The Platform is operated by dotte Ltd, a company established in England (company number 12671379) with its registered offices at PO Box 75987, London, E11 9GX (“we”, “us”, or “our”).
This privacy statement describes why and how we collect and use personal data and provides information about individuals’ rights. It applies to personal data provided to us, both by individuals themselves or by others on behalf of individuals. We may use personal data provided to us for the purposes described in this privacy statement or as made clear in another form before collecting personal data.
Personal data is any information relating to an identified or identifiable living person. When collecting and using personal data, our policy is to be transparent about why and how we process personal data.
We process personal data for numerous purposes, and the means of collection, lawful basis of processing, use, disclosure, and retention periods for each purpose differ, and are set out in the relevant sections below.
The personal data that is provided to us is provided either directly from the individual concerned, from a third party acting on behalf of an individual, or from publicly available sources (such as internet searches, and Companies House).
Where we receive personal data from a third party that relates to an individual, we request that this third party inform the individual of the necessary information regarding the use of their data. Where necessary, reference may be made to this privacy statement.
We take the security of all the data we hold seriously. Staff are trained on data protection, confidentiality and security, and we maintain a culture of confidentiality. All personal data will be collected, stored and used by us in accordance with the European Union General Data Protection Regulation No. 2016/679 (“GDPR”) and/or other applicable statutory regulations.
We have a framework of policies and procedures which ensure that we keep the data we hold secure.
All information you provide to us is stored on our secure servers. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our Platform, you are responsible for keeping this password confidential. We ask that you do not share your password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our Platform; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
3. Data we hold and how we use it.
We provide an online peer-to-peer marketplace which suggests relevant sellers and displays items to the most relevant potential buyers based on user preferences and other information submitted to it, which you can access via our Website/App (“Platform”). The services offered by us via the Platform can function only if we collect, store, transfer, delete and/or otherwise use (“collect and use”) specific data relating to you (“personal data” or “data”). Personal data means all information relating to an identified or identifiable natural person such as your name, date of birth, address, or email address.
You can search for items, log-in to your profile and view other profiles via the Platform. The above information will also be visible to search engines, including but not limited to the photos that you post. When you use our Platform we will collect and process certain information about you. The exact data held will depend on the services to be provided.
Certain services on our Platform are offered by third-party suppliers. When you use these services, the data protection regulations of the third-party suppliers will then apply in addition to this data protection statement. Prior to your use of such services, the third-party suppliers may require you to provide permission under data protection law.
Where we are legally permitted to do so, we shall notify you if we receive a request for a data subject to exercise their rights under GDPR, or if we are served with information from a supervisory authority.
4. What data is processed?
The data that is processed is dependent on the service that is being provided and on the recipient of this service.
We collect information from you when you voluntarily submit it to us and when you use the Platform. This can include information you provide when you register to use the Platform, complete a form, list an item, subscribe to our mailing lists or other marketing communications or take an action on the Platform (such as when you comment on or like an item, perform a search, communicate with other users of the Platform, or engage in a transaction).
We also collect information about the pages you look at on our Platform and Platform and/or the device you use to access the Platform and Platform.
The list below sets out categories of personal information we collect about you and how we use that information. Unless we specifically state below that we are relying on your consent, our legitimate interests or a legal obligation to process your personal information, the lawful basis we are relying on to process your personal information is to perform a contract with you. This contract is governed by our Terms of Service. We will only rely on legitimate interests to process your personal information where your interests and fundamental rights do not override our interests.
Where we state below that we use your information to send you marketing communications, we may do so on the basis it is in our legitimate interests (where you are an account holder and we are informing you about our products and services), where we provide you with an opt-out option, or because you have consented to receiving such marketing communications from us. We will only send you marketing communications in accordance with your marketing preferences.
4.1. Contact and identity details: When you open an account with us you will be asked to provide us with your contact information such as your name, your email address, child's date of birth, your telephone number and addresses associated with your account. We will use your contact details so that we can communicate with you directly about the products you purchase and that you sell through the Platform and about queries, issues or concerns you or other users have, to ensure account security (for example, email verification and 2 step phone verification), to enable you to participate in dotte’s referral programme, and to send you marketing communications. As a necessary part of participating in the Platform, you will also share your contact details with any buyer or seller you deal with through the Platform. We may also ask you to provide copies of identification documents which we will also use along with other contact information you provide for the legitimate interests of verifying your details and helping prevent fraudulent access to the Platform or use of your account.
4.2. Comments and opinions: When you contact us directly, e.g. by email, phone, post or by completing an online form we will record your comments and opinions. We will also record comments and opinions you express when responding to surveys, entering competitions, taking part in promotions we run or that you post on our community boards or other message areas. We will use your comments and opinions in the legitimate interests of addressing your queries, issues and concerns and improving our products and services. We will also use comments and opinions you express when posting on our community boards or other message areas (including in-app), responding to surveys, entering competitions or taking part in other promotions, to determine products and services that may be of interest to you and to send you marketing communications.
