Privacy Policy

PRIVACY POLICY  Updated 15th May 2018 

 

VSOCIETY’s approach to privacy  The VSOCIETY app (“App”) and website (“Site”) are run by VSOCIETY Limited a company established  in England (company number 08316342) with its registered offices at 9 th Floor, 107 Cheapside,  London, United Kingdom, EC2V 6DN (“VSOCIETY”, “we”, “our”, or “us”). We are committed to  protecting and respecting your privacy.  VSOCIETY provides a social media-inspired peer-to-peer marketplace which uses artificial  intelligence to suggest relevant sellers and items and to display items to the most relevant potential  buyers based on user preferences and other information submitted to it, which you can access via  the App and through our Site (“Service”).       When you use our Site or Service we will collect and process certain information about you. Our  Privacy Policy sets out how VSOCIETY collects, uses and shares information with the aim of  collecting such data is to provide you with a safe, efficient and personalised experience. We promise  that we will only collect information relating to you that we deem necessary for this purpose.  By setting up an account with us, you consent to the use of your personal information as described  in this Privacy Policy. You should also be aware that we use cookies to store and access information  whilst providing the Site and Service.   Our CEO is  responsible for overseeing questions in relation to this Privacy Policy. If you have any  questions about this Privacy Policy, including any requests to exercise your legal rights please  contact our Data Protection Officer using the details set out below:  Email Address : [email protected] 

Personal information we collect about you and how we use it  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, create an event, 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 following information sets out verticals 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 send information about our products and services - We will only send you marketing  communications in accordance with your marketing preferences and give you opportunity to opt out  altogether.  Contact and identity details: When you create an account with us you will be asked to provide your  contact information, this including your name, email address,  contact number and addresses  associated with your account. We will use your contact details so that we can communicate with you  directly about any events that you promote or 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. You may also be asked 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.  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 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.  In-app messages: If you choose to use our messaging functionality to message other users of the  Service, we may access and review your messages to assist in the fulfilment of orders made through  the Service, to respond to any query, issue, concern or dispute users raise and to resolve such  disputes and if we have reason to believe the messages may contain evidence that you have  breached our Terms of Service.  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 but do not collect your bank  or credit card details. 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.  Information provided by social networks you connect or link to our Service: If you choose to  connect an account on a social network, such as Instagram or Google to your VSOCIETY account  you are consenting to us collecting personal information from the social network in accordance with  your privacy settings on that social network. The connected social network may provide us with  information such as your name, account handle, profile picture, gender, username, user ID, age or  age range, language, country, friends list, follower list and any other information you have agreed it  can share. We will use the personal information provided to help create a public profile for you on  our Service and, where we provide the functionality. We may also use the connection between the  social network and our Service to provide you with updates on the social network that are relevant to  any account you have with us or promotion you are taking part in. Such updates will only be provided  with your consent. We will not post to your social network or to your friends, followers or contacts  without your consent.  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 VSOCIETY’s internal algorithm and to determine other products, activites 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.  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.  You are responsible for all actions taken with your username and password, and we recommend that  you do not disclose your user name and password to any third parties. If you lose control of your  password, you may lose substantial control over your personally identifiable information and may be  subject to legally binding actions taken on your behalf, so you should change such password  immediately and notify us of any unauthorised access to your account.  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.  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: 

● to provide analytics data on the use of the Service, Site and App which we use for the  legitimate interests of improving our Service, Site and App;  ● to show you your timeline and search results on our Service and order such results in a way  that is relevant to you using VSOCIETY’s internal algorithm based on your preferences and,  where you have consented to us using your location data, your location;  ● to display your items to the most relevant potential buyers using VSOCIETY’s internal  algorithm;  ● to send you tips and other notifications where we think this will improve your user experience  of the Service;  ● in the legitimate interests of determining the success of our marketing campaigns;  ● to send you marketing about products and services we think may be of interest to you;  and  ● in the legitimate interests of detecting or preventing any breach of our Terms of Service. 

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).  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.  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.  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. 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.  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  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.  Push notifications – where you allow us to in your operating system settings, we will send you  notifications relating to the Service.  You can change your push notification preferences at any time in your account settings.  Where you have given us permission to do so, we may share your information with selected third  parties so that they can provide you with information about their products and services using email.  If, after you have given us permission to share your email address with selected third parties, you  change your mind, you can change your email marketing preferences by emailing us at  [email protected] and letting us know that you do not want us to share your email address  with third parties for marketing purposes. 

