Privacy Policy

This Privacy Policy explains the policies and procedures relating to the use of information collected through our websites, mobile apps, or our physical business location (collectively “Site”) from visitors to or users of our Site, potential customers, and customers (collectively “Customers”, “you,” or “your”), whether through the Internet or otherwise, by broadarrowauctions.com, a Speed Digital, LLC client and its affiliates (collectively “Company”, “we”, “us” or “our”). Because Company’s products and services are not directed to or intended for (a) individuals under the age of 18 nor (b) individuals located or residing outside of North America, we ask that individuals in those categories not submit any information to us and not use our Site. By visiting or using our Site or our services, you consent to the collection, use, disclosure, retention, and protection of information as described in this Privacy Policy.

This Privacy Policy does not apply to:

• Credit-related products, which are covered by the issuing bank or financial institution’s privacy notices that appear on credit applications or that you receive with your credit accounts;
• Your interactions with third parties or their websites that are linked to or accessible from our Site or that are operated by unaffiliated third parties;
• Our employment-related records.

 

Information That We May Collect About You

• Identification information that can be used to identify you, such as your name, alias, address, phone number, email address, phone number, payment information, signatures, or other identifiers. We may also collect online identifiers, such as your IP address, when you browse or use our Site. For the purposes of facilitating some sales transactions, we may collect information from your government-issued ID, your social security number, insurance policy information, or bank account information, but please only provide this information if requested by us. We may also collect information about any automobile you sell, offer for sale, or purchase through our site, including the make, model, trim, model year, mileage, color, options, vehicle identification number (VIN), license plate number. When you apply to see if you pre-qualify for auto financing through one of our participating lenders, that lender may require you provide additional information, but that financing information is not captured or retained by us;
• Commercial information, such as goods or services you purchased or considered purchasing, including automobile sales information such as advertised price, purchase offers, actual sale price, and sale location;
• Protected class information under state or federal laws, such as age, gender, and family status; Online activities information, such as browsing history, search history, and other information when you interact with our Site, advertisements, and emails;
• Geolocation data, including precise geolocation data if the settings on the device you use to access our Site grants permission to obtain this information;
• Audio, electronic, or visual information, such as audio or video recording when you call us or when you visit our physical business location;
• Professional or employment information, such as when you provide us this information via a survey;
• Education information, such as when you apply for a job with us or respond to a customer survey;
• Inferences or preferences we learn or infer about you; and
• Other personal information, if it identifies, relates to, and can be reasonably associated with or linked to you or your household.

 

Sources of Collected Information

We collect different types of information about you from a variety of sources, including information you provide to us, information we automatically collect, information we obtain from other sources (see below), and information we derive or infer about you.

Information You Provide. You may choose to provide us with information when you interact with us, including:

• Identification information. We may collect and retain any information provided to us by you or your devices when you visit our Site, including when you register for an account, use our services, communicate with us, complete sales transactions, and subscribe to our email newsletters or other content we offer. When completing sales transactions, we may collect your payment information (e.g., credit/debit card information), signature, and, in some cases, government-issued ID information and date-of-birth.
• Commercial information. You may provide us or generate commercial information regarding your purchases from or involving our Site and any related transactions.
• Protected class information. You may provide us your protected demographic information, including age, gender, family status, such as when you complete a user profile or consumer survey.
• Your preferences and inferences. You may indicate your preferences when you complete our surveys, submit reviews and comments, or participate in our contests, promotions, or sweepstakes.
• Professional or employment-related information. You may also provide information related to your profession or employment when you complete our surveys, submit reviews and comments, or participate in our contests and promotions.
• Education information. You may provide information relating to your education when applying for a job with us or when responding to our customer surveys.
• Other information. When you apply to see if you pre-qualify for auto financing through one of our participating lenders, that lender may require you provide additional information, but that financing information is not captured or retained by us.

Automatically Collected Information. We may collect and retain your personal information automatically when you visit our Site. When using our website or mobile applications or when interacting with our emails, we and our partners may collect certain information by using first and third-party cookies, pixel tags, and similar technology that may exist today or that may be developed in the future. We may allow third parties to use these tools on our Site, and the information collected through these tools may be used on our Site or on other websites or services, including third-party sites. We may automatically collect the following information:

• Identification information, such as your IP address, device ID, cookie ID, mobile advertising identifier, pixel identifier, or phone number.
• Online activities, such as browse and search history, vehicles you view or configure, interactions with our websites, applications, or other information about your online interactions. When you use social networks to access our Site, information from those social networks may be made available to us. By associating a social network account with our Site, you agree that we may access and retain that information in accordance with the policies of the social network and this Privacy Policy.
• Geolocation data. If permitted by your browser, app, or device settings, we may collect certain information about your precise location to help you locate us, provide you with information relevant to your geographic area, or determine geographic information relevant to sales transactions.
• Audio, video, and electronic information, such as audio or video recording of telephone or online conversations between you and our customer support personnel for purposes of quality control, training, security, and analytics. We may also use video monitoring at our physical location to protect against theft and other crimes, although this information may not be capable of association with you.

