**Saconde & Saconde, LLC** **Revised: June 21, 2026** **Company Name:** Saconde, LLC **Principal Place of Business:** New York, United States **Website:** www.saconde.com ## 1. INTRODUCTION This Privacy Policy applies to Saconde, LLC (“Saconde,” “Company,” “we,” “us,” or “our”) and explains how we collect, use, disclose, retain, process, and safeguard personal information when you access, use, or interact with our website, mobile applications, iOS app, Android app, online store, retail locations, seller services, consignment services, buyout services, authentication services, marketplace listings, communications, promotions, events, or any other service that links to or references this Privacy Policy. This Privacy Policy applies when you: * Visit or use our website or mobile application; * Create or access an account; * Purchase items from us; * Sell, consign, or submit items to us; * Request a buyout offer, consignment offer, authentication review, or other service; * Submit photographs, videos, receipts, certificates, serial numbers, identification documents, authentication materials, or other content; * Communicate with us online, in person, by email, SMS, phone, app message, social media, or other communication channels; * Participate in promotions, waitlists, events, marketing campaigns, or customer programs; * Interact with our services, retail locations, marketplaces, affiliated platforms, service providers, or sales channels. This Privacy Policy applies to users located in the United States, including residents of California, New York, and other states with applicable privacy laws. It may also apply to international users who access or interact with Saconde’s services from outside the United States. Please review this Privacy Policy carefully. By accessing or using our services, you acknowledge that you have read and understand this Privacy Policy. Where required by law, Saconde will request additional consent, opt-in authorization, written release, app permission, or other legally required acknowledgment before collecting or processing certain categories of information, including biometric information, precise location information, sensitive personal information, or information used for certain advertising, tracking, or profiling purposes. Your use of Saconde’s services may also be governed by our Terms & Conditions, Seller Terms, Consignment Terms, Return Policy, SMS Terms, Biometric Notice, and any other applicable agreements, notices, or policies. ## 2. Scope of Website, App, Retail, Seller, and Marketplace Services **Mobile App Notice** This Privacy Policy also applies to information collected through the Saconde mobile application, including app account activity, app permissions, device identifiers, device information, camera or photo access, push notifications, app analytics, crash logs, fraud-prevention tools, authentication tools, biometric login features, and third-party software development kits (“SDKs”) integrated into the app. **App Store and Google Play Disclosures** Our privacy practices for the mobile app are also summarized in the Apple App Store privacy disclosures and Google Play Data Safety disclosures. Those disclosures are intended to be consistent with this Privacy Policy. If you believe any app store disclosure is inconsistent with this Privacy Policy, please contact us at Hello@saconde.com Please review this Privacy Policy carefully. By accessing or using our services, you acknowledge that you have read and understand this Privacy Policy. Where required by law, we will request additional consent, opt-in authorization, written release, app permission, or other legally required acknowledgment before collecting or processing certain categories of information, including biometric information, precise location information, sensitive personal information, or information used for certain advertising or profiling purposes. Your use of our services is also governed by our Terms & Conditions, Seller Terms, Consignment Terms, and Return Policy. ## 3. INFORMATION WE COLLECT A. Information You Provide We may collect information you voluntarily provide, including: * Full legal name; * Email address; * Phone number; * Billing and shipping addresses; * Username or account credentials; * Government-issued identification; * Payment and payout information; * Taxpayer identification information; * Communications with us; * Seller submission forms; * Consignment information; * Item descriptions; * Purchase history; * Transaction history; * Social media handles; * Photographs, videos, receipts, certificates, serial numbers, authenticity documentation, and related materials. For high-value transactions, fraud prevention, legal compliance, authentication, or risk review purposes, we may request additional verification information. B. Seller & Transaction Information If you sell or consign items with Saconde, we may collect: * Banking or payout information; * Transaction records; * Authentication history; * Consignment records; * Offer history; * Tax reporting information; * Identity verification documentation; * Shipping and delivery records; * Communications regarding submitted items; * Fraud-prevention or compliance records. C. Payment Information Payments may be processed through third-party payment processors, including [Stripe](https://stripe.com/?utm_source=chatgpt.com). We do not store complete payment card numbers on our systems. Third-party payment providers may collect: * Card or bank account details; * Transaction information; * Identity verification records; * Tax information; * Regulatory compliance information. Your use of third-party payment processors is subject to their separate policies and terms. D. Automatically Collected Information When you access our website or services, we may automatically collect: * IP address; * Device identifiers; * Browser type; * Operating system; * Session logs; * Clickstream data; * Approximate geolocation data; * Referral URLs; * Network information; * Device activity; * Usage analytics; * Metadata associated with uploaded files, photographs, videos, or images, including but not limited to EXIF data, timestamps, device identifiers, embedded geolocation information, camera or device information, file attributes, image characteristics, and other embedded metadata where available. E. Mobile App Information > When you use the Saconde mobile application, we or our service providers may collect information from or about your device and app usage, including: > * Mobile device identifiers, advertising identifiers, vendor identifiers, installation identifiers, and app instance IDs; > * Device type, operating system, app version, language settings, time zone, carrier, network information, and device settings; > * App usage information, including screens viewed, features used, clicks, session duration, referring pages, and interactions within the app; > * Crash logs, diagnostics, performance data, error reports, and security logs; > * Camera, photo, video, or file information if you choose to upload item photographs, videos, receipts, certificates, identification documents, or authentication materials; > * Approximate location based on IP address or device/network information; > * Precise location only if we request it, you grant permission, and the app uses a feature that requires it; > * Push notification tokens and notification preferences; > * Fraud-prevention signals, account-security signals, device-integrity signals, and risk-analysis data; > * Biometric login status or authentication confirmation, if you enable device-based biometric