Privacy Policy

Last Updated: 11/29/2022


Lucky 21 is dedicated to protecting your privacy when you visit or communicate with our site or personnel. The Privacy Policy offered here, along with our terms and conditions explains any personal data you may provide to us or that we garner from you. The Policy is changed occasionally to update you regarding any changes, so please make sure you review the Privacy Policy.  Our Data Controller is Lucky 21 Management LLC for purposes of the Data Protection Act of 1998.


  1. Collected Data and Information

Lucky 21 Management LLC (“Lucky 21”, “we”, “us” or “our”) provides technology and services that enable industry-leading companies (each “Lucky 21 Management Client”) to use online marketplaces to acquire customers and maximize inventory yield. Lucky 21 is committed to maintaining the privacy of all users of the Site (each “User”).  This Privacy Policy describes the Lucky 21 practices for gathering, storing, using, and disseminating information, including personally identifiable information.


By visiting, any of its subdomains, a Lucky 21 Client website powered by Lucky 21, or any other websites that links to this Policy (collectively, the “Site”), you agree to be bounded by the terms and conditions of this Privacy Policy. If you do not agree to the terms and conditions set forth below, please do not use or access the Lucky 21 services or Site. By accepting this Privacy Policy, you expressly consent to the use and disclosure of your information, including personally identifiable information, as outlined below.


This Privacy Policy might be changed from time to time. All the changes will be posted to the link of this Privacy Policy and you are encouraged to periodically check back to this Site for any changes to the Privacy Policy.  By continuing to use a Site after any posted revision, each User agrees to abide by it. Any changes to the Privacy Policy become effective upon posting.




Lucky 21 Management LLC complies with the EU-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personally identifiable information transferred from the European Union to the United States.  Lucky 21 Management LLC Software has certified to the Department of Commerce that it adheres to the Privacy Shield Principles.  If there is any conflict between the terms in this Privacy Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern.  To learn more about the Privacy Shield program, and to view our certification, please visit  [AQ13] For more information, please review our “Privacy Shield Provisions” section below.[AQ14]



We collect or receive information in a few different ways.  Often, you may choose what information to provide, but in other instances, we require you to provide certain information to use our Site or Services.


Lucky 21 may automatically collect information regarding your computer and connection, including previous and subsequent URL, IP address, and page viewing data. Lucky 21 may also collect information by using cookies (as defined below).


Lucky 21 will collect any comments you may send to Lucky 21 and any information you may post to the Site.


Lucky 21 collects personally identifiable information when you: (1) Register and create an account on Lucky 21; (2) Become a Lucky 21 Client; (3) Participate in a purchase/auction for a product listed by a Lucky 21 Client; (4) Complete a checkout page for a product purchased from a Lucky 21 Client; (5) Provide comments or submit a problem to Lucky 21 or a Lucky 21 Client; (6) Request information from Lucky 21, provide your name, or return contact information; or (7) Respond to special offers, contests, or surveys.


Buyers and Lucky 21 Clients.

If you are using the online services of Lucky 21, including Lucky 21 public Application Program Interface (“API”) (collectively, the “Services”), or the Site, Lucky 21 may collect personally identifiable information about you including email, billing and shipping addresses, credit card or bank account numbers, purchasing information, product information, and product order information. In addition, Lucky 21 may also collect information about your bidding, buying, and selling history as well as third-party comments regarding your bidding, buying, and selling behavior. Bidding and buying history may specifically include your history with respect to any failure to complete sales on winning bids.  As part of the registration or checkout process, you may be asked to provide contact and billing information, and other personally identifiable information. Providing some of the requested information is optional and Lucky 21 will indicate what information is required and what information is optional.  You can always choose not to provide information, even though it may be needed to make a purchase from a Lucky 21 Client, or take advantage of Lucky 21 Services or features.


How we use Cookies:

We may gather information regarding your computer for our services. This data collection is used for statistical analysis of our website to be used by us or our advertisers. Any information shared will not identify who you are, but rather will be mathematical data about our visitors and their use of our site. The data does not give out any personal details. Cookies may be used to gather this general internet data. When used, cookies are downloaded to your computer without prompting[AQ15] . The cookie file is stored on your hard drive, where files are transferred to. By using this information, we can improve our website and services. All computers can block cookies by activating the proper browser settings. From the options menu, there is a place where you can decline cookies. Please note if you decline cookies, you may experience limited access to certain areas of our site. Advertisers can use cookies that we do not control. [AQ16] If cookies are on, they will be downloaded once you click on any advertisement we have on this site.




Lucky 21 Users.  If you are a Lucky 21 Client or a Buyer, Lucky 21 shares personally identifiable information it collects, as further described below under “Bidding and Buying Process” under “HOW WE USE PERSONALLY IDENTIFIABLE INFORMATION”.


Third-Party Service Providers.  Lucky 21 shares personally identifiable information with our third-party service providers who help provide the Site and Services[AQ17] , including our website host provider, online marketplace support provider, web analytics provider, and payment processor.  Such third-party providers must agree to use such personally identifiable information only for the purposes for which they have been engaged by us.