Information Collected From Other Sources

• Identification information. We may collect your contact information or information relating to your sales transactions from our affiliates, acquired businesses, partners, public sources, or other individuals.
• Commercial information. We may obtain your commercial information, such as your purchase history and information relating to your sales transactions, from our affiliates, partners, public sources, or other individuals, including individuals involved in sales transactions with you facilitated by our Site.
• Inferences or preferences about you, protected class information under federal and state law, professional or employment-related information, education background, and geolocation information may be collected from our affiliates, partners, public sources (e.g., a publicly available customer review), or other individuals.

Information We Generate

• Inferences or preferences. We may generate or derive inferences or analyses based on collected, aggregated, or de-identified information to improve our services and understand user behaviors. We may generate or derive some information about you based on other information we collect. We may also conduct analyses based on aggregated or de-identified information.

 

Use of the Collected Information

We generally use the information collected about you to provide and improve our services. We may use this information to:

• Provide and deliver services to you, process transactions, and send related information such as confirmations and invoices, and revise, update and develop new services;
• Send you communications including technical and support notices, administrative messages, and inquiry/customer support responses;
• Communicate with you about products, services, offers, and promotions offered by us and certain third parties, and provide you with information that may be of interest;
• Personalize our services and present you with advertising, content, or features of interest to you;
• Allow you to participate in contests, sweepstakes, or similar promotions and to administer them;
• Link or combine with information we get from third parties to help understand your needs and provide you with better service;
• Monitor and analyze trends, usage, and activities in connection with our services;
• Detect, investigate, and prevent fraudulent transactions and other illegal activities and protect our rights and the rights of third parties;
• Respond to law enforcement requests or as required in connection with court orders, government regulations, or litigation; and
• Carry out any other purpose described to you at the time the information was collected.

 

Sharing of Collected Information

We may use or share (i) your personal identifiable information (PII) and (ii) de-identified and pseudonymized information based on your PII, for any purpose including marketing, research, and product and service development and improvement. We may share your PII with our affiliates, service providers and business partners, third parties that are not affiliated with us for business purposes, with other third parties as required by law, and also:

• With our service providers and business partners to perform services on our behalf or on your behalf, including email delivery and other communications with you, credit card and other payment processing, marketing, advertising, data analytics, website hosting, customer service, and similar services;
• With other automobile dealers, manufacturers, and similar businesses that may be unaffiliated with us, including to facilitate communications between these businesses and you;
• With lending companies and other financial institutions for purposes of determining your creditworthiness and facilitating financing, and for marketing their financial services to you;
• We may share information relating to the offering for sale and sale of automobiles on and through our Site, including make, model, year, VIN, listing price, sale price, sale date, and sale location with unaffiliated third parties for purposes of compiling, analyzing, marketing, selling, and publishing automobile sales data;
• With appropriate authorities or third parties to enforce our rights and those of our affiliates, customers, and members of the public, and to apply with applicable laws and legal processes, and for preventing fraud, theft, and injury to you or others;
• When we are involved in a business merger, acquisition, liquidation, valuation or similar business transaction;
• Unaffiliated third-party businesses so that they may market goods or services that may be of interest to you; and
• At such other times and for such other purposes as you may authorize us to disclose the information.

 

Your Privacy Choices and Rights

• You may have the right to opt out of the disclosure of personal information about you to third parties for monetary or other valuable consideration. To request to opt-out, please email optout@speeddigital.com with a subject of “Opt Out Request”. Please include your name and email address in your correspondence so we can identify your records in our system.. Note this will not affect the collection, storage, compilation, use, transfer, or sale of de-identified or pseudonymized information that may have been derived in part from your personal information (e.g., sales information).

• You may also have the right to request that we delete personal information about you that we have collected from you or through other sources, and you may request we do so by emailing us at optout@speeddigital.com with a subject line of “Deletion Request”. Please include your name and email address in your correspondence so we can identify your records in our system. You can also fill out our data deletion request form at speeddigital.com/privacy-request. Please be aware that you are not able to opt out of receiving communications about your account, the provision of our services to you, or related transactions with us.

