Auto Bid Systems, Inc., trading as myLIVEoffer.com^TM ("myLIVEoffer.com^TM"), owns and operates the website www.myLIVEoffer.com (the "Site"), as well as the services, features, platform, and technology that allow you to search for and eNegotiate on automobiles. These are referred to collectively in this Policy as the "myLIVEoffer.com^TM System," or sometimes simply as the "System."

I. An Overview of Our Privacy Policy

Summary:

Your personal information will not be sold, rented, bartered or shared with a third party without your permission.

In order to eNegotiate using the System, you must register by providing us with the information requested in the registration screens.

You control the messages and alerts that are generated by the System.

Third party affiliates, partners or advertising networks may use cookies on the System.

The myLIVEoffer.com^TM System offers various features. Some features, such as  allowing you to make offers on specific vehicles by VIN (Vehicle Identification Number), can only be used after you have provided us with information about yourself. You will be prompted to provide us with any additional information that is needed in order to access certain features. All of the information that we collect is governed by this  Privacy Policy. You do not have to provide us with such information, but, if you do not, you may not be able to take full advantage of the System. For example, users who do not provide requested information will not be able make offers on vehicles, and results of searches may not contain complete vehicle information. If you choose to complete the registration process, you consent to the transfer and storage of that information to our servers located in the United States.

The System is constructed to allow the user to maintain control over message alerts.  For example, a registered user will be able to turn on all message alerts to meet a more aggressive personal car buying timetable or limit the type and frequency of these messages to match a more casual purchase timeframe.

myLIVEoffer.com^TM respects the privacy of all those who use our System. This Privacy Policy discloses the types of information we gather, how we use it, and how to correct or change it. myLIVEoffer.com^TM takes the privacy of our users’ personal information very seriously and will use that information only in accordance with the terms of this Privacy Policy. We will not sell or rent our users’ personally-identifiable information or a list of our users to third parties. However, as described in more detail below, there are limited circumstances in which some information will be shared with third parties, under strict restrictions, so it is important for all users to review this Privacy Policy. This Privacy Policy applies to all services that are hosted on the Site. Except as set forth within this Privacy Policy and other published guidelines, we do not release personally-identifiable information about our users without their permission.

By accepting the Privacy Policy and User Agreement in registration, users expressly consent to our use and disclosure of their personal information in the manner described in this Privacy Policy. This Privacy Policy is incorporated into and subject to the terms of the User Agreement. This Privacy Policy will take effect on March 30, 2006.  This Privacy Policy was last updated on October 10, 2008.

In order to enhance the protection of your privacy and our compliance with this Privacy Policy, myLIVEoffer.com^TM has agreed to disclose our information practices and to have our practices reviewed for compliance by companies such as Habeas, TRUSTe and others.  These are independent organizations whose mission is to build users' trust and confidence in the Internet by promoting the use of fair information practices. By displaying the trustmark from any of these companies, myLIVEoffer.com^TM has agreed to notify you of:

1. What personally identifiable information of yours is collected by myLIVEoffer.com^TM.

2. The organization collecting the information.

3. How the information is used.

4. With whom the information may be shared.

5. What choices are available to you regarding collection, use and distribution of the information.

6. The kind of security procedures that are in place to protect the loss, misuse or alteration of information under myLIVEoffer.com^TM’s control.

7. How you can correct any inaccuracies in the information.

myLIVEoffer.com^TM has also contracted with Habeas.com, an e-mail trust authority that certifies the practices of legitimate e-mail senders. Habeas will review our e-mail policies to ensure that we are in compliance with industry standards, that we do not engage in e-mail activities that would be considered to be spam, and to ensure that our e-mail communications with you are not improperly blocked.

If you have questions or concerns regarding this Privacy Policy, you should first contact myLIVEoffer.com^TM at info@myliveoffer.com. If you do not receive acknowledgment of your inquiry or your inquiry has not been satisfactorily addressed, you should then contact TRUSTe ( http://www.truste.org/consumers/watchdog_complaint.php). TRUSTe will then serve as a liaison with myLIVEoffer.com^TM to resolve your concerns.

