Contents:
1. Introduction
2. What and who this policy applies to
3. Personal data we collect about you
4. Sensitive Data
5. Location services/data
6. How your personal data is collected
7. How and why we use your personal data
8. Marketing
9. Who we share your personal data with
10. How long your personal data will be kept
11. Transferring your personal data out of the UK
12. Your rights
13. Keeping your personal data secure
14. How to complain
15. Changes to this privacy policy
16. How to contact us
1. INTRODUCTION
This Privacy Policy is provided by Etikbee Ltd, a company registered in England and Wales under company number: 15324395 with its registered office at 71-75 Shelton Street, Covent Garden, London, WC2H 9JQ (‘we’, ‘our’ or ‘us’) and sets out how we process personal data in connection with our business, including the provision of our website https://www.etikbee.com and the services we offer, including the Etikbee Platform through our website (Services).
We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on how and why we collect, store, use and share any information relating to you (your personal data).
It also explains your rights in relation to your personal data and how to contact us or the relevant regulator in the event you have a complaint. Our collection, storage, use and sharing of your personal data is regulated by law, including under the UK General Data Protection Regulation (UK GDPR).
We are the controller of personal data obtained via the Services, meaning we are the business legally responsible for deciding how and for what purposes it is used.
2. WHAT AND WHO THIS POLICY APPLIES TO
This privacy policy relates to your use of the Services only and applies to the following people:
- Site visitors – if you browse our website, we will collect and process your personal data in connection with your interaction with us and the website;
- Customers - if you register an account with us to purchase or hire goods, or engage services via our website, we may collect your personal data in connection with facilitating the supply of goods or services to you from merchants;
- People who contact us with enquiries - if you contact us with an enquiry through our website, submit a complaint or provide any feedback to us, we will collect and process your personal data in connection with your interaction with us and the website;
- People who work for our merchants - if you work for one of our merchants (being individuals, companies and charity businesses) and have responsibility for registering an account with us to list goods and/or services with us or handle orders within your business, we will process your personal data in connection with your business’s relationship with us.
The Services may link to or rely on other apps, websites, APIs or services owned and operated by us or by certain trusted third parties to enable us to provide you with Services. These other apps, websites, APIs or services may also gather information about you in accordance with their own separate privacy policies. For privacy information relating to these other apps, websites or services, please consult their privacy policies as appropriate. For more information see the section ‘Who we share your personal data with’ below.
3. PERSONAL DATA WE COLLECT ABOUT YOU
The personal data we collect about you depends on the particular activities carried out through the Services. We will collect and use the following personal data about you:
| Category of data | Further information about the type of personal data we collect |
|---|---|
| Customer account data |
When you set up a customer account and use the Services, we may collect the following information from you:
|
| Merchant account data |
When you set up a merchant account and use the Services, we may collect the following information from you:
|
| Identity and contact data |
When you otherwise interact with us e.g. visiting our website or enquiring about the Services, we may collect the following information from you:
|
| Messages data |
Our website allows you to send a message via the website for a variety of reasons e.g. questions about a product or service. When you do so, we may collect the following information from you:
|
| Transaction data |
When you complete a transaction via our website, we may collect certain information from you related to the transaction, including:
|
| Marketing and communications data |
When you sign up to receive marketing communications or are an existing customer of ours, we may collect information about your preferences, including:
|
| Usage data |
When you access our Services, we may automatically collect certain information about your device and usage. Usage data may include:
|
| General location data |
When you permit the collection of location data, we may collect details of your location, which may include:
|
If you do not provide personal data we ask for where it is required, it may prevent us from providing services and/or the Services to you.
We collect and use this personal data for the purposes described in the section ‘How and why we use your personal data’ below.
4. SENSITIVE DATA
Sensitive personal data (also known as special category data) means information related to personal data revealing racial or ethnic origin; political opinions; religious or philosophical beliefs; trade union membership; genetic data; biometric data (where used for identification purposes); data concerning health; data concerning a person’s sex life; and data concerning a person’s sexual orientation.
Please note that we do not knowingly or intentionally collect sensitive personal data or information about criminal convictions from individuals and that you should not submit sensitive data to us.
If, however you do submit sensitive data to us, such as if you make this sensitive data available to other users of the Services (such as by publishing it through any forum feature we may make available from time to time) we will assume that you have purposefully made any such sensitive data manifestly public.
5. LOCATION SERVICES/DATA
The Services will request your consent to use location services to identify your location each session (i.e. each time the Services is opened or has been placed in the background for more than 30 seconds). We require access to that data in order to provide you with location-based services, such as radius search and other content that is personalised on the basis of your general location data.
If you do not provide your consent, you may use the Services but that will mean the location-based features of the Services will not be available. To withdraw your consent at any time you can turn off the localisation permissions for our app on your device.
