Privacy Policy

INTRODUCTION

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”) are committed to protecting and respecting the personal data that we hold. 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.​

SECURITY

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.​

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 site, 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 site; 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.

DATA THAT 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 (“Service”). You can search for items, log-in to your profile and view other profiles via the website. The above information will also be visible to search engines, including but not limited to the photos that you post. When you use our Service we will collect and process certain information about you. The exact data held will depend on the services to be provided.

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.​

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 Site and Service. This can include information you provide when you register to use the Service, complete a form, list an item, subscribe to our mailing lists or other marketing communications or take an action on the Service (such as when you comment on or like an item, perform a search, communicate with other users of the Service, or engage in a transaction).​

We also collect information about the pages you look at on our Site and Service and/or the device you use to access the Site and Service.​

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.​

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 Service and about queries, issues or concerns you or other users have and to send you marketing communications. As a necessary part of participating in the Service, you will also share your contact details with any buyer or seller you deal with through the Service. 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 Service or use of your account.

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 to 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, 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.​

3. Payment and transaction information: We keep records of the products you buy, sell or exchange though the Service 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 Service. 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, delivery address, email address and phone number 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 authorize 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 Service. 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. Your relationships with other users: We may collect information regarding other users that you are following on our Service 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 Service.

5. Website and app 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, for example through Facebook 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 user name 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.

​6. Your preferences: We hold information about the preferences you set for notifications, marketing communications and how our site is displayed or what content is displayed to you through our Service. We will use your preference settings for the purpose of providing notifications, sending marketing communications and displaying our Service in accordance with your choices.

7. Information about how you connect to and use our Site and Service: We collect information about how you use our Site and Service such as the pages you view on our Site and Service, the time you access our Site and Service and how long you use it for, the website from where you came to our Site or go to after leaving our Site (if applicable) and any selections and choices you make when using our Site and Service. We also collect information about any items you have searched for, listed, purchased, sold, bookmarked, liked or shared on the Site and Service.

We, and our third party analytics providers, process this data for the following purposes:

8. Information about your device: We collect information about the computer, tablet, smartphone or other electronic device you use to connect to our Service. This information can include details about the type of device, unique device identifying numbers, operating systems, browsers and applications connected to our Service 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 Service 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 Service to you on your device and in the legitimate interests of ensuring that banned users are not able to access the Service by creating a new account.​

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 Service 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.​

10. Information provided by other users: Sometimes, other users of our Service 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 they send to you. Other users may also share information relating to an item they have bought from you on the Service on other social media channels which link to the Service, but this will not result in any information that was not already public, being made public. Where users of our Service want to invite you to use our Service 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.

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 Service 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.

11. All personal information: We will use all the personal information we collect to monitor and improve our Service, App and Site and our procedures and processes. We also use the personal information we collect to help us develop new products and services. Our use of your personal information in this way will not result in information that was not previously publicly available being made public on our Service. We also use personal information we maintain about you to resolve disputes between users, to provide user support, to troubleshoot problems and enforce our Terms of Service and policies, including this Privacy Policy.

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 Service not to supply us or any other user with any sensitive personal information, given the nature of the Service and that user profiles and comments are visible by other users. Where you do provide sensitive personal information to us on the Service 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 Service.

YOUR MARKETING PREFERENCES​

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.

ADVERTISING AND THIRD PARTY WEBSITES​

We or our advertising partners may show advertisements to you on the Service or on other websites.

To do this we or our advertising partners may collect information about how you use the Service or the types of other web pages, content and ads you, or others who are using the device you connect to this Service, interact with, visit or view.

The information collected might also include the IP address of the device you connect to the Service.​

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 Service or other websites or apps (where our partner has advertising space) are more relevant to you.

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.

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.

INFORMATION AVAILABLE TO OTHER USERS VIA THE SERVICE

The Service is designed to help you interact with other users of the Service. As a result of this some of the information generated through the Service is shared with other users of the Service as described below.​

1. User profile
When you create an account on the Service 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 Service 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 Service on other social media channels which link to the Service, but this will not result in any information that was not already public, being made public.

3. Information about your activity on the Service
Some of your activities on the Services 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.

Information that cannot identify you

We do not disclose information about identifiable individuals to anyone else except as set out in this Privacy Policy and subject to applicable data protection legislation. We may provide third parties with aggregate statistical information and analytics about users of the Service but we will make sure that no one can be identified from this information before we disclose it.

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.​

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, security and storage services.

• Third party organisations that otherwise assist us in providing goods, services or information. In particular, we may share the personal information you provide to us with shipping providers (where you have chosen to use their services in relation to any items you sell), identity verification service providers (in order to verify your access to the Service and prevent fraudulent activity on your account), moderators who monitor our Service (to ensure our Terms of Service are being adhered to that no criminal activity is taking place using our Service), third party payment providers (for the purposes of processing any sales transactions you have consented to) and Site or Service analytics providers. In some cases, our service providers may collect information directly from you (e.g. if they are asked to conduct a survey for us), and in these cases you will be notified of the involvement of the service provider, and all information disclosures you make will be strictly optional. If you provide additional information to a service provider directly, then their use of your information is governed by their applicable privacy policy.

• dotte ltd and group businesses.

• Auditors and other professional advisers.

• Law enforcement or regulatory agencies or those required by law or regulations.

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.​

LOCATIONS OF PROCESSING

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.

INDIVIDUAL’S 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 Service. 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 do by learning about your tastes and preferences and the types of products you list.

If you wish to exercise any of these rights, please contact us at [email protected]

OUR POLICY TOWARDS CHILDREN

dotte LTD is a General Audience Site and our Service is only available to persons aged 13 and over.

​The Service is not directed to persons under 13 and we do not knowingly collect personal information from children under 13. Children under 13 years of age are prohibited from providing any personal information to the Site. 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.

INFORMATION ABOUT CHILDREN

As set forth above, the Services 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 Services (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 Services) 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.

COMPLAINTS

We hope that you won’t ever need to, but if you do 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

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]

CHANGES TO OUR PRIVACY STATEMENT

​Updates to this privacy statement will appear on this website. This privacy statement was last updated on 10th September 2020