DRAFT — NOT LEGAL ADVICE — ATTORNEY REVIEW REQUIRED
This document was drafted by a non-attorney assistant to accelerate review. It is not legal advice and is not final or legally sufficient. A licensed attorney must review, correct, and approve it before it is published or relied upon. Bracketed tags marked [ATTORNEY REVIEW] flag points that require a lawyer's judgment.
AuctionBuyers — Privacy Policy
Property: auctionbuyers.com (the "Site")
Provider: [ATTORNEY REVIEW] — insert the legal entity name once the LLC is formed (see the open-items checklist in docs/legal/README.md). Referred to below as "we," "us," or "AuctionBuyers."
Effective date: [ATTORNEY REVIEW] — insert on publication.
Last updated: DRAFT (not yet published).
This Privacy Policy explains what information AuctionBuyers collects, how we use it, and the choices you have. It covers two distinct kinds of information: (1) public-records data displayed on the Site (property auction and foreclosure records), and (2) information about you, a visitor.
1. Public-records data displayed on the Site
The property, auction, case, and party information shown on the Site (addresses, sale dates, case numbers, plaintiff/defendant names, and similar) is derived from public records and public notices — court dockets, sheriff and trustee sale notices, and other official government publications. We obtain this data from a third-party data provider that aggregates it from those official sources. It is not information you gave us, and displaying it is based on its status as public record. [ATTORNEY REVIEW] — confirm the public-records lawful-basis framing and whether any state (e.g., CA "publicly available information" definitions under CCPA/CPRA) requires additional disclosure.
We do not enrich these records with non-public personal information about the people named in them.
2. Information we collect from visitors
Today the Site works without accounts, and we collect very little:
- Server logs. Like nearly every website, our hosting infrastructure automatically records standard request logs: IP address, user-agent (browser/device type), the pages requested, referrer, and timestamps. We use these solely for operating, securing, debugging, and capacity-planning the Site. Logs are retained for a limited period per our hosting provider's defaults. [ATTORNEY REVIEW] — confirm the log-retention description once hosting configuration is final.
- Analytics: not yet in use. We do not currently run any analytics service. If we add privacy-respecting analytics later, we will update this policy first and describe what is collected. (Status: TBD — an analytics tool has not been chosen.)
- Accounts, saved searches, and alerts: not yet live. If we launch accounts, we will collect the information you provide (such as an email address) and will update this policy before doing so.
We do not collect payment information (there is nothing to buy on the Site today).
3. Cookies
The Site does not use advertising or cross-site tracking cookies. We use no cookies beyond those strictly necessary for the Site to function (for example, cookies our hosting/framework may set for essential operation). If that changes — for example, if we add login sessions or analytics — we will update this policy and, where required, ask for consent. [ATTORNEY REVIEW] — confirm whether any framework/host-set essential cookies require itemization under applicable law.
4. How we use visitor information
- To operate, maintain, secure, and improve the Site;
- To diagnose problems and prevent abuse (rate-limiting, blocking malicious traffic);
- To comply with law.
We do not use visitor information for advertising, and we do not build marketing profiles of visitors.
5. We do not sell your personal information
We do not sell personal information, and we do not "share" personal information for cross-context behavioral advertising (as those terms are defined in the California Consumer Privacy Act, as amended). [ATTORNEY REVIEW] — confirm this "no sale / no sharing" statement remains accurate before adding any analytics, advertising, or monetization feature, and whether a "Do Not Sell or Share" link is nonetheless required.
6. Sharing with service providers
We share visitor information only with the infrastructure providers that run the Site (for example, our hosting/CDN provider processes request logs as described above), and only so they can provide those services to us. We may also disclose information if required by law or to protect the Site and its users. [ATTORNEY REVIEW] — confirm service-provider/contractor contract language (e.g., CCPA service-provider terms) once the vendor list is final.
7. Your privacy rights (California CCPA/CPRA, Connecticut CTDPA, and similar state laws)
Depending on where you live, you may have rights to know/access, correct, or delete personal information we hold about you, and to be free from discrimination for exercising those rights. [ATTORNEY REVIEW] — confirm which state privacy laws actually apply to us given applicability thresholds (revenue/volume), and finalize the request-verification and appeal process (the CTDPA requires an appeal mechanism).
To make a privacy request, email [ATTORNEY REVIEW — placeholder]: privacy@auctionbuyers.com with the subject "Privacy request." We will need enough information to verify your identity and will respond within the time required by applicable law. If we deny your request, you may appeal by replying to our decision, and we will explain the outcome. [ATTORNEY REVIEW] — confirm response deadlines, verification standard, and the appeal-path description.
Note: because we collect so little visitor information today (server logs only), there is often nothing for us to access or delete beyond short-lived operational logs.
8. Removal requests for public-records listings
If you are named in a listing displayed on the Site and want it removed or suppressed, please note: we display data supplied by an upstream data provider, and removals and suppressions happen at the data source. Our provider processes removal/suppression requests against the underlying records; once a record is suppressed upstream, it disappears from or is anonymized on the Site automatically. To start a removal request, email [ATTORNEY REVIEW — placeholder]: removals@auctionbuyers.com with the listing link, and we will forward the request to the data provider and let you know the outcome. [ATTORNEY REVIEW] — confirm this pass-through removal process, its description, and any obligations that fall on us directly (rather than the provider) under state law.
9. Data retention
Server logs are retained only for the limited operational period described in Section 2. Public-records listing data is retained and refreshed per our data provider; it is not "your data held by us" in the account sense. If accounts launch later, we will state account-data retention here. [ATTORNEY REVIEW] — confirm retention statements against the final infrastructure configuration.
10. Security
We use reasonable technical and organizational measures appropriate to the small amount of visitor data we handle (transport encryption, access controls on infrastructure). No method of transmission or storage is 100% secure. [ATTORNEY REVIEW] — confirm the "reasonable security" formulation.
11. Children
The Site is not directed to children under 13 (or under 16/18 where higher thresholds apply), and we do not knowingly collect personal information from children. [ATTORNEY REVIEW] — confirm age thresholds and COPPA position.
12. Changes to this policy
We may update this policy from time to time. We will post the updated version with a new "Last updated" date and, for material changes, provide reasonable notice on the Site.
13. Contact
Privacy questions and requests: [ATTORNEY REVIEW — placeholder]: privacy@auctionbuyers.com Removal requests for listings: see Section 8.