The location services in the Services will not operate unless location services/data are generally enabled on your device. You may disable such functionality at any time by turning your device’s location on “off” using the device’s settings app.
There is also location field functionality within the Services where you can optionally decide to add the city or postcode from where you want to see the closest listing of products – where you add a location via this location field, we will assume that you have purposely provided this location data to us which we will treat in accordance with this policy.
6. HOW YOUR PERSONAL DATA IS COLLECTED
We collect personal data from you directly; for example, when you create an account for the Services, contact us directly, make submissions via the Services when a forum element is available, or indirectly, such as your activity while using the Services.
We also collect certain information automatically related to your use of the Services. Some of this information may be collected using cookies and similar tracking technology; while such data may not always be personal data as defined at law in all cases we will assume it is and treat it in accordance with this policy as if it were. Please refer to our Cookies Policy for further information.
We may also obtain personal data about you from third parties, including service providers who may collect information on our behalf; for example, companies who support our website and Services. Any information we receive from third parties will be treated in accordance with this policy. We are not responsible for the accuracy of any information provided to us by third parties and we are not responsible for any third party’s policies.
7. HOW AND WHY WE USE YOUR PERSONAL DATA
Under data protection law, we can only use your personal data if we have a proper reason, e.g.:
- where you have given consent
- to comply with our legal and regulatory obligations
- for the performance of a contract with you or to take steps at your request before entering into a contract, or
- for our legitimate interests or those of a third party
A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests. We will carry out an assessment when relying on legitimate interests, to balance our interests against your own. You can obtain details of this assessment by contacting us (see ‘How to contact us’ below).
The table below explains what we use your personal data for and why.
| What we use your personal data for | Our reasons |
|---|---|
| Create and manage your account with us (e.g. we collect certain information in order to set up your account with us and allow you to interact with other users of the website). | To perform our contract with you or to take steps at your request before entering into a contract. |
| Providing services and/or the functionalities of the Services to you (e.g. to facilitate transactions between customers and merchants via our website). |
Depending on the circumstances:
|
| To enforce legal rights or defend or undertake legal proceedings (e.g. in connection with civil, commercial, criminal or consumer protection matters, regulatory matters, corporate and taxation matters, or to exercise our legal rights in relation to a violation of any of our terms or policies). |
Depending on the circumstances:
|
| Communications with you not related to marketing (e.g. we use certain information to send you administrative or account-related information including about changes to our terms or policies or changes to the services or other important notices). |
Depending on the circumstances:
|
| Protect the security of systems and data (e.g. taking steps to detect, investigate and otherwise protection our community against spam, abuse, harassment, intellectual property infringement, crime, suspected fraud, suspected violations of our terms and safety and security risks of all kinds) | To comply with our legal and regulatory obligations we may also use your personal data to ensure the security of systems and data to a standard that goes beyond our legal obligations, and in those cases our reasons are for our legitimate interests or those of a third party, i.e., to protect systems and data and to prevent and detect criminal or otherwise harmful activity that could be damaging for you and/or us. |
| Operational reasons, such as improving efficiency, training, and quality control or to provide support to you. | For our legitimate interests or those of a third party, i.e., to be as efficient as we can so we can deliver the best service to you. |
| Statistical analysis to help us manage our business (e.g. in relation to our performance, customer base, app and functionalities and offerings or other efficiency measures). | For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service to you and improve and develop our website and Services. |
| Marketing and advertising (please see the ‘Marketing’ section below for additional information). |
Depending on the circumstances:
|
| Updating and enhancing user records. |
Depending on the circumstances:
|
| To comply with our legal and regulatory obligations (e.g. to verify your identity, in response to lawful requests by public authorities (including tax authorities) and to meet law enforcement requirements). |
Depending on the circumstances:
|
| To share your personal data with members of our group and third parties in connection with a significant corporate transaction or restructuring (e.g. including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency). |
Depending on the circumstances:
|
See ‘Who we share your personal data with’ for further information on the steps we will take to protect your personal data where we need to share it with others.
8. MARKETING
We intend to send you email marketing to inform you of our services such as promotions.
We will always ask you for your consent before doing sending you marketing communications, except where you have explicitly opted-in to receiving email marketing from us in the past or except where you were given the option to opt-out of email marketing when you initially signed up for your account with us and you did not do so.
You will have the right to opt out of receiving marketing communications at any time by using the ‘unsubscribe’ link included in all marketing emails you may receive from us.
We will always treat your personal data with the utmost respect and never sell or share it with other businesses for marketing purposes.
For more information on your right to object at any time to your personal data being used for marketing purposes, see ‘Your rights’ below.
9. WHO WE SHARE YOUR PERSONAL DATA WITH
We routinely share personal data with service providers we use to help us run our business or provide the services or functionalities in the Services, such as developers and cloud storage providers, and merchants who use our website to provide goods or services to you.
