Privacy Policy

1. Introduction

All Things Universal LLC (“ATU,” “Company,” “we,” “our,” or “us”) respects your privacy and is committed to protecting personal information.

This Privacy Policy explains how ATU collects, uses, discloses, processes, stores, transfers, and protects personal information obtained through the All Things Universal website, marketplace platform, vendor pages, mobile applications, communications, tools, and related services, collectively referred to as the “Platform.”

This Privacy Policy applies when you visit the Platform, create an account, register as a vendor, contact a vendor, communicate with ATU, subscribe to vendor services, submit information, use Platform features, interact with advertisements, or otherwise use ATU’s services.

By using the Platform, you acknowledge that you have read and understood this Privacy Policy.

This Privacy Policy should be read together with ATU’s Terms of Use, Vendor Terms of Service, Cookie Policy, Refund and Subscription Policy, DMCA and Intellectual Property Policy, Accessibility Statement, and any other policies published by ATU.

2. Scope of This Policy

This Privacy Policy applies to personal information collected from or about:

• Website visitors.
• Customers and prospective customers.
• Vendors, merchants, sellers, service providers, professionals, and business applicants.
• Vendor owners, officers, directors, beneficial owners, representatives, and authorized users.
• Individuals who contact vendors through the Platform.
• Individuals who contact ATU for support, legal, privacy, compliance, or business inquiries.
• Business partners, contractors, affiliates, advertisers, and service providers.
• Individuals who interact with ATU marketing, emails, advertisements, social media, or other communications.

This Privacy Policy does not apply to third-party websites, platforms, payment processors, vendor websites, social media platforms, or services that ATU does not own or control.

Vendors are independent businesses and may have their own privacy practices. Users should review the privacy policies or notices of any vendor they choose to contact, purchase from, or engage with.

3. Personal Information We Collect

The personal information ATU collects depends on how you interact with the Platform.

A. Account and Contact Information

We may collect:

• Full name.
• Business name.
• Username or account name.
• Email address.
• Telephone number.
• Mailing address.
• Billing address.
• Business address.
• Country, state, province, city, or region.
• Communication preferences.
• Account login credentials.
• Security questions or account recovery information.

B. Vendor and Business Verification Information

For vendors, business applicants, merchant accounts, service providers, professionals, and authorized representatives, we may collect:

• Business registration documents.
• Certificate of incorporation or formation.
• Articles of organization or equivalent documents.
• Trade name, DBA, or business name registration.
• Tax identification number.
• VAT, GST, sales tax, or other tax registration information.
• Business license information.
• Professional license information.
• Permits, certifications, registrations, or approvals.
• Proof of business address.
• Proof of ownership or authorization.
• Government-issued identification where required.
• Date of birth where required for identity verification.
• Beneficial ownership information.
• Officer, director, manager, or authorized representative information.
• Compliance documents requested during vendor onboarding or review.

C. Payment, Billing, and Subscription Information

We may collect or receive information related to:

• Vendor subscription plans.
• Vendor advertising or promotional purchases.
• Billing details.
• Payment confirmation.
• Payment status.
• Refund requests.
• Chargeback information.
• Transaction identifiers.
• Payment processor confirmations.
• Subscription renewal or cancellation records.

ATU may use third-party payment processors. ATU does not necessarily receive or store full credit card, debit card, or bank account numbers unless expressly stated or required for a particular service. Payment processors may collect and process payment information under their own terms and privacy policies.

D. Customer and Marketplace Interaction Information

We may collect information related to Platform interactions, including:

• Vendor pages viewed.
• Products or services viewed.
• Search activity.
• Listings saved, clicked, or contacted.
• Inquiry forms submitted.
• Messages or communications sent through the Platform.
• Reviews, ratings, comments, complaints, or feedback.
• Wishlist, cart, booking, request, or inquiry activity where applicable.
• Customer support information.
• Dispute, complaint, or compliance-related information.

E. User-Generated Content

We may collect content you submit to or through the Platform, including:

• Reviews.
• Ratings.
• Comments.
• Messages.
• Listings.
• Product or service descriptions.
• Images.
• Videos.
• Business profile information.
• Vendor advertisements.
• Promotional content.
• Support messages.
• Documents submitted for verification or compliance.

Content submitted to public areas of the Platform may be visible to other users, vendors, visitors, search engines, and third parties.

