Effective date: 1st October 2021
In the context of GDPR, it may referred to as Personal Data or Personal Information.
We take data protection very seriously and abide by the EU General Data Protection Regulation (GDPR), US CCPA and any other relevant privacy laws that govern our jurisdiction. The data controller within the meaning of Article 4 (7) of the EU General Data Protection Regulation (GDPR) which is responsible for the processing of your personal data is Just Loco Ltd.
PERSONAL INFORMATION WE COLLECT
Personal information you provide to us. Personal information you may provide to us through the Service or otherwise includes:
- Communications, such as information you provide when you contact us with questions, feedback, survey responses, or otherwise correspond with us,
- Marketing data, such as the email address or contact details that we use to send marketing communications and your preferences for receiving communications about our activities, events, sweepstakes and contests.
Data from other sources. We may also collect information about you from:
- Business partners, such as advertising and joint marketing partners.
- Data providers, such as information services and data licensors.
- Public sources, such as blogs, forums or social media platforms.
Automatic Collection. We and our service providers may automatically log information about you, your computer or mobile device, and your activity occurring on or through the Sites, such as:
- Device data, such as your computer or mobile device operating system type and version number, manufacturer and model, browser type, screen resolution, IP address, the website you visited before browsing our site, and general location information such as city, state or geographic area.
- Online activity data, such as pages or screens you viewed, how long you spent on a page or screen, navigation paths between pages or screens, information about your activity on a page or screen, access times, and duration of access.
HOW WE USE YOUR PERSONAL INFORMATION
Service delivery. We may use your personal information to:
- ● provide, operate and improve the Service;
- communicate with you about the Service, including by sending you announcements, updates, security alerts, and support and administrative messages;
- provide customer support and maintenance for the Service;
Direct Marketing. We may use your personal information to send you Tradeoo-related marketing communications as permitted by law. You will have the ability to opt-out of our marketing and promotional communications as described in the Your Choices section below.
For research and development. We may use your personal information for research and development purposes, including to analyze and improve the Service and our business.
To create anonymous data. We may create aggregated, de-identified or other anonymous data records from your personal information and other individuals whose personal information we collect. We make personal information into anonymous data by excluding information (such as your name) that makes the data personally identifiable to you. We may use this anonymous data and share it with third parties for our lawful business purposes, including to analyze and improve the Service and promote our business.
To comply with laws and regulations. We use your personal information as we believe necessary or appropriate to comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities.
For compliance, fraud prevention and safety. We may use your personal information and disclose it to law enforcement, government authorities, and private parties as we believe necessary or appropriate to: (a) protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims); (b) audit our internal processes for compliance with legal and contractual requirements; (c) enforce the terms and conditions that govern the Service; and (d) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity, including cyber attacks and identity theft.
With your consent. In some cases we may specifically ask for your consent to collect, use or share your personal information, such as when required by law.
HOW WE SHARE YOUR PERSONAL INFORMATION
Service providers. Companies and individuals that provide services on our behalf or help us operate the Service or our business (such as service fulfillment, customer support, hosting, analytics, email delivery, marketing, database management services, returns processing and risk and fraud mitigation).
Advertising partners. Third party advertising companies that collect information about your activity on the Site and other online services to help us advertise our services, and/or use hashed customer lists that we share with them to deliver ads to them and similar users on their platforms.
Third party platforms. Social media and other third party platforms that you connect to the Service, such as when you use options to access the Service by logging into a social media platform. Please note, we do not control the third party’s use of your personal information.
The public. Other users of the Service and the public, when you disclose personal information for public use. We do not control how other users or third parties use any personal information that you make available to them. Please be aware that any information you post publicly can be cached, copied, screen captured or stored elsewhere by others (e.g., search engines) before you have a chance to edit or remove it.
Professional advisors. Professional advisors, such as lawyers, bankers, auditors and insurers, where necessary in the course of the professional services that they render to us.
Authorities and others. Law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate to comply with law or for the compliance, fraud prevention and safety purposes described above.
Business transferees. We may sell, transfer, or otherwise share some or all of your personal information in connection with or during negotiation of any merger, financing, acquisition or dissolution, transaction or proceeding involving sale, transfer, divestiture, or disclosure of all or a portion of our business or assets, or in the event of an insolvency, bankruptcy, or receivership.
In this section, we describe the rights and choices available to all users.
Access or update your account information. If you have registered for an account with us, you may review and update certain personal information in your account profile by logging into the account.
Opt out of marketing communications. You may opt out of marketing-related emails by following the opt-out or unsubscribe instructions located at the bottom of the email. You may continue to receive service-related and other non-marketing emails. If you receive marketing text messages from us, you may opt out of receiving further marketing text messages from us by replying STOP to our marketing message.
Cookies. Most browsers let you remove and/or stop accepting cookies from the websites you visit. To do this, follow the instructions in your browser’s settings. .