Some of the information and services that are available on the System may come from third parties. Where applicable, we note any copyrights or other intellectual property rights of those parties.

A Special Note About Children and Minors.

All users must be 18 years of age or older in order to use our System. Children are not eligible to use our System and we ask that minors (under the age of 18) do not submit any personal information to us or use the System.

Please note that myLIVEoffer.com^TM reviews its privacy practices from time to time, and that those practices are therefore subject to change. We will post the amended Privacy Policy prominently on our Site so that you can always review what information we gather, how we might use that information, and whether we will disclose it to anyone. Please check the Site at any time for the most current version of our Privacy Policy. We ask that you bookmark and periodically review the Site to ensure continuing familiarity with the most current version of our Privacy Policy. Any modifications to our privacy practices will be reflected first within this area of our Site. If there is a material change in our privacy practices, we will indicate that our privacy practices have changed and provide a link to the new privacy statement. If we are going to be using the information collected from registered users in a manner materially different from that stated at the time of collection, we will send all registered users written notice of the change by e-mail.

To contact myLIVEoffer.com^TM about privacy issues, to report a violation of our Privacy Policy, or to send us any other comments, please e-mail us at info@myliveoffer.com

II. The Information That We Gather

myLIVEoffer.com^TM gathers two types of information about users: non-personally-identifiable information and personally-identifiable information, as explained below.

A. Non-personally identifiable information: When anyone accesses the System, we may collect and aggregate information indicating, among other things, which pages were visited, the order in which they were visited, and which hyperlinks were "clicked." Collecting such information involves the logging of IP addresses, operating system and browser software used by users of the myLIVEoffer.com^TM System. Although such information is not personally identifiable, we can determine from the IP address a visitor's Internet Service Provider and the geographic location of the visitor's point of connectivity.

We use this data to make decisions about the effectiveness of the System and our promotional activities. In addition, we may disclose some of this aggregated, non-personal information to our advertisers and partners to inform them of the number of people who have seen and/or clicked through their advertisements. See below - "How we use (and do not use) non-personally identifiable information."

We may also use small data files called "cookies." These are files that are created by our System that retain your username and password. Cookies are only stored on your computer, not on ours, and they are placed on your computer so that you do not have to re-enter your username and password every time that you access the System. Our cookies do not store any other information. We do not use cookies for any other purpose. You can disable these cookies if you prefer. Please refer to the documentation accompanying your Web browser for instructions on how to disallow or disable cookies. 

We may allow other companies that are presenting advertisements on our System to use tracking technology on your computer. We do not give any personally identifiable information to them as part of this relationship. Unless you visit the Web site of these companies and provide them with personally identifiable information about yourself, these tracking technologies do not tell those advertisers who you are. Our advertisers' use of tracking technology is subject to their own privacy policies.

B. Personally-identifiable information:

1. What we collect from users who registers. When you register by following the registration screens, we require that you provide us with personally-identifiable information about you in order to verify your identity and reduce the risk of fraud. This registration information will include, for example, first name, last name, street address, e-mail address and telephone number. During the registration process you may also be asked to state that you are 18 years of age or older and that you have a valid credit card. We use the credit card information to validate that the card and the billing statement address. We do not save your credit card information during registration, nor will we save your credit card information anywhere on the System unless we first clearly indicate the reason why you would want to save it and then only with your permission. (This could happen if, for example, you ask us to save your credit card information so that you do not have to enter it again if you decide to lock in an Accepted Offer.)

Please note that, if you wish to make an offer on a vehicle, you must complete all registration screens that are presented. We may also receive information about you from other sources, some of which may contain personally-identifiable information about you, and add it to the information you provided to us. Unless you give us express permission to do so, we will not use any personally-identifiable information for commercial purposes nor share it with third parties except as explained in this Privacy Policy.

