Privacy Policy - Remarket Space

Effective Date: August 17th, 2026

Welcome to Twin Cities Auctions, LLC d/b/a Remarket Space ("RMS," "we," "us," or "our"). This Privacy Policy governs your access to and use of the services provided by Remarket Space through our online vehicle auction platform (the "Platform"). By accessing or using the Platform, including registering an account or participating in any auctions, you agree to this Privacy Policy in full. If you do not agree, please discontinue use of our Platform immediately.

Privacy Statement

Remarket Space acknowledges your privacy and is committed to protecting your Personal Data, which is any information that can be used to identify or potentially identify a particular person.

The scope of this Privacy Policy relates to any Personal Data that Remarket Space processes under applicable data privacy laws. This Privacy Policy applies to your use of the Remarket Space website at remarketspace.com, the Remarket Space mobile application for iOS, the Remarket Space mobile application for Android, and all related Remarket Space services, regardless of how you access them. Where a practice described in this policy applies only to our website and not to our mobile applications, or only to our mobile applications and not to our website, we say so expressly. Unless otherwise specified, this policy applies to the operations of Remarket Space relating to vehicles that are physically located within the United States.

This version was last updated on August 17th, 2026. We may update this notice from time to time, and if we do so, we will upload a new version to our website and to our mobile applications.

Important Information

Our website and mobile applications are intended solely for users who are 18 years of age or older. They are not directed to children, and we do not knowingly collect Personal Data from anyone under 18. If we learn that we have collected Personal Data from a person under 18, we will delete that data promptly. When you register with Remarket Space, you represent that you are at least 18 years old and legally able to enter into a binding contract to purchase a vehicle.

It is important that you read this privacy policy together with any other privacy policy or fair processing notice we may provide on specific occasions when we are collecting or processing Personal Data about you. This privacy policy supplements other notices and is not intended to override them.

Data Controller

Twin Cities Auctions, LLC d/b/a Remarket Space is the data controller responsible for the personal data collected and used within the scope of this policy:

• Twin Cities Auctions, LLC d/b/a Remarket Space
• 9643 161st Ave NW, Elk River, MN 55330
• support@remarketspace.com
• 763-202-7252

Data We Collect

Depending on the context of your relationship with us, we collect different categories of data, which may include:

• Identity Data: Personal identifiers such as your name, username, password, government-issued ID (for example, a driver's license), and other similar data required for identification purposes.
• Contact Data: Your mailing address, email, phone number, and other contact information required to communicate with you.
• Financial Data: Payment information such as bank account numbers, payment card details, and other financial information required to process payments securely.
• Vehicle Data: Information about vehicles you buy or sell through us, including make, model, VIN, and condition.
• Technical Data (Website): When you use remarketspace.com, we collect IP address, device and browser information, time zone settings, and similar technical data through cookies and analytics and tracking technologies including Microsoft Clarity, Google Analytics, Google Tag Manager, Google Ads, and Meta Pixel.
• Technical Data (Mobile Applications): When you use our iOS or Android applications, we collect your device model and operating system version, app version, a device or installation identifier, IP address, session and authentication data processed by our identity provider, and crash and diagnostic logs. Our mobile applications do not contain advertising, marketing, or attribution software development kits, and we do not track you across other companies' apps or websites from within our mobile applications. We do not collect your device advertising identifier (IDFA or Android Advertising ID) in our mobile applications.
• Photos and Camera Data (Mobile Applications): With your permission, our mobile applications access your device camera and photo library so that you can capture or upload photographs of a vehicle, its condition, its title or supporting documents, or an image required to verify your identity. We access only the specific images you choose to submit. We do not scan, index, or browse your photo library, and we do not collect location metadata embedded in your photos. You may deny or revoke this permission at any time in your device settings, and the rest of the application will continue to function.
• Usage Data: Information about your activity on our website and in our mobile applications, such as browsing habits, listings viewed, bids and offers placed, interaction data, and preferences.
• Marketing Data: Your preferences regarding marketing communications, your responses to our campaigns, and data collected through third-party marketing tools like Google Ads and Meta Pixel on our website.

Purpose of Data Collection

We collect your Personal Data for various reasons, including but not limited to:

• Providing Services: To offer our auction services, facilitate vehicle sales, manage memberships, complete title and registration transfers, and provide customer service.
• Communication: To send service updates, transaction notifications, promotions, news, or notices that may interest you, and to respond to your queries.
• Legal Compliance: To comply with regulatory requirements, including motor vehicle title and registration law, cooperate with legal authorities, and meet our contractual obligations.
• Improving Services: To enhance our website, applications, services, and user experience through data analysis and feedback.
• Security: To protect your account, ensure the safety of transactions, and prevent unauthorized access, fraud, or misuse.
• Marketing: To provide you with information about our products or services and those of trusted third parties, using tools such as Google Ads, Meta Ads, and Microsoft Advertising. We may also use remarketing tools to reach users who have previously visited our website. These practices are conducted through our website only.

Sharing Personal Data

In addition to sharing your Personal Data within Remarket Space, we may disclose your Personal Data to external third parties in specific situations, including:

• Service Providers: We partner with service providers who assist with payment processing, IT support, marketing, and customer management. These partners are required to keep your data secure and use it only as directed by us.
• Identity and Authentication Providers: We use a third-party identity and authentication provider to create and secure your account, manage login sessions, and protect against unauthorized access. This provider processes your email address, phone number, hashed credentials, IP address, and device and session information on our behalf, and is contractually prohibited from using that information for its own purposes.
• Regulatory Compliance: We may disclose data to comply with legal obligations, including motor vehicle titling and tax reporting, or to cooperate with authorities when required by law.
• Marketing Partners: We may share limited data with third-party marketing platforms (for example, Google, Meta, Microsoft) to show relevant ads or communicate effectively with you. This applies to our website only. This does not include mobile phone numbers or SMS consent information, which are never shared with third parties for marketing purposes. See "SMS and Text Messaging" below.
• Analytics Partners: We use analytics providers, such as Google Analytics and Microsoft Clarity, to help us understand how users interact with our website and improve our services.

When we disclose Personal Data to an external third-party vendor for a business purpose, we enter into a contract with the vendor that describes the purpose of the processing and requires the recipient to both keep that Personal Data confidential and not use it for any purpose except performing the contract.

Account Deletion and Data Deletion

You may delete your Remarket Space account and the Personal Data associated with it at any time, through either of the following methods:

• Without logging in or installing the app: submit a request at remarketspace.com/delete-account.
• By contacting us: email support@remarketspace.com or call 763-202-7252.

When you delete your account, we permanently delete your profile, contact information, saved searches, watch list, marketing preferences, uploaded photographs, and stored payment credentials.

We retain a limited set of records after account deletion where we are legally required to do so. This includes completed vehicle transaction records, title and registration documents, and payment and tax records, which we are required to keep for the periods described under "Data Retention Periods" below. We also retain a record of your SMS opt-out if you have one, so that we do not message you again.

Deletion requests are completed within 30 days. We will confirm by email when the deletion is complete.

SMS and Text Messaging

Remarket Space offers SMS text message notifications to users who affirmatively opt in to receive them. This section describes how we handle information related to that program.

No sharing or sale of mobile information. Mobile phone numbers and SMS consent records collected for the purpose of text messaging are used solely to deliver the messages you have opted in to receive from Remarket Space. We do not share, sell, rent, or transfer mobile phone numbers or SMS consent information to any third parties, affiliates, lead generators, or marketing partners for their own marketing or promotional purposes. This restriction applies notwithstanding any other data-sharing practice described elsewhere in this Privacy Policy.

