Bezel Inc. (“Bezel,” “we,” “us,” or “our”) has prepared this Privacy Policy to explain what personal information we collect, how we use and share that information, and your choices concerning our information practices. Through our mobile application (the “App”), we provide an online marketplace for luxury watches (such services, including https://www.getbezel.com/ (the “Site”) and the App, are referred to collectively in this Privacy Policy as the “Service”).

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This Privacy Policy explains what personal information we collect, how we use and share that information, and your choices concerning our information practices. This Privacy Policy is incorporated into and forms part of our Terms of Service.

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Before using the Service or submitting any personal information to Bezel, please review this Privacy Policy carefully and contact us if you have any questions. By using the Service, you agree to the practices described in this Privacy Policy. If you do not agree to this Privacy Policy, please do not access the Site or otherwise use the Service.

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1. PERSONAL INFORMATION WE COLLECT

We collect personal information as follows:

Personal Information You Provide: We collect the following categories of personal information from you when you use our Service, create and update your account, contact us, join our waitlist, offer to sell or purchase a product, or otherwise interact with us: 

• Identification Information: We collect your name, email address, phone number, and mailing/billing addresses.
• Financial Information: We collect the financial information necessary to process your payments, such as your bank account number, routing information, payment card number, and authentication details. We then pass on this information to our third party payment processors. Please note, however, that we do not store such financial information. We only store a tokenized version of such information and do not maintain payment card information and bank account information on our servers. By using Bezel to purchase products, you are granting Bezel and our third party payment processors the right, power, and authority to act on your behalf to access and transmit your personal and financial information from the relevant financial institution.
• Communication Information: We may collect information contained in your communications to us or through the Service, such as when you contact us with questions or concerns, when you voluntarily respond to questionnaires, surveys or requests for market research seeking your opinion and feedback, or when you send messages to Bezel or to other users through the Service. 

• Commercial Information: We may retain a history of the watches you browse, purchase, or add to Your Collection.
• Social Media Information: 

• You may be able to create a Bezel account through a third party social media platform (“SMP”) and/or share your Bezel experiences on a SMP. To take advantage of this feature, we will ask you to log into or grant us permission to import certain personal information via the relevant SMP. If you do so, we may receive information that you have provided to your SMP (such as your contact details, profile picture, email address, friend lists, and other information you make publicly available via the applicable SMP). You may be able to adjust the information we receive by changing your SMP settings.  Please note that the manner in which the SMP collects, uses, stores and discloses your information is governed by the policies of the SMP and that if you share on an SMP your friends, followers, or subscribers will be able to view what you share.
• We also have pages on SMPs (“Social Media Pages”). When you interact with our Social Media Pages, we will collect personal information that you elect to provide to us, such as your contact details. In addition, the SMPs may provide us with aggregate information and analytics regarding the use of our Social Media Pages.

• Your Collection: We collect information relating to the watches in your personal Own section of the Collect tab, including the:

• reference number, brand, model, and condition of the watch;
• watch ownership status and history; and
• purchase price, time and place of purchase and photos of the watch.

We may estimate the value of your watch from the information you provide.

Internet Activity Information: When you visit, use, and interact with the Service, we may receive certain information about your visit, use, or interactions. For example, we may monitor the number of people that visit the Service, peak hours of visits, which page(s) are visited, the domains our visitors come from (e.g., google.com, yahoo.com, etc.), and which browsers people use to access the Service (e.g., Chrome, Firefox, Microsoft Internet Explorer, etc.), broad geographical information, and navigation pattern. In particular, the following information is created and automatically logged in our systems: 

• Log Information: Information that your browser automatically sends whenever you visit the Site. Log Information includes your Internet Protocol address, browser type and settings, the date and time of your request, and how you interacted with the Site. 
• Cookies Information: Please see the “Cookies” section below to learn more about how we use cookies.
• Device Information: Includes name of the device, operating system, and browser you are using. Information collected may depend on the type of device you use and its settings. 
• Usage Information: We collect information about how you use our Service, such as the types of content that you view or engage with, the features you use, the actions you take, and the time, frequency, and duration of your activities.
• Location Information: We derive a rough estimate of your location from your IP address. We collect your location information through the App using your device IP address, WiFi, Bluetooth, and GPS coordinates (e.g. latitude/longitude) of your mobile device. If you have given the App permission to access your location, we will collect your device’s location only while you are using the Service and store your location history. If you want to opt-out of the collection of your Location Information, please adjust your settings in your mobile device to limit the App’s access to your Location Information. 
• Email Open/Click Information: We use pixels in our email campaigns that allow us to collect your email and IP address as well as the date and time you open an email or click on any links in the email.