F. Technical, Usage, and Device Information

We may automatically collect:

• IP address.
• Device type.
• Device identifiers.
• Browser type.
• Operating system.
• Internet service provider.
• Referring and exit pages.
• Pages viewed.
• Time and date of visits.
• Session activity.
• Search activity.
• Clickstream data.
• Approximate location derived from IP address.
• Cookie identifiers.
• Advertising identifiers.
• Log files.
• Security event information.
• Performance and diagnostics data.

G. Cookies, Pixels, and Tracking Technologies

We may collect information through cookies, pixels, web beacons, tags, scripts, local storage, software development kits, analytics tools, advertising technologies, and similar tracking technologies.

More information is provided in ATU’s Cookie Policy.

H. Communications Information

We may collect information from communications with you, including:

• Emails.
• Support requests.
• Chat messages.
• Contact forms.
• Vendor inquiries.
• Privacy requests.
• Legal notices.
• Compliance communications.
• Marketing interactions.
• Social media interactions.

I. Information from Third Parties

We may receive information from third parties, including:

• Payment processors.
• Identity verification providers.
• Fraud prevention providers.
• Sanctions screening providers.
• Analytics providers.
• Advertising partners.
• Cloud hosting providers.
• Customer support providers.
• Vendors.
• Customers.
• Business partners.
• Public databases.
• Government or regulatory sources.
• Social media platforms.
• Other users who provide information about you.

J. Sensitive Personal Information

Depending on the services used and legal requirements, ATU may collect limited sensitive personal information, such as government identification, tax identification numbers, financial verification information, or data required for identity, fraud, sanctions, compliance, or vendor verification purposes.

ATU does not use sensitive personal information to infer characteristics about users unless expressly stated or required by applicable law.

4. How We Collect Information

ATU may collect personal information:

• Directly from you.
• When you create an account.
• When you register as a vendor.
• When you submit vendor verification documents.
• When you browse or use the Platform.
• When you contact a vendor through the Platform.
• When you submit forms, inquiries, reviews, or messages.
• When you purchase a vendor subscription or paid Platform service.
• When you communicate with ATU.
• When you interact with ATU emails, advertisements, social media, or marketing.
• Through cookies and similar tracking technologies.
• Through third-party service providers.
• From public sources or legally available databases.
• From other users, vendors, or business partners.

5. How We Use Personal Information

ATU may use personal information for the following purposes:

A. To Operate and Provide the Platform

We use personal information to:

• Create and manage accounts.
• Provide access to Platform features.
• Display vendor pages and listings.
• Enable customer-vendor contact.
• Process vendor subscriptions and Platform-related payments.
• Provide customer support.
• Respond to inquiries.
• Manage vendor onboarding.
• Maintain Platform functionality.
• Communicate service updates.

B. To Verify Vendors and Maintain Marketplace Trust

We use personal information to:

• Verify vendor identity.
• Verify business registration.
• Verify beneficial ownership.
• Verify licensing or authorization.
• Conduct fraud checks.
• Conduct sanctions screening.
• Review restricted categories.
• Evaluate vendor eligibility.
• Investigate complaints.
• Protect customers, vendors, ATU, and the Platform.

C. To Process Payments, Billing, and Subscriptions

We use personal information to:

• Process vendor subscription fees.
• Manage renewals.
• Confirm payments.
• Handle refund requests.
• Address billing issues.
• Prevent payment fraud.
• Maintain accounting records.
• Comply with tax or financial obligations.

D. To Communicate With You

We use personal information to:

• Send account notices.
• Send service notices.
• Send legal or policy updates.
• Respond to support requests.
• Send vendor onboarding communications.
• Send compliance communications.
• Send privacy request responses.
• Send marketing messages where permitted.
• Send transactional or operational notices.

E. For Marketing, Advertising, and Personalization

We may use personal information to:

• Send promotional communications.
• Display relevant content.
• Measure advertising performance.
• Improve marketing campaigns.
• Personalize Platform experiences.
• Recommend vendors, listings, services, or categories.
• Understand user interests and Platform engagement.

Users may opt out of certain marketing communications as described in this Privacy Policy.

F. For Security, Fraud Prevention, and Compliance

We use personal information to:

• Detect fraud.
• Prevent unauthorized access.
• Monitor Platform security.
• Investigate suspicious activity.
• Enforce ATU policies.
• Protect against abuse, spam, scams, illegal activity, sanctions evasion, money laundering, or other harmful conduct.
• Maintain audit logs.
• Respond to legal, regulatory, or compliance requests.

G. To Improve and Develop the Platform

We use personal information to:

• Analyze Platform performance.
• Improve user experience.
• Improve vendor tools.
• Troubleshoot errors.
• Test new features.
• Conduct research and analytics.
• Understand marketplace trends.
• Maintain and improve Platform security and reliability.