Anonymous Use and Sharing. Lucky 21 may share with third parties anonymized information in the performance of the Services, including evaluating market trends and/or under a joint marketing agreement to provide the Services. Such information will not include personally identifiable information.


Lawful Requests. Lucky 21 may disclose a User’s personally identifiable information if required to do so by law and in response to lawful requests by public authorities, including to meet national security or law enforcement requirements, or if Lucky 21 has a good faith belief that such disclosure is necessary to protect and/or defend the rights and interests of Lucky 21 or others. Lucky 21 may, as permitted by applicable law, disclose your personally identifiable information to Lucky 21 Clients, other Lucky 21 users, or third parties in connection with an investigation of fraud, infringement, piracy, or other unlawful activity and you expressly authorize Lucky 21 to make such disclosures.


  1. Information Use




We generally use the information we collect to communicate with you, including to respond to your questions or comments, provide the Site and the Services[AQ18] , improve the Site and Services, notify you about changes to the Site or the Services, provide you with the products or services you have requested or purchased, or provide you with information about the services we offer (including details of any products we believe that might be of interest to you) in accordance with your preferences, including any marketing preferences to audit, monitor and administer the Site, comply with any legal or regulatory obligations, and to protect and enforce our legal rights.


Bidding and Buying Process. As part of the buying and selling process, Lucky 21 will facilitate information sharing between Buyers (as defined below) and Lucky 21 Clients. If you are making a sale as a Lucky 21 Client or a purchase on the Site as a Buyer, you are directing us to share your information in accordance with this Privacy Policy. If you are a buyer involved in a transaction with a Lucky 21 Client (for example, purchasing an item from a seller) (each “Buyer”), we share personally identifiable information about you with that Lucky 21 Client in order to assist you with the bidding and buying process, as well as, to assist Lucky 21 Clients with the selling process. Lucky 21 will retain your information at Lucky 21 to support the transaction. To the extent that Lucky 21 Clients have access to a Buyer’s personally identifiable information, Lucky 21 does not control the use of such personally identifiable information by such Clients; Clients are only obligated to treat this information in no less a secure manner than they treat the personally identifiable information of customers who purchase directly through the Client’s website. If you are a Buyer, you are encouraged to review the privacy policies of the Lucky 21 Clients that provide the products or services related to your bid or purchase to understand how your personally identifiable information may be used by them. Buyers should contact Lucky 21 Clients directly and review their privacy policies should you have [AQ19] questions concerning their use of your information such as, for example, communications you may or may not wish to receive.


Customer Support. Contact information provided by a Buyer to Lucky 21 in connection with problems, comments, or requests about our Site or the Services is used only to respond to those problems, comments, or requests and may be provided to Lucky 21 Clients or third parties as necessary to respond to the comment, problem, or request.


Bidding, Buying, Selling History. Lucky 21 may use any information collected related to a Buyer or Lucky 21 Client’s bidding, buying, or selling history to generate recommendations and predictions related to the likelihood of your willingness to complete a bid and may submit such history and recommendations to Lucky 21 Clients.




Data Integrity; Choice. Lucky 21 will use personally identifiable information only in ways that are compatible with the purposes for which it was collected or subsequently authorized by a User. Lucky 21 will take reasonable steps to ensure that such information is relevant to its intended use, accurate, complete, and current.  Lucky 21 will offer Users the opportunity to choose (opt-out) whether their personally identifiable information is to be disclosed to a third party or used for a purpose other than the purpose for which it was originally collected or subsequently authorized by the User.


You may access, modify, remove, correct, or update personally identifiable information by contacting Lucky 21 (see “How To Contact Us[AQ21] ” section below). To protect your privacy and security, we will also take reasonable steps to verify your identity before granting access or making corrections. Please note that we may not be able to correct or update your personally identifiable information previously provided to us by third parties.


If you receive any promotional email communication from us, you will be given the option to “unsubscribe” from receiving further email communications from us at any time.  Your option not to receive promotional and marketing material from us will not preclude us from corresponding with you, by email or otherwise, regarding your existing or past business relationship with us.  Lucky 21 may retain transactional history in order to document a transaction you may have had with a Lucky 21 Client. You should contact the Lucky 21 Client (for example, the seller of an item you have purchased) directly in order to access, modify, or update your personally identifiable information with them.




As a part of the Services, Lucky 21 provides links to websites operated by third parties (including Lucky 21 Clients) that are not controlled by us. These links are made available to you as a convenience and you agree to use these links at your own risk. Lucky 21 is not responsible for the information collection, privacy practices, or content of those third-party sites. This Privacy Policy only applies to information we collect from you while you are using the Site or our Services. Users should check the privacy policies of any website prior to use.