login; > * Data collected by third-party SDKs, analytics tools, crash-reporting tools, payment tools, fraud-prevention tools, authentication tools, or marketplace integrations used in the app. You may control many mobile app permissions through your iOS or Android device settings. If you disable certain permissions, some app features may not function properly. F. Cookies & Tracking Technologies We may use cookies, pixels, analytics tools, scripts, session replay tools, and similar technologies to: * Operate and improve our services; * Analyze traffic and user behavior; * Authenticate users; * Prevent fraud and abuse; * Maintain security; * Personalize experiences; * Support marketing and analytics initiatives. You may disable cookies through your browser settings; however, portions of the website may not function properly. G. Sensitive Personal Information Saconde does not knowingly use sensitive personal information, government identification, Social Security numbers, taxpayer identification numbers, biometric information, seller payout information, or identity verification materials for targeted advertising or cross-context behavioral advertising. Depending on how you interact with Saconde, we may collect information that may be considered sensitive personal information, sensitive data, or similar terms under applicable law, including: > * Government-issued identification; > * Social Security number, EIN, taxpayer identification number, or tax forms; > * Bank account, payout, payment, or financial information; > * Account login credentials or authentication information; > * Precise location information, if enabled and collected; > * Biometric information, if collected or processed as described in this Privacy Policy; > * Contents of certain communications with Saconde; > * Information used for fraud prevention, identity verification, security, or legal compliance. > We use sensitive personal information only for purposes permitted by law, including to provide services, verify identity, process transactions, prevent fraud, maintain security, comply with legal obligations, process seller payouts, conduct authentication review, and enforce our rights and agreements. Where required by law, we will obtain consent before collecting or processing sensitive personal information. ## 4. MOBILE APP PERMISSIONS The Saconde mobile app may request access to certain device features or permissions. These permissions may include: **Camera Access.** We may request camera access so you can take photographs or videos of items, receipts, certificates, identification documents, packaging, shipping materials, condition issues, or other materials needed for authentication, seller intake, customer support, fraud prevention, or transaction processing. **Photo Library / Media Access.** We may request access to your photo library or files so you can upload photographs, videos, documents, receipts, certificates, or other materials. We only access files or media that you select or otherwise allow the app to access, subject to your device settings. **Push Notifications.** We may request permission to send push notifications about account activity, transaction updates, offers, authentication updates, seller submissions, payout status, order status, security alerts, promotions, or other service-related messages. You can disable push notifications through your device settings. **Location.** We may collect approximate location from IP address or device/network information. We will only collect precise GPS location if the app requests permission, you grant permission, and the feature requires it. You may disable location access through your device settings. **Biometric Authentication.** If offered, biometric login is optional and may allow you to access your account using device-based features such as Face ID, Touch ID, fingerprint authentication, facial authentication, or similar tools. Device-based biometric authentication is generally managed by your device operating system. Unless we expressly state otherwise at the time of collection, Saconde does not receive or store your device biometric template. Saconde does not receive or store your Face ID, Touch ID, fingerprint, face scan, or biometric template when biometric login is performed by your device operating system, unless we expressly state otherwise. **Notifications, Permissions, and Controls.** You may change app permissions through your iOS or Android settings. Disabling permissions may limit certain app features. ## 5. HOW WE USE INFORMATION We may use collected information for business, commercial, operational, legal, security, and compliance purposes, including to: * Process purchases, consignments, and transactions; * Pay sellers and consignors; * Authenticate products and transactions; * Detect, investigate, and prevent fraud, abuse, theft, counterfeiting, or unlawful activity; * Operate, maintain, improve, and develop our services; * Create listings and marketplace content; * Syndicate listings across marketplaces and sales channels; * Provide customer support; * Communicate regarding transactions or account activity; * Conduct analytics and internal reporting; * Train and improve internal systems and operational workflows; * Conduct risk analysis and account monitoring; * Comply with legal, tax, accounting, regulatory, and reporting obligations; * Enforce our agreements and policies; * Protect the rights, safety, and property of Saconde, our users, and third parties; * Maintain historical, archival, audit, and business records; * Send transactional, operational, promotional, or marketing communications where permitted by law. ## 6. DATA MINIMIZATION AND PURPOSE LIMITATION Saconde seeks to collect and process personal information that is reasonably necessary and proportionate for the purposes described in this Privacy Policy, including providing services, processing transactions, verifying identity, authenticating items, preventing fraud, maintaining security, complying with law, resolving disputes, and operating our business. We do not knowingly collect sensitive personal information unless it is reasonably necessary for the service requested, legal compliance, fraud prevention, security, seller payouts, authentication, or another disclosed purpose. ## 7. USER CONTENT, PHOTOS & SELLER SUBMISSIONS By submitting photographs, videos, item descriptions, authentication materials, communications, reviews, feedback, or other content (“Submitted Content”) to Saconde, you grant Saconde & Saconde, LLC a perpetual, irrevocable, worldwide, transferable, sublicensable, royalty-free license to: * Use; * Reproduce; * Modify; * Edit; * Adapt; * Publish; * Translate; * Create derivative works from; * Display; * Distribute; * Analyze; * Store; * Archive; * Commercially exploit; and * Otherwise utilize such Submitted Content for operational, authentication, fraud prevention, resale, archival, advertising, promotional, legal, machine learning, marketplace listing, analytics, training, business development, and commercial purposes. Submitted Content may include embedded metadata and technical information that Saconde may access, retain, analyze, process, and utilize in connection with authentication, fraud prevention, investigations, analytics, machine learning systems, and operational purposes. This license survives account termination, transaction completion, item rejection, and termination of any relationship with Saconde. You acknowledge and agree that: * Saconde may crop, edit, enhance, watermark, or modify submitted materials; * Submitted materials may appear on third-party marketplaces, social