1. Scope and Overview

RightoftheDot, LLC d/b/a Right of the Dot, LLC (“ROTD,” “we,” “us,” or “our”) respects your privacy. This Privacy Policy explains how we collect, use, disclose, retain, and protect personal information when you visit or use our websites, auction and brokerage services, communications, and other services that link to this Privacy Policy (collectively, the “Services”).

This Privacy Policy applies to information collected online and offline in connection with the Services, including when you register for an account, register to bid, submit a Lot, bid, buy, sell, use brokerage services, make a payment, communicate with us, or attend an auction. It does not apply to a third party’s website, application, service, or privacy practice, even if a link to that third party is available through the Services.

For individuals in the European Economic Area, the United Kingdom, and Switzerland, the supplemental provisions in Section 13 apply. For California residents, the supplemental provisions in Section 14 apply.

2. Personal Information We Collect

The personal information we collect depends on how you use the Services and may include the following categories:

1. Identifiers and contact information, including name, business name, username, mailing address, email address, telephone number, account credentials, and government-issued identifiers provided for identity verification.

2. Account and verification information, including registration details, proof of address, corporate formation documents, information concerning directors and beneficial owners, financial references, deposit information, and information provided to satisfy anti-money-laundering, know-your-customer, sanctions, fraud-prevention, or other compliance requirements.

3. Transaction information, including Lots submitted, catalogue information, bids, bid history, auction participation, purchase and sale history, invoices, Buyer’s Premiums, commissions, communications concerning a transaction, escrow or custody instructions, transfer status, disputes, and records of services requested or provided.

4. Payment and financial information, including payment method, payment confirmation, bank-account information, billing address, tax information, and cryptocurrency wallet address or transaction information when you elect to use a cryptocurrency payment option. Payment-card information may be processed by our payment service providers.

5. Domain-name and digital-asset information, including domain names, registrar and registry information, authorization codes, transfer status, wallet addresses, NFT or digital-asset metadata, blockchain transaction information, and information necessary to complete a transfer or administer a transaction.

6. Communications and recordings, including the contents of messages, emails, telephone calls, written bids, support requests, dispute submissions, and recordings of live auctions, telephone bidding, and other proceedings where permitted by law.

7. Internet, device, and usage information, including internet protocol address, browser type, operating system, device identifier, log data, approximate location derived from an IP address, pages viewed, referring and exit pages, interactions with the Services, and cookie or similar-technology information.

8. Inferences and preferences, including interests and preferences that we derive from your use of the Services, such as auction categories viewed, communication preferences, and service interests.

9. Information from third parties, including information from identity-verification providers, fraud-prevention providers, payment providers, registrars, registries, auction or platform partners, public sources, and persons acting for or with you in connection with a transaction.

You are responsible for ensuring that personal information you provide to us is accurate and for obtaining any permission required before you provide us with another person’s personal information.

3. How We Use Personal Information

We may use personal information to:

1. Provide, operate, maintain, and improve the Services.

2. Create and administer accounts; register bidders and sellers; evaluate registration, financial-capacity, deposit, and verification information; and administer auction, brokerage, payment, custody, transfer, and post-sale processes.

3. Process payments, issue invoices, calculate commissions and Buyer’s Premiums, administer taxes, maintain transaction and accounting records, and collect amounts owed.

4. Communicate with you about the Services, your account, auctions, bids, Lots, transactions, payments, policy updates, security matters, and customer-support requests.

5. Prevent, detect, investigate, and respond to fraud, shill bidding, payment reversals, security incidents, unlawful conduct, sanctions concerns, money laundering, violations of our terms, and other misuse of the Services.

6. Comply with legal, regulatory, tax, accounting, recordkeeping, reporting, court-order, and law-enforcement obligations; establish, exercise, or defend legal claims; and protect the rights, safety, property, and security of ROTD, our users, and others.

7. Understand how the Services are used, measure performance, troubleshoot, develop and improve features, and maintain service security and reliability.

8. Send marketing communications where permitted by law and consistent with your preferences. You may opt out of marketing emails through the unsubscribe link in the message or by contacting us. Opting out of marketing communications does not stop transactional, security, account, or legally required communications.

9. Create aggregated or de-identified information that does not reasonably identify you, and use and disclose it for lawful business purposes.

4. How We Disclose Personal Information

We may disclose personal information as follows:

1. To service providers and professional advisers that perform services for us, including hosting, technology, communications, identity verification, fraud prevention, payment processing, accounting, legal, tax, customer-support, analytics, marketing, and security providers. These parties may use personal information only as authorized by us or as otherwise permitted by law.

