Privacy Policy

Privacy Policy for ZeroZero

Last updated: 13.11.2024

1. Introduction

ZeroZero respects your privacy and is committed to protecting your personal data. This privacy policy will inform you about how we look after your personal data when you visit our website (regardless of where you visit it from) or use our mobile application (collectively, the "Platform") and tell you about your privacy rights and how the law protects you.

2. Important information and who we are

2.1 Purpose of this privacy policy

This privacy policy aims to give you information on how ZeroZero collects and processes your personal data through your use of this Platform, including any data you may provide through this Platform when you sign up for an account, list an item for sale, make a purchase, or use our services.

2.2 Controller

ZeroZero is the controller and responsible for your personal data (collectively referred to as "ZeroZero", "we", "us" or "our" in this privacy policy).

2.3 Contact details

If you have any questions about this privacy policy or our privacy practices, please contact us via [email protected]

3. The data we collect about you

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data: first name, last name, username or similar identifier, title, date of birth
• Contact Data: billing address, delivery address, email address and telephone numbers
• Financial Data: bank account and payment card details (stored by our payment service provider)
• Transaction Data: details about payments to and from you and other details of products you have purchased or sold on our Platform
• Technical Data: internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this Platform
• Profile Data: your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses
• Usage Data: information about how you use our Platform, products and services
• Marketing and Communications Data: your preferences in receiving marketing from us and our third parties and your communication preferences

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.

4. How we collect your personal data

We use different methods to collect data from and about you including through:

• Direct interactions: You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise.
• Automated technologies or interactions: As you interact with our Platform, we will automatically collect Technical Data about your equipment, browsing actions and patterns.
• Third parties or publicly available sources: We will receive personal data about you from various third parties and public sources as set out below:
  • Technical Data from analytics providers such as Google
  • Contact, Financial and Transaction Data from providers of technical, payment and delivery services

5. How we use your personal data

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

• Where we need to perform the contract we are about to enter into or have entered into 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 obligation

5.1 Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so.

Purpose/Activity	Type of data	Lawful basis for processing
To register you as a new user	(a) Identity (b) Contact	Performance of a contract with you
To process and deliver your order including: (a) Manage payments, fees and charges (b) Collect and recover money owed to us	(a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications	(a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you	(a) Identity (b) Contact (c) Profile (d) Marketing and Communications	(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To administer and protect our business and this Platform	(a) Identity (b) Contact (c) Technical	(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you	(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical	Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)

6. Disclosures of your personal data

We may share your personal data with the parties set out below for the purposes set out in the table above.

• Internal Third Parties: Other companies in the ZeroZero Group acting as joint controllers or processors.
• External Third Parties:
  • Service providers acting as processors who provide IT and system administration services.
  • Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers.
  • Regulators and other authorities acting as processors or joint controllers who require reporting of processing activities in certain circumstances.
• Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets.

7. International transfers

We share your personal data within the ZeroZero Group. This will involve transferring your data outside the European Economic Area (EEA).

Whenever we transfer your personal data out of the EEA, 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 by the European Commission.
• Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.

8. Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know.

9. Data retention

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements.

10. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. These include the right to:

• Request access to your personal data
• Request correction of your personal data
• Request erasure of your personal data
• Object to processing of your personal data
• Request restriction of processing your personal data
• Request transfer of your personal data
• Right to withdraw consent

If you wish to exercise any of the rights set out above, please contact us.

11. Changes to this Privacy Policy

We keep our privacy policy under regular review. This version was last updated on the date stated at the top of this policy. Historic versions can be obtained by contacting us.

12. Contact us

If you have any questions about this privacy policy or our privacy practices, please contact our data privacy manager via [email protected]