4.3. Payment and transaction information: We keep records of the products you buy, sell or exchange though the Platform and the payment method you use for the transaction. We will use payment and transaction information to assist in the payment process for any product you purchase through the Platform. We will use your payment and transaction information and history to determine products and services that may be of interest to you and send you marketing. We will provide your contact details to the seller of any item you purchase including your username and the name and delivery address you provide at the checkout.
In order to transfer funds and process refunds in connection with a transaction via Stripe (where you have been offered this option and choose to use Stripe), you agree to provide dotte accurate and complete information about you and your dotte account. By using the payment services provide by Stripe, you hereby authorise dotte to pass to Stripe any information and payment instructions you provide (which may include name, email address, unique customer identifier, order ID, bank account details, payment card details, card expiration date, CVC code, date/time/amount of transaction, merchant name/ID and location) to the extent required to complete payments via the Platform. In addition, where you elect to use Stripe, limited members of our support and moderation team may have access to your name, date of birth, address, and last 4 digits of the relevant bank card, in order to process and support transactions and moderate refunds. Stripe may collect information about your use of Stripe, including information collected by way of cookies or other similar means, to the extent this is necessary to process the transactions or to satisfy security requirements.
4.4. Your relationships with other users: We may collect information regarding other users that you are following on our Platform which we use to prioritise items displayed to you in your search results or your timeline based on dottie’s internal algorithm and to determine other products and services that may be of interest to you. We also store information regarding any blocked or banned relationships associated with your account in the legitimate interests of enforcing our Terms of Service and managing user preferences regarding who they wish to communicate with on our Platform.
4.5. Website and App “Platform” login details: Where you create an account with us we will hold your user name and password details in the legitimate interests of keeping your account secure. Where you are provided with the option to log-in using a social network or third party, for example through Apple ID sign- in, we will not be provided with your password or other account login details for those accounts. We will also collect device ID (Android ID, Apple ID, or your browser fingerprint). Browser fingerprints are based on your device type and browser type (including settings and version). dotte shall only use the above information in the legitimate interests of keeping your account secure.
You are responsible for all actions taken with your username and password, and we recommend that you do not disclose your user name and password to any third parties. If you lose control of your password, you may lose substantial control over your personally identifiable information and may be subject to legally binding actions taken on your behalf, so you should change such password immediately and notify us of any unauthorised access to your account.
4.6. Your preferences: We hold information about the preferences you set for notifications, marketing communications and how our Platform is displayed or what content is displayed to you through our Platform. We will use your preference settings for the purpose of providing notifications, sending marketing communications and displaying our Platform in accordance with your choices.
4.5 Items listed on our Platform: We collect and store information on items you have listed and sold via our Platform, (“content”). We will use this content to personalise marketing messages and campaigns, to contact you directly for publicity or earning opportunities, to conduct advertisement campaigns involving you and the content shared on our Platform, to enable us to post your content on our social media accounts and to allow you to see personalised advertisements.
4.7. Information about how you connect to and use our Platform: We collect information about how you use our Platform such as the pages you view on our Platform, the time you access our Platform and how long you use it for, the website from where you came to our Platform or go to after leaving our Platform (if applicable) and any selections and choices you make when using our Platform. We also collect information about any items you have searched for, listed, purchased, sold, bookmarked, liked or shared on the Platform. We, and our third party analytics providers, process this data for the following purposes:
4.8. Information about your device: We collect information about the computer, tablet, smartphone or other electronic device you use to connect to our Platform. This information can include details about the type of device, unique device identifying numbers, operating systems, browsers and applications connected to our Platform through the device, your Internet service provider or mobile network, your IP address and your device’s telephone number (if it has one). Typically, the information we collect about how you use or connect to our Platform is associated with your device and not you as a named individual. However, if you are logged into a registered account you have with us this information may also be associated with you directly. We use information about your device in order to optimise the presentation and functioning of our Platform to you on your device and in the legitimate interests of ensuring that banned users are not able to access the Platform by creating a new account.
4.9. Information about your location: Where you give us consent, we will collect and use information about your location, sometimes together with other personal information, to provide features of the Platform that are relevant to you and your location. For example, this can include allowing you to search for items that are for sale in your local area. If you change your mind about allowing us to use information about your location in the future, you can update your preferences in your device settings.
4.10. Information provided by other users: Sometimes, other users of our Platform provide information that is associated with you. Other users can provide information that is associated with you such as comments, feedback and likes relating to your items and messages (including in-app messages) they send to you. Other users may also share information relating to an item they have bought from you on the Platform on other social media channels which link to the Platform, but this will not result in any information that was not already public, being made public. Where users of our Platform want to invite you to use our Platform or to share information with you about our services we will use personal information that they provide about you to assist them in doing this; we will only do this where they indicate that you have provided your consent for them to communicate with you in this way.