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Personal Information Collected from Third Parties/Publicly Available Sources: We collect information from public sources, such as public websites and watch appraisal listing services. Most of the information we collect is about watches, not people. However, some of the information we collect, like the identity of a watch’s owner, may relate to individuals. Occasionally, users may communicate to us the personal information of third parties (e.g. authorized representatives, or different account owners). 

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Cookies: We use cookies to operate and administer our Site, gather usage data on our Site, and improve your experience on it. A “cookie” is a piece of information sent to your browser by a website you visit. Cookies can be stored on your computer for different periods of time. Some cookies expire after a certain amount of time, or upon logging out (session cookies), others survive after your browser is closed until a defined expiration date set in the cookie (as determined by the third party placing it), and help recognize your computer when you open your browser and browse the Internet again (persistent cookies). For more details on cookies please visit All About Cookies.

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On most web browsers, you will find a “help” section on the toolbar. Please refer to this section for information on how to receive a notification when you are receiving a new cookie and how to turn cookies off. 

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Please note that if you limit the ability of websites to set cookies, you may be unable to access certain parts of the Site and you may not be able to benefit from the full functionality of the Site.

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Advertising networks may use cookies to collect personal information. Most advertising networks offer you a way to opt out of targeted advertising. If you would like to find out more information, please visit the Network Advertising Initiative’s online resources and follow the opt-out instructions there.

If you access the Site on your mobile device, you may not be able to control tracking technologies through the settings. 

Online Tracking and Do Not Track Signals: We and our third party service providers, including Facebook, may use cookies, pixels, or other tracking technologies to collect information about your browsing activities over time and across different websites following your use of the Site and use that information to send targeted advertisements. Our Site currently does not respond to “Do Not Track” (“DNT”) signals and operates as described in this Privacy Policy whether or not a DNT signal is received. If we do respond to DNT signals in the future, we will update this Privacy Policy to describe how we do so.[ 

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2. HOW WE USE PERSONAL INFORMATION

We may use personal information for the following purposes:

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• To provide the Service, including to:

• provide a marketplace that connects watch buyers and sellers;
• document and assess the value of your watches;
• add watches to Your Collection 
• analyze the watches posted on the Service; and 
• discover new watches;

• To respond to your inquiries, comments, feedback, questions, or to forward to the relevant merchant or seller upon your request if you submit such a request through our website;
• To send administrative information to you, for example, information regarding the Service and changes to our terms, conditions, and policies;
• To analyze how you interact with our Service;
• To maintain and improve the Service;
• To develop new products and services;
• To prevent fraud, criminal activity, or misuses of our Service, and to ensure the security of our IT systems, architecture, and networks; and
• To comply with legal obligations and legal process and to protect our rights, privacy, safety, or property, and/or that of our affiliates, you, or other third parties.

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Aggregated Information. We may aggregate personal information and use the aggregated information to analyze the effectiveness of our Service, to improve and add features to our Service, and for other similar purposes. In addition, from time to time, we may analyze the general behavior and characteristics of users of our Service and share aggregated information like general user statistics with prospective business partners. We may collect aggregated information through the Service, through cookies, and through other means described in this Privacy Policy.

Marketing. We may use your personal information to contact you to tell you about products or services we believe may be of interest to you. For instance, if you elect to provide your email[ or telephone number], we may use that information to send you special offers. You may opt out of receiving emails by following the instructions contained in each promotional email we send you. You can also control the marketing emails and/or text messages you receive by updating your settings through your account. In addition, if at any time you do not wish to receive future marketing communications, you may contact us. If you unsubscribe from our marketing lists, you will no longer receive marketing communications but we will continue to contact you regarding management of your account, other administrative matters, and to respond to your requests.

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3. SHARING AND DISCLOSURE OF PERSONAL INFORMATION

In certain circumstances we may share the categories of personal information described above without further notice to you, unless required by the law, with the following categories of third parties:

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• Vendors and Service Providers: To assist us in meeting business operations needs and to perform certain services and functions, we may share personal information with vendors and service providers, including providers of security and fraud services, hosting services, cloud services, and other information technology services providers, email communication software and email newsletter services, advertising and marketing services, payment processors, customer relationship management and customer support services, and analytics services. Pursuant to our instructions, these parties will access, process, or store personal information in the course of performing their duties to us. We take commercially reasonable steps to ensure our service providers adhere to the security standards we apply to your personal information.

