This privacy notice sets out how we use and manage your personal data. Where we refer to “personal data” in this privacy notice, this means data which relates to you and which personally identifies you either directly or indirectly. This privacy notice applies to any SoloEbay website, application, service, or tool (collectively “Services”).
1. How We Use Your Data
We use your personal data to provide goods and services to you and to enter into and manage any credit accounts or financial services products you may have with us.
We will use your personal data in the following ways:
- To provide goods and services and to manage your retail account including administering payments, returns and responding to queries.
- To assess whether to offer you a credit facility and for ongoing administration of any credit facility. This includes accessing and sharing information with the Credit Reference Agencies.
- To manage any financial services products that you have.
- To manage any prize draw or competition you may enter.
- To analyze your shopping preferences or how you interact with or use our websites.
- For research and statistical purposes.
- To send you special offers or discounts and to tell you about our products and services. You control your preferences in respect of how your personal data is used for marketing and you can change these preferences when you log in to My Account.
- To record and monitor outbound and inbound telephone conversations with you to ensure consistent service levels, to prevent or detect fraud, to resolve queries and complaints and for performance management and training purposes.
We will collect personal data directly from you when you purchase goods or services, apply for a credit account or other financial services products, or change any of your details (such as your name or address) via My Account. We require you to provide personal data in order to assess whether to enter into a contract with you or to perform our contract with you and if you do not provide the personal data we request, we will be unable to enter into or fulfill this contract.
We obtain data from third-party sources such as credit reference agencies, fraud prevention agencies and publicly available information relating to you on the internet (for example on social media websites).
We may also obtain personal data from third-party companies for the purposes of sending marketing communications to you. Such marketing communication may be sent by ourselves or by the third parties. These third parties must check you have given your permission for such contacts to take place.
3. Why We Need Your Personal Data
We need to process your personal data for a number of different reasons and these are our legal bases for processing.
We rely on one or more of the following legal bases for processing personal data:
- To perform our contract with you or to enter into a contract with you.
- To fulfill our legitimate interests or the legitimate interests of a third party.
Examples of our legitimate interests are direct marketing, fraud prevention, preventing and investigating crime, assessing affordability and creditworthiness and IT security.
- To comply with legal obligations to which our business is subject.
If we are relying on consent as our legal basis to process your personal data, you have the right to withdraw consent at any time.
We will keep your personal data for the purposes set out in this privacy notice and only for as long as any legal basis continues to apply.
- Ensuring we have relevant information in the event of any queries or complaints.
- Being able to identify if you have purchased a product which is subject to a product recall.
- Being able to service any product or service guarantee you have purchased.
- To assist with the establishment, exercise or defense of legal claims.
The length of time we need to keep the personal data will vary depending on the nature of the personal data and the reason we are obliged to hold it. We will apply appropriate risk-based measures to protect your personal data.
4. Who We Transfer Data To
Transferring personal data to other organizations needs to take place with appropriate safeguards and you can be assured that we will only share the personal data that is needed for these organizations to be able to provide the right service to you or support us in doing so.
We may transfer your personal data to the following third parties:
- Other companies within the SoloEbay – including for credit assessment purposes or for fraud prevention purposes.
- Technology service providers – our partners who provide IT and website services.
- Customer service providers – our partners who work with us to administer your account and provide you with any help you may need.
- Telephony providers – our partners who provide telephone services and functionality.
- Delivery companies – our couriers, parcel firms, and mail firms who deliver your goods or services and manage any returns on our behalf.
- Distributors and manufacturers of goods – our partners who fulfill orders and deliver products to you and manage any returns on our behalf.
- Product service providers – our partners who provide products and services such as insurance or extended warranties.
- Marketing service providers – our partners who work with us to make sure we send your information about products, services and special offers that are of interest to you.
- Data pool facilitators – we may share and pool information (on an anonymous basis or otherwise) with other third-party retailers or financial service providers. This may help up to improve our products and quality of service to all customers.
- Debt collectors, tracing agencies, debt purchasers or organizations providing debt support – our partners who help us to recover debts, who purchase debts or who offer debt advice and support.
- Regulators and other governmental agencies or law enforcement agencies.
We will only transfer your personal data to third parties who adhere to appropriate data security standards and controls. From time to time we may need to transfer your personal data to other countries. Where this is the case, we will ensure that the transfer is subject to appropriate safeguards to protect your personal data and complies with applicable law which may include having standard contractual clauses in place with the third party. For further information on how data can be transferred to other countries, please find enclosed a link to the European Commission website: https://ec.europa.eu/info/law/law-topic/data-protection_en
5. Your Rights
You have certain rights in respect of your personal data and we have processes to enable you to exercise these rights.
Right of Access
This is known as a Subject Access Request. If you want to know if we are processing personal data relating to you and to have access to any such personal data you can mail us on[email protected]
Right to Rectification
If you believe that we hold inaccurate personal data about you, then you can either update this information directly by logging in to My Account and updating the relevant details or you can request that we carry out a review by emailing us on [email protected]. Depending on the type of personal data you believe is inaccurate, we may ask you for further proof to ensure that the personal data is being corrected properly. If we are satisfied that the personal data is inaccurate we will make the necessary changes.