media, advertisements, or promotional content; * Saconde may retain copies of submitted materials even if an item is rejected, returned, abandoned submissions, or not purchased; * No compensation shall be owed for use of Submitted Content; * You represent and warrant that you own or have sufficient rights to submit such content. Submitted materials may be used to develop, train, test, improve, or operate authentication systems, fraud detection systems, artificial intelligence models, machine learning systems, internal analytics tools, and operational workflows. You may not submit personal information, photographs, identification documents, financial information, communications, or other materials about another person unless you have the legal right and authority to do so. Saconde may delete, restrict, reject, or refuse to process submissions that appear to contain unauthorized third-party personal information. ## 8. AI, AUTOMATED PROCESSING & AUTHENTICATION DISCLOSURES Saconde may utilize automated systems, artificial intelligence tools, machine learning technologies, image recognition software, fraud detection systems, and third-party authentication providers in connection with our operations. Submitted information may be analyzed for purposes including: * Product authentication; * Fraud prevention; * Risk analysis; * Operational analytics; * Marketplace optimization; * Quality control; * Compliance monitoring. Saconde and its service providers may analyze uploaded photographs, videos, and files, including associated metadata such as EXIF data, timestamps, device identifiers, embedded geolocation information, file attributes, and image characteristics, for authentication, fraud prevention, risk analysis, operational analytics, security, compliance, and investigative purposes. We may share information, photographs, metadata, and related materials with third-party authentication providers, service providers, marketplaces, or operational partners. Automated systems or third-party reviews may influence pricing decisions, authentication determinations, account actions, transaction approvals, or offer decisions. Where required by applicable law, users may have the right to opt out of certain profiling or automated decision-making that produces legal or similarly significant effects. Saconde may use automated tools to assist with fraud prevention, authentication review, account security, payout verification, transaction review, pricing support, or risk scoring, but Saconde may also use human review where appropriate. Automated tools may support or influence decisions such as whether to approve an account, request additional verification, delay or deny a transaction, modify an offer, flag suspicious activity, or restrict certain services. To submit a request regarding automated processing, contact Hello@saconde.com with the subject line “Automated Processing Request.” ## 9. BIOMETRIC AUTHENTICATION, IDENTITY VERIFICATION & BIOMETRIC INFORMATION Saconde may offer or use account security, login, identity verification, fraud prevention, payment verification, transaction authorization, access control, counterfeit prevention, and account recovery features that involve biometric authentication, facial comparison, liveness detection, identity verification, or related security technologies. These features may be provided by Saconde, device operating system providers, payment processors, identity verification providers, fraud-prevention vendors, authentication vendors, or other service providers. A. Device-Based Biometric Login > The Saconde mobile app may allow users to log in or authenticate using device-based biometric features, such as Apple Face ID, Apple Touch ID, Android fingerprint authentication, Android face authentication, or similar device-based biometric authentication tools. > Device-based biometric login is optional. If you enable this feature, the biometric authentication process is generally performed by your device operating system. Unless Saconde expressly states otherwise at the time of collection, Saconde does not receive, collect, possess, or store your fingerprint, face scan, face geometry, voiceprint, retinal scan, iris scan, or biometric template used by your device for Face ID, Touch ID, fingerprint login, or similar device-based login. > Saconde may receive a confirmation that the authentication was successful or unsuccessful, along with technical information needed to maintain account security, prevent fraud, and operate the app. B. Identity Verification, Selfies, Liveness Checks & ID Review > For seller onboarding, high-value transactions, payout changes, fraud prevention, legal compliance, account recovery, payment verification, or security review, Saconde or its service providers may request identity verification information, including government-issued identification, selfies, live camera captures, liveness checks, photographs, videos, account information, transaction information, device information, and related verification materials. > These materials may be used to compare your identity document with your selfie or live image, verify that you are a real person, detect fraud, prevent account takeover, confirm payout instructions, investigate suspicious activity, comply with legal obligations, or protect Saconde, users, sellers, buyers, consignors, and third parties. C. Biometric Information We May Collect Only Where Applicable > Depending on the feature used and the service provider involved, identity verification or security tools may process information that may be considered biometric information, biometric identifiers, biometric data, biometric templates, biometric scans, or similar terms under applicable law. This may include face geometry, facial comparison data, liveness detection data, voiceprint data, fingerprint-related data, or other biometric identifiers if such information is collected or processed by Saconde or its service providers. > Saconde will not knowingly collect or process biometric identifiers where legally prohibited. Where required by law, Saconde will provide notice and obtain consent, written release, opt-in authorization, or other legally required permission before collecting or processing biometric information. D. Purposes for Biometric and Identity Verification Processing > Saconde may use biometric authentication, identity verification, facial comparison, liveness detection, and related security information for: > * Account login and authentication; > * Multi-factor authentication; > * Seller, consignor, buyer, or customer identity verification; > * Fraud prevention and account security; > * Payout verification and payout-change verification; > * Payment verification and transaction authorization; > * Anti-money laundering, sanctions, tax, or compliance review where applicable; > * Counterfeit prevention and marketplace integrity; > * Account recovery; > * Security monitoring and risk analysis; > * Investigation of theft, fraud, chargebacks, unauthorized transactions, or policy violations; > * Compliance with law, legal process, and law enforcement requests. E. Consent and Written Release > Where required by applicable law, Saconde will obtain consent, written release, opt-in authorization, or other legally required approval before collecting, capturing, receiving, otherwise obtaining, disclosing, redisclosing, or processing biometric information. > Consent may be obtained electronically where permitted by law. You may decline optional biometric features, but some identity verification or security checks may be required to use certain