Privacy Policy

Holy Grails Holding LLC (“Borough,” “we,” “us,” or “our”) operates the Borough mobile application, website, marketplace, and related services (collectively, the “Services”).

This Privacy Policy explains how we collect, use, disclose, retain, and protect information when you access or use our Services, including when you create an account, browse or purchase products, list products for sale, participate in drawings or other marketplace activities, use rewards, communicate with other users, or otherwise interact with Borough.

By using the Services, you acknowledge the practices described in this Privacy Policy.

1. INFORMATION WE COLLECT

The information we collect depends on how you use the Services.

A. Information You Provide to Us

You may provide information directly to us when you:

Create or update a Borough account;
Create a profile or username;
Purchase an item;
List or sell an item;
Enter a drawing or other promotional or marketplace activity;
Earn, receive, or redeem rewards;
Communicate with other users or Borough;
Contact customer support;
Participate in surveys, promotions, contests, or other activities;
Subscribe to marketing communications; or
Otherwise use features of the Services.

This information may include:

Name;
Username;
Email address;
Phone number;
Shipping and billing addresses;
Account credentials;
Profile information;
Product listings, descriptions, photographs, prices, and other content you submit;
Purchase, sale, listing, drawing-entry, and transaction history;
Rewards balances and redemption activity;
Communications with Borough and, where applicable, other users;
Information you provide to customer support; and
Other information you voluntarily provide.

B. Payment and Transaction Information

When you make a purchase or otherwise conduct a transaction through Borough, payment information may be processed by third-party payment processors.

Depending on the payment method and services used, payment information may include payment card information, billing information, transaction amounts, and other information necessary to process the transaction.

Where a third-party payment processor processes your payment information directly, Borough may not receive or retain your full payment card number. Instead, we may receive information such as transaction identifiers, payment status, card type, limited payment details, and other information necessary to operate the transaction.

We may use payment and transaction information to process purchases and seller payments, prevent fraud, resolve disputes, provide customer support, maintain transaction records, and comply with legal and financial obligations.

C. Seller Information

If you sell or list an item through Borough, we may collect information necessary to operate the marketplace and facilitate transactions.

This may include:

Seller name and account information;
Listing information;
Item photographs and descriptions;
Sale price;
Shipping information;
Transaction history;
Payout information;
Information necessary for tax reporting or compliance;
Information necessary to verify your identity or account; and
Information related to marketplace activity and seller performance.

Certain information associated with your seller profile or listings may be visible to other users, including your username, listing information, photographs, item descriptions, prices, and other information you choose to make publicly available.

D. Automatically Collected Information

When you use the Services, we and our service providers may automatically collect certain technical and usage information.

This may include:

IP address;
Device type;
Operating system and version;
App version;
Device identifiers;
Browser type;
Mobile network information;
General location information derived from your IP address;
Date and time of access;
Pages, screens, products, or features viewed;
Searches and interactions with the Services;
Information about how you navigate through the Services;
Crash reports and diagnostic information;
Referral information; and
Other technical information reasonably necessary to operate, secure, and improve the Services.

We may use cookies, pixels, software development kits (SDKs), local storage, and similar technologies for these purposes where applicable.

E. Information From Third Parties

We may receive information from third parties that help us operate the Services.

For example, we may receive information from:

Payment processors;
Shipping and fulfillment providers;
Identity or account verification providers;
Fraud prevention and security providers;
Analytics providers;
Advertising or marketing providers;
Authentication providers, if you choose to sign in through a third-party service;
Social media platforms when you interact with Borough through those platforms; and
Other service providers or business partners.

The information we receive depends on the services you use and the permissions or authorizations you provide.

2. HOW WE USE INFORMATION

We may use information we collect to:

Create and maintain your Borough account;
Provide and operate the marketplace;
Process purchases and sales;
Facilitate seller payouts;
Process drawing entries and other marketplace activities;
Maintain and administer rewards;
Display listings and marketplace content;
Facilitate communications between users where applicable;
Provide customer service and support;
Communicate with you regarding your account, orders, listings, transactions, and use of the Services;
Send service-related notifications;
Send promotional or marketing communications where permitted by law;
Personalize and improve your experience;
Recommend products, listings, or other content;
Detect, investigate, and prevent fraud, abuse, manipulation, unauthorized transactions, bots, and other suspicious or unlawful activity;
Protect the security and integrity of the Services;
Authenticate or verify accounts and transactions;
Enforce our policies and agreements;
Conduct analytics and understand how users interact with the Services;
Develop and improve products, features, and functionality;
Maintain business and transaction records;
Comply with applicable laws, regulations, legal processes, and governmental requests; and
Protect the rights, property, safety, and security of Borough, our users, and others.

3. REWARDS AND MARKETPLACE ACTIVITIES

Borough may offer marketplace features that allow users to participate in rewards programs, or other activities.

When you participate in these features, we may collect and use information about your rewards, eligibility, results, and related transactions.

We may use this information to:

Prevent fraud, bots, manipulation, duplicate accounts, or other abuse;
Award and administer rewards;
Provide customer support; and
Comply with applicable laws and regulations.

Additional terms may apply to promotions, rewards programs, or other activities.

We may disclose information we collect in the following circumstances.

A. Service Providers

We may share information with third-party service providers that perform services on our behalf.

These providers may assist with:

Payment processing;
Seller payouts;
Shipping and fulfillment;
Hosting and cloud services;
Database management;
Analytics;
Customer support;
Fraud prevention;
Identity or account verification;
Security;
Communications;
Marketing;
Advertising;
Information technology; and
Other services necessary to operate the Services.

These providers may access information only as reasonably necessary to perform services for Borough, subject to applicable contractual and legal requirements.

B. Other Users and Marketplace Participants

Borough is a marketplace. Certain information may therefore be visible to other users.

For example, depending on the features you use, other users may see:

Your username;
Public profile information;
Product listings;
Product photographs;
Listing prices;
Item descriptions;
Marketplace activity that Borough makes publicly available; and
Other information you choose to make available through the Services.

When necessary to complete a transaction, we may provide relevant information to a buyer, seller, shipping provider, or other transaction participant.

C. Legal and Safety Purposes

We may disclose information when we reasonably believe disclosure is necessary to:

Comply with a law, regulation, subpoena, court order, or other legal process;
Respond to a lawful governmental request;
Protect the rights, property, or safety of Borough or others;
Investigate fraud, abuse, security incidents, or unlawful activity;
Enforce our Terms of Use or other policies; or
Protect the integrity and security of the Services.

D. Business Transfers

If Borough is involved in a merger, acquisition, financing, reorganization, bankruptcy, sale of assets, or similar business transaction, information may be transferred as part of that transaction.

We may disclose information when you direct us to do so or otherwise provide your consent.

F. Aggregated or De-Identified Information

We may use and disclose aggregated, statistical, or de-identified information that does not reasonably identify you, to the extent permitted by applicable law.

5. ADVERTISING, ANALYTICS, AND TRACKING TECHNOLOGIES

We may use analytics and similar technologies to understand how users interact with the Services, measure performance, identify technical problems, and improve Borough.

Depending on the technologies implemented in the Services, these tools may collect information such as device information, IP address, app activity, pages or screens viewed, interactions, and other usage information.

If we use third-party advertising or analytics services that process information for their own purposes, their collection and use of information may also be governed by their respective privacy policies.

You may be able to control certain tracking technologies through your device settings, browser settings, app settings, or other available privacy controls.

6. YOUR CHOICES AND PRIVACY RIGHTS

Depending on where you live, you may have certain rights regarding your personal information.

These rights may include the right to:

Know or access certain personal information we maintain about you;
Request correction of inaccurate information;
Request deletion of certain information;
Obtain a copy of certain information in a portable format;
Opt out of certain forms of targeted advertising or sharing;
Opt out of certain marketing communications;
Withdraw consent where processing is based on consent; and
Appeal certain privacy-related decisions, where required by applicable law.

Some rights are subject to exceptions and limitations under applicable law.

Marketing Communications

You may opt out of promotional emails by following the unsubscribe instructions contained in those communications.

Even if you opt out of marketing communications, we may continue to send transactional or service-related communications, including information concerning your account, purchases, sales, security, or other transactions.

Privacy Requests

To submit a privacy-related request, contact us using the contact information provided in the “Contact Us” section below.

We may need to verify your identity before completing certain requests. We may also retain certain information when required or permitted by law, including information necessary to complete transactions, prevent fraud, resolve disputes, maintain security, or comply with legal obligations.

7. DATA RETENTION

We retain personal information for as long as reasonably necessary to provide the Services, maintain business and transaction records, comply with legal and regulatory obligations, resolve disputes, enforce our agreements, prevent fraud and abuse, maintain security, and fulfill other legitimate business purposes.

The specific retention period depends on the nature of the information and why we collected it.

When personal information is no longer reasonably necessary for these purposes, we may delete it, anonymize it, or otherwise dispose of it in accordance with applicable law and our data retention practices.

8. DATA SECURITY

We use reasonable administrative, technical, and organizational safeguards designed to protect information against unauthorized access, disclosure, alteration, or destruction.

However, no method of transmitting information over the Internet or storing information electronically is completely secure. Accordingly, we cannot guarantee that your information will never be accessed, disclosed, altered, or destroyed as a result of a security incident.

You are responsible for maintaining the confidentiality of your account credentials and should notify us promptly if you believe your account has been compromised.

9. CHILDREN’S PRIVACY

The Services are intended for a general audience and are not directed to children under the age of 13. Borough does not knowingly collect personal information from children under 13 without obtaining verifiable parental consent where required by applicable law.

Individuals under the age of 18 may be able to access and use the Services, including marketplace listings, Regular Purchases, Rewards, messaging, and other available features, subject to applicable law and the terms and requirements governing those activities.

Certain activities available through Borough may be subject to additional eligibility requirements. Users are responsible for reviewing the applicable terms, requirements, and disclosures before participating in any Draw or other activity.

Borough does not knowingly seek or solicit personal information from children under 13. If we learn that we have collected personal information from a child under 13 without the required parental consent or other authorization, we will take reasonable steps to delete that information in accordance with applicable law.

If you are a parent or legal guardian and believe that a child under 13 has provided personal information to Borough, please contact us using the information in the “Contact Us” section below.

Borough does not knowingly sell or share the personal information of children under 13 for targeted advertising or other purposes prohibited by applicable law.

Parents and legal guardians are responsible for supervising their children’s use of the Services and should review the Services, User Agreement, Community Guidelines, and applicable activity terms with their children as appropriate.

Nothing in this Privacy Policy changes or overrides any age, eligibility, payment, transaction, or other requirements contained in the User Agreement or applicable terms for a particular Borough activity.

10. THIRD-PARTY SERVICES AND LINKS

The Services may contain links to third-party websites, applications, payment services, social media platforms, or other services.

We are not responsible for the privacy practices of third parties that we do not own or control.

Your interactions with third-party services may be governed by their own privacy policies and terms.

We encourage you to review the privacy policies of third-party services before providing them with personal information.

11. INTERNATIONAL USERS

Borough is based in the United States. If you access the Services from outside the United States, your information may be transferred to, stored in, or processed in the United States or other jurisdictions where Borough or its service providers operate.

Privacy and data protection laws in those jurisdictions may differ from the laws in your country or region.

Where required by applicable law, we will provide additional notices or protections regarding international transfers and processing.

12. STATE-SPECIFIC PRIVACY RIGHTS

Certain U.S. states provide residents with additional privacy rights.

Depending on your state of residence and applicable law, you may have rights concerning access, correction, deletion, portability, opt-out of certain processing, and other aspects of your personal information.

The availability and scope of these rights may vary depending on applicable law and the circumstances of your request.

If you would like to exercise an applicable privacy right, contact us using the information below.

We will process qualifying requests in accordance with applicable law.

13. DO NOT TRACK

Some web browsers and devices may transmit “Do Not Track” signals.

Because there is currently no universally accepted standard for responding to such signals, Borough may not respond to Do Not Track signals unless required by applicable law.

14. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time to reflect changes to our Services, business practices, technology, or legal requirements.

When we make changes, we will update the “Effective Date” at the top of this Privacy Policy.

If we make material changes, we may provide additional notice through the Services or by other appropriate means where required by law.

Your continued use of the Services after the effective date of an updated Privacy Policy means that you acknowledge the updated policy.

15. CONTACT US

If you have questions about this Privacy Policy or would like to submit a privacy-related request, please contact us at:

Holy Grails Holding LLC
Privacy Email: boroughmarketplace@gmail.com

For privacy requests, please include sufficient information for us to understand and respond to your request. We may request additional information to verify your identity where required or permitted by applicable law.