not be processed further.
   6. The Right to Object to Processing: You have the right to object to certain types of processing, including processing for direct marketing purposes. To change your email communication preferences, please contact us.
   7. The Right to Withdraw Consent: If you have provided consent for any processing activities involving your Personal Information, you have the right to withdraw your consent at any time. Please note that withdrawing consent does not invalidate any processing that occurred before the withdrawal.

   We strive to address requests and provide information free of charge. However, in cases of baseless, excessive, or repeated requests, or for additional copies of the same information, we may charge a reasonable fee to cover administrative costs. We may also refuse requests in certain circumstances. Before submitting your request, please consider it responsibly. We will respond as promptly as possible.

   D. Canadian Rights

   You possess various rights concerning your Personal Information. For further information and guidance on your rights, please consult the data protection regulator in your country of residence. To exercise any of these rights, subject to legal exceptions, please get in touch with us via email at the address provided in the “Contact Us” section below.

1. 1. The Right to be Informed: You have the right to receive clear, transparent, and easily understandable information about how we use your information and your rights. This Policy serves the purpose of providing you with such information.
   2. The Right of Access: You have the right to request access to your information, including confirmation of whether we are processing it and similar details provided in this Policy. To exercise this right, please get in touch with us via email at the address below.
   3. The Right to Rectification: If your information is inaccurate or incomplete, you can request its correction. Please write to us at the email address provided below to request the rectification of any errors in the Personal Information we hold.
   4. The Right to Lodge a Complaint: If you believe that we have mishandled or improperly processed your Personal Information, you have the right to lodge a complaint with the national data protection regulator.
   5. The Right to Withdraw Consent: If you have provided consent for any processing activities involving your Personal Information, you have the right to withdraw your consent at any time. Please note that withdrawing consent does not invalidate any processing that occurred before the withdrawal.

Verification: To exercise your rights, we may need to verify your identity or obtain information to locate you in our records, depending on the nature of the request.

E. Other Rights

A user may request the discontinuation of the use of their Personal Information. If you would like to know what information we have collected, have any information purged, or want us to discontinue using your Personal Information, please contact us at legal@surpplax.com.br. Please note that returning certain Personal Information may restrict or limit your access to certain portions of our websites. We will make an effort to communicate the extent to which your request will affect your website usage before complying with your request.

We value your privacy and strive to ensure that your rights regarding your Personal Information are respected and upheld. If you have any questions or concerns about your rights or our privacy practices, please contact us at the email address provided below.

Contact Us: Email: legal@surpplax.com.br

When you register on our site, you have the option to receive email communications from us. If you no longer wish to receive marketing emails from us, you can choose to opt out by contacting us using the details provided in the “Contact Us” section below. Additionally, you can follow the opt-out/unsubscribe instructions included in our marketing emails.

To ensure the efficient delivery of our marketing emails, we may engage third party providers to assist us with the sending process. These providers help us maintain the quality and effectiveness of our communications.

We value your preferences and strive to respect your choices regarding email communications. If you have any questions or concerns about our email communications or wish to update your preferences, please reach out to us using the contact information provided below.

Contact Us: Email: legal@surpplax.com.br

Safeguarding your Personal Information is of utmost importance to us. We have implemented appropriate technical and organizational measures to protect against the loss, misuse, and alteration of your Personal Information.

To maintain the security of your data, our employees who have access to Personal Information undergo thorough data privacy training. They are closely monitored by management to ensure they employ adequate safeguards to protect the confidentiality of our customers’ information.

Our Websites are equipped with robust security measures to prevent unauthorized access, misuse, and alteration of the data under our control. We utilize SSL (secure sockets layer) encryption, a standard security protocol, to protect all sensitive information transmitted over the Internet. This includes data added by customers to the Website as well as data transmitted by employees off the Website. Rest assured that no information, including passwords granting access to sensitive data, is ever transmitted over the Internet without encryption.

While we strive to employ commercially acceptable security measures designed to protect your Personal Information, it is important to note that no method of transmission over the internet or method of electronic storage is completely infallible. Although we continuously work to enhance the security of your data, we cannot guarantee its absolute security.

