Privacy Policy

This privacy policy ("Policy") describes how Gavel FZ LLC ("Gavel FZ LLC", "we", "us" or"our") collects, protects and uses the personally identifiable information ("PersonalInformation") you ("User", "you" or "your") may provide on the websiteand any of its products or services (collectively, "Website" or "Services"). It alsodescribes the choices available to you regarding our use of your Personal Informationand how you can access and update this information. This Policy does not apply to thepractices of companies that we do not own or control, or to individuals that we do notemploy or manage.

Collection of personal information

We receive and store any information you knowingly provide to us when you create anaccount, publish content, make a purchase, fill any online forms on the Website. Whenrequired this information may include your email address, name, phone number,address, credit card information, or other Personal Information. You can choose not toprovide us with certain information, but then you may not be able to take advantage ofsome of the Website's features. Users who are uncertain about what information ismandatory are welcome to contact us.

Collection of non-personal information

When you visit the Website our servers automatically record information that yourbrowser sends. This data may include information such as your device's IP address,browser type and version, operating system type and version, language preferences orthe webpage you were visiting before you came to our Website, pages of our Websitethat you visit, the time spent on those pages, information you search for on our Website,access times and dates, and other statistics.

Managing personal information

You are able to access, add to, update and delete certain Personal Information aboutyou. The information you can view, update, and delete may change as the Website orServices change. When you update information, however, we may maintain a copy ofthe unrevised information in our records. Some information may remain in our privaterecords after your deletion of such information from your account. We will retain anduse your information as necessary to comply with our legal obligations, resolvedisputes, and enforce our agreements. We may use any aggregated data derived from orincorporating your Personal Information after you update or delete it, but not in amanner that would identify you personally. Once the retention period expires, PersonalInformation shall be deleted. Therefore, the right to access, the right to erasure, theright to rectification and the right to data portability cannot be enforced after theexpiration of the retention period.

Use and processing of collected information

You agree to comply with all applicable domestic and international laws, statutes, ordinances and regulations regarding your use of our Website, Content, Services, and any software provided therein.

Information transfer and storage

Depending on your location, data transfers may involve transferring and storing yourinformation in a country other than your own. You are entitled to learn about the legalbasis of information transfers to a country outside the European Union or to anyinternational organization governed by public international law or set up by two ormore countries, such as the UN, and about the security measures taken by us tosafeguard your information. If any such transfer takes place, you can find out more bychecking the relevant sections of this document or inquire with us using the informationprovided in the contact section.

The rights of users

You may exercise certain rights regarding your information processed by us. Inparticular, you have the right to do the following: (i) you have the right to withdrawconsent where you have previously given your consent to the processing of yourinformation; (ii) you have the right to object to the processing of your information if theprocessing is carried out on a legal basis other than consent; (iii) you have the right tolearn if information is being processed by us, obtain disclosure regarding certainaspects of the processing and obtain a copy of the information undergoing processing;(iv) you have the right to verify the accuracy of your information and ask for it to beupdated or corrected; (v) you have the right, under certain circumstances, to restrict theprocessing of your information, in which case, we will not process your information forany purpose other than storing it; (vi) you have the right, under certain circumstances,to obtain the erasure of your Personal Information from us; (vii) you have the right toreceive your information in a structured, commonly used and machine readable formatand, if technically feasible, to have it transmitted to another controller without anyhindrance.

This provision is applicable provided that your information is processed byautomated means and that the processing is based on your consent, on a contract whichyou are part of or on pre-contractual obligations thereof.

The right to object to processing

Where Personal Information is processed for the public interest, in the exercise of anofficial authority vested in us or for the purposes of the legitimate interests pursued byus, you may object to such processing by providing a ground related to your particularsituation to justify the objection. You must know that, however, should your PersonalInformation be processed for direct marketing purposes, you can object to thatprocessing at any time without providing any justification. To learn, whether we areprocessing Personal Information for direct marketing purposes, you may refer to therelevant sections of this document.

How to exercise these rights

Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by the Owner as early as possible and always within one month.

Billing and payments

In case of services requiring payment, we request credit card or other payment accountinformation, which will be used solely for processing payments. Your purchasetransaction data is stored only as long as is necessary to complete your purchasetransaction. After that is complete, your purchase transaction information is deleted. Alldirect payment gateways adhere to the latest security standards as managed by the PCISecurity Standards Council, which is a joint effort of brands like Visa, MasterCard,American Express and Discover.

Sensitive and private data exchange happens over aSSL secured communication channel and is encrypted and protected with digitalsignatures, and our Website is also in compliance with PCI vulnerability standards inorder to create as secure of an environment as possible for Users. Scans for malware areperformed on a regular basis for additional security and protection.

Product and service providers

We may contract with other companies to provide certain products and services. Theseservice providers are not authorized to use or disclose the information except asnecessary to perform services on our behalf or comply with legal requirements. We mayshare Personal Information for these purposes only with third-parties whose privacypolicies are consistent with ours or who agree to abide by our policies with respect toPersonal Information Our service providers are given the information they need toperform their designated functions, and we do not authorize them to use or disclosePersonal Information for their own marketing or other purposes.