2. Children and Minors. Minors under the age of 18 are not permitted to register on the System nor use the System. Accordingly, we do not knowingly collect personally identifiable information from children (minors under thirteen years old) or otherwise from minors under the age of eighteen.

3. Information About You From Third Parties. In order to protect all our customers and dealers against potential fraud, we verify with third parties the information you provide. In the course of such verification, we receive personally-identifiable information about you from such services. In particular, when you provide us with your credit card or debit card information, we may use card authorization and fraud screening services to verify that your card information and address matches the information that you supplied to us, and that the card has not been reported as lost or stolen.

III. How We Use (and Do Not Use) the Information We Gather

Please take some time to familiarize yourself with the different ways myLIVEoffer.com^TM uses the information that it gathers. Keep in mind that, while myLIVEoffer.com^TM encourages all third parties involved, including, but not limited to, its affiliates and advertisers, to adhere to our policies regarding the privacy of our users and to otherwise handle personal information in a responsible manner, we cannot and do not assume any responsibility for any actions or omissions of third parties, including the manner in which they use information received either from myLIVEoffer.com^TM or independently. Nevertheless, in the event you encounter any third party associated with, or who claims association with myLIVEoffer.com^TM who you feel is improperly collecting or using information about you, please contact us at info@myLIVEoffer.com; we will be happy to forward your message to the third party. Below we explain how we use the information that we collect.

A. How We Use (and Do Not Use) Non-Personally Identifiable Information:

1. We use non-personally identifiable information in aggregate form to build higher quality, more useful online services by performing statistical analyses of the collective characteristics and behavior of users, and by measuring demographics and interests regarding specific areas and features of the System. We provide statistical information based on this data to advertisers, affiliates, and other current and potential business partners. We also use the aggregate data to inform these third parties as to the number of people who have seen and clicked on links to their web sites.

2. Our System may contain links to other websites, including co-branded or other affiliated sites which may or may not be owned or operated by myLIVEoffer.com^TM.  Unless otherwise explicitly stated, we are not responsible for the privacy practices or the content of such websites, including such sites' use of any information (such as IP number, browser type, or operating system) collected when users of our myLIVEoffer.com^TM System click through links to those websites. Even though such information might not identify you personally, we strongly encourage you to become familiar with the privacy practices of those other websites.

B. How We Use (and Do Not Use) Personally-Identifiable Information: 

1. Use of Information Generally. We use the personally-identifiable information that we collect about you in order to: a) verify that you are who you say you are; b) verify that you are the holder of the credit or debit card that you enter into the system and that the card is valid, which protects you, other users, and the Dealer; c) to allow you to make an offer on a vehicle and to lock in an Accepted Offer and receive a Dealer’s Guarantee; d) otherwise to take advantage of the services that myLIVEoffer.com^TM offers on the System; e) to communicate with you; and f) to allow communication between you and the Dealer to facilitate a transaction involving a vehicle. Your e-mail address is also used as your unique name in the myLIVEoffer.com^TM System.

2. Release of Information to Dealers After You Lock In an Accepted Offer. The System allows registered users to search for and make an offer on automobiles, with the object of securing a guarantee on behalf of the Dealer offering the vehicle that the Dealer will sell the registered user the selected vehicle at the successful Lock-inn price. In the event that the registered user makes an Accepted Offer and agrees to have a charge placed on his or her credit card in order to lock in the purchase price and receive a Dealer’s Guarantee, the myLIVEoffer.com^TM System will automatically send information regarding the registered user to the Dealer so that the Dealer can hold the vehicle for the registered user and so that the Dealer can charge the user’s credit card.  This information will include the registered user’s name, address, telephone number(s) and e-mail address, and possibly other related information.

