This USMART21.com Privacy Policy (this "Policy") tells you about how we collect, use, and protect your personal information. By accepting this Policy and the Usmart21.com User Agreement (the "User Agreement") during registration, you expressly consent to our collection, storage, use and disclosure of your personal information as described in this Policy. This Policy is effective upon acceptance for new users and is otherwise effective on Usmart21.com as of November 2010.

1. Applicability

This Policy describes how we handle your personal information for our services on USMART21.COM websites. It applies generally to the USMART21.COM websites and content and other related websites where a link to this Policy appears in the footer of the page. This Policy does not apply to the practices of companies that USMART21.COM does not own or control, or to people that USMART21.COM does not employ or manage or to information which is collected in offline mode.

Some USMART21.COM branded websites or websites we operate may be governed by separate privacy policies. The policy that applies on any of our domains or subdomains is always the policy to which a link appears in the footer of each website. Our subsidiaries’ and joint ventures’ privacy practices, if applicable, are similar to those described in this Policy. Subject to the requirements of applicable law, we strive to provide a consistent set of privacy practices throughout the global USMART21.COM trading community.

2. Collection

You may browse USMART21.COM websites without telling us who you are or revealing any personal information about yourself. Once you give us your personal information, you are not anonymous to us. If you choose to provide us with personal information, you consent to the transfer and storage of that information on our servers located in the United States.

We may collect and store the following personal information when you register with USMART21.COM and when you use our products and services:

• Contacts: email address, physical contact information, shipping, billing and other information you provide to purchase or ship an item;

• Transactions: based on your activities on USMART21.COM websites - bidding, buying, selling, item and content you generate or that relates to your account;

• Correspondence: community discussions, chats, dispute resolution, correspondence through USMART21.COM websites, and correspondence sent to us;

• Statistics: statistics related to information from your interaction with USMART21.COM websites, services, content and advertising, including computer and connection information, statistics on page views, traffic to and from USMART21.COM websites, ad data, IP address and standard web log information;

• Security answers: additional information we ask you to submit to authenticate yourself or if we believe you are violating site policies;

• Financial information: (depending on the service used) sometimes financial information, such as credit card or bank account numbers;

• Information from other companies, such as demographic and navigation data; and

• Other supplemental information from third parties (for example, if you incur a debt to USMART21.COM, we will generally conduct a credit check by obtaining additional information about you from a credit bureau, as permitted by law).

3. Marketing

We don't sell or rent your personal information to third parties for their marketing purposes without your explicit consent. We may combine your information with information we collect from other companies and use it to improve and personalize our services, content and advertising. If you don't wish to receive marketing communications from us or participate in our ad-customization programs, simply indicate your preference in your Profile Page or by following the directions provided with the communication or advertisement.

4. Use

Our primary purpose in collecting personal information is to provide you with a safe, smooth, efficient, and customized experience. You agree that we may use your personal information to:

• Provide the services and customer support you request;

• Resolve disputes, collect fees, and troubleshoot problems;

• Prevent potentially prohibited or illegal activities,

• Enforce the User Agreement;

• Customize, measure and improve our services, content and advertising;

• Tell you about our services, conduct targeted marketing, and provide service updates, and promotional offers based upon the communication preferences you have comunicated to us; and

• Compare information for accuracy, and verify it with third parties.

5. Our Disclosure of Your Information

We may disclose personal information to respond to legal requirements, enforce our policies, and the User Agreement, respond to claims that a listing or other content violates the rights of others, or protect anyone's rights, property, or safety. Such information will be disclosed in accordance with applicable laws and regulations.

We may also share your personal information with:

• Members of the USMART21 Inc. corporate family to provide joint content and services (like registration, transactions and customer support), to help detect and prevent potentially illegal acts and violations of our policies, and to guide decisions about products, services and communications. Members of our corporate family will use this information to send you marketing communications only if you have requested their services.

• Service providers under contract who help with our business operations (such as fraud investigations, bill collection, affiliate and rewards programs and co-branded credit cards).

• Other third parties to whom you explicitly ask us to send your information (or about whom you are otherwise explicitly notified and consent to when using a specific service).

• Law enforcement or other governmental officials, in response to a verified request relating to a criminal investigation or alleged illegal activity. Other business entities, should we plan to merge with or be acquired by that business entity. Without limiting the above, in an effort to respect your privacy and our ability to keep the community free from bad actors and illegal activity, we will not otherwise disclose your personal information to law enforcement, other government officials, or other third parties without a subpoena, court order or substantially similar legal procedure, except when we believe in good faith that the disclosure of information is necessary to prevent imminent physical harm or financial loss or to report suspected illegal activity.

