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PRIVACY POLICY This policy (our “Privacy Policy”) explains how and why Declutter On Demand Ltd collects and processes your personal data, what it is used for, how it is kept safe and how long it is retained for. We are the data controller of the information you provide to us and we are committed to ensuring privacy for our Clients and only using Client data as set out in this Privacy Policy. We want to provide a safe and secure experience for our Clients. Please read this Privacy Policy in conjunction with Declutter on Demand’s Terms & Conditions (the "Terms").1. DEFINITIONSAll definitions in the Terms will have the same meanings here.2.CONTACT US
2.1 For any questions or requests regarding this Privacy Policy or how we handle your data, please contact hello@declutterondemand.com. 2.2 Declutter On Demand Ltd operates as a limited company and our corporate information is set out below: (a) we are registered at Companies House (company number: 12128495); (b) our business trading address is 72 Badminton Road, London, SW12 8BL, UK; (c) we are registered as a data controller with the UK Information Commissioner’s Office, with data protection registration number ZA543955. 3. HOW WE COLLECT YOUR DATA 3.1 We collect your data when you interact with us or use our Website, make a Booking, write a review or login to the Website. 3.2 We also collect technical information from third party sites, such as advertising platforms and analytics providers. 4. THE DATA WE COLLECT ABOUT YOU 4.1 We collect the following types of information: (a) information about your computer, mobile phone and/or other electronic device as applicable and about your visits to and use of the Website (including your IP address, geographical location, browser type and version, operating system, searches made, referral source, length of visit, page views and website navigation paths); (b) information that you provide to us when registering with the Website (including your name, email address, contact details and information about your home); (c) information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (including your name, email address and other contact details); (d) information that you provide to us when using the Website, or that is generated in the course of the use of those services (including the timing, type, frequency and pattern of Website use); (e) information relating to any Bookings made through the Website (including date, time, type, spend and payment details); (f) information that you post to the Website or our social media accounts for publication on the internet (including your name, pictures and the content of your posts); (g) reviews you give for Organisers; (h) information contained in or relating to any communications that you send to us or send through the Website (including the communication content and metadata associated with the communication); (i) information you send to us via email, phone, chat or text message for customer service purposes; (j) information you send to us for feedback (including surveys and feedback responses); (k) information about your communication preferences (including whether you subscribe to marketing and other communications); and (l) any other personal information that you choose to send to us. 4.2 We never store full card information and use a third party payment processor. 4.3 Before you disclose to us the personal information of another person, you must obtain that person’s consent to both the disclosure and the processing of that personal information in accordance with the terms of this Privacy Policy. 4.4 We may also collect, use and share aggregated data such as statistical or demographic data for any purpose. Such data is anonymous and is not personal data. 4.5 The Website is not intended for individuals under the age of 18 and we do not knowingly collect data relating to children. 5. HOW WE USE YOUR DATA 5.1 We will use your personal data in the following circumstances: (a) where we need to act as an intermediary between Clients and Organisers to arrange Bookings; (b) where we need to comply with a legal or regulatory obligation; and (c) where it is necessary for our legitimate interests. In such cases we use a ‘balancing test’ to make sure such processing is needed and that your rights do not override those interests. 5.2 Where our basis for processing is as set out in paragraph 5.1(a) above, we may use your information to: (a) administer the Website and business; (b) personalise the Website for you; (c) enable your use of the Services available on the Website; (d) supply to you Services purchased through the Website; (e) send statements, invoices and payment reminders to you, and collect payments (such as Deposits) from you; (f) send you information about your Services and any changes; (g) send you non-marketing commercial communications; (h) send you email notifications that you have specifically requested; (i) allow you to make and receive referrals; (j) help our support team help you with any complaints, enquiries or requests for information as quickly and effectively as possible; (k) update you on changes to prices and any terms and conditions; (l) update you on new features; (m) deal with enquiries and complaints made by or about you relating to the Website; (n) keep the Website secure and prevent fraud; and (o) verify compliance with any terms and conditions governing the use of the Website (including messages sent). 