3. E-mail Communications With Dealers.  Dealers participating in the myLIVEoffer.com^TM System will have the opportunity to take actions that may lead to the System sending e-mail messages to eNegotiators or to users based on searches that they have conducted and only when those users have chosen to receive such email messages. myLIVEoffer.com^TM System includes the ability of users and dealers to send communications to each other via e-mail. myLIVEoffer.com^TM may use a third party service provider for such e-mail communications, and that provider will have access to your e-mail address, and possibly other personally-identifiable information, although such providers will only be authorized to use such information in order to complete e-mail messages requested by the myLIVEoffer.com^TM System and not for any other purposes.

4. Our Communications with Users. We communicate with users via e-mail to provide requested services, and we also communicate by phone to resolve customer complaints or investigate suspicious transactions. We use your e-mail address to confirm your registration, to send you notice of charges that you have authorized to your credit or debit card, to send information about important changes to our services, and to send notices and other disclosures required by law. If you send us correspondence, including e-mails and faxes, we retain such information in the records of your account. We will also retain customer service correspondence and other correspondence from myLIVEoffer.com^TM to you. We retain these records in order to measure and improve our customer service, and to investigate potential fraud and violations of our User Agreement. We may, over time, delete these records if permitted by law.

5. In the Event of Merger or Sale. As with any other business, it is possible that myLIVEoffer.com^TM, which owns and operates the System, could merge with or be acquired by another company. If such an acquisition occurs, the successor company would have access to the information maintained by myLIVEoffer.com^TM and, in those events, our databases of information, including information that you have provided to us, will most likely be one of the assets sold to whoever acquires the company or its assets. We will include a provision in any sale of the company or its assets that the acquirer abide by the terms of this Privacy Policy.

6. Audits.  In connection with independent audits of our financial statements and operations, the auditors may seek to contact a sample of our customers to confirm that our records are accurate. However, these auditors cannot use personally-identifiable information for any secondary purposes.

7. If and when myLIVEoffer.com^TM sponsors promotions or sweepstakes, or third parties sponsor promotions or sweepstakes in conjunction with myLIVEoffer.com^TM, either myLIVEoffer.com^TM or the third party will post relevant information in the official rules and/or registration area for the promotion or sweepstakes. That privacy information, to the extent it conflicts with this Privacy Policy, will govern for that particular promotion or sweepstakes.

8. myLIVEoffer.com^TM does not control the acts of its users. All users should be aware that, when they disclose personally-identifiable information in a bulletin board, chat room, guestbook, or other forum or public area of a website, the information may be collected and used by others for the purposes of distributing unsolicited communications to you or to others outside the myLIVEoffer.com^TM System. In the event that you encounter any myLIVEoffer.com^TM user who is improperly collecting or using information about you or other users, please contact us at info@myLIVEoffer.com.

C. Release of Information In Event of Potential Wrongful Activity, Court Action: 

1. In the event that we determine or have a good-faith basis to suspect that a user is engaging in a fraud or illegal act, we reserve the right to provide information that we have colleted to any affected automobile dealer and/or to appropriate law enforcement agencies. We also reserve the right to release information contained within our access logs concerning any user who is in violation of our Privacy Policy or Terms of Service or other published guidelines, or who partakes (or is reasonably suspected of partaking) in any illegal activity, even without a subpoena, warrant, or other court order, and to release such information in response to discovery requests. We cooperate with law enforcement agencies in identifying those who may be using the System or our servers for illegal activities. We also reserve the right to report any suspected illegal activity to law enforcement for investigation or prosecution, or to suspend or terminate your use of the System in connection with any suspected illegal activity.

2. Subpoenas and Court Orders.  We disclose information in response to a subpoena, warrant, court order, levy, attachment, order of a court-appointed receiver or other comparable legal process, including subpoenas from private parties in a civil action.