Advertising Choices. You may opt-out of interest-based advertising.
Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” or similar signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com
Privacy settings and location data. Users of our App can disable our access to their device’s precise geo-location in their mobile device settings.
Choosing not to share your personal information. If you do not provide information that we need to provide the Service, we may not be able to provide you with the Service or certain features. We will tell you what information you must provide to receive the Service when we request it.
Third-party platforms or social media networks. If you choose to create an account through or connect the Service with another third-party platform, you may have the ability to limit the information that we may obtain from the third-party at the time you log in to the Service using the third-party’s authentication service or otherwise connect your account. You may also be able to control your settings through the third-party’s platform or service after you have connected your accounts.
OTHER SITES, MOBILE APPLICATIONS AND SERVICES
The Sites may contain links to other websites and online services operated by third parties. These links are not an endorsement of, or representation that we are affiliated with, any third party. In addition, our content may be included on web pages or online services that are not associated with us. We do not control third party websites or online services, and we are not responsible for their actions. Other websites and services follow different rules regarding the collection, use and sharing of your personal information. We encourage you to read the privacy policies of the other websites and online services you use.
Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Services. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.
For more information on the privacy practices of Google, please visit the Google Privacy Terms web page: http://www.google.com/intl/en/policies/privacy/
We may publish Google Adsense interest-based advertisements on our Site.
These are tailored by Google to reflect Your interests. To determine Your interests, Google will track Your behaviour on our Site and on other Sites across the web using the DART cookie. You can view, delete or add interest categories associated with your browser using Google’s Ads Preference Manager, available at:https://adssettings.google.com/authenticated?hl=en. You can opt-out of the Adsense partner network cookie at: https://policies.google.com/technologies/ads
The security of your personal information is important to us. We employ a number of organizational, technical and physical safeguards designed to protect the personal information we collect. However, security risk is inherent in all internet and information technologies and we cannot guarantee the security of your personal information.
INTERNATIONAL DATA TRANSFERS
Tradeoo is headquartered in the United Kingdom and may have service providers in other countries. The data can transfer to other countries.
In the case of discovering a child under 16 has provided us with personal data without parents/guardians consent, we will immediately remove it from our servers. If you are a parent or guardian and are aware that your child has provided us with personal data, please contact us so that we will be able to take necessary action.
To the extent, the EU General Data Protection Regulation, which came into force on 25 May 2018, applies to the processing of your personal information you have the following rights and choices:
What are your data protection rights?
Tradeoo is committed to ensuring fair and transparent processing. That is why it is important to us that data subjects can not only exercise their right to object but also the following rights where the respective legal requirements are satisfied:
- Right to information, Art. 15 of the GDPR
- Right to correction, Art. 16 of the GDPR
- Right to deletion (“Right to be forgotten”), Art. 17 of the GDPR
- Right to limit processing, Art. 18 of the GDPR
- Right to data transmissibility, Art. 20 of the GDPR
- Right to object, Art. 21 of the GDPR
To exercise your right, please contact us as indicated in the “How to Contact Us” section below.
In order to be able to process your request, as well as for identification purposes, please note that we will use your personal information in accordance with Art. 6 para. 1 (c) of the GDPR.
You also have the right to lodge a complaint with a supervisory authority pursuant to Art. 77 GDPR in combination with Section 19 GDPR.
How can you withdraw your consent?
If you consent to us processing your personal information, please note that you may withdraw this consent at any time.
If you have consented to receive our marketing mailings, such as newsletters, you may withdraw this consent yourself using the Unsubscribe link in the marketing mailings.
If you have consented to the use of our cookies you can withdraw your consent as explained in our cookie section above.
In all other cases or if you have problems withdrawing your consent on this website, you can contact us as indicated in the “How to Contact Us” section below.
Please note that your consent can only be withdrawn with future effect and such a withdrawal does not have any influence on the lawfulness of past processing. In some cases, we may be entitled in spite of your withdrawal to continue to process your personal information on a different legal basis—to perform a contract, for example.
Information about your right to object pursuant to Art. 21 GDPR
You have the right to object, on grounds relating to your particular situation, at any time to the processing of your personal information based on Article 6 (1) (e) or (f) of the GDPR.
The controller shall no longer process the personal information that relates to you unless the controller demonstrates compelling legitimate grounds for the processing which override your interests, rights and freedoms, or processing is necessary for the establishment, exercise or defense of legal claims.
Where personal information that relates to you is processed for direct marketing purposes, you have the right to object at any time to the processing of your personal information for such marketing purposes, which includes profiling to the extent that it is related to such direct marketing.
Where you object to processing for direct marketing purposes, the personal information that relates to you shall no longer be processed for such purposes.
You have the option of exercising your right of objection in connection with the use of the services of the information company using an automated procedure – notwithstanding Directive 2002/58/EC—in which technical specifications are used.