Unless your browser settings are configured to make your online activities and publicly available information about your online activities invisible to usage analytics tools, we do not presently have the capability to omit you from usage analytics to the extent your browser only sends us a “do not track” message and does not otherwise screen you from tracking without any action on our part.  To learn more about browser tracking signals and “do not track”, visit  Third parties, other than our service providers, do not have our permission to track which websites you visit prior to and/or after visiting our Site.  That said, we cannot control all third-party tracking, and there may be third-party tracking without our knowledge or consent.




Pursuant to Section 1798.83 of the California Civil Code, California residents have the right to request from a business with whom the California resident has an established business relationship: (1) What types of personally identifiable information, if any, of the California resident the business shares with third parties for direct marketing purposes of those third parties; and (2) The identities of the third parties with whom the business has shared such information in the immediately preceding calendar year.


If you have any questions, comments, or requests related to this section of the Privacy Policy, please contact us by email at with “California Privacy Rights” in the subject line.  A number of states are currently considering enacting laws similar to the California law mentioned above.  If you are a resident of a state that enacts such a law, please use the contact information above to contact us with any questions, comments, or requests you may have.




Lucky 21 treats data as an asset and therefore stores personally identifiable information it obtains using safeguards. Although guaranteed security does not exist on the internet or offline, we make commercially reasonable efforts to handle such information consistent with this Privacy Policy and applicable laws.  To prevent unauthorized access, maintain data accuracy, and ensure the appropriate use of information, Lucky 21 has put in place physical, electronic, and managerial procedures to protect personally identifiable information in its possession from loss, misuse, unauthorized access, disclosure, alteration, or destruction. You should consider any communication that you transmit to Lucky 21 (such as data, questions or answers, comments, or suggestions) as non-confidential, and agree that Lucky 21 will not be liable or responsible if information that belongs to you is intercepted and used by an unintended recipient.




Lucky 21 does not knowingly, and uses reasonable efforts not to, collect, use, or disclose personally identifiable information from children under the age of 13. If we learn we have collected or received personally identifiable information from children under 13, we will take steps to delete the information as soon as possible. The Services are not targeted at children, individuals under 18 years of age, or the age of majority in their jurisdiction of residence if higher, may not register for any of the Services.


Additionally, any information collected and stored regarding you is to enable us to offer better services to you. We may also use the data collected for the following:


3.1 We may use the data you provided in order to offer you the information you asked for from our site, in direct relation to our services or products. We may also send information on products we feel might interest you, as long as you have consented to such communications.


3.2 Any commitments we made to you may require the use of your information, used only to fulfil your request.


3.3 We may use your information to explain any changes our website has undergone such as structural or service/product modifications, which could affect our service to you.


3.4 An existing customer may require contact regarding goods or services that were a subject of an earlier sale.


3.5 We may use your data or allow third parties to use the data, in order to give you information about unrelated goods or services you may find of interest. We may contact you about these services or goods if you consented to the contact.


3.6 A new customer may be contacted by us or a third party if the new customer has consented to such communication.


3.7 If you do not wish communication from our website or a third party, you will be given the opportunity to decline said communication. We will not allow your information collected while you were on our site to be used by us or a third party if the consent is withheld.


3.8 Please understand that we do not share information that is going to identify you to our advertisers. However, on occasion, we may provide them with statistics about our site visitors.


  1. Personal Data Storage

4.1 It is possible that we may collect transfer data from you regarding locations outside of the European Economic Area. This information is used for storing and processing. It may be processed by staff outside the European Economic Area, a company that works for us, or a supplier we have. An example is where we may process and conclude your order by using payment details or offering support services. You have agreed to this communication by processing and finalizing your order. At any time you provide personal data, you agree to a transfer for processing and storage. We take all reasonable steps to ensure the safety of the data transfer in agreement with this Privacy Policy.


4.2 Data you provide us with will be stored on secure servers. Any transaction details will be encrypted to keep your information safe.


4.3 Transmission of data via the internet is never completely secure, thus a guarantee of data sent electronically or transmitted cannot be given. The information offered is therefore at your own risk. If given a password or chosen to obtain a password, you can access the secure section, requiring the password to remain confidential by you, as your responsibility.


  1. Sharing Your Information

5.1 If applicable, we may share your personal information with any group member. This will include subsidiaries or holding companies we may work with, as well as their subsidiaries if any.


5.2 Personal Information may be shared with third parties:


5.2.1 If we sell part or all of our business or assets we may share personal information with a third party.


5.2.2 When legally requested, we may share your information.


5.2.3 Fraud protection and minimizing credit risk may require sharing your information.


Third-Party Links

Third-Party Links to websites on our website are not included in our Privacy Policy. You will need to check their privacy policy regarding data. We do not accept liability or responsibility for third-party links and their privacy policies.


  1. Information Access

The Data Protection Act 1998 gives you the right to access any information we may collect and store about you. If you wish to have access to this information, it may be subject to a $100 payment fee, used to cover our costs regarding the information you requested. If you wish to access this data, please submit your contact details below[AQ22] .


  1. Contacting Us

We are happy to receive any queries, comments, or requests you may have regarding our Privacy Policy. Feel free and do not hesitate to contact us via the contact portion of the website.