Cookies and other Identifiers

1. A cookie is a small file of letters and numbers that we put on your computer, mobile phone or tablet if you agree. Cookies allow us to distinguish you from other users of our website and mobile applications, which helps us to provide you with an enhanced browsing experience. For more information about cookies and how we use them, please read our Cookie Notice:

How We Use Your Personal Data

1. We use your personal data to operate, provide, develop and improve the products and services that we offer, including the following:
   1. Registering you as a new customer.
   2. Processing and delivering your orders.
   3. Managing your relationship with us.
   4. Enabling you to participate in promotions, competitions and surveys.
   5. Improving our website, applications, products and services.
   6. Recommending/advertising products or services which may be of interest to you.
   7. Enabling you to access certain products and services offered by our partners and vendors.
   8. Complying with our legal obligations, including verifying your identity where necessary.
   9. Detecting fraud.

Legal basis for the processing of Personal Data

1. We will only process your personal data where we have a legal basis to do so. The legal basis will depend on the purposes for which we have collected and used your personal data. In almost every case the legal basis will be one of the following:
   1. Consent: For example, where you have provided your consent to receive certain marketing from us. You can withdraw your consent at any time, including by clicking on the “unsubscribe” link at the bottom of any marketing email we send you
   2. Our legitimate business interests: Where it is necessary for us to understand our customers, promote our services and operate effectively, provided in each case that this is done in a legitimate way which does not unduly affect your privacy and other rights.
   3. Performance of a contract with you: This would also apply where we need to take steps prior to entering into a contract with you. For example, where you have purchased a product from us and we need to use your contact details and payment information in order to process your order and send the product to you.
   4. Compliance with law: Where we are subject to a legal obligation and need to use your personal data in order to comply with that obligation.

How We Share Your Personal Data

1. A. We may need to share your personal data with third parties for the following purposes:
   1. Sale of products and services: In order to deliver products and services purchased on our marketplace from third parties, we may be required to provide your personal data to such third parties.
   2. Working with third party service providers: We engage third parties to perform certain functions on our behalf. Examples include fulfilling orders for products or services, delivering packages, analyzing data, providing marketing assistance, processing payments, transmitting content, assessing and managing credit risk, and providing customer service.
   3. Business transfers: As we continue to develop our business, we might sell or buy other businesses or services. In such transactions, customer information may be transferred together with other business assets.
   4. Detecting fraud and abuse: We release account and other personal data to other companies and organizations for fraud protection and credit risk reduction, and to comply with applicable law.
2. B. When we share your personal data with third parties we:
   • require them to agree to use your data in accordance with the terms of this Privacy Notice, our Privacy Policy and in accordance with applicable law; and
   • only permit them to process your personal data for specified purposes and in accordance with our instructions. We do not allow our third-party service providers to use your personal data for their own purposes.

International Transfers

1. We may transfer your personal data to locations in another country, if this is permissible pursuant to applicable laws in your location. There are inherent risks in such transfers.
2. In the event of international transfers of your personal data, we shall put in place measures necessary to protect your data and ensure the same level of protection available in the country of data origin. We shall continue to respect your legal rights pursuant to the terms of this Privacy Notice and applicable laws in your location.

Data Retention

1. We will take every reasonable step to ensure that your personal data is processed for the minimum period necessary for the purposes set out in this Privacy Notice. Your Personal Data may be retained in a form that allows for identification only for as long as:
   1. We maintain an ongoing relationship with you. This will enable us to improve your experience with us and to ensure that you receive communications from us
   2. Your Personal Data is necessary in connection with the purposes set out in this Privacy Notice and we have a valid legal basis,
   3. The duration of: (i) any applicable limitation period (i.e., any period during which a person could bring a legal claim against us), and
2. We will actively review the personal data we hold and delete it securely, or in some cases anonymise it, when there is no longer a legal, business or consumer need for it to be retained.

Data Security

1. We have put in place security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.
2. 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.
3. 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.

Your Legal Rights

1. A. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
2. B. Under certain circumstances, you have rights under data protection laws in relation to your personal data, including the right to access, correct or erase your personal data, object to or restrict processing of your personal data, right to ask that we transfer your personal data to a third party, and unsubscribe from our emails and newsletters.
3. C. Where you wish to permanently delete your data from our website and other applications, you can choose the option of closing your account. You can close your account by clicking on this link and following the instructions. Once your account is closed, all products and services that you access through your account will no longer be available.
4. D. We can refuse to accede to your request where it is unreasonable or where you have failed to provide additional information necessary to confirm your identity.