Smart Labels Privacy Statement

This Privacy Statement applies to Individuals who
interact with us or use Smart Labels Products and Services.

This
Privacy Statement covers our privacy and information practices and applies to our Products and Services, including our websites (https://www.qrsmartlabels.com/), mobile application, any AI-enabled valuation or price-range features (which may process item details, images, descriptions, metadata, listing history, and other information you submit or authorize us to access in order to generate outputs such as estimated values, price ranges, suggested titles/descriptions, and other recommendations), any integrations or workflows that assist you in creating, exporting, listing, posting, or publishing product listings to third-party marketplaces (including eBay), and any related software, firmware, documentation and other information and materials provided on or in connection with such services products, applications, marketing efforts, physical facilities, and any related services. Please remember that our Terms of Use may also govern your use of our Products and Services.

SmartLabels may process the Personal Data of customers, partners, vendors, employees, applicants, visitors, or other individuals (“Individuals”) who are affiliated with or seeking an affiliation with us, our affiliates, subsidiaries and brands. This Privacy Statement applies to these Individuals regardless of
their geographic location during their interactions with Smart Labels.

Smart Labels allows you to exercise your privacy rights and manage how we use your information, including choices regarding certain uses of your User Content for AI model training (as described below) and choices regarding targeted advertising where applicable.

Smart Labels allows you to exercise your privacy rights and manage how we use your information, including choices regarding certain uses of your User Content for AI model training (as described below) and choices regarding targeted advertising where applicable.

Privacy and data protection laws in different geographic regions give Individuals certain rights in relation to their Personal Data. We conduct our privacy practices according to this Privacy Statement and applicable laws, including U.S. state privacy laws where they apply (which may provide rights to access, delete, correct, obtain a copy of, and limit or opt out of
certain processing of Personal Data, including certain targeted
advertising, and to appeal certain decisions) . Smart Labels encourages you to Contact Us to learn more about your privacy rights and how we collect and use your Personal Data.

A. Your AI Training Opt-Out Rights.

Smart Labels allows you to opt out of having your User Content used to train, test, and improve our AI valuation and price-range models.

● How to Opt Out. You may opt out of having your identifiable User Content used for AI model training by submitting a request through your account settings or by emailing help@qrsmartlabels.com with "AI Training Opt-Out" in the subject line. Upon receipt and verification of your opt-out request, we will cease using your identifiable User Content for AI model training purposes within a commercially reasonable period.
● Limitations of Your Opt-Out. Your opt-out does not apply to aggregate and de-identified data that has already been incorporated into AI models or datasets prior to the effective date of your opt-out request. Opting out will not affect your access to core Products and Services. However, certain personalization features that rely specifically on your individual usage data to generate tailored outputs may be less personalized to your specific preferences. Smart Labels will not discriminate against you for exercising your opt-out rights, and opting out will not result in a degraded level of service.
We retain the right to use your User Content for purposes other than AI model training as otherwise permitted under this Privacy Statement (such as providing the Services to you, customer support, and fraud prevention). Data that has been lawfully aggregated, de-identified, or incorporated into AI models prior to your opt-out request will not be removed from those models, as removal may not be technically feasible without complete model retraining.
Smart Labels does not sell or share your Personal Data, such as for cross-context behavioral advertising. For more information, see Section 4.G.

We collect information that relates to you and your interactions with Smart Labels.

