Privacy Policy

Please read this Privacy Policy carefully. You must not use this Website or our Services if you do not accept this Privacy Policy or our Website Terms and Conditions.

Introduction

Welcome to the Deallocker Ltd Privacy Policy.

Deallocker Ltd respects your privacy and is committed to protecting your personal data. This Privacy Policy will inform you on how we look after your personal data when you visit our Website (regardless of where you visit it from), including:

where and how we collect your personal information from;
what personal information we collect;
how we use your personal information;
who your personal information is shared with; and
telling you about your privacy rights and how the law protects you.

This Privacy Policy aims to give you information on how Deallocker Ltd collects and processes your personal data through your use of this Website, including any data you may provide through this Website when you sign up to our newsletter, purchase a Product or Service through the Website or take part in a competition.

It is important that you read this Privacy Policy together with any other Privacy Policy or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you, so that you are fully aware of how and why we are using your data. This Privacy Policy supplements the other notices and is not intended to override them.

Important information and who we are

Deallocker Ltd, referred to as Deallocker Ltd “we”, “us” or “our” in this Privacy Policy, is the controller and responsible for your personal data.

We have appointed a data protection officer (DPO) who 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 the DPO using the details set out below.

Contact details

Our full details are:

Full name of legal entity: Deallocker Ltd
Email address: hello@deallocker.club
Postal address: 128 City Road, London, United Kingdom, EC1V 2NX

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

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

Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
Contact Data includes billing address, delivery address, email address and telephone numbers.
Financial Data includes bank account and payment card details.
Transaction Data includes details about payments to and from you and other details of Products and Services you purchase through our Website.
Technical Data includes 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 Website.
Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
Usage Data includes information about how you use our Website and how you purchase Products and Services through our Website..
Marketing and Communications Data includes 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 may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific Website 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.

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.

This Website is not intended for children and we do not knowingly collect data relating to children.

We may monitor or record your calls, emails, text or other communications but we will do so in accordance with data protection legislation and other applicable law. Monitoring or recording will always be for business purposes, such as for quality control and training, to prevent unauthorised use of our telecommunication systems and Website, to ensure effective systems operation, to meet any legal obligation and/or to prevent or detect crime.

In order to ensure the Product or Services that are available to purchase through our Website continue to meet your needs, we may ask you for feedback on your experience of using the Website. Any feedback you provide will only be used as part of our programme of continuous improvement and will not be published on the Website.

Note that it is your responsibility to check and ensure that all information, content, material or data you provide on the Website is correct, complete, accurate and not misleading and that you disclose all relevant facts.

Where we need to collect personal data by law and you fail to provide that data when requested, the Product or Service that you are intending to purchase through our Website from a Provider may not be available, or the Provider may cancel any such purchase.

How is your personal data collected?

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. This includes personal data you provide when you:

apply to purchase a Product or Service through our Website;
create an account on our Website;
subscribe to any Service that is available through our Website;
request marketing to be sent to you;
enter a competition, promotion or survey; or
give us some feedback.

Interactions with Providers. In purchasing a Product or Service through our Website from a Provider, they may send us information they hold relating to the Product or Service you have purchased. This allows us to improve our Service.

Automated technologies or interactions. As you interact with our Website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other Websites employing our cookies.

Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below.

We may collect Technical Data from the following parties:

analytics providers such as Google based inside or outside the EU;
advertising networks such as based inside or outside the EU; and
search information providers based inside or outside the EU.

We may collect Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as based inside or outside the EU.

We may collect Identity and Contact Data from data brokers or aggregators based inside or outside the EU.

We may collect Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the EU.

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 in order to facilitate the purchase of a Product or Service through our Website (including with subsidiary companies within our group of companies).
Where it is necessary for our lawful and 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.

Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

Identity document verification

We use Stripe for identity document verification. Stripe collects identity document images, facial images, ID numbers and addresses as well as advanced fraud signals and information about the devices that connect to its services. Stripe shares this information with us and also uses this information to operate and improve the services it provides, including for fraud detection. You may also choose to allow Stripe to use your data to improve Stripe’s biometric verification technology. You can learn more about Stripe and read its privacy policy at https://stripe.com/privacy.

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. If you would like to amend your marketing preferences, please contact us.

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which Products and Services may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased goods or services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.

Third party marketing

We will get your express opt-in consent before we share your personal data with any company outside Deallocker Ltd for marketing purposes.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by logging into the Website and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you or by contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a purchasing a Product or Service through our Website.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when Websites set or access cookies. If you disable or refuse cookies, please note that some parts of this Website may become inaccessible or not function properly.

For more information on the cookies we use, please see our Cookie Policy.

Change of purposes

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Disclosures of your personal data

We may have to share your personal data with Providers and other third parties for the purposes set out in the table in paragraph 4 above.

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.

International transfers

We do not transfer your personal data outside the European Economic Area (EEA).

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

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. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.

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.

Data retention

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, or until you request that it is deleted.

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.

Generally, you can expect us to keep your personal data while you use the Website or if you have an active account with us.

For identity verification, Stripe retains a copy of all the data provided as part of a verification. You may also have consented to allow Stripe to use your data to improve their technology. You can delete your information from Stripe’s servers or revoke your consent by visiting https://support.stripe.com.

Your legal rights

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

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.

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

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Glossary

A lawful basis for processing personal data in accordance with article 6 GDPR, as implemented into English law by the Data Protection Act 2018, being:

Performance of a contract;
Compliance with a legal obligation;
Necessary to protect the vital interests of a person;
Necessary for the performance of a task carried out in the public interest; or
The legitimate interests of a company/organisation (except where those interests are overridden by the interests or rights and freedoms of the data subject)

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best abilities to purchase a Product or Service through our Website 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 or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

Third party links

This 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 Policy of every Website you visit.

Changes to the privacy policy

We reserve the right to amend or modify this Privacy Policy at any time and any changes will be published on the Website. The date of the most recent revision will appear on this page. If we make significant changes to this Privacy Policy, we may also notify you by other means such as sending an email. Where required by law, we will obtain your consent to make these changes. If you do not agree with any changes, please do not continue to use the Website.