2. To transaction participants and their authorized representatives when reasonably necessary to facilitate, complete, administer, investigate, or enforce a transaction. Depending on the transaction, this may include a Buyer, Seller, bidder, broker, registrar, registry, payment provider, Custody Agent, or transfer-service provider. ROTD may limit disclosure of a Seller’s identity where consistent with the applicable transaction and our legal or operational requirements.

3. To auction, brokerage, and platform partners when necessary to provide, promote, administer, or support the Services or an applicable auction or transaction.

4. To government authorities, law enforcement, regulators, courts, or other third parties when we reasonably believe disclosure is required or appropriate to comply with law or legal process; respond to claims; prevent fraud, security threats, or illegal activity; or protect rights, safety, property, and security.

5. To an actual or prospective purchaser, successor, lender, investor, or professional adviser in connection with a merger, acquisition, financing, reorganization, bankruptcy, or sale or transfer of all or part of our business or assets.

6. With your consent or at your direction.

We do not disclose personal information to third parties for their own direct-marketing purposes without your consent. We do not sell personal information for money. If our use of cookies or similar technologies constitutes a sale or sharing under California law, we will provide the required notice and opt-out mechanism as described in Section 14.

5. Cookies and Similar Technologies

We and our service providers may use cookies, web beacons, pixels, software-development kits, local storage, log files, and similar technologies to operate the Services, remember preferences, maintain account security, understand use of the Services, measure performance, and, where permitted, support advertising.

Our Cookie Notice provides additional information about the categories of cookies and similar technologies we use, their purposes, your choices, and how to use the cookie-preference center when it is available.

You may manage cookies through your browser settings. If we make non-essential cookies available through the Services, we will provide a cookie notice or preference mechanism where required by applicable law. Disabling cookies may affect the availability or functionality of portions of the Services.

Where required by law, we will honor applicable opt-out preference signals for sales, sharing, or targeted advertising to the extent the signal is associated with the browser or device and can be recognized by our Services.

6. Marketing Choices

You may opt out of marketing emails by using the unsubscribe link in the email or by contacting us at legal@rightofthedot.com. We may continue to send non-promotional communications, including messages about auctions, bids, transactions, account administration, payments, security, and changes to our terms or policies.

If you receive text messages from us, you may opt out as directed in the message or by replying STOP where that option is available. Your mobile carrier’s message and data rates may apply.

7. Data Retention

We retain personal information for as long as reasonably necessary for the purposes described in this Privacy Policy, including to provide the Services; complete and document transactions; maintain required records; resolve disputes; enforce agreements; prevent fraud; protect security; comply with legal, tax, accounting, and regulatory obligations; and establish, exercise, or defend legal claims.

Retention periods depend on the nature of the information, the applicable service or transaction, our legal obligations, the sensitivity of the information, and whether continued retention is necessary for a legitimate business purpose. When personal information is no longer required, we will delete, anonymize, or aggregate it, subject to lawful retention requirements and technical limitations.

8. Data Security

We use reasonable administrative, technical, and physical safeguards designed to protect personal information from unauthorized access, use, disclosure, alteration, and destruction. No method of transmission over the internet or method of electronic storage is completely secure. Accordingly, we cannot guarantee absolute security.

You are responsible for maintaining the confidentiality of your account credentials, wallet credentials, and other access information under your control. Notify us promptly if you believe your account or information has been accessed without authorization.

9. International Transfers

ROTD is based in the United States. We may collect, store, process, and transfer personal information in the United States and other countries where we, our service providers, or transaction participants operate. These countries may have data-protection laws that differ from those of your country of residence.

When we transfer personal information subject to applicable international-transfer restrictions, we will use an appropriate transfer mechanism or other safeguards required by applicable law. Depending on the circumstances, these may include a transfer to a country recognized as providing adequate protection, contractual safeguards, or another lawful transfer mechanism.

10. Third-Party Services and Links

The Services may link to third-party websites, platforms, registrars, registries, payment services, wallets, marketplaces, social-media services, or other services. Their privacy practices are governed by their own policies, not this Privacy Policy. We encourage you to review those policies before providing personal information to a third party.

11. Children’s Privacy

The Services are not directed to children under 18 years of age, and we do not knowingly collect personal information from children under 13. If we learn that we have collected personal information from a child under 13 without legally required consent, we will take reasonable steps to delete it. If you believe a child has provided us personal information, please contact us at legal@rightofthedot.com.

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. The Effective Date at the top identifies when it was last updated. If we make a material change, we will provide notice as required by applicable law, which may include posting the updated Privacy Policy on our website or sending a notice through the Services or by email.

13. Additional Information for EEA, UK, and Swiss Individuals

This Section 13 applies to the extent applicable data-protection law, including the General Data Protection Regulation (“GDPR”), applies to our processing of your personal data.

