Privacy Policy

Effective Date: April 4th 2026

Council (“Council,” “we,” “us,” or “our”), operated by Atley LLC, respects your privacy and is committed to protecting your personal information. This Privacy Policy explains how we collect, use, share, and safeguard information in connection with our website and services.

1. Scope

This Privacy Policy applies to information we collect through our website and services in connection with facilitating transactions between individuals and independent watch dealers.

2. Information We Collect

We collect the following categories of information:

a. Contact Information

  • Name

  • Email address

  • Phone number

b. Transaction Information

  • Watch and asset details

  • Shipping or mailing address

  • Payment-related details (such as bank account or wire instructions)

c. Identity Verification Information

  • Government-issued identification (e.g., driver’s license), when required for verification, fraud prevention, or dealer requirements

d. Communications

  • Emails, messages, and other communications with us

e. Technical Information

  • IP address

  • Browser type

  • Device information

  • Basic website usage data

3. How We Use Information

We use your information to:

  • Facilitate and coordinate transactions between users and independent dealers

  • Obtain and present offers from dealers

  • Share relevant transaction details with appropriate counterparties

  • Verify identity and prevent fraud

  • Communicate with you about your inquiry or transaction

  • Operate and improve our services

  • Comply with legal obligations

4. How We Share Information

We may share your information as follows:

a. Independent Dealers / Counterparties

We share relevant information with independent dealers or buyers involved in a potential or completed transaction, including contact details and transaction-related information, where necessary to facilitate the transaction.

b. Service Providers

We may share information with service providers who assist with operations (e.g., hosting, communications, logistics), subject to appropriate safeguards.

c. Legal and Compliance

We may disclose information if required to:

  • comply with applicable law

  • respond to legal process

  • protect rights, safety, or property

d. Business Transfers

Information may be transferred in connection with a merger, sale, or other business transaction.

5. Important Clarification Regarding Our Role

Council acts solely as an independent service provider that facilitates introductions and coordination between parties.

  • Council is not a buyer or seller of goods

  • Council does not take possession of items

  • Council does not process or hold customer funds

Information is shared only as necessary to enable transactions between independent parties.

6. Data Retention

We retain personal information only as long as reasonably necessary to:

  • facilitate transactions

  • comply with legal obligations

  • resolve disputes

  • maintain business records

7. Data Security

We implement reasonable administrative, technical, and organizational safeguards to protect personal information. However, no method of transmission or storage is completely secure, and we cannot guarantee absolute security.

8. Your Rights

a. California Residents (CCPA / CPRA)

If you are a California resident, you have the right to:

  • Request access to personal information we collect about you

  • Request deletion of your personal information

  • Request correction of inaccurate information

  • Know what categories of information we collect and how we use it

To exercise these rights, contact us at: info@councilwatches.com

We do not sell personal information.

b. European Economic Area / United Kingdom (GDPR)

If you are located in the EEA or UK, you have the right to:

  • Access your personal data

  • Request correction or deletion

  • Restrict or object to processing

  • Request data portability

We process personal data based on:

  • performance of a contract

  • legitimate interests (such as facilitating transactions)

  • compliance with legal obligations

  • your consent where applicable

9. International Data Transfers

Your information may be processed in the United States. By using our services, you acknowledge that your information may be transferred and processed outside your jurisdiction.

10. Children’s Privacy

Our services are not directed to individuals under 18. We do not knowingly collect personal information from children.

11. Changes to This Policy

We may update this Privacy Policy from time to time. The updated version will be posted with a revised effective date.

12. Contact Us

If you have any questions or requests regarding this Privacy Policy, please contact:

Council
Atley LLC
info@councilwatches.com