6. Information You Share on USMART21.COM

Your User ID is displayed throughout USMART21.COM (and so available to the public), and is connected to all of your USMART21.COM activity. Other people might see your bids, purchases, items for sale, stores, feedback, ratings and associated comments. Notices sent to other community members about suspicious activity and policy violations on our sites refer to User IDs and specific items. Therefore, if you associate your name with your User ID, the people to whom you have revealed your name will be able to personally identify your USMART21.COM activities.

If you access USMART21.COM websites from a shared computer or a computer in an internet cafe, certain information about you, such as your User ID, activity or communications from USMART21.COM, may also be visible to other individuals who use the computer after you.

7. Using Information from USMART21.COM

USMART21.COM enables you to share personal and financial information to complete transactions. We encourage you to disclose your privacy practices and respect the privacy of other users. We cannot guarantee the privacy or security of your information and therefore we encourage you to evaluate the privacy and security policies of your trading partner before entering into a transaction and choosing to share your information. To help protect your privacy, we allow only limited access to other users' contact, shipping and financial information to facilitate your transactions. When users are involved in a transaction, they may have access to each other's name, User ID, email address and other contact and shipping information. In all cases, you must give other users a chance to remove themselves from your database and a chance to review what information you have collected about them.

You agree to use user information only for:

• USMART21.COM transaction-related purposes that are not unsolicited commercial messages;

• using services offered through USMART21.COM; or

• other purposes that a user expressly chooses.

8. Cookies

We use "cookies," (small files placed on your hard drive), on certain USMART21.COM websites to help analyze our web page flow; customize our services, content and advertising; measure promotional effectiveness and promote trust and safety. Some USMART21.COM features are available only through the use of cookies. We use cookies to help identify you and maintain your signed-in status. Most cookies are "session cookies," meaning that they are automatically deleted from your hard drive at the end of a session. You are always free to decline our cookies, although doing so may interfere with your use of some USMART21.COM features and services. You may encounter cookies from third parties on certain websites that we do not control. (For example, if you view a web page created by another user, there may be a cookie placed by that web page).

9. No Spam, Spyware or Spoofing

We and our users do not tolerate spam. Make sure to set your USMART21.COM notification preferences so we may communicate to you as you prefer. You are not licensed to add other USMART21.COM users, even a user who has purchased an item from you, to your mailing list (email or physical mail) without their express consent. To report USMART21.COM-related spam or spoof emails to USMART21.COM, please forward the email tospam@USMART21.COM. You may not use our communication tools to send spam or otherwise send content that would violate the User Agreement. We automatically scan and may manually filter messages to check for spam, viruses, phishing attacks and other malicious activity or illegal or prohibited content, but we do not permanently store messages sent through these tools. If you send an email to an email address that is not registered in our community (via Bring-a-Pal or other tools), we may sell such email addresses to third parties with your consent.

10. Account Protection

Your password is the key to your account. Use a unique combination of numbers, letters and special characters, to create your password. We reserve the right (but not the obligation) to reject your password if it is not sufficiently unique. Do not disclose your USMART21.COM password to anyone. If you do share your password or your personal information with others, remember that you are responsible for all actions taken in the name of your account. If you lose control of your password, you may lose substantial control over your personal information and may be subject to legally binding actions taken on your behalf. Therefore, if your password has been compromised for any reason, you should immediately notify USMART21.COM and change your password.

11. Accessing, Reviewing and Changing Your Personal Information

You can see, review and change most of your personal information by signing on to USMART21.COM. Generally, we will not manually modify your personal information because it is very difficult to verify your identity remotely. You must promptly update your personal information if it changes or is inaccurate. Once you make a public posting, you may not be able to change or remove it. Upon your request, we will close your account and remove your personal information from view as soon as reasonably possible, based on your account activity and in accordance with applicable law. We do retain personal information from closed accounts to comply with law, prevent fraud, collect any fees owed, resolve disputes, troubleshoot problems, assist with any investigations, enforce User Agreement, and take other actions otherwise permitted by law.

12. Security

Your information is stored on our servers located in the United States. We treat data as an asset that must be protected and we use a variety of tools (encryption, passwords, physical security, etc.) to protect your personal information against unauthorized access and disclosure. However, as you probably know, third parties may unlawfully intercept or access transmissions or private communications, and other users may abuse or misuse your personal information that they collect from the site. Therefore, although we work very hard to protect your privacy, we do not promise, and you should not expect, that your personal information or private communications will always remain private.

13. General

We may update this policy. We will notify you about significant changes in the way we treat your personal information by sending you an email or by placing a notice on USMART21.COM. If your questions about privacy are not answered online, you may write to us by using the Contact Us form.