A. Personal Data You Provide.

● When you interact with us through our Products or Services, we may collect Personal Data, such as your name, shipping/billing address, email address, phone number, device IDs, username and password, payment information
(processed by our payment service providers), and
information you submit or upload through the Products
and Services (such as item descriptions, images, metadata,
pricing inputs, and listing preferences).
● You may be invited to provide additional Personal Data to personalize your interactions with us and your use of our Products and Services. For instance, you may provide preferences and item attributes
(e.g., category, brand, materials, condition, and
comparable listing inputs) to help us generate AI-enabled
valuation or price-range outputs to help you create marketplace listings.
● Providing us with some Personal Data may be required in order for you to interact with us or to use our Products and Services.
● You also may provide information that is published or displayed (“posted”) on public areas of websites belonging to Smart Labels or other third parties, or which may be transmitted to other users of the same (“User Content”) including content you choose to export, publish, list, or
post to third-party marketplaces (including eBay) using our
Products and Services. Your User Content is posted on and transmitted to others at your own risk. Smart Labels is not responsible for the actions of others with respect to your User Content.
● If you work at Smart Labels or are applying to work with us, Personal Data will be required in order for you to apply for, be considered for, and maintain employment with Smart Labels.
● When you use our AI-enabled valuation and price-range features, we collect your AI valuation requests and queries, item details and images you provide for valuation, AI-generated outputs we provide to you (estimated values, price ranges, suggested descriptions), your interactions with AI outputs (whether you accept, modify, or reject suggestions), how you use AI-generated content in marketplace listings, feedback you provide on AI feature accuracy or usefulness, and transaction outcomes when items are sold using AI-assisted listings.

B. Personal Data from Third Parties.

● If you interact with Smart Labels through a third party, including by connecting a third-party marketplace account (such as eBay) or other integration, we may receive Personal Data from that third party when you have consented for them to share it with us or otherwise authorized the connection.
● We may use third party services to supplement, validate or increase the accuracy of Personal Data that you give to Smart Labels.
● The Personal Data that you share with third parties is not controlled by Smart Labels or covered by our privacy practices. We encourage you to review third party policies and privacy settings so that you understand how the Personal Data you share with them may be used or shared with others.
● When you connect your account to a third-party marketplace (such as eBay), we may collect authorization tokens and access credentials issued by the marketplace platform, listing information and product/pricing data from your marketplace account, listing status and performance metrics, transaction outcomes and sales data, marketplace account status, and data necessary to create, publish, update, and manage listings on your behalf. We do not store your third-party marketplace login credentials. Access is maintained through secure authorization tokens issued by the third-party platform using protocols such as OAuth.

C. Automatic Functional Information.

We may automatically collect some usage information when you interact with us. For instance, we use cookies and other tracking technologies to automatically collect technical information, such as URL, cookie data, IP address, device type, unique device IDs, device attributes, network connection type (e.g., WiFi, 3G, LTE, Bluetooth) and provider, network and device performance, browser type, language, operating system, and other functional information. This information may also include log entries, diagnostics, bandwidth usage, WiFi usage, performance information, and other analytics associated with devices tied to you, and may be collected to facilitate the provision of our Products and Services and product support.

D. Image and AI-Processed Data.

When you use AI-powered features of the Products and Services, including item recognition, photo categorization, or authentication tools, we may collect and process images and photographs you upload or capture through the application (“Image Data”). Image Data may include visual content of items, text appearing on items, barcodes, QR codes, and other identifiable characteristics. Image Data is transmitted to and processed by third-party artificial intelligence service providers operating under an architecture similar to large-scale AI platforms. By using AI-powered features, you consent to the collection, transmission, and processing of Image Data by Smart Labels and its designated AI service providers for the purpose of delivering the requested feature. Smart Labels does not use Image Data for independent marketing purposes and does not sell Image Data to third parties except as otherwise disclosed in this Privacy Statement. You should not submit images containing sensitive personal information, private identification documents, or confidential business data unless necessary for the intended feature.

E. Derived Information.

Smart Labels may use information we have about you to draw inferences about you and we may then use those inferences to gain a more complete understanding of your preferences. We use preference data in order to offer you potential choices, make recommendations, or to alert you to our Products and Services that may be of interest to you, including information about how you interact with our emails, advertisements, and features (where permitted by law). This technical and usage information may also include log entries, diagnostics, bandwidth usage, WiFi usage, performance information, and other analytics associated with devices tied to you

F. Children’s Information.

Smart Labels Products and Services are intended for and directed to adults, not children. If you are under 18, do not supply any Personal Data to Smart Labels for the purposes of subscribing to Smart Labels or purchasing or using our Products or Services. If you are under 18 and wish to purchase a Smart Labels Product or use our Services, please ask your parent or guardian to handle these transactions for you. If you are aware that we have unintentionally collected information from someone who is underage, please notify us immediately by sending an email to help@qrsmartlabels.com or by submitting a request a https://www.qrsmartlabels.com/pages/contact.