services, complete high-value transactions, receive seller payouts, change payout information, recover an account, or satisfy legal, fraud-prevention, or compliance requirements. F. Disclosure and Sharing of Biometric Information > Saconde does not sell, lease, trade, or otherwise profit from biometric information. Saconde may disclose biometric information or identity verification information only as permitted by applicable law, including to: > * Service providers, processors, contractors, authentication vendors, fraud-prevention vendors, identity verification providers, payment processors, cloud providers, and security vendors; > * Complete or verify a transaction requested by the user; > * Prevent fraud, theft, account takeover, counterfeit activity, or unlawful conduct; > * Comply with applicable law, legal process, subpoenas, warrants, regulatory requests, or law enforcement requests; > * Protect the rights, safety, property, security, or legal interests of Saconde, users, customers, sellers, consignors, employees, service providers, or third parties; > * Enforce Saconde’s agreements, terms, policies, and legal rights. > Saconde prohibits its service providers from using biometric information for purposes other than providing services to Saconde, complying with law, protecting security, preventing fraud, or as otherwise permitted by applicable agreements and law. G. Retention and Destruction of Biometric Information > Saconde will retain biometric information only for as long as reasonably necessary to fulfill the purpose for which it was collected, provide the requested service, maintain account security, verify identity, prevent fraud, comply with legal obligations, resolve disputes, enforce agreements, complete investigations, maintain audit records, or as otherwise permitted or required by law. > Where a specific biometric retention period is required by law, Saconde will comply with that requirement. Unless a shorter period is required by law, biometric information controlled by Saconde will be deleted, destroyed, anonymized, or de-identified when the initial purpose for collection has been satisfied or within three years after the individual’s last interaction with Saconde, whichever occurs first, unless retention is required or permitted for legal compliance, fraud prevention, dispute resolution, security, tax, accounting, litigation hold, law enforcement, regulatory, or operational purposes. > Biometric information maintained by third-party service providers may be subject to their own legally compliant retention schedules, contractual obligations, and deletion procedures. H. Security of Biometric Information > Saconde uses commercially reasonable administrative, technical, physical, and organizational safeguards designed to protect biometric information and identity verification information from unauthorized access, disclosure, acquisition, destruction, use, modification, or misuse. These safeguards may include access controls, encryption, vendor review, internal access restrictions, audit logs, secure transmission methods, and data minimization where appropriate. I. State-Specific Biometric Rights > Residents of certain states and localities may have additional rights regarding biometric information, including rights to notice, consent, disclosure, deletion, retention information, and limits on sale or disclosure. These laws may include, depending on applicability, the Illinois Biometric Information Privacy Act, Texas Capture or Use of Biometric Identifier Act, Washington biometric identifier law, Colorado Privacy Act biometric amendments, California privacy laws, New York City biometric identifier information law, and other biometric or privacy laws. To submit a biometric privacy request, contact Saconde at Hello@saconde.com with the subject line “Biometric Privacy Request.” This Privacy Policy is intended to provide notice of Saconde’s biometric and identity verification practices. Where a separate written release, consent screen, acknowledgment, opt-in, or authorization is required by law, Saconde will seek that consent separately before collecting or processing the applicable biometric information. Some state privacy laws apply only to businesses that meet certain legal thresholds. Saconde will honor applicable privacy rights where required by law. ## 10. BIOMETRIC RETENTION AND DESTRUCTION SCHEDULE Saconde maintains the following general biometric retention and destruction schedule, subject to applicable law, legal holds, fraud-prevention needs, security investigations, dispute resolution, regulatory obligations, tax/accounting obligations, law enforcement requests, and other legally permitted or required retention: **Device-Based Biometric Login.** If biometric login is performed locally by Apple Face ID, Apple Touch ID, Android biometric authentication, or similar device-based authentication, Saconde does not receive or store the biometric template used by the device unless expressly stated otherwise. Saconde may retain account-security logs confirming whether authentication succeeded or failed for as long as reasonably necessary for security, fraud prevention, audit, and account-integrity purposes. **Identity Verification Images and Selfies.** Selfies, ID images, liveness-check materials, and related verification records may be retained for as long as reasonably necessary for identity verification, transaction security, seller payout verification, fraud prevention, legal compliance, dispute resolution, and audit purposes. **Biometric Identifiers Controlled by Saconde.** Where Saconde controls biometric identifiers or biometric information, Saconde will permanently delete, destroy, anonymize, or de-identify such information when the original purpose for collection has been satisfied or within the period required by applicable law. **Service Provider Records.** Biometric information processed by service providers is subject to contractual obligations, applicable law, and the provider’s retention and deletion procedures. **Deletion Requests.** Where required by law, users may request deletion of biometric information by contacting Hello@saconde.com. Saconde may deny or limit deletion requests where retention is necessary or permitted for fraud prevention, legal compliance, security, investigations, dispute resolution, tax/accounting obligations, legal claims, or other lawful purposes. ## 11. HOW WE SHARE INFORMATION We may disclose information to: A. Payment Processors Including providers such as [Stripe](https://stripe.com/?utm_source=chatgpt.com). B. Service Providers Including: * Shipping carriers; * Authentication providers; * Fraud prevention vendors; * Cloud hosting providers; * Technology vendors; * Analytics providers; * Marketing providers; * Customer support providers. C. Marketplaces & Sales Channels We may share listings, product images, item information, and related content with third-party marketplaces and sales platforms. D. Legal & Regulatory Authorities We may disclose information: * To comply with applicable law; * In response to subpoenas, court orders, or lawful requests; * To enforce our agreements; * To investigate fraud or illegal activity; * To protect rights, safety, and property. E. Business Transfers Information may be transferred in connection with: * Mergers; * Acquisitions; * Financing transactions; * Restructuring; * Bankruptcy; * Asset sales; * Corporate transactions. We require service providers, processors, contractors, and vendors that process personal information on our behalf to use personal information only to provide services to Saconde, comply with law, maintain security, prevent fraud, or perform other contractually permitted purposes. Where required by law, we maintain contracts with service providers that include confidentiality, security, data-use, retention, deletion, and assistance obligations. ## 12. COMMUNICATIONS, SMS, EMAIL & PUSH NOTIFICATIONS Saconde may send transactional, operational, security, account, seller, payout, order, authentication, shipping, return, fraud-prevention, and customer-service communications by email, SMS, phone, push notification, in-app message, postal mail, or other available channels. Saconde may also send promotional or marketing communications where permitted by law. Consent to receive marketing messages is not a condition of purchase. **SMS/Text Messages.