• If you would like to opt-out of receiving email marketing communications from us, you may click the “Unsubscribe” link found at the bottom of our marketing emails.
• Please note that like many websites our Site does not make any modifications or otherwise respond to Do Not Track signals generated by your browser or device.
• Most major web browsers provide users the option to accept or reject cookies. If you delete cookies, use a different device, or change web browsers, you may need to repeat the steps to accept or reject cookies on the new device or browser. If you use your browser settings to block all cookies you may not be able to access parts of our Site. The “Help” future on most browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookies, or how to disable cookies altogether. If you block or otherwise reject our cookies, you may not be able to utilize certain features on our Site including services requiring you to sign in.
• A pixel tag (i.e., tracking pixel, web beacon, clear GIF, 1x1 pixel) is an invisible tag or small graphic placed on certain pages of our Site or in emails but not on your computer. When you access these pages or emails, the pixel tags help maintain a record that you visited a webpage or received or opened an email. When such a message is opened in an HTML-capable email program, the recipient’s computer or device will communicate with our server to retrieve the pixel tag file, allowing us to record and store the date and time the email was viewed, the fact that the email client is capable of receiving HTML-encoded email, other standard logging information, and the recipient’s email address. These pixel tags help us analyze our customers’ online behavior and measure the effectiveness of our marketing. You can disable the pixel tag feature by changing the settings on your email client to prevent the automatic downloading of images, changing your browser settings to omit images, disabling Javascript, or utilizing commercially available software that can omit pixel tags and most advertisements.
• Where applicable, the California Consumer Privacy Act (CCPA) affords you the right to request that we disclose to you the personal information we collect, use, or disclose, and information about our data practices; the right to request that we delete your personal information that we have collected from you; and our assurances that we will not discriminate against you for exercising these rights.

 

Policy Changes

We reserve the right to modify and revise this Privacy Policy from time to time. If we make material changes to this policy, we will notify you of such changes by posting them on our Site or by sending you an email or other communication, and we will notify you of the effective date of the changes. By continuing to access or use our Site or our services after these changes become effective, you are agreeing to be bound by the revised Privacy Policy.

 

Contacting Us

You can contact us with questions or comments about privacy practices or this Privacy Notice by emailing us at legal@speeddigital.com or by calling us at 866-457-7333

 

 

Supplemental Privacy Notice for individuals participating in live auctions, private sales, online auctions, and/or financing (collectively “Broad Arrow Transactions”).

March 2025

This Privacy Notice ("Privacy Notice") supplements the above provided Privacy Policy and applies only to persons who participate in live auctions, private sales, online auctions, and/or financing (collectively “Broad Arrow Transactions”). The above Broad Arrow Privacy Notice contains information relevant to the processing of your personal data obtained through our websites, mobile apps, or our physical business location, including information processing that is specific to Broad Arrow Transactions occurring anywhere around the globe.

Broad Arrow Group, Inc. (“Company”, “we”, “us”) is the controller of your personal data, and we believe it is important that you understand how we collect, store, share and use information in relation to our live auctions. We are part of the Hagerty Group of companies, specializing in vehicle auctions, with our main offices in the United States. We can be contacted as follows:

• Privacy@Hagerty.com
• Broad Arrow Group, Inc. c/o Hagerty Legal Department
  Attn: Privacy Administrator
  141 River’s Edge Dr., Suite 200
  Traverse City, Michigan, 49684

Note: You must reference Broad Arrow Transactions in all correspondence.

For the purpose of this Privacy Notice, personal data means any information relating to an identified or identifiable person. Please read this Privacy Notice carefully as it provides important information about how we use personal data in relation to our live auctions and explains your legal rights.

 

Types of Information We Collect

The types of information we collect will vary depending on the purpose for your interaction with us. We may collect limited sensitive personal data (such as data relating to criminal records and offences). This information is only collected where strictly relevant to the services we provide and in accordance with applicable law. See the sections below for details on how we use personal data and the legal grounds for our processing.

• Identification information: such as your name, alias, email, postal address, social media handle, phone number, government-issued ID and other identifiers.
• Auction-related information: information about any automobile you sell, offer for sale, or purchase through live auction, including make, model, trim, year, mileage, color, options, VIN, license plate number.
• Demographic details: such as date of birth, age, gender, marital status, and any demographic details discerned from identification documents.
• Financial information: such as proof of funds documentation, credit history, and bankruptcy status.
• Geolocation data: if the settings on the device you use to access our live auction site grant permission to obtain this information.
• Audio or electronic information: such as recordings when you call us in relation to an auction or our services.
• Comments, feedback or other information: for example, comments provided on feedback forms or surveys, and questions or information sent to our support services.
• Payment information: such as credit or debit card number and bank account details, including electronic funds transfer information.
• Sensitive information & criminal records: such as health information and background-check data (e.g., alleged criminal offences and records).
• Marketing & communications preferences: such as interests and preferred language.