H. For Legal and Business Purposes

We use personal information to:

• Comply with applicable laws.
• Respond to subpoenas, court orders, or government requests.
• Enforce contracts and policies.
• Resolve disputes.
• Defend legal claims.
• Protect ATU’s rights.
• Support corporate transactions.
• Maintain business records.

6. Legal Bases for Processing

Where privacy laws require a legal basis for processing personal information, ATU may process personal information based on:

• Contract performance: To provide the Platform, manage accounts, process subscriptions, and perform agreements with users or vendors.
• Legal obligations: To comply with tax, accounting, sanctions, fraud prevention, consumer protection, privacy, and regulatory obligations.
• Legitimate interests: To operate, secure, improve, promote, and protect the Platform, prevent fraud, verify vendors, enforce policies, and communicate with users.
• Consent: Where we request and receive consent, including for certain marketing, cookies, tracking, or data uses where required.
• Vital interests: Where necessary to protect life, safety, or urgent security interests.
• Public interest: Where applicable law permits or requires processing for public interest purposes.

Users may have the right to withdraw consent where processing is based on consent.

7. How We Share Personal Information

A. Service Providers and Vendors Working for ATU

We may share information with companies that provide services to ATU, including:

• Cloud hosting providers.
• Website and platform providers.
• Payment processors.
• Identity verification providers.
• Fraud prevention providers.
• Sanctions screening providers.
• Email service providers.
• SMS or communications providers.
• Analytics providers.
• Advertising technology providers.
• Customer support providers.
• Security providers.
• Data storage providers.
• Professional advisors.
• Legal, accounting, tax, compliance, or insurance advisors.

These providers may process information to perform services for ATU.

B. Vendors and Customers

Where a user contacts a vendor, submits an inquiry, requests a service, places an order, books a service, leaves a review, sends a message, or otherwise interacts with a vendor through the Platform, ATU may share relevant information with that vendor.

Information shared may include:

• Name.
• Contact information.
• Inquiry details.
• Order or request details.
• Delivery or service information.
• Communications.
• Review or complaint information.

Vendors are independent businesses and are responsible for their own handling of personal information they receive.

C. Payment Processors

Payment information may be provided to third-party payment processors to process payments, prevent fraud, handle refunds, manage billing, and comply with financial or legal requirements.

Payment processors may also collect information directly from users under their own privacy notices.

D. Business and Marketing Partners

We may share information with advertising, analytics, promotional, affiliate, or marketing partners where permitted by law and subject to applicable consent or opt-out rights.

E. Legal, Compliance, and Safety Disclosures

We may disclose information where we believe it is necessary or appropriate to:

• Comply with laws.
• Respond to subpoenas, warrants, court orders, legal requests, or government inquiries.
• Cooperate with law enforcement or regulators.
• Enforce ATU’s Terms, Vendor Terms, and policies.
• Investigate fraud, security incidents, sanctions concerns, illegal activity, or policy violations.
• Protect ATU, users, vendors, or the public.
• Defend legal claims.

F. Corporate Transactions

We may disclose or transfer information in connection with:

• Merger.
• Acquisition.
• Sale of assets.
• Financing.
• Reorganization.
• Bankruptcy.
• Corporate restructuring.
• Transfer of ownership or control.

G. Affiliates

We may share information with ATU affiliates or related entities where permitted by law and consistent with this Privacy Policy.

8. Categories of Personal Information and Recipients

Depending on your interaction with the Platform, ATU may collect and disclose the following categories of personal information:

ATU does not sell personal information in the traditional sense. Where certain privacy laws define “sale” or “sharing” broadly to include some advertising or analytics activities, users may have rights to opt out as described in this Privacy Policy.

9. Cookies and Similar Technologies

ATU uses cookies and similar technologies to operate, secure, analyze, improve, and personalize the Platform.

Types of cookies and technologies may include:

• Essential cookies.
• Functional cookies.
• Analytics cookies.
• Advertising cookies.
• Security cookies.
• Preference cookies.
• Pixels.
• Web beacons.
• Tags.
• Local storage.
• Similar tracking technologies.

These technologies may help ATU:

• Keep users logged in.
• Remember preferences.
• Measure Platform performance.
• Understand user behavior.
• Improve services.
• Prevent fraud.
• Deliver or measure advertising.
• Support security.

Users may manage cookie preferences through browser settings, device settings, or consent tools where available.

Some cookies are necessary for the Platform to function properly. Blocking cookies may affect Platform features.