** If you provide a phone number, you may receive transactional or service-related text messages. If you separately consent to marketing texts, you may receive promotional SMS messages. Message and data rates may apply. Message frequency may vary. You may opt out of marketing texts by replying STOP where supported or by contacting us. **Email Marketing.** You may unsubscribe from marketing emails using the unsubscribe link in the email or by contacting us. We may still send non-marketing transactional or account-related emails. **Push Notifications.** If you enable push notifications, we may send app notifications about account activity, seller submissions, offers, payouts, authentication updates, purchases, shipping, security alerts, promotions, or service updates. You may disable push notifications through your device settings. ## 13. NO SALE OF PERSONAL INFORMATION Saconde does not sell personal information as defined under applicable law. We also do not share personal information for cross-context behavioral advertising as defined under California law. ## 14. GLOBAL PRIVACY CONTROL AND UNIVERSAL OPT-OUT SIGNALS Where required by applicable law, Saconde will recognize legally required browser-based opt-out preference signals, such as Global Privacy Control or other universal opt-out mechanisms, for applicable websites, browsers, devices, or app environments. If Saconde does not sell personal information or process personal information for targeted advertising as defined by applicable law, an opt-out signal may not change our practices. If we begin engaging in data sales, targeted advertising, or cross-context behavioral advertising subject to opt-out rights, we will provide legally required notices and honor applicable opt-out signals. ## 15. ANALYTICS, ADVERTISING & SDK DISCLOSURES We may use analytics tools, attribution tools, crash-reporting tools, fraud-prevention tools, app-performance tools, advertising technologies, pixels, cookies, SDKs, and similar technologies to operate, measure, secure, and improve our website and mobile app. These technologies may collect or receive information such as device identifiers, advertising identifiers, IP address, app interactions, browsing activity, transaction events, approximate location, device information, and usage analytics. Saconde does not currently sell personal information or share personal information for cross-context behavioral advertising as defined by California law. If Saconde uses advertising or tracking technologies in a way that constitutes a sale, sharing, targeted advertising, or profiling under applicable law, Saconde will provide legally required notices, choices, and opt-out mechanisms. Users may limit certain tracking through browser settings, cookie controls, iOS App Tracking Transparency settings, Android advertising ID settings, device permissions, and other platform controls. ## 16. APP TRACKING, SDKs, PRIVACY CONTROLS, AND ACCOUNT DELETION **Apple App Tracking Transparency** If Saconde or its partners collect app data for tracking as defined by Apple, the iOS app will request permission through Apple’s App Tracking Transparency prompt where required. If you decline tracking permission, Saconde will not use app-collected data for tracking that requires such permission. Saconde may still process information for app functionality, account security, fraud prevention, authentication, legal compliance, customer support, internal analytics, and other purposes that do not require tracking permission, subject to applicable law and platform rules. **Google Play Data Safety** Saconde will review the data collected, used, shared, retained, and protected through the Android app for purposes of completing Google Play Data Safety disclosures. These disclosures may include whether data is collected, whether data is shared, whether data is encrypted in transit, whether users can request deletion, whether account deletion is available, and whether certain data is required or optional. If the Saconde Android app allows account creation, Saconde will provide an in-app method and a web-based method for users to request account deletion and associated data deletion, subject to legal, fraud-prevention, tax, accounting, transaction, seller payout, authentication, chargeback, security, dispute, and compliance retention exceptions. **Third-Party SDKs and App Technology Providers** Saconde may use third-party SDKs, APIs, pixels, cookies, analytics tools, attribution tools, crash-reporting tools, fraud-prevention tools, payment tools, identity verification tools, authentication tools, push notification tools, marketing tools, customer support tools, marketplace integrations, and security tools in connection with the website and mobile app. These technologies may collect or process information such as: * Device identifiers; * Advertising identifiers; * App instance IDs; * IP address; * Device type; * Operating system; * App version; * Usage data; * App interactions; * Product interactions; * Crash logs; * Diagnostics; * Performance data; * Approximate location; * Push notification tokens; * Fraud-prevention signals; * Account-security signals; * Identity verification signals; * Payment or transaction events; * Other information reasonably necessary to operate, secure, measure, improve, or support the app. Saconde reviews third-party SDKs and app technology providers for privacy disclosure purposes. Saconde requires service providers, processors, contractors, and vendors that process personal information on Saconde’s behalf to use personal information only to provide services to Saconde, comply with law, maintain security, prevent fraud, or perform other contractually permitted purposes. Where required by law, Saconde maintains contracts with service providers that include confidentiality, security, data-use, retention, deletion, assistance, and processing restrictions. **Mobile App Permissions** The Saconde mobile app may request access to device features or permissions, including camera access, photo library or media access, file access, push notifications, location, and biometric authentication. Camera access may be used so users can take photographs or videos of items, receipts, certificates, identification documents, packaging, shipping materials, condition issues, or other materials needed for authentication, seller intake, customer support, fraud prevention, or transaction processing. Photo library, media, or file access may be used so users can upload photographs, videos, documents, receipts, certificates, identity documents, or other materials. Saconde only accesses files or media that users select or otherwise permit the app to access, subject to device settings. Push notifications may be used to provide account activity notices, transaction updates, offers, authentication updates, seller