Privacy Policy

PRIVACY POLICY – Updated & Published 24^th May 2018

Scope and Consent
This Privacy Notice describes our collection, use, disclosure, retention, and protection of your personal information. It applies to any Swapz site where this Privacy Notice appears in the footer, and to any Swapz application, service, or tool (collectively "Services") where this Privacy Notice is referenced, regardless of how you access or use them, including through mobile devices.

By using our Services or registering for an account with us, you are accepting our Terms of Use, this Privacy Notice and our Cookies Policy, and you are consenting to our collection, use, disclosure, retention, and protection of your personal information as described in this Privacy Notice.

You are contracting with Swapz (the data controller) which is responsible for the collection, use, disclosure, retention and protection of your personal information in accordance with our global privacy standards as well as applicable national laws. Swapz may transfer your personal information to third party processors in other countries including other members of the Swapz corporate family as described in this Privacy Notice. We may process and retain your personal information on our servers in the U.S. and elsewhere in the world where theirr data centres are located.

Personal Information
Personal information is information that can be associated with a specific person and could be used to identify that specific person whether from that data or from that data and other information that Swapz has or is likely to have access to. We do not consider personal information to include information that has been made anonymous or aggregated so that it can no longer be used to identify a specific person, whether in combination with other information or otherwise.

Changes to this Notice
We may amend this Privacy Notice at any time by posting an updated Privacy Notice with the amended terms on this site.

Collection
We collect, process, and retain personal information from you and any devices (including mobile devices) you may use when you: use our Services, register for an account with us, provide us information via a web form, update or add information to your account, participate in community chats, or dispute resolution, or when you otherwise correspond with us regarding our Services.

The personal information we collect includes the following:
Personal information you give us when you use our Services or register for an account with us

Any identifying information such as your name, addresses, telephone numbers or email addresses when you register for an account with us or conduct dealings or transactions with other members.

Buying or selling information you provide during a transaction, or other transaction-based content that you generate or is connected to your account as a result of a transaction you are involved in.

Other content that you may generate, or that is connected to your account and your use of our website including your use of the following website functions: My Account (My Listings, Messages, Homepage Preferences and Favourites, Saved Searches, My Details, Create Account), Posting a Listing or the Help section.

You may also provide us with your information by submitting a web form, updating or adding information to your account, through your participation in chats, dispute resolution, or when you otherwise correspond with us regarding our Services.

Additional information we are required or authorised by applicable national laws to collect and process in order to authenticate or identify you or to verify the information we have collected.

Personal information we collect automatically when you use our Services or register for an account with us

We also collect information about your interaction with our Services, your advertising preferences, and your communications with us. This is information we receive from the devices (including mobile devices) you use when you use our Services, register for an account with us, provide information on a web form, update or add information to your account, participate in chats, or dispute resolution, or when you otherwise correspond with us regarding our Services. This information can include some or all of the following: device ID or unique identifier, device type, ID for advertising, and unique device token.

Geo-location information, including location information from your mobile device. Keep in mind that most mobile devices allow you to control or disable the use of location services by any application on your mobile device in the device's 'Settings' menu.

Computer and connection information that can include some or all of the following: statistics on your page views, traffic to and from the sites, referral URL, ad data, your IP address, your browsing history, and your web log information.

Personal information we collect using cookies, web beacons, and similar technologies

We use cookies, web beacons, unique identifiers, and similar technologies to collect information about the pages you view, the links you click, and other actions you take on our Services, within our advertising or e-mail content. For more information about our use of these technologies and how to control them, see our notice on Cookie Policy at the foot of every page.

Personal information from other sources

We may supplement the personal information we collect with information from third parties as allowed by applicable national laws.

We may allow you to share information with social media sites, or use social media sites to create your account or to connect your account with the respective social media site. Those social media sites may give us automatically access to certain personal information retained by them about you (e.g., content viewed by you, content liked by you, and information about the advertisements you have been shown or may have clicked on, etc. You control the personal information you allow us to have access to through the privacy settings on the applicable social media site and the permissions you give us when you grant us access to your personal information retained by the respective social media site about you. By associating an account managed by a social media site with your account and authorizing us to have access to this information, you agree that we may collect, use and retain the information provided by these social media sites in accordance with this Privacy Notice.

If you give us personal information about someone else, you must do so only with their explicit and prior consent. You have to inform them how we collect, use, disclose, and retain their personal information according to our Privacy Notice.

Use and Retention
We use the personal information we collect to: provide and improve our Services, provide you with a personalized experience on our sites (especially, by offering you services and items that you may like), contact you about your account and our Services, provide you with customer service, provide you with personalized advertising and marketing, and detect, prevent, mitigate, and investigate fraudulent or illegal activities.

We retain your personal information as long as it is necessary and relevant for our operations. In addition, we may retain personal information from closed accounts to comply with national laws, prevent fraud, collect any fees owed, resolve disputes, troubleshoot problems, assist with any investigation, enforce our Terms of Use and take other actions permitted or required by applicable national laws.