5.3 Where our basis for processing is as set out in paragraph 5.1(b) above, we may use your information to: (a) create a record of your transactions; and (b) comply with any legal obligation or regulatory requirement to which we are subject. 5.4 Where our basis for processing is as set out in paragraph 5.1(c) above, we may use your information to: (a) send you marketing (you can opt out any time); (b) request your views and feedback (you can opt out any time); and (c) provide third parties with statistical information about our users (but those third parties will not be able to identify any individual user from that information). 5.5 If you submit personal information for publication on the Website, we will publish and otherwise use that information in accordance with the consent you grant to us. 5.6 All our financial transactions are handled through our payment services provider, PayPal, whose privacy policy is set out at: https://www.paypal.com/uk/webapps/mpp/ua/privacyfull. We will share information with PayPal only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds. 5.7 We may, in the future, use anonymised customer information to perform large scale analysis for the purposes of improving our services. 5.8 We may, in the future, undertake profiling and automated decision-making in order to prevent fraud or to display or allocate an appropriate service provider. 6. DISCLOSURE OF YOUR DATA 6.1 We may disclose your personal information to any of our employees, officers, insurers, professional advisers, agents, suppliers or subcontractors insofar as reasonably necessary for the purposes set out in this Privacy Policy. 6.2 We may also share limited personal data with third party service providers. Any such third party must be acting in accordance with all relevant regulation in their processing of your data, including: (a) Organisers so that they can help you declutter and organise your home; (b) payment providers such as PayPal so that we can bill you for Services; (c) customer service software providers such as email, telephone, chat and text message providers so that we can communicate with you about any enquiries, any Bookings and any issues; (d) marketing and advertising partners so we can send you relevant information; and (e) referrals where you have referred someone or someone has referred you to the Website. 6.3 Except as provided in this Privacy Policy, we will not provide your personal information to third parties. 6.4 We may disclose your personal information: (a) to the extent that we are required to do so by law; (b) in connection with any ongoing or prospective legal proceedings; (c) in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk); (d) to any purchaser (or prospective purchaser) of any business or asset that we are (or are contemplating) selling; and (e) to any person who we reasonably believe may apply to a court or other competent authority for disclosure of that personal information where, in our reasonable opinion, such court or authority would be reasonably likely to order disclosure of that personal information. 7. DATA SECURITY 7.1 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. 7.2 We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so. 7.3 You acknowledge that the transmission of information over the internet is inherently insecure and we cannot guarantee the security of data sent over the internet. 8. RETENTION OF YOUR DATA 8.1 We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. 8.2 To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. 9. COOKIES 9.1 Our Website uses cookies to enhance the user experience. By using the Website and agreeing to this Privacy Policy, you consent to our use of cookies in accordance with the terms of this Privacy Policy. 9.2 A cookie is a small file which asks permission to be stored on your computer’s hard drive, mobile phone or other electronic device. Once you agree, the file is added and the cookie records how you move around and use a website. Cookies can also be used to analyse website traffic and for advertising and marketing purposes. The website can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences. Cookies are used by nearly all websites and do not harm your system. Overall, cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies. 9.3 Cookies may be either “persistent” or "session" cookies. A persistent cookie is stored by a web browser and remains valid until its set expiry date, unless deleted by the user before that date. A session cookie expires at the end of the user session, when the web browser is closed. 9.4 Cookies may also be “first party” or “third party” cookies. First party cookies are placed on your computer by the website you are visiting. Third party cookies are instead placed on your computer through a third party website such as Google. 9.5 You can choose to accept or decline cookies. Most web browsers automatically accept cookies. However, you can usually modify your browser settings to block all cookies if you prefer, or to alert you when a cookie is being sent which enables you to decide if you want to accept it or not. However, some of the services and features offered through our Website may not function properly if your cookies are disabled (i.e. blocked). 