We remain committed to safeguarding your Personal Information and will continue to review and improve our security measures to ensure the utmost protection of your data.

It is important to be aware that no transmission of data over the internet can be guaranteed to be completely secure. There is a possibility that third parties, beyond our control, may intercept or unlawfully access transmissions or private communications. Therefore, any transmission of your information online is done at your own risk.

To enhance the protection of your data when transmitting information over the internet, we recommend employing additional measures such as using firewalls, antivirus software, and similar technologies that enhance data protection.

It is crucial never to send credit card information via email. Email communications are not inherently secure, and sensitive information like credit card details should be transmitted through secure channels or trusted platforms.

Furthermore, exercise caution when sharing information about your account. Only provide account details to individuals who are authorized by you to transact business on your behalf. It is essential to maintain control over who has access to your account information.

Additionally, protect the confidentiality of your password. Refrain from sharing your password with anyone, and remember that we will never request your password to verify your identity. If you encounter any request for your password, it is likely an attempt to deceive you, and you should not disclose it.

By following these best practices and remaining vigilant, you can play an active role in safeguarding your personal information and reducing the risk of unauthorized access or misuse.

In addition to cookies, we or third-party analytics providers contracted by us may utilize “web beacons” to gather information regarding your interaction with our Website, as well as the websites of chosen sponsors and advertisers. Web beacons are small graphic image files that are embedded within web pages or emails. They serve as a presence indicator on the respective web page or email and transmit information from the user’s browser back to their originating server.

By employing web beacons, we can gather statistical data on the usage of our Website, as well as the websites of selected sponsors and advertisers. This information enables us to monitor the number of people accessing our Website, visiting the websites of sponsors and advertisers, and utilizing our services. It also helps us understand the purposes for which these services are utilized.

Please note that the information collected through web beacons is aggregated and anonymous. It aids us in analyzing trends and patterns, enhancing the user experience, and optimizing our services. Rest assured that any information gathered through web beacons is treated in accordance with our privacy policy.

If you have concerns about web beacons or would like to learn more about how they are utilized, please refer to our privacy policy for detailed information.

When you use the Website, small text files known as cookies are placed on your device (e.g., computer, smartphone, tablet) to collect certain information. These cookies store details such as your username, user preferences, visited web pages, and activities performed on the Website.

We utilize cookies for various purposes, including delivering content tailored to your interests, enhancing your experience with the Website, and remembering your information to save you from having to re-enter it on subsequent visits. Enabling cookies is preferable to ensure the effective functioning of our Website and provide you with the best user experience.

Please note that some of our business partners may also use cookies to provide us with anonymous, aggregated data and insights about our users. However, we do not have access or control over these cookies, and they are not covered by our Policy.

In particular, we employ the following types of cookies:

1. Functional Cookies: These cookies enhance the functionality and personalization of the Website. They may be set by us or by third-party providers whose services we have integrated into our pages. If you choose to disable these cookies, some or all of these services may not function properly.
2. Targeting Cookies: Our Website employs targeting cookies that are set through our site by our advertising partners. These cookies help our partners display more relevant advertisements on other websites. If you opt not to allow these cookies, you will still see advertisements on the internet, but they may be less tailored to your interests. Additionally, while we do not sell Personal Information for monetary exchange, some of the ways in which we share Personal Information for advertising or marketing purposes may be considered “sales” or “sharing” under the California Consumer Privacy Act. California Consumers have the right to opt out of the sale of Personal Information by managing their Cookie preference settings for each Website.
3. Strictly Necessary Cookies: These cookies are essential for the Website to function and cannot be disabled in our systems. They are typically set in response to your actions, such as setting privacy preferences, logging in, or filling out forms. Although these cookies do not store personally identifiable information, blocking them or receiving alerts about them may impact certain parts of the Website, rendering them inoperable.
4. Performance Cookies: These cookies allow us to count visits and track traffic sources to measure and improve the performance of our Website. They provide insights into the most and least popular pages and how visitors navigate the Website. All information collected by these cookies is aggregated and anonymized. If you choose to disable these cookies, we will be unable to monitor the performance of our Website and determine when you have visited it.

You can manage your Cookie preference settings for each Website you access, allowing you to control how cookies are used.