Privacy of children

We do not knowingly collect any Personal Information from children under the age of13. If you are under the age of 13, please do not submit any Personal Informationthrough our Website or Service. We encourage parents and legal guardians to monitortheir children's Internet usage and to help enforce this Policy by instructing theirchildren never to provide Personal Information through our Website or Service withouttheir permission. If you have reason to believe that a child under the age of 13 hasprovided Personal Information to us through our Website or Service, please contact us.You must also be at least 16 years of age to consent to the processing of your personaldata in your country (in some countries we may allow your parent or guardian to do soon your behalf).


We offer electronic newsletters to which you may voluntarily subscribe at any time. Youmay choose to stop receiving our newsletter or marketing emails by following theunsubscribe instructions included in these emails or by contacting us. However, you willcontinue to receive essential transactional emails.


The Website uses "cookies" to help personalize your online experience. A cookie is atext file that is placed on your hard disk by a web page server. Cookies cannot be used torun programs or deliver viruses to your computer. Cookies are uniquely assigned toyou, and can only be read by a web server in the domain that issued the cookie to you.We may use cookies to collect, store, and track information for statistical purposes tooperate our Website and Services. You have the ability to accept or decline cookies.Most web browsers automatically accept cookies, but you can usually modify yourbrowser setting to decline cookies if you prefer. If you choose to decline cookies, youmay not be able to fully experience the features of the Website and Services. To learnmore about cookies and how to manage them, visit internetcookies.orgIn addition to using cookies and related technologies as described above, we also maypermit certain third-party companies to help us tailor advertising that we think may beof interest to users and to collect and use other data about user activities on theWebsite. These companies may deliver ads that might also place cookies and otherwisetrack user behavior.


We may display online advertisements and we may share aggregated and nonidentifyinginformation about our customers that we collect through the registrationprocess or through online surveys and promotions with certain advertisers. We do notshare personally identifiable information about individual customers with advertisers. In some instances, we may use this aggregated and non-identifying information todeliver tailored advertisements to the intended audience.


We may disclose information about you to our affiliates for the purpose of being able tooffer you related or additional products and services. Any information relating to youthat we provide to our affiliates will be treated by those affiliates in accordance with theterms of this Privacy Policy.

Links to other websites

Our Website contains links to other websites that are not owned or controlled by us.Please be aware that we are not responsible for the privacy practices of such otherwebsites or third-parties. We encourage you to be aware when you leave our Websiteand to read the privacy statements of each and every website that may collect PersonalInformation.

Information security

We secure information you provide on computer servers in a controlled, secureenvironment, protected from unauthorized access, use, or disclosure. We maintainreasonable administrative, technical, and physical safeguards in an effort to protectagainst unauthorized access, use, modification, and disclosure of Personal Informationin its control and custody. However, no data transmission over the Internet or wirelessnetwork can be guaranteed. Therefore, while we strive to protect your PersonalInformation, you acknowledge that (i) there are security and privacy limitations of theInternet which are beyond our control; (ii) the security, integrity, and privacy of anyand all information and data exchanged between you and our Website cannot beguaranteed; and (iii) any such information and data may be viewed or tampered with intransit by a third-party, despite best efforts.

Data breach

In the event we become aware that the security of the Website has been compromisedor users Personal Information has been disclosed to unrelated third parties as a resultof external activity, including, but not limited to, security attacks or fraud, we reservethe right to take reasonably appropriate measures, including, but not limited to,investigation and reporting, as well as notification to and cooperation with lawenforcement authorities. In the event of a data breach, we will make reasonable effortsto notify affected individuals if we believe that there is a reasonable risk of harm to theuser as a result of the breach or if notice is otherwise required by law. When we do, wewill send you an email.

Legal disclosure

We will disclose any information we collect, use or receive if required or permitted bylaw, such as to comply with a subpoena, or similar legal process, and when we believe ingood faith that disclosure is necessary to protect our rights, protect your safety or thesafety of others, investigate fraud, or respond to a government request. In the event wego through a business transition, such as a merger or acquisition by another company,or sale of all or a portion of its assets, your user account, and personal data will likely beamong the assets transferred.

Changes and amendments

We reserve the right to modify this Policy relating to the Website or Services at anytime, effective upon posting of an updated version of this Policy on the Website. Whenwe do we will revise the updated date at the bottom of this page. Continued use of theWebsite after any such changes shall constitute your consent to such changes.

Acceptance of this policy

You acknowledge that you have read this Policy and agree to all its terms and conditions. By using the Website or its Services you agree to be bound by this Policy. If you do not agree to abide by the terms of this Policy, you are not authorized to use or access the Website and its Services.

Contacting us

If you have any questions about this Policy, please contact us.
This document was last updated on February 14, 2019