FINDS World Limited – FINDs Application Privacy Policy

CONSENT TO INSTALLATION OF THE APP

Under data protection laws, we are required to provide you with certain information about who we are, how we process your personal data and for what purposes, and your rights in relation to your personal data.

Before installation of this App, please indicate your consent to our processing of your personal data (including your name, contact details, financial and device information) as described in this policy.

YES I consent to the installation of the App for the purposes of gaining access to and use of FINDs, a second-hand electronic fashion marketplace, and any associated processing of my personal data in accordance with this policy.

NO I do not consent to the installation of the App.

HOW YOU CAN WITHDRAW CONSENT

Once you provide consent by selecting “YES”, you may change your mind and withdraw consent at any time by contacting us by email at [email protected] but that will not affect the lawfulness of any processing carried out before you withdraw your consent.

CONSENT TO PROCESSING LOCATION DATA

YES I consent to processing of my Location Data (including details of my current location disclosed by GPS technology).

NO I do not consent to processing of my Location Data and location-enabled Services are disabled in my settings.

1. INTRODUCTION 

1.1 FINDS World Limited (collectively referred to as “we”, “us” or “our” in this policy) are committed to protecting your personal data and respecting your privacy.

1.2 This policy (together with our Terms and Conditions (“Terms”) and any additional terms of use incorporated by reference into the Terms, (together our “Terms of Use”) applies to your use of:

  • FINDs mobile and/or web-based application software (the “App”) once you have downloaded or streamed a copy of the App onto your mobile telephone, handheld device or computer (together the “Device”); and

  • any of the services accessible through the App (the “Services”) unless the Terms states that a separate privacy policy applies to a particular Service, in which case that privacy policy only applies. This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. The App is not intended for children and we do not knowingly collect data relating to children. Please read the following carefully to understand our practices regarding your personal data and how we will treat it.

This policy is provided in a layered format so you can click through to the specific areas set out below. Alternatively, you can download a pdf version of the policy here:

IMPORTANT INFORMATION AND WHO WE ARE

THE DATA WE COLLECT ABOUT YOU HOW IS YOUR PERSONAL DATA COLLECTED?

HOW WE USE YOUR PERSONAL DATA

DISCLOSURES OF YOUR PERSONAL DATA

INTERNATIONAL TRANSFERS

DATA SECURITY

DATA RETENTION

YOUR LEGAL RIGHTS

2. IMPORTANT INFORMATION AND WHO WE ARE

2.1 We are the controller and responsible for your personal data.

2.2 We have appointed a data protection officer (the “DPO”). If you have any questions about this privacy policy, please contact them using the details set out below.

3. CONTACT DETAILS

3.1 Our full details are:

  • Full name of legal entity: FINDS World Limited

  • Name or title of DPO: Carl Mustad

  • Email address: [email protected]

3.2 You have the right to make a complaint at any time to the Information Commissioner’s Office (the “ICO”), the UK regulator for data protection issues (www.ico.org.uk).

4. CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES

4.1 We keep our privacy policy under regular review.

4.2 This version was last updated on 1 December 2021. It may change and if it does, these changes will be posted on this page and, where appropriate, notified to you when you next start the App. The new policy may be displayed on-screen and you may be required to read and accept the changes to continue your use of the App or the Services.

4.3 It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during our relationship with you.

5. THIRD PARTY LINKS

5.1 The App may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. Please note that these websites and any services that may be accessible through them have their own privacy policies and that we do not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites or services, such as Contact and Location Data. Please check these policies before you submit any personal data to these websites or use these services.

6. THE DATA WE COLLECT ABOUT YOU

6.1 We may collect, use, store and transfer different kinds of personal data about you as follows:

  • Identity Data: first name, last name, username or similar identifier.

  • Contact Data: billing address, delivery address, email address and telephone numbers.

  • Financial Data: bank account and payment card details.

  • Transaction Data: includes details about payments to and from you and details of in-App purchases.

  • Device Data: includes the type of mobile device you use, a unique device identifier (for example, your Device’s IMEI number, the MAC address of the Device’s wireless network interface, or the mobile phone number used by the Device), your IP address browser/platform type and version, mobile network information, your mobile operating system, referral source/exit pages, length of visit, page views, App navigation and search terms that you use, the type of mobile browser you use, and time zone setting.

  • Content Data: includes information stored on your Device, including friends’ lists, login information, photos and videos or other digital content.

  • Profile Data: includes your username and password, in-App purchase history, your interests, preferences, feedback and survey responses.

  • Usage Data: includes details of your use of any of our Apps or your visits to the App including, but not limited to, traffic data and other communication data, whether this is required for our own billing purposes or otherwise and the resources that you access.

  • Marketing and Communications Data: includes your preferences in receiving marketing from us and our third parties and your communication preferences.

  • Location Data: includes your current location disclosed by GPS technology.

6.2 We also collect, use and share “Aggregated Data” such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific App feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

6.3 We do not collect any “Special Categories” of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

7. HOW IS YOUR PERSONAL DATA COLLECTED?

We will collect and process the following data about you:

  • Information you give us. This is information (including Identity, Contact, Financial, and Marketing and Communications Data) you consent to giving us about you by filling in forms on the App, or by corresponding with us (for example, by email or any other contact form provided on the App). It includes information you provide when you register to use the App, download the App, use any of our Services, list an item for sale or sell or buy an item, make an in-App purchase, share data via the App’s social media functions, enter a competition, promotion or survey, opt in to our newsletter and/or to receiving push notifications and when you report a problem with an App, or our Services. If you contact us, we will keep a record of that correspondence.