We use your Personal Data to develop and provide our Products and Services and to personalize, improve and promote our interactions with you.

Unless we specifically disclose otherwise, you understand that we may use any of your collected Personal Data for any of the purposes described in this Privacy Statement (as permitted by applicable law), including the AI-enabled features and marketplace integration workflows described in this Privacy Statement:

A. For Account Registration and Servicing.

● We may use your Personal Data to create, maintain, supplement, service, change or delete your customer account with us.
● If you have a customer account with us, we may collect certain Personal Data for security purposes in order to verify your authorized access to your accounts with us.
● We may use your Personal Data to resolve customer service questions you may have about our Products and Services and to follow up with you about your experience.

B. To Communicate with You.

● We may use your Personal Data to communicate with you about our Products and Services, , including through targeted advertising where permitted by law and subject to your choices.
● We may use your Personal Data to identify and share offers for third party products and services that we think you may find useful Unless you give consent, we do not disclose your Personal Data to third parties for their independent marketing or promotional purposes.

C. To Improve and Develop New Products and Services.

● We may use your Personal Data to personalize your interactions and experiences with us.
● We may use your Personal Data and User Content
(as permitted by law and subject to your choices) to improve the quality of and to develop new products and services, including to develop, train, test, and improve AI models and features.
● We may use any information you give to us in surveys or other forms of feedback.
● We may combine your information with that from other Individuals in order to better understand our Products and Services and how we may improve them.

D. To Provide Our Products and Services and Operate Our Business.

● We may use your Personal Data to operate our business, including fulfilling your requests, providing you with technical or customer support, and to help us protect our Products and Services, including to combat fraud and protect your information.
● We may conduct research using your Personal Data, alone or in combination with that of other Individuals. When we share that research outside of Smart Labels for research, academic, marketing and/or promotional purposes, we do so in an aggregated or de-identified way such that no individual or household is identifiable, and we maintain
safeguards designed to prevent re-identification.

E. To Provide and Improve AI-Enabled Features.

● We may use your Personal Data and User Content to provide AI valuation and price-range estimation features.
● We may use your Personal Data and User Content to train, test, improve, and maintain our AI valuation algorithms and machine learning models.
● We may use your Personal Data and User Content to develop and refine price-range estimation models.
● We may use your Personal Data and User Content to personalize and optimize AI-generated recommendations and outputs.
● We may use your Personal Data and User Content to analyze AI usage patterns to improve feature functionality and accuracy.
● We may use your Personal Data and User Content to update, retrain, and modify AI models and data sources.
● Subject to your opt-out rights described in Section 2, we may use User Content (including product descriptions, images, metadata, pricing data, AI valuation requests, listing information, and transaction outcomes) for these AI training and improvement purposes.

F. To Facilitate Third-Party Marketplace Integrations.

● We may use your Personal Data to establish and maintain connections to third-party marketplaces like eBay.
● We may use your Personal Data to authenticate your access using authorization tokens within the scope of permissions you grant.
● We may use your Personal Data to create, publish, update, and manage listings on third-party marketplaces on your behalf.
● We may use your Personal Data to retrieve pricing data, product information, and listing performance metrics from marketplace platforms.
● We may use your Personal Data to monitor listing status and transaction outcomes.
● We may use your Personal Data to improve integration features and workflows.
● We may use your Personal Data to troubleshoot integration issues and provide customer support.

G. No Sale/Share of Your Personal Data.

● Smart Labels does not sell or share (as those terms are defined under applicable U.S. state privacy laws, such as the CPRA) Personal Data for cross-context behavioral advertising.
● We also do not permit our authorized third party partners and service providers to sell or share Personal Data we disclose to them for their own independent marketing purposes.

We will only share your Personal Data as we have described in this Privacy Statement.