We use the personal information we collect to: provide and improve our Services, to provide you with a personalized experience on our sites (especially, by offering you services and items that you may like), to contact you about your account and our Services, to provide you customer service, to provide you with personalized advertising and marketing, and to detect, prevent, mitigate and investigate fraudulent or illegal activities. We may use and retain your personal information as follows:

Provide, improve, and personalize our Services
Provide access to and use of our Services.

Offer you site content that includes items and services that you may like.

Keep track of functions you use within the My Account section of the Service and to manage your ads.

Give you access to your internal messages and other features.

Customize, measure, and improve our Services.

Provide other services requested by you as described when we collect the information.

We may use geo-location information to provide you with location based services (such as advertising, search results, and other personalized content).

Contact you about your account and provide you customer service
Contact you to notify you regarding your account, to troubleshoot problems with your account, to resolve a dispute, to collect fees or monies owed, to poll your opinions through surveys or questionnaires, or as otherwise necessary to provide you customer service.

Contact you as necessary to enforce our Terms of Use, applicable national laws, and any agreement we may have with you.

For these purposes we may contact you via email, telephone, text messages, and postal mail.

Personalize our advertising and marketing communications
Personalize, measure, and improve our advertising based on your advertising customization preferences.

Deliver targeted marketing, service updates and promotional offers based on your communication preferences.

Prevent, detect, mitigate, and investigate fraudulent or illegal activities
Prevent, detect, mitigate, and investigate fraud, security breaches, potentially prohibited or illegal activities.

Enforce our Privacy Notice, Terms of Use or other policies.

Choice
You have a choice about how we use your personal information to communicate with you, to send you marketing information, how we provide you with customized and relevant advertising, and whether you want to stay signed into your account.

Communication preferences
You can control the methods by which we may contact you in My Account. There, you can also change your password or update your profile information.

MarketingIf you do not wish to receive marketing communications from us, you can unsubscribe in My Account > My Account > Settings > Email Notifications.

Advertising
If you do not wish to participate in our advertising personalization programs, you can opt-out by following the directions provided within each applicable advertisement. The effect of an opt-out will be to stop personalized advertising, but it will still allow the collection of information for certain purposes such as usage, research, analytics and internal online services operation purposes). In addition to that, we do not allow third parties to track or collect your personal information on our sites for their own advertising purposes without your consent.

Signed in
When you sign into your account on our Services, we may give you the option to stay signed in to your account for a certain period of time. If you are using a public or shared computer, we encourage you not to choose to stay signed in. You or any other user of the computer/browser you signed in on will be able to view and access most parts of your account and take certain specific actions during this signed in period without any further authorization. The specific actions and account activities that you or any other user of this computer/browser may take include:

Listing or enquiring about an ad

Manage your ads

View My Account page

View your profile page

Send messages to other members

If you attempt to change your password, update any other account information or attempt other account activity beyond those listed above, you may be asked to enter your password.

You can typically end your signed in session by either signing out and/or clearing your cookies. If you have certain browser privacy settings enabled, simply closing your browser may also end your signed in session. If you are using a public or shared computer you should sign out and/or clear your cookies when you are done using our Services in order to protect your account and your personal information.

Withdraw consent
If you withdraw your consent for the use or disclosure of your personal information for purposes set out in this Privacy Notice you may not have access to all our Services and we might not be able to provide you all of the Services and customer support offered to our users and authorized under this Privacy Notice and our Terms of Use.

Access
We take steps to ensure that the personal information we collect is accurate and up to date, and that you have the ability to access and make corrections to it.

Once you make a public posting, you may not be able to change or remove it. Upon your request, we will close your account and remove your personal information from view as soon as reasonably possible, based on your account activity and in accordance with applicable national laws.

You can update or correct your personal information on your own Swapz account or if you do not have a Swapz account.

You can request a copy of the personal information that Swapz holds about you by contacting us at legal@swapz.co.uk and we will let you know if any fees apply. Where you have a statutory right to request access or request the modification or erasure of your personal information, we can still withhold that access or decline to modify or erase your personal information in some cases in accordance with applicable national laws but will give you reasons if we do so.

Disclosure
We may disclose your personal information to other members of the Swapz corporate family or to third parties. This disclosure may be required for us to provide and to provide you access to our Services, to comply with our legal obligations, to enforce our Terms of Use, to facilitate our marketing and advertising activities, or to prevent, detect, mitigate, and investigate fraudulent or illegal activities related to our Services. We minimize the amount of personal information we disclose to what is directly relevant and necessary to accomplish the specified purpose. As stated above, we do not disclose your personal information to third parties for their marketing and advertising purposes without your consent.

We may disclose your personal information to the following parties and for the following purposes.