Limited operational exception. We share mobile numbers only with the telecommunications and messaging service providers that transmit messages on our behalf, and only as necessary to deliver those messages. These providers are contractually prohibited from using the information for any other purpose.

Consent records. We retain a record of your opt-in, including the date, time, and method of consent, in order to demonstrate compliance with applicable telecommunications regulations.

Opting out. You may withdraw SMS consent at any time by replying STOP to any message, by updating your notification preferences in your account, or by contacting us at support@remarketspace.com or 763-202-7252. Opting out of SMS does not affect your email preferences or your ability to use the Platform.

For full SMS program terms, including message frequency and rate information, see our Terms of Service.

Text messaging originator opt-in data and consent will not be shared with any third parties, excluding aggregators and providers of the text message services.

Message frequency varies based on your account activity and the auctions you participate in. Message and data rates may apply. Reply STOP to unsubscribe or HELP for help.

Promotional Marketing

Depending on your location and, if applicable, whether you provide your affirmative consent, we may use your identity, contact, technical, usage, and transaction data to form a view on what products or services we think you may want or need, or what may be of interest to you. This is how we decide which products, services, and offers may be relevant to you. Mobile phone numbers collected for SMS text messaging are excluded from this practice except to send the specific categories of messages you opted in to receive directly from Remarket Space.

The advertising and remarketing practices described in this section are conducted through our website only. Our mobile applications do not deliver personalized advertising and do not share data with advertising platforms.

You may opt out of promotional marketing by contacting us at support@remarketspace.com. All recipients of marketing and promotional communications from us may also opt out by clicking the "unsubscribe" link included at the bottom of our marketing communications.

Government-Issued Identification

To comply with motor vehicle title and registration requirements and to prevent fraud, we may ask you to provide an image of a government-issued identification document such as a driver's license. This information is used solely to verify your identity and to complete the legal transfer of vehicle ownership. It is transmitted over an encrypted connection, stored with restricted access limited to employees who need it to complete your transaction, and is never sold, shared, or used for marketing or advertising of any kind. We retain these images only for the period described under "Data Retention Periods" below.

International Transfers

For the purposes of the General Data Protection Regulation (GDPR), some recipients of your Personal Data are located outside of your country or have offices in countries where data protection laws may provide a different level of protection than the laws in your country. When transferring Personal Data to such recipients, we provide appropriate safeguards to ensure compliance with applicable data protection laws.

Cookies and Similar Technologies

Our website uses cookies and similar tracking technologies to enhance your user experience, provide customized services, and gather usage analytics. These cookies may be used for:

• Necessary Services: Enabling core functionalities of our website.
• Analytics: Understanding how visitors interact with our website, including tracking interactions through Google Analytics, Microsoft Clarity, and similar tools.
• Advertising: Delivering personalized ads relevant to you, using tools such as Google Ads and Meta Pixel.

You can manage or block cookies through your browser settings, opt out of the sale or sharing of your information for advertising at remarketspace.com/do-not-sell, or enable a Global Privacy Control signal in your browser (see below).

Our mobile applications do not use advertising or analytics cookies. They store only the session and preference data required to keep you logged in and to operate the application.

Global Privacy Control (GPC)

Some browsers and browser extensions send a Global Privacy Control (GPC) signal indicating a preference to opt out of the sale or sharing of personal information. We honor GPC signals as a valid request to opt out of the sale or sharing of personal information for the browser or device sending the signal. We do not currently respond to general "Do Not Track" browser signals outside of GPC, as there is no common industry standard for interpreting them.

Data Security

We use industry-standard measures to protect your data from unauthorized access, alteration, or disclosure. These measures include encryption in transit, secure servers, and access controls.

In the event of a data breach affecting your Personal Data, we will notify affected users and applicable regulators as required by law.

Despite our best efforts, no security measures are perfect or impenetrable. Please note that any information you send to us electronically may not be secure during transmission. We recommend using secure channels when transmitting sensitive information.