A. Third Party Service Providers.

With your permission or at your direction, we may disclose, or share your Personal Data with third party service providers (including vendors, consultants, payment processors, hosting providers, analytics providers, customer support providers, and security providers) who we contract with to help us provide our Products and Services and to operate our business. For example, your Personal Data may be shared when you authorize a third party application or integration (including a third-party marketplace integration such as eBay) to access your account or when you direct us to publish or transmit listing content to a third-party marketplace. We disclose Personal Data to fulfill your requests, provide you with technical or customer support, and to help us protect our Products and Services, including to combat fraud and to protect your information. Our service providers are authorized to use Personal Data only as necessary to provide services to us and are contractually required to protect it and not use it for other purposes, except as permitted by applicable law.

(1) Third-Party Marketplace Integrations:

● When you authorize a third-party application or integration to access your account or when you direct us to publish or transmit listing content to a third-party marketplace (such as eBay), your Personal Data may be shared.
● We access your third-party account only within the scope of permissions you approve, which may include the ability to create and publish listings, retrieve pricing and product data, and manage listing status.
● We use secure authorization tokens (OAuth or similar protocols) issued by third-party platforms; we do not store your third-party marketplace login credentials.
● When you use our Services to create and post listings to marketplaces, your User Content (descriptions, images, prices, item details) is transmitted to and published on those platforms according to your instructions.
● When you direct us to create, publish, or manage listings on third-party marketplaces, we transmit your User Content (including product titles, descriptions, images, pricing, item condition, category, and other listing attributes) to those platforms. We may also transmit your account identifiers, authorization tokens, and technical metadata necessary to establish and maintain the connection. We do not transmit your payment information, Smart Labels account credentials, or Personal Data beyond what is necessary to fulfill your listing requests to these platforms.

(2) AI and Machine Learning Service Providers:
We may share item details, images, descriptions, metadata, and other User Content with third-party artificial intelligence and machine learning service providers who assist us in providing AI-enabled valuation and price-range features. These providers process your data solely on our behalf and pursuant to our instructions and are contractually prohibited from using your data for their own purposes, including for training their own models, unless you separately consent to such use. Our current AI service providers include Google, OpenAI and eBay. These providers’ own privacy practices are governed by their respective privacy policies, which we encourage you to review.

B. Information Sharing Between Smart Labels’ Entities.

This Privacy Statement applies to all of your interactions with Smart Labels, regardless of geography, corporate entity, or brands, meaning that your information is shared with and among our affiliates and subsidiaries. Except where prohibited by law, regulation, or contractual obligation, we share your information across Smart Labels to support our business operations, to enhance your experiences with our Products and Services, to improve your interactions with us, and to help detect and prevent fraud. When we share information between Smart Labels’ entities, we do so as permitted by applicable law and using adequate technological and data minimization and protection measures to safeguard Personal Data during collection, processing and transfer.

C. Following the Law and Protecting Smart Labels.

We may share your information with courts, law enforcement or regulatory agencies, or other government bodies when we have a good faith belief we are required or permitted to do so by applicable law, regulation, or legal process. We may also disclose your information if we believe it is appropriate to enforce our Terms, to protect the rights, property or safety of Smart Labels and our Products and Services, or to protect or assist others as required by law or contract.

D. Credit Reporting.

We may share your Personal Data with payment processors, collections providers, and professional advisors (such as lawyers and auditors) as necessary to process payments, prevent fraud, and collect amounts owed, consistent with applicable law.

E. Sale of Our Business.

If we sell, merge, or transfer any part of our business, information about you may be shared or transferred as part of that transaction, subject to applicable law. We may also share your information with current or future corporate parents, to our subsidiaries, between our brands, or with our affiliates.

F. De-identified, Anonymized or Aggregated Data.

We may de-identify, anonymize, or aggregate your information, alone or in combination with other individuals’ information. For purposes of this Privacy Statement, “de-identified”
data means data that has been processed to remove or
obscure identifiers such that it cannot reasonably be used to
infer information about, or otherwise be linked to, a particular
individual or household, and we maintain reasonable
safeguards designed to prevent re-identification. Smart Labels
will not attempt to re-identify de-identified data except as
permitted by applicable law (for example, to test the
effectiveness of de-identification measures). Such de-identified
or aggregated information will not contain Personal Data and
may be used, disclosed, licensed, sold, or otherwise
commercialized by Smart Labels for lawful business purposes,
including to create analytics, benchmarking, or market insights
products.