Additional details are provided in ATU’s Cookie Policy.

10. Marketing Communications

ATU may send marketing communications by email, SMS, platform messages, or other channels where permitted by law.

Users may opt out of marketing emails by using the unsubscribe link in the email or by contacting ATU.

Even if you opt out of marketing communications, ATU may still send non-marketing messages, including:

• Account notices.
• Transaction notices.
• Legal notices.
• Security notices.
• Policy updates.
• Vendor compliance notices.
• Support responses.
• Subscription or billing messages.

11. Automated Tools and Decision-Making

ATU may use automated or semi-automated tools to:

• Detect fraud.
• Verify identities.
• Screen vendors.
• Monitor sanctions or compliance risks.
• Detect spam or abuse.
• Monitor Platform security.
• Recommend content.
• Improve Platform performance.
• Review suspicious activity.

Where required by applicable law, users may have the right to request human review, contest a decision, or obtain information about automated processing.

ATU may combine automated review with manual human review where appropriate.

12. International Data Transfers

ATU may transfer, store, access, or process personal information outside your country of residence, including in the United States and other countries where ATU, its service providers, vendors, partners, or affiliates operate.

These countries may have privacy laws that differ from those in your country.

Where required by applicable law, ATU may use safeguards such as:

• Standard Contractual Clauses.
• Data Processing Agreements.
• Adequacy decisions.
• Transfer impact assessments.
• Consent-based transfer mechanisms.
• Other lawful transfer mechanisms.

By using the Platform, you acknowledge that your information may be transferred internationally as described in this Privacy Policy.

13. Data Retention

ATU retains personal information for as long as reasonably necessary for the purposes described in this Privacy Policy.

Retention periods may depend on:

• Account status.
• Vendor relationship status.
• Subscription history.
• Legal obligations.
• Tax and accounting requirements.
• Compliance obligations.
• Fraud prevention needs.
• Security needs.
• Dispute resolution.
• Contract enforcement.
• Recordkeeping requirements.
• User requests.
• Business operations.

ATU may retain certain information after account closure where necessary for legal, compliance, fraud prevention, audit, accounting, tax, dispute, security, or legitimate business purposes.

Where possible, ATU may delete, anonymize, or aggregate information that is no longer needed.

14. Security Measures

ATU maintains reasonable administrative, technical, and physical safeguards designed to protect personal information.

These safeguards may include:

• Access controls.
• Password protections.
• Multi-factor authentication.
• Encryption where appropriate.
• Secure hosting.
• Security monitoring.
• Logging and audit controls.
• Vendor security reviews.
• Employee or contractor access limitations.
• Data minimization practices.
• Backup and recovery measures.
• Incident response procedures.

No system, website, platform, or transmission method can be guaranteed completely secure. Users are responsible for protecting their login credentials and using secure communication methods.

If you believe your account or information has been compromised, contact ATU promptly.

15. Children’s Privacy

The Platform is not directed to children under thirteen (13) years of age.

ATU does not knowingly collect personal information from children under 13.

If ATU becomes aware that it has collected personal information from a child under 13 without appropriate consent, ATU will take steps to delete the information as required by law.

Parents or guardians who believe a child has provided personal information to ATU may contact ATU using the contact information below.

ATU may apply higher age thresholds where required by applicable law.

16. Your Privacy Rights

Depending on your location and applicable law, you may have some or all of the following rights:

• Right to access or know what personal information ATU holds about you.
• Right to receive information about how ATU collects, uses, shares, or discloses personal information.
• Right to correct inaccurate personal information.
• Right to request deletion of personal information.
• Right to restrict processing.
• Right to object to processing.
• Right to data portability.
• Right to withdraw consent where processing is based on consent.
• Right to opt out of certain marketing communications.
• Right to opt out of certain sales, sharing, targeted advertising, or profiling where applicable.
• Right to limit the use or disclosure of sensitive personal information where applicable.
• Right to appeal a privacy request decision where applicable.
• Right to lodge a complaint with a data protection authority where applicable.

These rights are not absolute and may be subject to legal limits, verification requirements, exceptions, and jurisdiction-specific rules.

17. How to Exercise Your Rights

You may submit privacy requests by contacting ATU at:

ATU may need to verify your identity before responding to a request.

Verification may require:

• Email confirmation.
• Account login.
• Government identification where appropriate.
• Business verification documents.
• Additional information needed to match you to records.

Authorized agents may submit requests on behalf of individuals where permitted by law. ATU may require proof of authorization and may ask the individual to verify their identity directly.