Data Retention Periods

We retain your Personal Data only as long as necessary to fulfill the purposes for which we collected it or as required by law. When determining retention periods, we consider the sensitivity of the data, the potential risk of harm from unauthorized use, and applicable legal requirements.

Third-Party Links

This website may include links to third-party websites, plug-ins, and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

If You Fail to Provide Personal Data

When we need to collect Personal Data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you. In such cases, we may have to cancel a service you have with us, but we will notify you if this is the case.

Non-Discrimination

We will not discriminate against you for exercising any of your data privacy rights. Your access to our services and benefits remains unaffected.

Change of Purpose

We will only use your Personal Data for the purposes for which we collected it, unless we reasonably conclude that we need to use it for another reason that is compatible with the original purpose. If you wish to obtain an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us at support@remarketspace.com

If we need to use your Personal Data for an unrelated purpose, we will notify you and explain the legal basis that allows us to do so. Please note that we may process your Personal Data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Changes to This Privacy Policy

Remarket Space may update this Privacy Policy periodically. We reserve the right to amend this privacy policy at our discretion and at any time. When we make material changes to this Privacy Policy, we will notify you by email or through another appropriate communication method, including in-app notice where applicable. Please review it regularly to stay informed about our practices.

Contact Information

We have appointed a privacy contact responsible for overseeing questions regarding this Privacy Policy, including any requests to exercise your legal rights. If you have any questions or comments about this policy, the ways in which we collect and use your Personal Data, your choices and rights regarding such use, or wish to exercise your rights under the GDPR, CCPA, or other applicable data privacy laws, please contact us at:

• Email: support@remarketspace.com
• Phone: 763-202-7252
• Address: Remarket Space, 9643 161st Ave NW, Elk River, MN 55330

Your California Privacy Rights

If you are a California resident, you have the following rights under the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA):

• Right to Know: You may request that we disclose the categories and specific pieces of personal information we have collected about you, the sources of that information, and the purposes for collecting it.
• Right to Delete: You may request that we delete personal information we have collected from you, subject to certain exceptions permitted by law. See "Account Deletion and Data Deletion" above.
• Right to Correct: You may request that we correct inaccurate personal information we maintain about you.
• Right to Opt Out of Sale or Sharing: On our website, we use tools such as Google Ads and Meta Pixel, which may be considered a "sale" or "sharing" of personal information under the CCPA. You may opt out at any time using the link below or by enabling a Global Privacy Control signal in your browser. Our mobile applications do not sell or share personal information.
• Right to Limit Use of Sensitive Personal Information: You may request that we limit the use of sensitive personal information, including government-issued identification, to what is necessary to provide the services you requested.
• Right to Non-Discrimination: We will not discriminate against you for exercising any of these rights.

To exercise any of these rights, contact us at support@remarketspace.com or 763-202-7252. You may also designate an authorized agent to submit a request on your behalf; we will ask the agent for proof of your written authorization and verify your identity before acting on the request. We will verify your request before processing it and will respond within the timeframes required by law.

Do Not Sell or Share My Personal Information: Visit remarketspace.com/do-not-sell to opt out of the sale or sharing of your personal information for targeted advertising purposes.

Other U.S. State Privacy Rights

Depending on your state of residence, you may have similar rights under your state's privacy law, including the Minnesota Consumer Data Privacy Act and comparable laws in states such as Colorado, Connecticut, Virginia, and Texas. These rights typically include the right to access, correct, and delete your Personal Data, the right to obtain a portable copy of it, and the right to opt out of targeted advertising or the sale of Personal Data.

To exercise any of these rights, contact us at support@remarketspace.com or 763-202-7252, use remarketspace.com/delete-account for deletion, or use remarketspace.com/do-not-sell to opt out of targeted advertising. If we decline to act on your request, you may appeal our decision by replying to our response or emailing support@remarketspace.com with the subject line "Privacy Appeal," and we will respond to your appeal within the timeframe required by your state's law.