G. With your Consent.

Other than as set out above, we may also share your Personal Data and your other information for additional purposes with your consent or at your direction.

Smart Labels uses appropriate data transfer mechanisms and protection measures.

Smart Labels is based in and conducts its business from within the State of California in the United States. We have adopted a broad view on privacy with the intent of providing our customers with strong privacy rights regardless of where they reside geographically. We have attempted to recognize and implement high standards for privacy rights compliance and our use of terminology in this Privacy Statement should be interpreted to reflect that intent.

Where permitted by applicable law, we may transfer, process or store your Personal Data in any country or region where we have facilities, business operations, or in which we engage service providers.  For Individuals located in the EU, EEA, UK, or Switzerland, transfers of Personal Data to countries outside of your country of residence are conducted pursuant to appropriate legal mechanisms as described in this Section 6 (such as Standard Contractual Clauses), and not solely on the basis of your use of our Products and Services. For Individuals located in other jurisdictions, by using our Products and Services, you acknowledge that your Personal Data may be transferred to, processed, and stored in countries outside of your country of residence, subject to the safeguards described in this Privacy Statement.

Some countries may have data protection laws that are different from the laws of your country. However, Smart Labels has taken appropriate safeguards to require that your Personal Data remains protected when it is being transferred, processed, and stored.

For transfers of Personal Data from the European Union (“EU”), the European Economic Area (“EEA”), the United Kingdom (“UK”), or Switzerland (“CH”) to jurisdictions that are not recognized as having laws that provide an adequate level of protection, Smart Labels relies on the legal mechanisms such as the European Commission approved Standard Contractual Clauses or your consent (in limited circumstances). For a copy of the Clauses, you may Contact Us as described below.

Smart Labels may work with third parties to enhance your experience with our Products and Services.

In your interactions with Smart Labels and our Products and Services, it may be necessary for us to sync, link or connect your information with third parties, including third-party marketplaces (such as eBay) and other integrations, including providing Personal Data necessary to identify or authenticate your requested interactions and to carry out the actions you request (e.g., create, update, or publish listings). Your consent for these interactions will be required by us, by the third party or by both. We encourage you to review the privacy practices of any third party that you choose to share your Personal Data with, as we are not responsible for the privacy practices of third parties.

AI Service Providers: Our Products and Services use third-party AI technology providers to power image recognition, item identification, and authentication features. When you use these features, Image Data and related metadata may be transmitted to and stored by such AI providers in accordance with their own privacy policies.

Google Services: Certain features of the Products and Services may utilize Google APIs or other Google technology. Google’s use of data received from Smart Labels is governed by Google’s Privacy Policy (available at https://policies.google.com/privacy). Smart Labels does not formally incorporate Google’s policies into these terms, and your use of Google-integrated features is subject to Google’s own terms. Smart Labels is not responsible for Google’s data practices or any changes to Google’s policies.

You may review and change your information, deactivate your account with us, manage the use of information that identifies you, decide what marketing communications you receive, and understand our use of Cookies.

We may retain certain information and you may still receive other non-promotional messages from us.

A. Managing Marketing Communications From Us.

Smart Labels will honor your choices when it comes to receiving marketing communications from us. If you have received marketing communications from us that you no longer wish to receive, you may:

• Contact Us or adjust your customer account settings to manage your preferences regarding your Personal Data and your interactions with Smart Labels.
• If you have received electronic promotional communications from us and no longer wish to receive them, click the "unsubscribe" link in the promotional communication you received.
• For SMS messages, reply "STOP" or follow the instructions in the message or settings to discontinue the communications.
• If you are receiving push notifications from us to your mobile device and no longer wish to receive these types of communications, you may turn them off at the device level.
• Remember that even if you choose not to receive marketing communications from us, we will continue to send you mandatory service or transactional communications, or communications related to the safe use of our Products or Services.
• If you do not have a customer account, you may Contact Us if you wish to adjust your Personal Data preferences and your interactions with us.
  