13.1 Controller

For personal data covered by this Section 13, RightoftheDot, LLC d/b/a Right of the Dot is the controller responsible for the processing described in this Privacy Policy. You may contact us at info@rightofthedot.com. If we are required to appoint a representative in the EEA, the United Kingdom, or Switzerland, we will identify that representative in a supplemental notice or in this Privacy Policy.

13.2 Legal Bases

We process personal data only when we have a lawful basis. Depending on the context, we may process personal data because:

1. Processing is necessary to perform a contract with you or to take steps at your request before entering into a contract, including registering you, administering bids and transactions, processing payments, and facilitating transfers.

2. Processing is necessary to comply with a legal obligation, including tax, accounting, anti-money-laundering, sanctions, fraud-prevention, recordkeeping, and legal-process obligations.

3. Processing is necessary for our legitimate interests or those of another person, where those interests are not overridden by your interests or fundamental rights. These interests include operating and improving the Services, maintaining security, preventing fraud and abuse, protecting rights, resolving disputes, and managing our business.

4. You have given consent, including, where required, for non-essential cookies, certain marketing communications, or other processing for which consent is the applicable basis. You may withdraw consent at any time. Withdrawal does not affect the lawfulness of processing before withdrawal.

5. Processing is necessary to protect a person’s vital interests or for another purpose permitted by applicable law.

13.3 Your Rights

Subject to applicable law and applicable exceptions, you may have the right to request access to personal data; correction of inaccurate or incomplete personal data; erasure; restriction of processing; data portability; objection to processing based on legitimate interests; and withdrawal of consent. You may object at any time to direct marketing.

We do not make decisions based solely on automated processing that produce legal or similarly significant effects concerning you, unless permitted by applicable law and accompanied by required safeguards.

To exercise a right, contact us at info@rightofthedot.com. We may request information necessary to verify your identity and authority. We will respond within the period required by applicable law. You also may lodge a complaint with the data-protection authority in your habitual residence, place of work, or the place of an alleged infringement.

14. Additional Information for California Residents

This Section 14 supplements the other parts of this Privacy Policy for California residents and is intended to provide notices under the California Consumer Privacy Act, as amended (the “CCPA”), to the extent applicable.

14.1 Notice at Collection

During the preceding 12 months, ROTD may have collected the following categories of personal information: identifiers; customer-record information; protected-class information only where voluntarily provided or required for lawful verification; commercial information; internet or electronic-network activity information; approximate geolocation information; audio and visual information; professional or employment-related information where provided in a business transaction; sensitive personal information, including government-issued identification, account credentials, financial-account information, and precise geolocation only where collected; and inferences drawn from personal information.

We collect this information from you, your devices, your authorized representatives, transaction participants, service providers, registrars, registries, payment and identity-verification providers, public sources, and other sources described in Section 2. We use and disclose it for the business and commercial purposes described in Sections 3 and 4.

We retain each category of personal information for the period described in Section 7. We do not sell personal information for monetary consideration. We may disclose personal information to service providers, contractors, and transaction participants for the purposes described in this Privacy Policy. If we engage in a practice that constitutes selling or sharing personal information under the CCPA, we will provide a clear and conspicuous opt-out mechanism and honor applicable opt-out preference signals.

14.2 California Privacy Rights

Subject to applicable law and verification, California residents may have the right to:

1. Know the categories and specific pieces of personal information we collected about them, the sources, purposes, and categories of recipients.

2. Request deletion of personal information, subject to legal and statutory exceptions.

3. Request correction of inaccurate personal information.

4. Opt out of the sale or sharing of personal information if ROTD engages in those activities.

5. Limit certain uses and disclosures of sensitive personal information if applicable.

6. Not receive discriminatory treatment for exercising CCPA rights.

14.3 Making a California Request

To submit a California privacy request, email info@rightofthedot.com with the subject line “California Privacy Request” or call us at +1 954-288-6810. Please identify the right you seek to exercise and provide enough information for us to verify your request. You may use an authorized agent where permitted by law. We may request proof of the agent’s authority and information necessary to verify your identity.

We will use information collected to verify a request only for verification and security purposes. We will respond within the time required by law and may extend the response period where permitted after providing required notice. We will not require you to create an account to submit a request, although we may require you to use an existing account to facilitate verification.

If you believe we improperly denied a request, you may ask us to reconsider by replying to our decision within a reasonable period and stating the basis for reconsideration.

15. Contact Us

If you have questions, concerns, or requests relating to this Privacy Policy or our privacy practices, contact us at:

RightoftheDot, LLC d/b/a Right of the Dot

Email: legal@rightofthedot.com

Please include “Privacy Request” in the subject line of your email.