submission updates, payout status, order status, shipping updates, security alerts, promotional messages, or other service-related messages. Location may be collected approximately from IP address or device/network information. Saconde will only collect precise GPS location if the app requests permission, the user grants permission, and the feature requires it. Biometric authentication, if offered, is optional and may allow users to access their account using device-based features such as Face ID, Touch ID, fingerprint authentication, facial authentication, or similar device-based tools. Unless Saconde expressly states otherwise at the time of collection, Saconde does not receive or store the user’s Face ID, Touch ID, fingerprint, face scan, or biometric template when biometric login is performed by the device operating system. Users may control many mobile app permissions through iOS or Android device settings. Disabling permissions may limit certain app features. ## 17. Global Privacy Control and Universal Opt-Out Signals Where required by applicable law, Saconde will recognize legally required browser-based opt-out preference signals, such as Global Privacy Control or other universal opt-out mechanisms, for applicable websites, browsers, devices, or app environments. If Saconde does not sell personal information or process personal information for targeted advertising as defined by applicable law, an opt-out signal may not change Saconde’s practices. If Saconde begins engaging in data sales, targeted advertising, or cross-context behavioral advertising subject to opt-out rights, Saconde will provide legally required notices and honor applicable opt-out signals. ## 18. Account Deletion If you create a Saconde account, you may request deletion of your account by contacting Hello@saconde.com with the subject line “Account Deletion Request” or through any account deletion feature made available in the app or on Saconde’s website. Deleting your account may not delete all information immediately. Saconde may retain information where necessary or permitted for legal compliance, tax and accounting records, fraud prevention, transaction records, seller payout records, authentication records, chargeback defense, dispute resolution, security investigations, law enforcement requests, enforcement of agreements, or other legitimate business purposes. If Saconde is legally required or permitted to retain certain information, Saconde will retain it only as permitted or required by law and will delete, de-identify, anonymize, or aggregate it when retention is no longer necessary. ## 19. APPLE AND ANDROID PLATFORM CONTROLS **Apple App Tracking Transparency.** If Saconde or its partners collect app data for tracking as defined by Apple, the iOS app will request permission through Apple’s App Tracking Transparency prompt where required. If you decline tracking permission, Saconde will not use app-collected data for tracking that requires such permission. **Android Controls.** Android users may control certain permissions, notification settings, location access, advertising ID settings, and app data access through Android device settings and Google account settings. **Device Permission Controls.** You may disable camera, photo, location, notification, or other permissions through your device settings. Disabling permissions may affect app functionality. ## APP STORE AND GOOGLE PLAY DATA SAFETY DISCLOSURES Saconde’s mobile app may be distributed through the Apple App Store, Google Play Store, or other app marketplaces. Those marketplaces may require Saconde to provide standardized privacy disclosures, app privacy labels, data safety information, app permission descriptions, account deletion information, and similar notices. These app marketplace disclosures are intended to summarize certain data practices of the Saconde mobile app. They may include information about categories of data collected, categories of data shared, whether data is linked to a user, whether data may be used for tracking, whether data is encrypted in transit, whether users may request deletion, and whether certain data collection is optional or required. Depending on the features used, Saconde’s app marketplace disclosures may reference categories such as: * Contact information; * Financial information; * Purchase history; * User content, including photographs, videos, files, documents, seller submissions, and communications; * Identifiers, including user IDs, device IDs, installation IDs, app instance IDs, advertising identifiers, and push notification tokens; * Usage data, including app interactions, product interactions, feature usage, screens viewed, and session information; * Diagnostics, including crash logs, error reports, performance data, and app stability information; * Approximate location and, if enabled and collected, precise location; * Sensitive information, including government identification, taxpayer information, financial account information, biometric information, or identity verification information where applicable; * Fraud-prevention, authentication, account-security, risk-analysis, and device-integrity information; * Data collected or processed by third-party SDKs, service providers, processors, and app technology partners. Saconde seeks to keep its Apple App Store privacy disclosures, Google Play Data Safety disclosures, app permission prompts, in-app notices, account deletion disclosures, and Privacy Policy consistent with one another. However, app marketplace disclosures are summaries and may not describe every detail of Saconde’s privacy practices. This Privacy Policy provides a more complete explanation of how Saconde collects, uses, discloses, retains, processes, and safeguards information. If Saconde materially changes the data collected through the mobile app, integrates new SDKs, changes app permissions, adds new tracking, changes biometric or identity verification features, or changes how information is shared, Saconde will review whether updates are needed to this Privacy Policy, Apple App Store disclosures, Google Play Data Safety disclosures, and any related in-app notices. ## 20. CALIFORNIA PRIVACY RIGHTS (CCPA/CPRA DISCLOSURE) This section applies to residents of California under the **California Consumer Privacy Act and California Privacy Rights Act**. A. Categories of Personal Information Collected We may collect the following categories: * Identifiers (name, email, IP address) * Commercial information (purchase history) * Financial information (payment and payout data) * Internet activity (site usage) * Geolocation data (approximate location via IP) B. Purposes for Collection We collect personal information to: * Provide services * Process transactions * Prevent fraud * Comply with legal obligations C. Sharing of Personal Information We may disclose personal information to: * Service providers (e.g., Stripe) * Shipping partners * Legal authorities We do not sell or share personal information for cross-context behavioral advertising. D. Your Rights Under CCPA/CPRA You have the right to: * **Know** what personal information we collect * **Access** your personal data * **Delete** your personal data * **Correct** inaccurate data * **Limit use of sensitive personal information** * **Opt out of sale/share** (not applicable, as we do not sell data) E. Exercising Your Rights To submit a request email us at **hello@saconde.com** We may verify your identity before fulfilling requests. F. Non-Discrimination We will not discriminate against you for exercising your rights. G. Retention Disclosure We retain personal