  B. Cookies and Similar Tracking Technologies.
  
  We may use and allow others to use cookies, web beacons, pixels, local shared objects, device identifiers, and other similar technologies ("Cookies”) to collect information about you. We use this information to improve your experiences when you interact with us, including for analytics and (where permitted) targeted advertising. You have control over some of the data we collect from Cookies and how we use it. You may learn more about Cookies and how to manage them at https://www.allaboutcookies.org/manage-cookies.
  
  Please note that even if you elect not to enable Cookies or interest-based advertising and marketing, you may still receive advertisements, they just won't be tailored to your interests. Also, if you elect to receive Cookies and later delete them, use a different browser, update your systems, or use a different device, you may need to renew your choices.
  
  C. Do Not Track.
  
  Like most other companies, Smart Labels is not currently configured to respond to browser "Do Not Track" signals because, at this time, no formal "Do Not Track" standard has been adopted. We honor Global Privacy Control (GPC) signals as valid requests to opt out of the sale or sharing of Personal Data under the CPRA and other applicable laws. When we detect a GPC signal from your browser, we will treat it as a valid opt-out request and process it accordingly without requiring additional action from you.
  
  
  D. Social Media Features.
  
  Smart Labels or our authorized third parties may use social media features to gather certain information about you. These features may collect your IP address, log which pages you are visiting, and may set a Cookie to enable the feature to function properly. Your interactions with these social media features are governed by the privacy policies and practices of the providing company and not by Smart Labels.
  
  E. AI Feature Consent and Notification.
  
  If you were an existing customer before the posting date, June 19 2026, when you first access any new AI-powered feature within the Products and Services (including item recognition, photo categorization, or AI-based authentication), you will be presented with a notification informing you of: (i) the nature of the AI technology being used; (ii) a general description of the types of data collected and processed in connection with the feature, including Image Data; (iii) any relevant updates to the Terms and this Privacy Statement if applicable; and (iv) your right to decline use of the AI feature. Your affirmative acknowledgment of these notices are required before accessing the AI feature. You may manage your AI feature data preferences at any time by contacting Smart Labels at the address provided in the “How to Contact Us” section below.
  

You may have the right to exercise certain data protection rights regarding your Personal Data.

Smart Labels will not discriminate against you for exercising your privacy rights.

A. Data Retention.

Smart Labels retains and uses your information in accordance with and as permitted by applicable law and regulations, based on criteria such as the nature and sensitivity of the information, the purposes for which we process it, the length of time we have an ongoing relationship with you, and our legal and contractual obligations:

● We will retain your information as long as necessary to serve you, to maintain your account for as long as your account is active, or as otherwise needed to operate our business.
● When you close your account, we may continue to communicate with you about your account, transactions, security, and other non-promotional matters, and we will only send promotional communications where permitted by applicable law and consistent with your marketing preferences.
● If you decide not to receive promotional communications from Smart Labels, your opt out will not apply to information provided by us as a result of a product purchase, warranty registration, product service experience or other transactions.
● We may also continue to use some of your information for our legitimate business purposes and to improve our Products and Services (including AI-enabled features) or to develop new ones, subject to applicable law and your choices.
● We will retain and use your information as required by applicable regulations and Smart Label’s records and information management practices, comply with our legal and reporting obligations, resolve disputes, enforce our agreements, complete any outstanding transactions, and for the detection and prevention of fraud.
● De-identified and aggregated data used in AI models may be retained indefinitely, as it cannot reasonably be attributed to you individually. Authorization tokens for third-party marketplace connections are retained only while the connection is active and are deleted promptly upon revocation of access. Subject to your opt-out rights, identifiable AI interaction data and User Content used for AI training may be retained for up to eighteen (18) months after your last use of AI features or account closure for quality assurance, model improvement, and legal compliance purposes. Data that has been incorporated into AI models, aggregated, or de-identified prior to an opt-out request or account closure may remain in those models and datasets indefinitely, as removal may not be technically feasible without complete model retraining. Smart Labels uses machine learning models in which individual data points are incorporated into aggregate model weights and parameters during the training process. Once training is complete, it is not technically possible to isolate or extract any individual’s specific data from the resulting model. De-identification and aggregation safeguards are applied prior to model training to minimize the extent to which any individual’s data is represented in model outputs.