4.11 Information about fraudulent or criminal activity relating to your account: We will use information about fraudulent or criminal activity relating to your use of our Platform for the legitimate interests of detecting and preventing fraud or crime and to comply with our legal obligations. We may monitor, including by means of AI, the information you provide to detect potential fraud or breach of Terms of Service.
We shall not request from you any personal information, which is deemed sensitive data, including without limitation, information regarding religious or other beliefs, physical and mental health details, sexual life, racial or ethnic origin, trade union membership and/or offences, and we ask users of the Platform not to supply us or any other user with any sensitive personal information, given the nature of the Platform and that user profiles and comments are visible by other users. Where you do provide sensitive personal information to us on the Platform you hereby confirm that you are deliberately making this information public of your own volition and accept that we may request that you remove such data from the Platform.
5. Receipts of personal data
dotte transfers or shares personal data with service providers only insofar as necessary and allowed in accordance with applicable laws. In addition, we appoint the following service providers that, as a result, receive personal data as recipients of data.
We constantly conduct and improve technical maintenance of the Platform to protect the security and confidentiality of personal data we process and to perform certain business-related functions that help make our services available and functional. For this reason, we transfer your profile data to service providers which provide cloud and hosting services, IT security, maintenance and technical services, communications services.
Where possible, personal data resides within the UK territory but may be transferred to, and stored at, a destination outside the European Economic Area (EEA). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. We will take all reasonable steps to ensure that your data is treated securely, in accordance with this privacy statement.
We have taken steps to ensure all personal data is provided with adequate protection and that all transfers of personal data outside the EEA are done lawfully. Where we transfer personal data outside of the EEA to a country not determined by the European Commission as providing an adequate level of protection for personal data, the transfers will be under an agreement which covers the EU requirements for the transfer of personal data outside the EU.
The following service providers are established outside the European Economic Area, which may result in your data being transferred outside the European Economic Area.
We transfer personal data to attorneys, attorney assistants, notaries, bailiffs, auditors, accountants, bookkeepers, debt collectors, consultants, translation agencies, IT service providers, insurance companies, archiving services that provide services to dotte.
The Platform is designed to help you interact with other users of the Platform. As a result of this some of the information generated through the Platform is shared with other users of the Platform as described below.
1. User profile
When you create an account on the Platform a user profile will be generated for you that makes the following information publicly available: user name, city location, details about the items you are selling. If you add any of the following information to your profile this will also be made publicly available: profile picture, profile description and website address.
2. Item listings
When you list an item for sale on the Platform information you add to the listing will be made publicly available such as the item photograph, price, item description, accepted payment method and delivery options. Any comments or likes other users add to your item listing will also be made publicly available as well as any reply comments or images you post. Other users may also share a link to an item they have bought from you via the Platform on other social media channels which link to the Platform, but this will not result in any information that was not already public, being made public.
3. Information about your activity on the Platform
Some of your activities on the Platform are public by default. These activities are when you follow a user, or a user follows you, when you comment on or like an item, when you list an item for sale, when your item is sold, or when you purchase an item.
4. Information that cannot identify you
6. Your marketing preferences
6.1 Email: From time to time we may contact you by email with information about our products and services. If you do not want us to contact you by email, you can change your email marketing preferences by emailing us at [email protected] and letting us know that you do not want to receive marketing emails from us. You can also unsubscribe from our marketing emails by clicking on the unsubscribe link in the emails we send to you.
6.2 Push notifications: If you give us permission in your device settings to send push notifications, we will send you these notifications from our Platform. You can change your push notification settings at any time in your device settings or via the dotte App.
7. Advertising and third party websites
We or our advertising partners may show advertisements to you on the Platform or on other websites or platforms..
To do this we or our advertising partners may collect information about how you use the Platform or the types of other web pages, app, content and ads you, or others who are using the device you connect to this Platform, interact with, visit or view.
The information collected might also include the IP address of the device you connect to the Platform.
Such data may be exchanged between us and our advertising partners to measure the success of advertising campaigns.
We or our advertising partner use the information that is collected to make sure adverts you see either on the Platform or other platforms (where our partner has advertising space) are more relevant to you. We may also share this type of data with our advertising partners to help measure how successful our advertising has been.
The techniques our advertising partners use do not use obvious identifying information such as name, address, email address or telephone number. This information is used to recognise the device you are using but not to identify you as a named individual.