information only as long as reasonably necessary for: * Business operations * Fraud prevention * Legal compliance ## 21. U.S. STATE PRIVACY RIGHTS > Depending on your state of residence and whether applicable legal thresholds are met, you may have certain privacy rights under state privacy laws. These rights may include the right to: > * Confirm whether we process your personal information; > * Access personal information we maintain about you; > * Correct inaccurate personal information; > * Delete personal information, subject to legal exceptions; > * Obtain a portable copy of certain personal information; > * Opt out of certain processing for targeted advertising; > * Opt out of the sale of personal information; > * Opt out of certain profiling or automated decision-making that produces legal or similarly significant effects; > * Limit or revoke consent for certain sensitive personal information processing; > * Appeal a denied privacy request where required by law. Saconde does not sell personal information for money. Saconde also does not knowingly share personal information for cross-context behavioral advertising as defined by California law unless we provide any legally required notice and opt-out mechanism. To exercise privacy rights, contact us at Hello@saconde.com with the subject line “Privacy Rights Request.” We may verify your identity before fulfilling a request. Authorized agents may submit requests where permitted by law, but we may require proof of authorization and identity verification. If we deny your request and applicable law gives you the right to appeal, you may appeal by replying to our decision email or contacting Hello@saconde.com with the subject line “Privacy Appeal.” These state rights may apply to residents of states with comprehensive privacy laws, which may include California, Colorado, Connecticut, Virginia, Utah, Oregon, Texas, Montana, Delaware, Iowa, Nebraska, New Hampshire, New Jersey, Tennessee, Minnesota, Maryland, Indiana, Kentucky, Rhode Island, Arkansas, and other states as their laws become effective or are amended. **Withdrawal of Consent** Where Saconde relies on consent to process personal information, sensitive personal information, biometric information, marketing communications, or optional app permissions, you may withdraw consent where required by applicable law. Withdrawal of consent may limit or disable certain services, including identity verification, seller payouts, account recovery, transaction review, biometric login, marketing communications, or app features. ## 22. AUTHORIZED AGENTS Where permitted by applicable law, you may designate an authorized agent to submit privacy requests on your behalf. Saconde may require proof of authorization, verification of your identity, and confirmation that the agent is authorized to act for you. ## 23. VERIFYING PRIVACY REQUESTS Before fulfilling a privacy request, Saconde may verify your identity by requesting information reasonably necessary to confirm that you are the person about whom we collected information or that you are authorized to act on that person’s behalf. For security-sensitive requests, seller payout records, tax records, identity verification records, biometric information, or account deletion requests, we may require additional verification. We may deny requests that cannot be verified, are fraudulent, conflict with legal obligations, or are subject to an applicable legal exception. **Privacy Request Response Timing** Saconde will respond to verified privacy requests within the time required by applicable law. If additional time is needed, Saconde may extend the response period where permitted by law and will notify the requester as required. ## 24. NEW YORK DISCLOSURES This section applies to users interacting with Saconde & Saconde, LLC in connection with transactions, services, or activities occurring in New York. A. Identity Verification & Fraud Prevention To protect our customers, sellers, consignors, business partners, and the integrity of our marketplace, Saconde may collect, verify, review, retain, and analyze information for identity verification, fraud prevention, counterfeit prevention, anti-theft, financial crime prevention, and security purposes. Such information may include: * Government-issued identification; * Transaction records; * Shipping and billing information; * Device and network information; * Photographs and authentication materials; * Payment verification information; * Communications and account activity. Saconde reserves the right to delay, refuse, cancel, suspend, limit, or investigate transactions or accounts that we reasonably believe may involve fraud, theft, unlawful conduct, counterfeit goods, suspicious activity, policy violations, or financial risk. B. Financial Fraud Monitoring Saconde may utilize internal review processes, automated systems, artificial intelligence tools, machine learning systems, fraud detection technologies, transaction monitoring systems, and third-party service providers to identify, assess, investigate, and prevent: * Unauthorized transactions; * Payment fraud; * Counterfeit activity; * Chargeback abuse; * Money laundering; * Account takeovers; * Identity theft; * Suspicious financial activity; * Marketplace abuse. We may use personal information and transaction data to conduct sanctions screening, anti-money laundering (“AML”) compliance reviews, Know Your Customer (“KYC”) verification, fraud prevention, risk analysis, and compliance with financial crime prevention obligations. We reserve the right to refuse, suspend, delay, or cancel transactions or accounts that may present elevated legal, regulatory, compliance, reputational, or financial risk. Transaction activity and related information may be reviewed manually or through automated processes. Saconde may retain fraud-prevention and compliance-related records for legal, operational, security, audit, and investigative purposes. C. Cooperation With Law Enforcement & Regulatory Authorities Saconde may disclose information to law enforcement agencies, regulators, courts, governmental authorities, financial institutions, payment processors, fraud-prevention organizations, or other authorized parties when we determine, in our sole discretion, that disclosure is appropriate or necessary to: * Comply with applicable laws, regulations, subpoenas, court orders, or legal process; * Investigate suspected fraud, theft, counterfeiting, money laundering, or unlawful conduct; * Protect the rights, safety, property, or security of Saconde, our users, or third parties; * Enforce our agreements, policies, or legal rights; * Prevent financial loss or reputational harm. Saconde reserves the right to cooperate fully with law enforcement investigations and regulatory inquiries relating to transactions, accounts, or activities associated with our services. D. Record Retention for Compliance & Investigations Saconde may retain transaction records, communications, authentication materials, account activity, identity verification information, and fraud-monitoring records for extended periods where reasonably necessary for: * Fraud prevention; * Legal compliance; * Tax compliance; * Security purposes; * Investigations; * Dispute resolution; * Regulatory obligations; * Enforcement of rights and agreements. Retention periods may extend beyond account closure or transaction completion where permitted or required by law. If Saconde collects, retains, converts, stores, or shares customer biometric identifier information at a New York City commercial establishment, Saconde will provide notice as required