• Business Transfers: If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, dissolution, sale of all or a portion of our assets, or transition of service to another provider (collectively a “Transaction”), your personal information may be shared in the diligence process with counterparties and others assisting with the Transaction and transferred to a successor or affiliate as part of or following that Transaction along with other assets.
• Legal Requirements: If required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation, including to meet national security or law enforcement requirements, (ii) protect and defend our rights or property, (iii) prevent fraud, (iv) act in urgent circumstances to protect the personal safety of users of the Service, or the public, or (v) protect against legal liability.
• Other Users: Certain actions you take may be visible to other users of the Service. For example, your profile information may be accessible to other users if you post a watch. You acknowledge that by adding information to your profile you make the information shared available to other users and that Bezel cannot control, and shall not be responsible for any use other users make of such information. 

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4. DATA RETENTION

We keep personal information for as long as reasonably necessary for the purposes described in this Privacy Policy, while we have a business need to do so, or as required by law (e.g. for tax, legal, accounting, or other purposes), whichever is longer.

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5. CALIFORNIA PRIVACY RIGHTS DISCLOSURES

Where provided for by law and subject to any applicable exceptions, California residents may have the right:

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• To know the categories of personal information that Bezel has collected about you, the business purpose for collecting your personal information, and the categories of sources from which the personal information was collected;
• To access the specific pieces of personal information that Bezel has collected about you;
• To know whether Bezel has disclosed your personal information for business purposes, the categories of personal information so disclosed, and the categories of third parties to whom we have disclosed your personal information;
• To have Bezel, under certain circumstances, delete your personal information; 
• To instruct businesses that sell personal information to stop doing so –Bezel, however, does not sell personal information; and
• To be free from discrimination related to the exercise of these rights.

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If you would like to exercise any or all of these rights, you may do so by emailing us at help@getbezel.com or mailing us at 1653 7th Street, #1606 Santa Monica, CA 90406. After we receive your request, we may request additional information from you to verify your identity. Your authorized agent may submit requests in the same manner, although we may require the agent to present signed written permission to act on your behalf, and you may also be required to independently verify your identity with us and confirm that you have provided the agent permission to submit the request.

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Please contact us with questions or to request access to an alternative format of this Privacy Policy.

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6. CHILDREN

Our Service is not directed to children who are under the age of 16. Bezel does not knowingly collect personal information from children under the age of 16. If you have reason to believe that a child under the age of 16 has provided personal information to Bezel through the Service please contact us and we will try to delete that information from our databases.

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7. LINKS TO OTHER WEBSITES

The Service may contain links to other websites not operated or controlled by Bezel, including social media services (“Third Party Sites”). The information that you share with Third Party Sites will be governed by the specific privacy policies and terms of service of the Third Party Sites and not by this Privacy Policy. By providing these links we do not imply that we endorse or have reviewed these sites. Please contact the Third Party Sites directly for information on their privacy practices and policies. 

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8. JOB APPLICANTS 

When you visit the “Jobs” page of the Site, we collect the information that you provide to us in connection with your job application. This includes business and personal contact information, professional credentials and skills, educational and work history, and other information that may be included in a resume. We also collect diversity information if you choose to provide it. We use this information to facilitate our recruitment activities and process employment applications, such as by evaluating a job candidate for an employment activity, and monitoring recruitment statistics. We may also use and disclose this information (a) to improve the “Jobs” page of the Site, (b) as necessary to comply with relevant laws, (c) to respond to subpoenas or warrants served on Bezel, and (d) to protect and defend the rights or property of Bezel or others.

9. SECURITY

You use the Service at your own risk. We implement commercially reasonable technical, administrative, and organizational measures to protect personal information both online and offline from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. However, no Internet or e-mail transmission is ever fully secure or error free. In particular, e-mail sent to or from us may not be secure. Therefore, you should take special care in deciding what information you send to us via the Service or e-mail. Please keep this in mind when disclosing personal information to Bezel via the Internet. In addition, we are not responsible for circumvention of any privacy settings or security measures contained on the Service, or third party websites.

10. PERSONAL INFORMATION PROCESSING IN THE U.S.

The Service is not intended for use outside the United States. By using our Service, you understand and acknowledge that your personal information will be transferred from your location to our facilities and servers in the United States, where data protection laws may differ from those in your jurisdiction.

11. YOUR CHOICES

In certain circumstances providing personal information is optional. However, if you choose not to provide personal information that is needed to use some features of our Service, you may be unable to use those features. You can also log in to your account or contact us to request updates or corrections to your personal information.

12. CHANGES TO THE PRIVACY POLICY

The Service and our business may change from time to time. As a result we may change this Privacy Policy at any time. When we do we will post an updated version on this page, unless another type of notice is required by the applicable law. By continuing to use our Service or providing us with personal information after we have posted an updated Privacy Policy, or notified you by other means if applicable, you consent to the revised Privacy Policy and practices described in it.

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13. CONTACT US

If you have any questions about our Privacy Policy or information practices, please feel free to contact us at our designated request address: help@getbezel.com.  

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