B. Responses from Smart Labels.

We respond to all requests from individuals regarding the exercise of their data protection rights in accordance with applicable data protection laws. While your data protection rights may vary depending on your location, they generally include:
● Accessing, correcting, updating, or requesting deletion of your information.
● Objecting to or asking us to restrict the processing of your information.
● Requesting the portability of your information and providing the same in a timely manner and at no charge.
● Electing whether or not to receive marketing communications from us.
● Withdrawing your consent at any time for us to collect, process, store, or share your information (noting that such withdrawal will not affect the lawfulness of any processing that we conducted prior to your withdrawal, nor will it affect otherwise lawful processing or storage), opting out of certain processing such as targeted advertising where applicable, and appealing certain decisions we make regarding your requests where required by applicable law.
C. Data Controller.

Smart Labels is considered to be a “controller” of your information under data privacy regulations. Other entities may also act as controllers of your information and you should contact them if you have any questions about how they use your information.

We provide our products and services from our base of operations in California.

Smart Labels conduct our privacy practices according to this Privacy Statement and the relevant laws of the United States and the State of California, where our company is based and from where we engage in our interactions with you. Smart Labels wants Individuals located in the State of California to understand the following additional privacy and data protection measures which may be applicable (“California Privacy Terms”). These California Privacy Terms apply to the processing by Smart Labels of Personal Data related to identified or identifiable Individuals and households located in the State of California.

Controlling Law:
We include this additional information to comply with the California Consumer Privacy Act of 2018 (“CCPA”), and as of January 1, 2023 the California Privacy Rights Act of 2020 (“CPRA”). Any terms defined in the CCPA have the same meaning when used in this section. For purposes of this Privacy Statement and this section, the terms Personal Data and personal information are used as interchangeable.

Managing Your Data:
Smart Labels has adopted internal policies and implemented measures to ensure that the applicable legal requirements are met and that your personal information is processed with respect and care using the appropriate technology.

A. Smart Labels may collect, process, store and disclose your personal information for the business and commercial purposes described in this Privacy Statement and as permitted by applicable law. Where required by law, we will obtain your consent. California residents may have the right to opt out of the “sale” or “sharing” of personal information (as those terms are defined by the CPRA), including for cross-context behavioral advertising (also commonly referred to as targeted advertising). California residents may also have the right to
limit our use and disclosure of “sensitive personal information” (as defined by the CPRA) where applicable. If consent is required for us to process your personal information, you may withdraw or modify such consent at any time by contacting us.

B. When we disclose personal information for a business purpose, we endeavor to execute contracts that describe the purpose and require the recipient to both keep that personal information confidential and not use it for any other purpose except as permitted by the contract and applicable law.

C. In the preceding twelve (12) months, Smart Labels has disclosed the following categories of personal information for a business purpose:
● Contact information that includes identifiers such as your first and last name, business entity name, e-mail address, and telephone number.
● Financial information (account or credit card numbers).
● Demographic information (address or age).
● Other unique identifiers such as your tax ID number (where applicable), IP addresses, and geolocation data (where enabled).
● Internet or other similar network activity, including but not limited to, browsing history, search history, activity history, informational materials from our websites, location data, logs, language, date and time of access, frequency, http response code, and other communication data or information regarding your interaction with us.
● Commercial information, including our Products or Services with which you interact (including AI valuation requests, listing content, and marketplace workflow activity), including historical or trend information, and inferences or profiling information created therefrom.
● AI valuation requests, item details submitted for valuation, AI-generated outputs (estimated values, price ranges, suggested descriptions), your acceptance or modification of AI suggestions, and feedback on AI features.
● Authorization status with connected marketplaces (such as eBay), listing information transmitted to marketplaces, marketplace account status, listing performance data, and transaction outcomes from marketplace sales.
● Product descriptions, images, metadata, pricing data, marketplace listing information, and transaction outcomes used to train, test, and improve AI valuation algorithms and machine learning models (subject to your opt-out rights described in this Privacy Statement).