ATU will respond to valid requests within the time required by applicable law.

18. California and U.S. State Privacy Rights

Residents of California and certain other U.S. states may have additional privacy rights under applicable state privacy laws.

These rights may include the right to:

• Know categories of personal information collected.
• Know categories of sources of personal information.
• Know purposes for collecting, using, selling, or sharing personal information.
• Know categories of third parties to whom information is disclosed.
• Access personal information.
• Correct personal information.
• Delete personal information.
• Opt out of certain sales or sharing of personal information.
• Opt out of targeted advertising.
• Limit certain uses of sensitive personal information.
• Appeal denied privacy requests.
• Not be discriminated against for exercising privacy rights.

ATU does not sell personal information for money.

Where applicable law defines “sale,” “sharing,” or “targeted advertising” to include certain advertising, analytics, or tracking activities, users may have the right to opt out.

ATU should provide a “Do Not Sell or Share My Personal Information” or similar mechanism if required by applicable law.

19. European Economic Area, United Kingdom, and Switzerland Privacy Rights

Individuals located in the European Economic Area, United Kingdom, or Switzerland may have rights under applicable data protection laws, including the right to:

• Access personal data.
• Rectify inaccurate personal data.
• Erase personal data.
• Restrict processing.
• Object to processing.
• Receive data portability.
• Withdraw consent.
• Object to direct marketing.
• Lodge a complaint with a supervisory authority.

Where required, ATU will identify the applicable data controller, representative, or data protection contact.

ATU should seek legal counsel to determine whether an EU or UK representative, Data Protection Officer, or additional jurisdiction-specific notices are required.

20. Latin America and Other International Privacy Rights

ATU may operate or make the Platform available in countries where additional privacy laws apply.

Depending on location, users may have privacy rights under laws such as:

• Brazil’s Lei Geral de Proteção de Dados.
• Mexico’s Federal Law on Protection of Personal Data Held by Private Parties.
• Colombia’s personal data protection laws.
• Argentina’s personal data protection laws.
• Other applicable Latin American, Caribbean, or international privacy laws.

ATU will make reasonable efforts to honor valid privacy requests and comply with applicable privacy obligations in the jurisdictions where it operates or targets users.

Legal counsel should confirm which country-specific disclosures are required based on ATU’s launch markets.

21. Vendor Handling of Customer Information

Vendors may receive customer or inquiry information through the Platform.

Vendors are independent businesses and are responsible for their own use, protection, retention, and disclosure of personal information they receive.

Vendors must:

• Use customer information only for the purpose for which it was provided.
• Use customer information only to respond to inquiries, fulfill orders, provide services, resolve disputes, or comply with legal obligations.
• Not sell, rent, trade, or misuse customer information.
• Not send unrelated marketing without proper consent.
• Not spam customers.
• Protect customer information using reasonable security measures.
• Comply with applicable privacy, communications, consumer protection, and data protection laws.
• Notify ATU promptly of suspected unauthorized access, misuse, loss, disclosure, or breach involving customer information received through the Platform.

Vendor data obligations may also be addressed in ATU’s Vendor Terms of Service.

22. Third-Party Websites, Vendors, and Links

The Platform may contain links to third-party websites, vendor websites, payment processors, social media platforms, advertisements, tools, or services.

ATU does not control and is not responsible for the privacy practices, security practices, terms, content, products, services, or policies of third parties.

Users should review the privacy policies and terms of any third-party website, vendor, payment provider, or service before providing personal information.

23. Data Breach and Security Incident Notification

ATU maintains procedures for identifying, assessing, responding to, and documenting security incidents.

Where required by applicable law, ATU will notify affected individuals, regulators, supervisory authorities, vendors, service providers, or other parties of reportable data breaches or security incidents.

The timing, content, and method of notification may depend on the nature of the incident, the information involved, applicable law, and law enforcement or regulatory guidance.

24. Complaints

If you have concerns about how ATU handles personal information, you may contact ATU using the contact information in this Privacy Policy.

ATU will review privacy complaints and respond as appropriate.

Depending on your location, you may have the right to lodge a complaint with your local data protection authority, attorney general, consumer protection agency, or privacy regulator.

25. Changes to This Privacy Policy

ATU may update this Privacy Policy from time to time.

When changes are made, ATU may update the “Last Updated” date, post the revised Privacy Policy on the Platform, and take any additional steps required by applicable law.

Continued use of the Platform after changes are posted means you acknowledge the updated Privacy Policy.

26. Contact Information

Questions, concerns, or privacy requests may be directed to: