Privacy Policy
Linn County Market
Effective Date: [INSERT DATE] Last Updated: [INSERT DATE]
1. Who We Are
This Privacy Policy describes how Linn County Market (“we,” “us,” “our”) collects, uses, and shares personal information in connection with the Linn County Market platform (the “Platform”). Linn County Market is operated by Huestone Holdings LLC, an Iowa limited liability company; references to “Linn County Market,” “we,” and “us” include Huestone Holdings LLC.
For purposes of this Policy, “personal information” and “personal data” have the meanings given by applicable law, including the Iowa Consumer Data Protection Act (ICDPA) at Iowa Code Chapter 715D, the California Consumer Privacy Act / California Privacy Rights Act (CCPA/CPRA), and equivalent state laws.
2. Information We Collect
We collect information in three ways: information you provide, information we collect automatically, and information from third parties.
2.1 Information You Provide
| Category | Examples |
|---|---|
| Identifiers | Name, email, phone, mailing address, username |
| Account information | Password (hashed), profile photo, preferences |
| Seller information | Business name, tax ID (EIN/SSN where required), bank account info, government ID for INFORM Act verification |
| Transactional information | Listings, bids, purchases, prices, shipping addresses |
| Communications | Messages between users, support tickets, reviews |
| User Content | Listing photos, descriptions, item attributes |
2.2 Information Collected Automatically
| Category | Examples |
|---|---|
| Device and usage | IP address, browser type, operating system, device identifiers, referring URLs, pages viewed, clickstream, timestamps |
| Location | Approximate location derived from IP; precise location only with consent |
| Cookies and similar | See our Cookie Policy |
2.3 Information from Third Parties
| Source | Examples |
|---|---|
| Payment processors | Transaction status, payout details (we do not receive full card numbers) |
| Identity verification services | Confirmation that submitted seller information matches authoritative records |
| Analytics and advertising partners | Aggregated and pseudonymized usage data |
| Public sources | Business registration data, fraud-prevention databases |
We do not knowingly collect personal information from children under 13. See Section 9.
3. How We Use Information
We use personal information to:
- Operate and improve the Platform;
- Create and manage accounts;
- Process listings, bids, transactions, and payouts;
- Verify seller identity (including for INFORM Consumers Act compliance);
- Prevent fraud, abuse, and security incidents;
- Communicate with you about transactions, account activity, and service updates;
- Provide customer support and resolve disputes;
- Comply with legal obligations, including tax reporting (Form 1099-K and equivalents), subpoenas, and law-enforcement requests;
- With your consent, send marketing communications (which you may unsubscribe from at any time);
- Analyze usage to improve features and performance.
We will not process personal data for a materially different purpose than described above without providing notice and, where required by law, obtaining consent.
4. Legal Bases for Processing
Where required by law (e.g., GDPR for any EEA visitors), we rely on the following legal bases:
- Contract performance — to provide the Platform and process transactions;
- Legal obligation — to comply with tax, anti-fraud, and INFORM Act requirements;
- Legitimate interests — to secure the Platform, prevent fraud, improve services, and conduct internal analytics;
- Consent — for marketing communications, precise location, and certain cookies.
5. How We Share Information
We share personal information with:
- Other users — limited information necessary for transactions (e.g., shipping addresses to sellers, seller names/contact info to buyers; for high-volume third-party sellers, statutorily required information per the INFORM Consumers Act).
- Service providers / processors — hosting (e.g., Vercel, Cloudflare), payments (Stripe), email, analytics, identity verification, customer support tooling, all bound by contractual confidentiality obligations.
- Payment processors and financial institutions — for transaction settlement and fraud prevention.
- Government authorities — when required by law, subpoena, court order, or to protect rights, property, or safety.
- Successors — in connection with a merger, acquisition, financing, or sale of assets, subject to confidentiality.
- With your consent — for any purpose disclosed at the time of collection.
We do not sell personal information for money. We may share certain information with analytics or advertising partners in ways that, under California and other state laws, may be considered a “sale” or “share” for purposes of cross-context behavioral advertising; see Section 8 and our “Your Privacy Choices” notice.
6. Cookies, Analytics, and Tracking
See our separate Cookie Policy for details on the cookies and similar technologies we use, your choices, and how we respond to Global Privacy Control (GPC) signals.
7. Data Retention
We retain personal information only as long as necessary for the purposes described in this Policy, or as required by law. Specifically:
- Account data — for the life of the account plus a reasonable archival period;
- Transaction records — at least seven years, to satisfy tax, audit, and dispute-resolution obligations;
- INFORM Act records — as required by 15 U.S.C. § 45f and implementing regulations;
- Communications and listings — typically two years after closure, subject to legal-hold extensions.
Backup copies may persist for additional limited periods before secure deletion.
8. Your Privacy Rights
Depending on where you reside, you may have some or all of the following rights:
| Right | Iowa (ICDPA) | California (CCPA/CPRA) | Other states (VCDPA, CTDPA, CPA, etc.) |
|---|---|---|---|
| Access / Know | ✓ | ✓ | ✓ |
| Delete | ✓ | ✓ | ✓ |
| Portability | ✓ | ✓ | ✓ |
| Correct inaccuracies | — | ✓ | ✓ (most) |
| Opt out of sale | ✓ | ✓ | ✓ |
| Opt out of targeted advertising | ✓ | ✓ | ✓ |
| Opt out of profiling for legal/significant decisions | — | ✓ | ✓ (most) |
| Limit use of sensitive personal information | — | ✓ | — |
8.1 How to Exercise Your Rights
Submit a request via privacy@linncountymarket.com or through the in-account privacy controls at /account/privacy. We will verify your identity using information already on file. We respond within 45 days; we may extend by an additional 45 days where reasonably necessary and will notify you of the extension.
8.2 Appeals
If we deny your request, you may appeal by replying to our denial within 60 days. We will respond to the appeal within 60 days. If the appeal is denied, you may contact the Iowa Attorney General’s Office at https://www.iowaattorneygeneral.gov.
8.3 Authorized Agents
You may designate an authorized agent to act on your behalf. We will require proof of authorization.
8.4 No Discrimination
We will not discriminate against you for exercising any privacy right.
9. Children’s Privacy
The Platform is not directed to children under 13, and we do not knowingly collect personal information from them. If you believe a child has provided us information, contact privacy@linncountymarket.com and we will delete it. We comply with the Children’s Online Privacy Protection Act (COPPA).
10. Security
We implement reasonable administrative, technical, and physical safeguards designed to protect personal information, including encryption in transit, encryption at rest for sensitive fields, access controls, logging, and regular security review. No system is impenetrable; we cannot guarantee absolute security.
11. International Transfers
The Platform is operated from the United States. If you access the Platform from outside the U.S., you understand and consent to the transfer of your information to the U.S., where data protection laws may differ from those in your jurisdiction.
12. Third-Party Links
The Platform may contain links to third-party sites. We are not responsible for the privacy practices of those sites.
13. Changes to This Policy
We may revise this Policy from time to time. Material changes will be posted to the Platform and, where required, emailed to registered users with at least 30 days’ advance notice.
14. Contact
Linn County Market Attn: Privacy c/o Huestone Holdings LLC [INSERT ADDRESS]
Email: privacy@linncountymarket.com