by New York City law, including clear and conspicuous signage near customer entrances where required. Saconde does not sell, lease, trade, share in exchange for anything of value, or otherwise profit from customer biometric identifier information. ## 25. TAX REPORTING & SELLER COMPLIANCE If you sell or consign items through Saconde, we may collect and retain information necessary for tax, accounting, legal, fraud-prevention, and regulatory compliance purposes. This may include: * Name; * Address; * Taxpayer Identification Number; * SSN or EIN; * Payment records; * Identity verification records. We may issue tax reporting forms including: * Form 1099-MISC; * Form 1099-NEC; * Other applicable reporting forms. Sellers remain solely responsible for reporting income and complying with tax obligations. Saconde does not provide legal or tax advice. ## 26. DATA RETENTION We retain information for as long as reasonably necessary for: * Business operations; * Transactions; * Authentication records; * Legal compliance; * Fraud prevention; * Dispute resolution; * Security purposes; * Audit obligations; * Enforcement of agreements; * Internal analytics; * Archival purposes. We may retain anonymized or aggregated information indefinitely. | Category | Typical Retention Purpose | | ----- | ----- | | Account information | Maintained while account is active and as needed for legal, security, fraud-prevention, and operational purposes. | | Purchase and order records | Maintained for transaction records, customer support, tax, accounting, chargeback defense, and legal compliance. | | Seller, consignor, and payout records | Maintained for seller services, tax reporting, fraud prevention, payout verification, accounting, disputes, and compliance. | | Authentication records and item photos | Maintained for authentication history, counterfeit prevention, marketplace integrity, disputes, legal claims, fraud prevention, and archival purposes. | | Government ID and identity verification records | Maintained as needed for identity verification, high-value transactions, fraud prevention, seller payouts, legal compliance, disputes, and security. | | App analytics and diagnostics | Maintained as needed to operate, secure, debug, improve, and analyze the website and app. | | Biometric information, if collected | Maintained according to the biometric retention section and applicable law. | | Communications | Maintained for customer service, transaction history, dispute resolution, fraud prevention, legal compliance, and business records. | | Marketing preferences | Maintained to honor opt-outs, consents, suppression lists, and communication preferences. | | Security and fraud logs | Maintained as needed to detect, prevent, investigate, and respond to fraud, abuse, theft, account takeover, legal claims, and security incidents. | ## 27. ACCOUNT DELETION If you create a Saconde account, you may request deletion of your account by contacting Hello@saconde.com with the subject line “Account Deletion Request” or through any account deletion feature made available in the app. Deleting your account may not delete all information immediately. Saconde may retain information where necessary or permitted for legal compliance, tax and accounting records, fraud prevention, transaction records, seller payout records, authentication records, chargeback defense, dispute resolution, security investigations, law enforcement requests, enforcement of agreements, or other legitimate business purposes. If we are legally required to retain certain information, we will retain it only as permitted or required by law and will delete, de-identify, or aggregate it when retention is no longer necessary. ## 28. DATA SECURITY We implement commercially reasonable administrative, technical, and organizational safeguards designed to protect information. However: * No method of transmission or storage is completely secure; * We cannot guarantee absolute security; * Users transmit information at their own risk; * Third-party providers maintain independent security practices. For mobile app and account security, Saconde may use safeguards such as encryption in transit, access controls, authentication controls, audit logs, secure cloud infrastructure, permission restrictions, monitoring, fraud detection, vulnerability management, and vendor security review. For sensitive personal information, identity verification information, payout information, and biometric information where applicable, Saconde applies additional access restrictions and security controls designed to reduce unauthorized access, disclosure, misuse, alteration, or destruction. Users are responsible for maintaining the confidentiality of their account credentials, devices, passwords, and authentication methods. You should notify Saconde immediately if you believe your account, device, password, payout information, or identity information has been compromised. ## 29. INTERNATIONAL USERS & DATA TRANSFERS Saconde is based in the United States. If you access our services from outside the United States, your information may be transferred to, stored in, and processed in the United States and other jurisdictions where Saconde, our service providers, or operational partners maintain facilities. These jurisdictions may have data protection laws that differ from those in your location. Where required by applicable law, Saconde will use appropriate safeguards for international transfers. ## 30. CHILDREN’S AND MINORS’ PRIVACY Our services are not directed to children under 13 years of age, and we do not knowingly collect personal information from children under 13\. Users must be at least 18 years old, or the age of legal majority in their jurisdiction, to sell, consign, submit items for buyout, receive payouts, enter into seller agreements, or complete transactions requiring legal capacity, unless a parent or legal guardian is involved and Saconde expressly approves the transaction. If we learn that we have collected personal information from a child under 13 without legally required consent, we will take appropriate steps to delete the information. Parents or guardians may contact us at Hello@saconde.com. ## 31. DO NOT TRACK Our website does not currently respond to “Do Not Track” browser signals. ## 32. CHANGES TO THIS PRIVACY POLICY We may update this Privacy Policy from time to time. The “Revised” date above indicates when this Privacy Policy was last updated. Updates are effective when posted unless otherwise stated. If we make material changes to how we collect, use, disclose, retain, or process personal information, we may provide additional notice as required by law. Where required by law, we will obtain additional consent before applying material changes to certain sensitive personal information, biometric information, or other legally protected information. ## 33. Accessibility / ADA Statement Saconde strives to maintain accessible online services and improve usability for all users. If you encounter accessibility barriers, contact us at Hello@saconde.com ## 34. CONTACT INFORMATION **Saconde, LLC** 521 W 26th St Floor 5 New York, NY 10001 United States **Email:** Hello@saconde.com **Website:** [www.saconde.com](http://www.saconde.com/) **Privacy requests:** Hello@saconde.com **Biometric privacy requests:** Hello@saconde.com, subject line “Biometric Privacy Request” **Account deletion requests:** Hello@saconde.com, subject line “Account Deletion Request” **App privacy questions:** Hello@saconde.com, subject line “App Privacy” **Accessibility requests:** Hello@saconde.com, subject line “Accessibility”