IV. Information Security

A. How We Safeguard Your Information.  myLIVEoffer.com^TM is committed to handling your information with high standards of information security. Credit or debit card information is collected when a registered user locks in an Accepted Offer , and it is also stored if a user asks us to keep it for him or her so that he or she does not have to enter it again. Credit or debit card information may also be collected at other times, as indicated by registration screens presented by the System. For example, you may be asked for such information to allow us to verify your identity. Such information may be stored or it may be discarded. Any credit or debit card information that we store is stored only in encrypted form on computers that are not connected to the Internet. We restrict access to personally-identifiable information to employees who need to know that information in order to provide services to users. We maintain physical, electronic and procedural safeguards to guard nonpublic personal information. We test our security systems regularly and also contract with outside companies to audit our security systems and processes. Although myLIVEoffer.com^TM has taken these measures to ensure that personal information is delivered and disclosed only to the appropriate parties in accordance with your instructions, we cannot and do not guarantee that the personal information you provide will not be intercepted by others and decrypted.

B. You Must Protect Your Own Password. The security of your information also relies on your protection of your myLIVEoffer.com^TM password. Your password is the key to your registration, your use of the System, and your personal information. Use unique numbers, letters, and special characters and do not disclose your 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 registration. 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 using that password. myLIVEoffer.com^TM will never ask you to send your password or other sensitive information to us in an e-mail, though we may ask you to enter this type of information on the screens presented by the myLIVEoffer.com^TM System, which will always have a URL beginning with https://www.myLIVEoffer.com/. If you believe someone else has obtained access to your password or if you password is otherwise compromised, please change it immediately by logging in to your account at https://www.myLIVEoffer.com/ and changing your Profile settings, and also contact us right away.

V. Opting In to and Opting Out of Certain Features

As part of the registration process, you will be provided with tools that will allow you to manage what communications you receive that are initiated from third parties.

As part of the registration process , you may have the opportunity to choose to "opt in" to receive information or promotional materials provided by third party sponsors, advertisers or business partners whose offerings are not directly related to our System. We ask that you carefully review the Privacy Policies of those persons providing you with such promotional material and note that myLIVEoffer.com^TM will not be held responsible in any way for the privacy policies or information use by said third parties.

myLIVEoffer.com^TM reserves the right to periodically contact you about third parties who provide goods or services that we believe may be of interest to you. If you wish to "opt-out" of that myLIVEoffer.com^TM service, please send an email to us at info@myLIVEoffer.com with the subject line "Opt-Out". If there are features, subscriptions or products made available to you through the operation of the System which require you to provide myLIVEoffer.com^TM with your credit or debit card information, we will not release your credit or debit card information to third parties unless necessary to complete a transaction between you and such third party.

VI. Changing or Deleting Personal Information

You can review the personal information that you provided to us and make any desired changes to such information, or to the settings for your use of the System (such as e-mail preferences, etc.), at any time by logging in to the myLIVEoffer.com^TM Site and changing your preferences in the Profile page of the "My Account" tab. You can also close your account through the myLIVEoffer.com^TM Site. If you close your myLIVEoffer.com^TM account, we will mark your account in our database as "Closed," but may keep your account information in our database. This is necessary in order to deter fraud, by ensuring that persons who try to commit fraud will not be able to avoid detection simply by closing their account and opening a new account. However, if you close your account, your personally identifiable information will not be used by us for any further purposes, nor sold or shared with third parties.

VII. Questions?

Questions regarding this Privacy Policy should be directed to myLIVEoffer.com^TM at info@myLIVEoffer.com.

VIII. Miscellaneous

This Agreement and the resolution of any dispute related to this Agreement or the myLIVEoffer.com^TM System shall be governed by the laws of the Commonwealth of Virginia, as applied to contracts entered into by Virginia residents within Virginia, which contracts are to be performed entirely within Virginia. Failure by myLIVEoffer.com^TM, or its affiliates to insist upon strict enforcement of any provision of this Agreement shall not be construed as a waiver of any provision or right. You agree that regardless of any statute or law to the contrary, any claim or cause of action arising out of or related to use of the myLIVEoffer.com^TM System or this Agreement must be filed within one (1) year after such claim or cause of action arose or be forever barred.