9.6 We will use cookies to: (a) recognise a computer when a user visits the Website; (b) track users as they navigate the Website; (c) enable a Booking on the Website; (d) improve the Website’s usability; (e) analyse the use of the Website; (f) administer the Website; (g) prevent fraud and improve the security of the Website; (h) personalise the Website for each user; and (i) keep track of your personal and home information; and for other possible uses. 9.7 We may use the following types of cookies on the Website: (a) Strictly necessary cookies. These cookies are essential in order to enable you to move around our Website and use its features. Without these cookies, services you have asked for cannot be provided. These are first party cookies. (b) Performance cookies. These cookies collect information in an anonymous form about how visitors use our Website and apps. They allow us to recognise and count the number of visitors, see how visitors move around the Website when they are using it and identify the regions that they are visiting from. These are first party cookies. (c) Functionality cookies. These cookies allow our Website and apps to remember choices you make (such as your user name, language or the region you are in) and provide enhanced, more personal features. The information these cookies collect will be anonymised and they cannot track your browsing activity on other websites. These are first party cookies. (d) Analytics. We use Google Analytics and other third party analytics services to collect and analyse statistics and generate reports about the Website. This helps us to better understand user patterns and improve the Website. The information generated by the cookie about your use of the Website will be transmitted to and stored by third party analytics service providers which may be on servers outside of the European Economic Area. The information collected for this purpose will be disclosed to or collected directly by these service providers. These service providers may retain and use anonymised, aggregated data collected from users of our Website in connection with their own businesses, including in order to improve their products and services. (e) Social media cookies. These third party cookies together with social media plug-ins allow you to use functionalities of social media networks such as Facebook, Twitter and Instagram on our Website. These are persistent cookies which will be kept on your device until their expiration or earlier manual deletion. If you use these functionalities, the plug-in and its content are loaded directly from the social media provider’s servers and included in the Website by your browser. If you log into your respective social media account at the time you interact with the social media plug-ins on our Website, the social media provider will connect this information with your social media user August 2019 Edition 6 profile. We cannot influence which personal data the social media provider will collect about you. Please see their privacy policies for further information. 10. YOUR RIGHTS 10.1 Under data protection law, you may have rights concerning the data we hold about you. If you wish to exercise any of these rights, please contact Declutter On Demand Ltd at hello@declutterondemand.com. You may have the right to: (a) be informed about how your personal data is being used; (b) request a copy of the personal data we hold about you and check we are processing it lawfully (known as a "subject access request"); (c) request the correction of any inaccurate personal data we may hold about you; (d) request that we delete your personal data, or stop processing it or collecting it, in some circumstances; (e) object to certain types of processing of your personal data, such as direct marketing messages and opt out at any time; (f) ask that we transfer elements of your data to you or another service provider; (g) withdraw your consent at any time where we are relying on consent to process your personal data; and (h) complain to your data protection regulator about the way Declutter On Demand Ltd is handling your data. In the UK, this is the Information Commissioner’s Office. 10.2 When exercising one of the rights under paragraph 10.1 above: (a) we may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data, for your own security; (b) we do not charge a fee unless your request is clearly unfounded, repetitive or excessive (and we may refuse to comply with your request in these circumstances); (c) our response to such requests will be as soon as possible and we aim to respond to all legitimate requests within 30 days. 11. GENERAL 11.1 We may change this Privacy Policy from time to time. An updated Privacy Policy will be labelled with a new edition date and such changes will be effective when we post the updated Privacy Policy on the Website, unless otherwise required by applicable law. By using the Website and/or making a Booking, you will be deemed to be subject to the Privacy Policy in force at that time. 11.2 The Website may include links to third party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third party websites and are not responsible for their privacy statements. When you leave our Website, we encourage you to read the privacy notice of every website you visit. 11.3 Organisers will have their own privacy policies in place and any data they collect from you will be governed by their own privacy policies.