D. You have the right to:

● Request access to your personal information as it is processed and stored by us.
● Correct or delete your personal information that we hold unless Smart Labels is legally required to retain it.
● Restrict or object to our processing of your personal information.
● Opt out of the sale or sharing of your personal information, including for cross-context behavioral advertising (targeted advertising), where applicable.

E. You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your request, we may disclose to you:

● The categories of personal information we collected about you.
● The categories of sources and third parties for the personal information we collected about you.
● Our business or commercial purpose for collecting or selling that personal information.
● The categories of third parties with whom we share that personal information.
● The specific pieces of personal information we collected about you (also called a data portability request).

We will respond to properly submitted and verified requests for access, disclosure, deletion, correction, or objection within 45 days. Where required by applicable law, we will provide a
process to appeal certain decisions regarding your requests.

F. Sensitive Personal Information.

Under the CPRA, "sensitive personal information" includes categories such as Social Security numbers, driver's license numbers, financial account credentials, precise geolocation, contents of mail/email/text messages not directed to the business, genetic data, biometric data, and certain health or sexual orientation information.

Smart Labels does not knowingly collect or process sensitive personal information as defined by the CPRA. To the extent any sensitive personal information is inadvertently collected, we do not use or disclose it except as permitted by law and the CPRA (for example, to perform services reasonably expected by consumers or to prevent fraud and security incidents).


Please Contact Us for more information or to exercise a request regarding your California data privacy rights. If you are concerned about Smart Label’s compliance with California laws relating to the privacy of your Personal Data (personal information), you may also contact the California Privacy Protection Agency or the California Attorney General’s Office.

Additional Regional Privacy Considerations
Canada Europe (EU), United Kingdom (UK) and Switzerland

We provide reasonable and appropriate security measures in connection with securing your Personal Data.

Keeping your Personal Data safe is important to us. We have implemented measures designed to secure your Personal Data from accidental loss and from unauthorized access, use, alteration and disclosure. At Smart Labels, we:

● Work to review and update our security practices and implement accepted methods to protect your Personal Data.
● Store Personal Data on our secure servers behind firewalls and securely transmit such.
● Transmit, store, protect, and access all cardholder information in compliance with the Payment Card Industry's Data Security Standards. Payment transactions are encrypted using SSL or other encryption technology, or will use our third party payment processors, who will use appropriate security procedures.
● Comply with applicable laws and security standards.
● Train applicable employees and contractors on data privacy and require them to safeguard your data.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain of our Products or Services (such as our websites or your customer account), you are responsible for keeping this password confidential. You should not share your password with anyone. We urge you to be careful about giving out information in public areas, like message boards or social media.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your Personal Data, we cannot guarantee its security during transmission to us. Any transmission of your information to us is at your own risk. Smart Labels is not responsible for circumvention of any privacy settings or security measures.

We may make changes to our Privacy Statement or our supporting privacy procedures at any time.

From time to time we may change or update this Privacy Statement. We reserve the right to make changes or updates at any time and without prior notice to you.

If we make material changes to the way we process your Personal Data, we will provide you notice by posting the most current version of this Privacy Statement on our websites and we may also advise you of changes via our Products and Services information, or by other communication channels, such as by email, newsletters or community post. Please review any changes carefully.

If you object to any changes and no longer wish to use our Products and Services, you may close your accounts and cease use of our Products and Services. All changes to our Privacy Statement are effective immediately upon posting and your continued interaction with us or your use of our Products and Services after a posting of an updated Privacy Statement constitutes your consent to all changes.

If you have questions or comments about this Privacy Statement, you may contact us by email, website, or direct mail. 

A. Email at help@qrsmartlabels.com is the fastest and most-preferred way to reach us with your data management or privacy-related questions and concerns.

B. Via inquiry on our website at https://www.qrsmartlabels.com/pages/contact.

C. Via Direct Mail:  

Smart Labels LLC