Service Providers and financial institutions partners
Third party service providers who help us to provide our Services, payment processing services, assist us in providing customized advertising, to assist us with the prevention, detection, mitigation, and investigation of potentially illegal acts, violations of our Terms of Use, fraud and/or security breaches, bill collection, affiliate and rewards programs, co-branded credit cards and other business operations.

Law enforcement, legal proceedings, and as authorized by law
To comply with our legal requirements, enforce our Terms of Use, respond to claims that a listing or other content violates the rights of others, or protect anyone's rights, property or safety.

To law enforcement or governmental agencies, or authorised third parties, in response to a verified request relating to a criminal investigation or alleged or suspected illegal activity or any other activity that may expose us, you, or any other of our users to legal liability. We will only disclose information we deem relevant to the investigation or inquiry, such as name, address, city, state, postcode, telephone number, email address, User ID history, IP address, fraud complaints, offer and listing history.

To enquiries relating to Intellectual Property matters, if we in our sole discretion deem necessary or appropriate in connection with an investigation of fraud, intellectual property infringement, piracy, or other unlawful activity. In such events, we may disclose contact details including the member's name, street address, city, , postcode, country, phone number, email address and company name to the aggrieved party.

To third parties involved in a legal proceeding, if they provide us with a subpoena, court order or substantially similar legal procedure, or we otherwise believe in good faith that the disclosure of information is necessary to prevent imminent physical harm or financial loss or to report suspected illegal activity.

We may transfer your information to data processors outside the European Economic Area in accordance with applicable data protection laws and regulations. In some of these countries, the privacy and data protection laws may differ from those in the country where you live.

Change of Ownership
If we were to merge with or be acquired by another company, we may share information with them in accordance with applicable global privacy standards. Should such an event occur, we will require that the new combined entity follow this Privacy Notice with respect to your personal information. If your personal information will be collected, used, disclosed, or retained for any purposes not covered in this Privacy Notice, you will receive prior notification of the processing of your personal information for the new purposes.

Security
We protect your information using appropriate technical and administrative security measures to reduce the risks of loss, misuse, unauthorized access, disclosure and alteration. Some of the safeguards we use are firewalls and data encryption and information access authorization controls.

If you believe your account has been abused, please contact legal@swapz.co.uk

Important Information
This section describes some additional important information related to your use of our Services.

There are just a few more pieces of important privacy information related to your use of our Services that we need to cover:

When you share your personal information on our sites or applications - what happens?
Other users may have access to the information you share on Swapz including feedback, ratings and associated comments and any information you chose to share in your profile or your collections.

Your User ID is displayed throughout Swapz and is available to the public. It is connected to all of your Swapz activity. Notices sent to other users about suspicious activity and notice violations on our sites refer to User IDs and specific items. So if you associate your name with your User ID, the people to whom you have revealed your name will be able to personally identify your Swapz activities.

To help protect your privacy, we allow only limited access to other users' contact, shipping and other information as necessary to facilitate your dealings. However, when users are involved in a transaction, they have access to each other's name, User ID, telephone and other contact and shipping information.

How you should use the information you receive on Swapz
When you are in a transaction with another user we may provide you with the personal information of the other user (such as his/her name, account ID) to complete the transaction. We encourage you to inform the other user about your privacy practices and respect his/her privacy. In all cases, you must give the other user a chance to remove himself/herself from your database and give him/her a chance to review what information you have collected about them.

You may use the personal information that you have access to only for Swapz transaction-related purposes, or for other services offered through Swapz (such as fraud complaints, and member to member communications), and for purposes expressly consented by the user to whom the information relates. Using personal information of other users that you have access to for any other purpose constitutes a violation of our Terms of Use.

Unwanted or threatening email
We do not tolerate abuse of our Services. You do not have permission to add other users to your mailing list (email or postal), call, or send them text messages for commercial purposes, even if this user has dealt with you, unless the user has given their explicit consent. Sending unwanted or threatening email messages is against our Terms of Use.

Children's Privacy
Our websites are general audience websites, and our Services are not intended for individuals under the age of 18. We do not knowingly collect personal information from users in this age group.

Third Party Privacy Practices
This Privacy Notice addresses only the use and disclosure of personal information we collect from you. If you disclose your information to others, or if you are directed to a third party website, their privacy notices and practices will apply.

We cannot guarantee the privacy or security of your information once you provide it to a third party and we encourage you to evaluate the privacy and security policies of your trading partner before entering into a transaction and choosing to share your information. This is true even where the third parties to whom you disclose personal information are bidders, buyers or sellers on our sites.

Questions or Complaints
If you have a question or a complaint about this Privacy Notice or information handling practices, you can contact us by writing to: Swapz Ltd (Privacy), Summit House, 170 Finchley Road, London, NW3 6BP, UK.

For any other questions or complaints please use the HELP link on the swapz.co.uk website.

Swapz Ltd ("Swapz", "we" or "us" or "our"), Summit House, 170 Finchley Road, London, NW3 6BP, UK, registered in England and Wales with number 4304506 is the data controller and operator of Swapz.Ltd ("the Site").