  • Information we collect about you and your device. Each time you visit the App we will automatically collect personal data including Device, Content and Usage Data. We collect this data using cookies and other similar technologies. Please see our Cookie Policy for further details.

  • Location Data. We also use GPS technology to determine your current location. Some of our location-enabled Services require your personal data for the feature to work. If you wish to use the particular feature, you will be asked to consent to your data being used for this purpose. You can withdraw your consent at any time by disabling Location Data in your settings.

  • Information we receive from other sources including third parties and publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:

    • Device Data from the following parties:
      (a) analytics providers such as Google and Facebook;
      (b) advertising networks such as Google and Facebook; and
      (c) search information providers Google and Facebook.

  • Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as Stripe; and

  • Identity, Contact, Content and Profile Data from social networks such as Facebook, Instagram or TikTok.

8. COOKIES

8.1 We use cookies and/or other tracking technologies to distinguish you from other users of the App or the distribution platform (the “Appstore”) and to remember your preferences. This helps us to provide you with a good experience when you use the App and also allows us to improve the App. For detailed information on the cookies we use, the purposes for which we use them and how you can exercise your choices regarding our use of your cookies, see our Cookie Policy.

9. HOW WE USE YOUR PERSONAL DATA

9.1 We will only use your personal data when the law allows us to do so. Most commonly we will use your personal data in the following circumstances:

  • Where you have consented before the processing.

  • Where we need to perform a contract we are about to enter or have entered with you.

  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

  • Where we need to comply with a legal or regulatory obligation.

9.2 We will only send you direct marketing communications by email or text if we have your consent. You have the right to withdraw that consent at any time by contacting us.

9.3 We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

10. PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

We will use your personal data for the following purposes:

Purpose/activity

Type of data

Lawful basis for processing

To install the App and register you as a new App user

Identity

Contact 

Device

Your consent

To process in-App purchases and deliver Services including managing payments

Identity 

Contact 

Financial 

Transaction

Device

Marketing and Communications 

Location

Your consent

Necessary for our legitimate interests (to facilitate your use of the App to place orders for or sell items)

To manage our relationship with you including notifying you of changes to the App or any Services

Identity 

Contact 

Financial 

Profile 

Marketing and Communications

Your consent

Necessary for our legitimate interests (to keep records updated and to analyse how customers use our products/ Services)

Necessary to comply with legal obligations (to inform you of any changes to our Terms)

To enable you to participate in a prize draw, competition or complete a survey

Identity

Contact

Device 

Profile 

Marketing and Communications

Content

Your consent 

Necessary for our legitimate interests (to analyse how users make use of our Services and interact with each other which we can use to develop the App and grow our business)]

To administer and protect our business and this App including troubleshooting, data analysis and system testing

Identity 

Contact

Device 

Usage

Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security)

To deliver content and advertisements to you 

To make recommendations to you about items which may interest you

To measure and analyse the effectiveness of the advertising we serve you 

To monitor trends so we can improve the App

Identity 

Contact 

Device 

Content 

Profile 

Usage 

Marketing and Communications 

Location

Your consent 

Necessary for our legitimate interests (to develop our App and grow our business)

10.2 In this clause 10, capitalised terms shall have the meanings given below:

Consent means processing your personal data where you have signified your agreement by a statement or clear opt-in to processing for a specific purpose. Consent will only be valid if it is a freely given, specific, informed and unambiguous indication of what you want. You can withdraw your consent at any time by contacting us.

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

11. DISCLOSURES OF YOUR PERSONAL DATA

11.1 When you consent to providing us with your personal data, we will also ask you for your consent to share your personal data with the third parties set out below for the purposes set out in the table Purposes for which we will use your personal data above:

  • Other companies associated with us acting as joint controllers or processors and who are based in the United Kingdom and provide IT and system administration services and undertake leadership reporting.

  • HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.

  • Service providers acting as processors who provide IT and system administration services.

  • The seller or store from whom you have purchased items through our App, to allow them to complete your order.

  • Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

11.2 We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

12. INTERNATIONAL TRANSFERS

12.1 Some of our external third parties might be based outside the UK so their processing of your personal data will involve a transfer of data outside the UK.

12.2 Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

  • We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.

  • Where we use certain service providers, we may use specific contracts approved by the UK which give personal data the same protection it has in the UK.

12.3 Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.

13. DATA SECURITY

13.1 All information you provide to us is stored on our secure servers. Any payment transactions carried out by our chosen third-party provider of payment processing services will be encrypted using Secured Sockets Layer technology. Where we have given you (or where you have chosen) a password that enables you to access certain parts of the App, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

13.2 Once we have received your information, we will use strict procedures and security features to try to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way.

13.3 We will collect and store personal data on your Device using application data caches and browser web storage (including HTML5) and other technology. Certain Services include social networking, video, live stream, chat room or forum features. Ensure when using these features that you do not submit any personal data that you do not want to be seen, collected or used by other users.

13.5 We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator when we are legally required to do so.

14. DATA RETENTION

14.1 By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.

14.2 In some circumstances you can ask us to delete your data: see YOUR LEGAL RIGHTS below for further information.

14.3 In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

14.4 In the event that you do not use the App for a period of 24 months then we will treat the account as expired and your personal data may be deleted.

15. YOUR LEGAL RIGHTS

15.1 Under certain circumstances you have the following rights under data protection laws in relation to your personal data.

15.2 You have the right to:

  • Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

  • Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

  • Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

  • Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

  • Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

(a) if you want us to establish the data’s accuracy;

(b) where our use of the data is unlawful but you do not want us to erase it;

(c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or

(d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

  • Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

  • Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

15.3 You also have the right to ask us not to continue to process your personal data for marketing purposes.

15.4 You can exercise any of these rights at any time by contacting us at [email protected].