We may transfer the personal information we collect about you to recipients in countries other than the country in which the information originally was collected.
If you are located in the European Economic Area (“EEA”), we will comply with applicable legal requirements providing adequate protection for the transfer of personal information to recipients in countries outside of the EEA.
Tradeoo recognizes that the EU-U.S. Privacy Shield and Swiss-U.S. Privacy Shield are no longer valid transfer mechanisms for personal information from the European Union and its Member States, the European Economic Area, or Switzerland. The U.S. Department of Commerce, which oversees compliance with Privacy Shield, has stated that it will nonetheless continue to administer the Privacy Shield program and that participants are not relieved of their obligations under Privacy Shield. Accordingly, Tradeoo, as a participant in the Privacy Shield program, will continue to comply with its commitments under the Privacy Shield and its robust internal data protection policies. For data transfers to non-EU countries we will rely, inter alia, on the European Commission approved standard contractual clauses.
We maintain administrative, technical and physical safeguards designed to protect the personal information you provide on the Sites against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure, or use.
Your information is erased as soon as it is no longer required for the purposes stated. Your information is deleted as soon as it is no longer needed for the specified purposes. However, we must sometimes continue to store your personal information until the retention periods and deadlines set by statute, regulation, or supervisory authorities, which may arise, for instance, from the applicable commercial code, tax code or money laundering acts and regulations, expire. These generally amount to six to ten years. We may also retain your personal information until the statutory limitation periods have expired (usually three years, but up to 30 years in some cases), provided that this is necessary for the establishment, exercise or defense of legal claims. After that, the relevant personal information is routinely erased.
We are required by the California Consumer Privacy Act (“CCPA”) to provide to California residents an explanation of how we collect, use and share their Personal Information, and of the rights and choices, we offer to California residents concerning that Personal Information.
Your California privacy rights. The CCPA grants California residents the following rights. However, these rights are not absolute, and in certain cases we may decline your request as permitted by law.
- Information. You can request information about how we have collected, used and shared and used your Personal Information during the past 12 months.
- The categories of Personal Information that we have collected.
- The categories of sources from which we collected Personal Information.
- The business or commercial purpose for collecting and/or selling Personal Information.
- The categories of third parties with whom we share Personal Information.
- Whether we have disclosed your Personal Information for a business purpose, and if so, the categories of Personal Information received by each category of third party recipient.
- Whether we’ve sold your Personal Information, and if so, the categories of Personal Information received by each category of third party recipient.
- Access. You can request a copy of the Personal Information that we have collected about you during the past 12 months.
- Deletion. You can ask us to delete the Personal Information that we have collected from you.
You are entitled to exercise the rights described above free from discrimination in the form of legally prohibited increases in the price or decreases in the quality of our Service.
How to exercise your California rights. You may exercise your California privacy rights described above as follows:
- Right to information, access and deletion. You can request to exercise your information, access and deletion rights, by emailing firstname.lastname@example.org. We reserve the right to confirm your California residence to process your requests and will need to confirm your identity to process your requests to exercise your information, access or deletion rights. As part of this process, government identification may be required. Consistent with California law, you may designate an authorized agent to make a request on your behalf. In order to designate an authorized agent to make a request on your behalf, you must provide a valid power of attorney, the requester’s valid government-issued identification, and the authorized agent’s valid government issued identification. We cannot process your request if you do not provide us with sufficient detail to allow us to understand and respond to it.
- Request a list of third party marketers. California’s “Shine the Light” law (California Civil Code § 1798.83) allows California residents to ask companies with whom they have formed a business relationship primarily for personal, family or household purposes to provide certain information about the companies’ sharing of certain personal information with third parties for their direct marketing purposes during the preceding year (if any). You can submit such a request by sending an email to email@example.com with “Shine the Light” in the subject line. The request must include your current name, street address, city, state, and zip code and attest to the fact that you are a California resident.
We cannot process your request if you do not provide us with sufficient detail to allow us to understand and respond to it.
California Online Privacy Protection Act
According to CalOPPA, we agree to the following:
Users can visit our site anonymously.
Can change your personal information:
- By emailing us
Sharing your personal information
We do not sell, trade, or rent Users personal identification information to others in accordance with the CCPA. We may share generic aggregated demographic information not linked to any personal identification information regarding visitors and users with our business partners, trusted affiliates and advertisers for the purposes outlined above.
If you feel we have been either unable or unwilling to resolve your data concerns you have the right to make a complaint to the supervisory authority for UK Data, the Information Commissioner’s Office (ICO), using the details below:
The Information Commissioner, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF Telephone: 08456 30 60 60
For more information, including a template you can use to raise a concern, please visit the relevant page at the ICO website here: https://ico.org.uk/your-data-matters/raising-concerns/