 

How we collect personal data

In general, we collect personal data about you in the following ways:

(i)	Information you provide directly to us, when you: register your interest to attend a live auction, or to place auction bids; contact our team to request a service from us, such as discussing your selling options for your vehicle or to register your interest in an auction; complete our consignment inquiry form on our website; correspond with us by phone, email, or otherwise using our contact details or via the website; use our services (e.g., completing our consignment inquiry or other forms on our website, providing comments, feedback, or communicating directly with us). Where we obtain information directly from you, we will inform you whether the information is mandatory and explain the consequences of not providing it. For example, we need your contact details to provide you with a service or communicate with you. If you do not provide the relevant information, we may be unable to offer the services to you and/or may terminate the service if it is not possible to fulfill it without that information.
(ii)	Information from other sources: We may collect information about you from publicly available sources, such as vetting and data validation agencies, in order to meet our Know Your Customer (“KYC”) obligations.
(iii)	Information we collect automatically: We may collect certain types of information about you automatically when you visit our websites or communicate with us online (including via email). We may use “cookies” or similar technologies such as web beacons, GIF or pixel tags, or other unique identifiers to measure online activity, provide more relevant advertising, or analyze the effectiveness of our communications and promotional campaigns.

 

Information relating to children

Our services are not directed to children, and we do not knowingly collect personal data from children.

 

Processing your information and the legal grounds for processing

We use the personal data we collect about you in connection with the services to:

• offer, administer and manage the services provided to you, including registering you for live auctions, facilitating the auction and sale of your vehicle, delivering our services to you, and sending related information such as confirmations and invoices;
• carry out due diligence, identity confirmations, Know Your Customer (“KYC”) or other vetting and risk management checks;
• process payments from or to you, as required;
• facilitate the prevention, detection and investigation of crime and the apprehension or prosecution of offenders;
• fulfil legal and regulatory obligations, resolve disputes and monitor compliance with our obligations;
• offer other products and services that may be of interest to our customers or prospective customers;
• communicate with you and respond to your requests, inquiries, comments and concerns;
• record phone calls for training and monitoring purposes.

We rely on appropriate legal grounds for our processing of your personal data. Where processing involves sensitive personal data, we also rely on an additional legal justification to use such information.

We rely on one or more of the following legal grounds:

• Legal and regulatory obligation: collection and use of your personal data is necessary to enable us to meet our legal and regulatory obligations. For example, we are required to conduct KYC checks to prevent money laundering and fraud, and may need to correspond with government bodies, law enforcement, regulators, auditors, legal advisers, or parties to a lawsuit if required by court order or other legal requirement.
• Performance of a contract: where we enter into a contract with you to provide services, we will collect and use your personal data as necessary to take steps to offer you the services, process your acceptance of the offer, and fulfil our contractual obligations. This may include taking payments and facilitating access to your consignment and our live auctions.
• Legitimate interest: the collection and use of some aspects of your personal data will be necessary for us to pursue our legitimate commercial interests or those of a third party. For example, we have legitimate interests in:
  • operating our business, managing and developing relationships with customers and suppliers;
  • understanding and responding to inquiries;
  • sharing data in connection with mergers, acquisitions and business transfers;
  • preventing and detecting fraud;
  • improving our services; and
  • understanding how our customers use our services.

  Where we rely on this legal ground, we take appropriate steps to ensure processing does not infringe your rights and freedoms.

• Consent: you may provide us with your consent to receive certain services, marketing or communications from us (where consent is legally required). You are not obliged to provide consent and may withdraw it at any time.

 

Additional legal conditions for processing sensitive information and data relating to criminal records and offences

• Substantial public interest: where applicable laws allow, we may collect and use your personal data for a substantial public interest or specific exemptions (for example, to prevent or detect unlawful acts).
• The establishment, exercise or defence of legal claims: we may need to process some sensitive personal data to establish, exercise or defend legal claims by us or third parties.

For ease, we have set out in the table below the categories of data we process, the purposes for our processing and the lawful grounds we rely on to process your personal data.

 

If you have any questions about our purposes of processing or the legal grounds relied on, you can contact us as provided above.

 

Who we share personal data with

As a participant in live auctions, your personal data may be shared as follows:

• With other Hagerty companies and subsidiaries. We may share personal data with our parent company and other Hagerty companies to help facilitate the provision of our services to you or for other legitimate purposes.