Advertising on the Service 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.  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.  

Your Rights  Right to access your information: You are entitled to see the information held about you and to  check that we are lawfully processing it, and we shall comply with our obligations under applicable  data protection legislation in relation to any request by you. We may charge you a reasonable fee or  refuse to comply with your request if it is clearly unfounded, repetitive or excessive. We try to  respond to all legitimate requests within one month (once we have been able to verify your identity).  Occasionally it may take us longer than this if your request is particularly complex or you have made  a number of requests.  Right to request correction of your information: You may ask us to make any necessary changes to  ensure that the data we hold about you is accurate and kept up to date. Please keep us informed if  your personal information changes during your relationship with us.  Right to request erasure of your information: In certain circumstances you may also ask us to erase  personal information relating to you. We may not always be able to comply with your request for  specific legal reasons which will be notified to you, if applicable, at the time of your request. You can  exercise your right to delete certain personal information about you by closing your account with us.  Right to object to processing: You may object to use processing your personal information where  we are relying on a legitimate interest where you believe it impacts on your fundamental rights and  freedoms. We will consider any such objection, however in some cases we may demonstrate that  our legitimate grounds override your rights and freedoms. You may also object to us processing your  personal information for direct marketing purposes.  Right to restriction of processing: You may ask us to suspend the processing of your personal  information 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; © 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.  Right to request the transfer of your information: You have the right to request a transfer of certain  of your personal information to you or a third party of your choice, which we will provide in a  structured, commonly used, machine-readable format.  Right to withdraw consent: Where we are relying on your consent to process your personal  information you may withdraw this consent at any time (which you can do by changing the settings  in your mobile device in relation to location data or by changing the privacy settings on your social  networks in relation to information we collect from those networks).  Right to opt-out of behavioural analytics: If you do not want us to conduct behavioural analytics for  the purposes of VSOCIETY’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 VSOCIETY account and  cease using our Service. This is because it is essential to VSOCIETY 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.  To exercise any of the above rights, or if you have any questions relating to your rights, please  contact us by using the details set out in the “Contacting us” section below. We may need to request  specific information from you when you exercise your rights to confirm your identity and to speed up  our response. We may not be able to fulfil your request if we are not able to identify you.  Most of the personal information we hold about you is either available directly from viewing your  account and looking back over your own activities or is available from the social networks that you  have connected to our Service. If you think that there is other personal information which you think  we hold, please contact us using the contact details set out in the “Contacting us” section below.  Please provide as much information as you can about the personal information you are looking for  and we will be happy to try and help you find it. 

Links to third party sites  The Service may, from time to time, contain links to and from third party websites of our partner  networks, advertisers, partner merchants, retailers and affiliates. If you follow a link to any of these  websites, please note that these websites have their own privacy policies and that we do not accept  any responsibility or liability for their policies. Please check the individual policies before you submit  any information to those websites. 

Our policy towards children  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. 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 

Changes to this policy  We may amend this Privacy Policy from time to time in order that it accurately reflects the regulatory  environment and our own data collection and disclosure practices. Accordingly you should review  this policy periodically. When we change this Privacy Policy in a material way, we will update the  “last modified” date at the top of this Privacy Policy. Changes to this Privacy Policy are effective  when they are posted on this page. 

Notice to you  If we need to provide you with information about something, whether for legal, marketing or other  business related purposes, we will select what we believe is the best way to get in contact with you.  We will usually do this through email, or by placing a notice on the Service. The fact that we may  send notices to you will not stop you from being able to opt out of certain types of contact as  described in this Privacy Policy. 

Contacting us  Questions, comments and requests regarding this Privacy Policy are welcome and should be  addressed to [email protected] or to our Data Protection Officer (whose contact details are  stated at the beginning of this Privacy Policy). 

Complaints  In the event that you have a complaint about our treatment of your personal information, you have  the right to lodge a complaint with the supervisory body, the Information Commissioner.  However VSOCIETY welcomes the opportunity to resolve any complaint and we would suggest you  first refer your complaint to our Data Protection Officer (whose contact details are stated at the  beginning of this Privacy Policy), prior to making a complaint to the Information Commissioner