We may share certain information with third party platforms such as Meta, TikTok and Google to enable us to better target our advertising on those third party platforms to users of our Platform who are also users on those platforms, or to individuals on those platforms that may be similar to users of our Platform. In addition, we may also use information we collect via the Platform for the purposes of our advertising on third party platforms. In those circumstances, we may share certain information with third party platform providers which allows us to better target our advertising to users on those third party platforms. Any third party platforms will also have their own privacy policies which you should read. We obtain your consent before doing so where applicable laws require us to obtain your consent or rely on legitimate interest. Please contact [email protected] to opt out of such sharing. We may ask you to provide some information to verify your identity before we stop sharing your data with our advertising partners.
Typically cookies and similar technologies are used to provide this type of advertising. You can find out more about cookies and how to manage their use by reading our Cookies Policy.
You can also find out more about this type of advertising from www.youronlinechoices.com.
8. How long do we hold data for?
We retain the personal data processed by us in a live environment for as long as is considered necessary for the purpose(s) for which it was collected (including as required by applicable law or regulation, typically 6 years).
In addition, personal data may be securely archived with restricted access and other appropriate safeguards where there is a need to continue to retain it.
9. Sharing personal data
We will only share personal data with others when we are legally permitted to do so. When we share data with others, we put contractual arrangements and security mechanisms in place to protect the data and to comply with our data protection, confidentiality and security standards.
Personal data held by us may be transferred to:
• Third party organisations that provide applications/functionality, data processing or IT services to us. We use third parties to support us in providing our services and to help provide, run and manage our internal IT systems. For example, providers of information technology, cloud based software as a service providers, identity management, website hosting and management, data analysis, data back-up, email service providers, security and storage services.
Occasionally, we may receive requests from third parties with authority to obtain disclosure of personal data, such as to check that we are complying with applicable law and regulation, to investigate an alleged crime or to establish, exercise or defend legal rights. We will only fulfil requests for personal data where we are permitted to do so in accordance with applicable law or regulation.
10. Individuals rights
Individuals have certain rights over their personal data and data controllers are responsible for fulfilling these rights as follows:
- Individuals may request access to their personal data held by us as a data controller.
- Individuals may request us to rectify personal data submitted to us or, where appropriate, contact us via the relevant website registration page or by amending the personal details held on relevant applications with which they registered.
- Individuals may request that we erase their personal data
Where we process personal data based on consent, individuals may withdraw their consent at any time by contacting us or clicking on the unsubscribe link in an email received from us.
Individuals may have other rights to restrict or object to our processing of personal data and the right to data portability.
Individuals may request information about, or for human intervention into, any automated data processing that we may undertake.
- Individuals have the right to opt-out of behavioural analytics: If you do not want us to conduct behavioural analytics for the purposes of dotte’s internal algorithm used to display relevant sellers and items to you or to display your items to the most relevant potential buyers, you must close your dotte account and cease using our Platform. This is because it is essential to dotte to suggest the right items and sellers to you and to display your items to the right buyers which we can only fulfil by learning about your tastes and preferences and the types of products you list. We may have access to your personal data for a short period of time after your account has been closed.
If you wish to exercise any of these rights, please contact us at [email protected]
11. Our policy towards children
dotte LTD is a General Audience Platform and our Platform is only intended for use by persons aged 18 and over.
The Platform is not directed to persons under 18 and we do not knowingly collect personal information from minors under 18. Minors under 18 years of age are prohibited from providing any personal information to the Platform. If you become aware that your child has provided us with personal information without your consent, then please contact us using the details below so that we can take steps to remove such information and terminate the child’s account.
12. Information about children
As set forth above, the Platform allow (but do not require) users to submit information about their children. Such information may include your child’s or children’s name(s), age(s), size(s), gender(s) and photos of your child or children. Submitting information about your child or children is always optional. We urge you to exercise caution when submitting information about your child. If you choose to submit your child’s name or a photo of your child, we may use that information to customise your experience in using the Platform (such as by displaying the child’s name and photo in your private profile or in connection with search results), but we do not display or disclose your child’s name or photos of your child to other users or members of the public. If you choose to submit other information about your child (i.e., age, size or gender), we may display such information on your public profile (which may be accessed by other users and visitors of the Platform) or otherwise use such information to facilitate your discussions and transactions with other users. You may adjust your sharing preferences with respect to information about your child’s age, size and gender in the account settings page of the App.
If you want to complain about our use of personal data, please send an email with the details of your complaint to [email protected] We will look into and respond to any complaints we receive.
You also have the right to lodge a complaint with the UK data protection regulator, the Information Commissioner’s Office (“ICO”). For further information on your rights and how to complain to the ICO, please refer to the ICO website https://ico.org.uk/concerns
13. Data Controller and contact information
The data controller for dotte Ltd and its associated businesses is DOTTE LTD; the limited partnership registered in England under registration no. 12671379 and with its registration address at PO Box 75987, London, E11 9GX.
If you have any questions about this privacy statement or how and why we process personal data, please contact us at [email protected]
14. Changes to our privacy statement
This privacy statement was last updated on 7th November 2022