• With our business partners and third parties that provide or help facilitate the services we offer (e.g., auction houses to register you for auctions; third-party carriers to collect or deliver auctioned vehicles).

• With auctioneers, to assist in managing commercial risks and to protect all parties we work with from any form of illegal, unfair, or inappropriate behaviour.

• With third parties who perform professional or business services for us, including IT service providers, legal advisers, credit reference agencies (for affordability checks), and vetting agencies (for KYC checks).

• With advertisers and marketing service providers that help us deliver content, products, and services tailored to your interests.

• With analytics and search engine providers that assist us in improving and optimising our website and live auction platform.

• With government bodies and agencies, law enforcement, regulators, auditors, attorneys/legal advisers, or parties to a lawsuit, if required by court order, subpoena, litigation, or other legal requirement.

• With third-party payment processors in connection with processing your payments.

• If the ownership of Broad Arrow Group changes, we will transfer personal data to the prospective buyer of the business.

 

Transferring personal data globally

We operate on a global basis and, as such, your personal data may be transferred outside the territory where you reside or where it was originally collected. We will transfer personal data only for the purposes described in this Privacy Notice and will take appropriate steps to ensure such transfers comply with applicable laws and protect your privacy rights.

Transfers within Hagerty Group are covered by an intra-group agreement that contractually obliges each member to provide an adequate and consistent level of protection wherever data is transferred within the Group.

When we transfer your personal data to third-party service providers, we obtain contractual commitments (e.g., Standard Contractual Clauses for transfers between the EU and non-EU countries) or other approved transfer mechanisms.

You have the right to obtain more information about the safeguards we have put in place for international transfers. To exercise this right, please contact us as provided above.

 

Information security and retention of your information

The security of your personal data is important to us. We have implemented appropriate measures to protect the confidentiality, integrity, and availability of the personal data we collect and ensure processing in accordance with applicable laws.

We retain personal data for as long as reasonably necessary to fulfil the purposes described above, operate our business, and comply with legal obligations. In some cases, we may retain data longer to meet regulatory, tax, or accounting requirements, support complaint or legal claim handling, or in anticipation of litigation.

 

Your Information Rights

Subject to certain exemptions and depending on our processing activities, users of our services in North America have the rights set out in the “Your Privacy Choices and Rights” section of the Broad Arrow Privacy Policy, available as provided above.

Users of our services in the European Economic Area and the United Kingdom have the following rights:

(i)	Right to access: a right to access your personal data or be provided with a copy of the information we hold about you.
(ii)	Right to correction: a right to request the correction of your personal data or, in cases where the accuracy of information is disputed, to supplement the information we hold about you.
(iii)	Right to erasure: a right to request the erasure of your personal data, where the continued processing of the information is no longer necessary.
(iv)	Right to object to processing: a right to object to the use of your personal data, particularly where you feel there are no longer sufficient legitimate grounds for us to continue processing the information.
(v)	Right to object to direct marketing: a right to object to the use of your personal data for direct marketing purposes.
(vi)	Right to restrict processing: a right to request the restriction of your personal data from further processing (e.g., where the accuracy of the information is disputed and you request that the information not be used until its accuracy is confirmed).
(vii)	Right to portability: the right to request that some aspects of your personal data be provided to you or a third party of your choice in electronic form to enable its reuse.
(viii)	Right to withdraw consent: where the processing of your personal data is based on consent, you can withdraw your consent at any time. Withdrawing consent will not affect the lawfulness of processing carried out prior to the withdrawal.
(ix)	Right to obtain a copy of, or reference to, the safeguards we implement to transfer your personal data outside the EEA or the UK: where you exercise this right, we may redact some commercially sensitive information within such documents.
(x)	Right to lodge a complaint with a regulator: a right to complain to the relevant data protection regulator in your country about our processing of your personal data.

 

You can exercise your rights by using the information in the Contact Us section below. Subject to legal and other permissible considerations, we will make every reasonable effort to facilitate your request promptly.

 

Contact Us

If you wish to make a complaint or have any questions regarding our compliance with this Privacy Notice, the information we hold about you, or you wish to exercise your rights, we encourage you to contact us using the information provided above.

We will investigate and attempt to resolve complaints within a reasonable time and the timescales provided by applicable privacy laws.

 

Changes to this Privacy Notice

This Privacy Notice is not contractual, and we reserve the right to amend it from time to time to ensure it accurately reflects how we process personal information. Any updates or changes will be made available on our website.

This Privacy Notice was last updated on the date provided above.