Right to Erasure
You have a right to ask for your personal data to be erased in certain circumstances. However, this right does not apply where we have to comply with a legal obligation or where we need personal data for the establishment, exercise or defense of legal claims. Therefore we cannot comply with an erasure request where you have a retail shopping account, owe money on a credit facility or have otherwise bought products and services for which we must keep records. In addition, if you opt out of marketing communications or have previously opted out of marketing communications, we have to keep a record or such opt out to ensure that we don’t contact you in the future.
Right to Restriction
You have a right to request that processing of personal data is restricted in certain circumstances. However, we shall still continue to process the personal data for storage purposes, for the establishment, exercise or defense of legal claims or with your consent
Right to Object
Where we are relying on legitimate interests as a legal basis to process your data, you have a right to object to such processing on grounds relating to your particular situation.
If you object to our use of your personal data for marketing purposes, we will opt you out of marketing. You can do this by logging into My Account and amending your preferences or you can call our Customer Services on 0044 788 23456 10. You may also object to other processing when we rely on our legitimate interests as the basis for processing, but we do not have to stop the processing if we can demonstrate compelling legitimate grounds for the processing (taking into account our processing activities, the nature of our business and our legitimate interests) and that these grounds override your interests, rights, and freedoms or in the event that we need the personal data for the establishment, exercise or defense of legal claims. To enable us to consider any objection we will need to know what specific interests, rights or freedoms relating to the particular situation you believe will potentially be put at risk by our processing. If we do stop processing your personal data (apart from for direct marketing purposes), this may affect our ability to trade with you.
From time to time, in deciding whether to enter into a contract with you or during the ongoing performance of a contract, we take decisions based on automated processing which produces legal effects or similarly significantly affects you, for example, deciding whether to offer a credit facility or assessing a fraud risk. We use data from a variety of sources in our automated processing for credit scoring and fraud decision making and we use statistical methods to produce the results. This logic helps us understand the risk posed by individuals by placing a weighting on certain criteria which are then calculated to give an overall score.
There are a number of consequences of such automated processing:
- If any of our sellers decide to offer you other credit terms such as buy now pay later or interest-free credit which will facilitate your purchase of goods and services.
- We may refuse your application for credit or we may decide not to offer certain credit products which may have an impact on your ability to purchase goods and services from us. This is in line with our obligations as a responsible lender as we have to assess affordability for credit purposes and to protect customers from financial distress and difficulty.
- We may conduct a further review or request additional information from you in relation to your request to purchase goods and services if our fraud decision making highlights any issues.
We also use automated processing in relation to the information we hold about you to make recommendations of products and services we think you would be interested in and to improve your experience when you visit our website by making it relevant and tailored to you.
Right to Portability
In certain circumstances, you can request that we provide to you your personal data in a commonly used format. If you wish to make such a request you can mail us on [email protected]
Right to Complain to the Information Commissioner
You have the right to lodge a complaint with the Information Commissioner and more details can be found on their website www.ico.org.uk.
6. Credit Applications
In order to process your application and during our relationship with you, we will perform credit and identity checks on you with one or more credit reference agencies (‘CRAs’).
To do this, we will supply your personal information to CRAs and they will give us information about you. This will include information from your credit application and about your financial situation and financial history. CRAs will supply to us both public (including the electoral register) and shared credit, financial situation and financial history information and fraud prevention information.
We will use this information to:
- Assess your creditworthiness and whether you can afford to take the product.
- Verify the accuracy of the data you have provided to us.
- Prevent criminal activity, fraud and money laundering.
- Manage your account(s).
- Trace and recover debts.
- Ensure any offers provided to you are appropriate to your circumstances.
7. Fraud Prevention
Before we provide services, goods or financing to you, we undertake checks for the purposes of preventing fraud and money laundering and to verify your identity. These checks require us to process personal data about you.
What We Process & Share
The personal data you have provided, we have collected from you, or we have received from third parties may include your:
- Date of birth.
- Residential address and address history.
- Contact details such as email address and telephone numbers.
- Cookie Identifiers.
- Device Information.
- Advertising Identifiers.
- Geo Location.
- Social Media Information.
- Consumer Preferences.
- Company and VAT Details.
- Identifiers assigned to your computer or other internet connected devices including your Internet Protocol (IP) address.
When we and fraud prevention agencies process your personal data, we do so on the basis that we have a legitimate interest in preventing fraud and money laundering, and to verify identity, in order to protect our business and to comply with laws that apply to us. Such processing is also necessary to enable us to enter into and perform our contracts with you.
Fraud prevention agencies can hold your personal data for different periods of time, and if you are considered to pose a fraud or money laundering risk, your data can be held for up to six years.
Whenever fraud prevention agencies transfer your personal data outside of the European Economic Area, they impose contractual obligations on the recipients of that data to protect your personal data to the standard required in the European Economic Area.
They may also require the recipient to subscribe to ‘international frameworks’ intended to enable secure data sharing.
Your personal data is protected by legal rights, which include your rights to:
- Object to our processing of your personal data.
- Request that your personal data is erased or corrected.
- Request access to your personal data.
8. How to Contact Us
If you have any queries about how we use your information or on data protection generally please mail to us at [email protected]
From time to time we may contact you with details on special promotional offers or products that we think you would be interested in, via Email, Telephone, SMS, and Post or from specially selected Third Parties, if you do not want to receive these communications you can mail to us at [email protected]. Please state which contact method you wish to be removed from (existing customers should provide their Account Number). Please clearly state whether you wish to be removed from Very communications, communications from Third Parties, or both.