We only allow service providers to handle your personal data if we are satisfied they take appropriate measures to protect your personal data. We also impose contractual obligations on service providers to ensure they can only use your personal data to provide services to us and to you.
We or the third parties mentioned above may occasionally also need to share your personal data with:
- external auditors, e.g. in relation to the audit of our accounts and our company - the recipient of the information will be bound by confidentiality obligations
- professional advisors (such as lawyers and other advisors) - the recipient of the information will be bound by confidentiality obligations
- law enforcement agencies, courts or tribunals and regulatory bodies to comply with legal and regulatory obligations
- other parties in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency - usually, information will be anonymised but this may not always be possible, however, the recipient of the information will be bound by confidentiality obligations
If you would like more information about who we share our data with and why, please contact us (see ‘How to contact us’ below).
We will not share your personal data with any other third party.
10. HOW LONG YOUR PERSONAL DATA WILL BE KEPT
We will keep your personal data for as long as you have an active account with us and for a period of up to 6 years thereafter to comply with any accounting or legal obligations including in the event of the pursuit or defence of legal claims. Once you have closed your account with us, we will move your personal data to a separate database so that only key stakeholders in our business on a ‘need to know basis’ have access to such data.
Following the end of the of the aforementioned retention period, we will delete or anonymise your personal data.
11. TRANSFERRING YOUR PERSONAL DATA OUT OF THE UK
At this point in time, we do not transfer your personal data outside of the UK. If this changes, we would comply with applicable UK laws designed to ensure the continued protection and privacy of your personal data. Any updated destinations to which we send your personal data, would be indicated in the present section and notified to you in accordance with the section on ‘Changes to this privacy policy’ below.
Furthermore, under UK data protection laws, we can only transfer your personal data to a country outside the UK where: the UK government has decided the particular country ensures an adequate level of protection of personal data (known as an ‘adequacy regulation’) further to Article 45 of the UK GDPR; there are appropriate safeguards in place, together with enforceable rights and effective legal remedies for you; or a specific exception applies under relevant data protection law.
Accordingly, if we were to start transferring your personal data from the UK to:
- The EEA: we would rely on the adequacy finding granted by the UK to the EU under the Withdrawal Agreement to do; for any transfers from the EU to the UK, we would rely on the adequacy regulation granted to the UK under the Adequacy Decision.
- Any country located outside the UK/EEA: we would rely an appropriate safeguards under the UK GDPR, such as by including the relevant Standard Contractual Clauses in our data processing agreements.
In the event we could not or choose not to continue to rely on either of those mechanisms at any time we would not transfer your personal data outside the UK unless we could do so on the basis of an alternative mechanism or exception provided by UK data protection law.
12. YOUR RIGHTS
You generally have the following rights, which you can usually exercise free of charge. For more information regarding these rights, please visit the ICO website here.
| Access to a copy of your personal data | The right to be provided with a copy of your personal data. |
| Correction (also known as rectification). | The right to require us to correct any mistakes in your personal data. |
| Erasure (also known as the right to be forgotten). | The right to require us to delete your personal data - in certain situations. |
| Restriction of use | The right to require us to restrict use of your personal data in certain circumstances, e.g. if you contest the accuracy of the data. |
| Data portability | The right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party - in certain situations. |
| To object to use |
The right to object:
|
| Not to be subject to decisions without human involvement |
The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you
We do not make any such decisions based on data collected by the Services. |
For further information on each of those rights, including the circumstances in which they do and do not apply, please contact us (see ‘How to contact us’ below). You may also find it helpful to refer to the guidance from the UK’s Information Commissioner on your rights under the UK GDPR.
If you would like to exercise any of those rights, please email us - see below: ‘How to contact us’. When contacting us please:
- provide enough information to identify yourself (e.g., your full name and username) and any additional identity information we may reasonably request from you, and
- let us know which right(s) you want to exercise and the information to which your request relates
13. KEEPING YOUR PERSONAL DATA SECURE
We have appropriate security measures to prevent personal data from being accidentally lost, or used or accessed unlawfully. We limit access to your personal data to those who have a genuine business need to access it.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.
14. HOW TO COMPLAIN
Please contact us if you have any queries or concerns about our use of your information (see below ‘How to contact us’). We hope we will be able to resolve any issues you may have.
You also have the right to lodge a complaint with the Information Commissioner.
The Information Commissioner can be contacted at https://ico.org.uk/make-a-complaint or telephone: 0303 123 1113.
15. CHANGES TO THIS PRIVACY POLICY
We may change this privacy policy from time to time. When we make significant changes we will take steps to inform you, for example via the Services or by other means, such as email.
16. HOW TO CONTACT US
You can contact us via the ‘Contact Us’ page on our website if you have any questions about this privacy policy or the information we hold about you, to exercise a right under data protection law or to make a complaint.
