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PRIVACY & COOKIE POLICY

1.General

This data protection statement applies to the online platform at www.visionoffashion.co.uk  (“Website”) as operated by Vision of Fashion Limited (company registration number 12052753) (“Us”“We” or “VOF”) and to any associated app (“App”) operated by VOF. More details about how to get in contact with us can be found at the end of this data protection statement under Clause 12.

We take your privacy extremely seriously. We will not sell or lease your personal data. All data will be collected, stored and processed by us in accordance with the European Union General Data Protection Regulation No. 2016/679, other statutory regulations and not passed on to any third party unless we are under a statutory obligation to do so, or unless necessary for the provision of our services, or unless you have expressly agreed to the passing on of your data.

The services offered by us via the website and/or app (jointly the “Platform”) can function only if we collect, store, transfer, delete and/or otherwise use (“Process” or “Processing”) specific data relating to you. Personal data means all information relating to an identified or identifiable natural person (“Data”) such as your name, date of birth, address or email address.

This data protection statement describes which of your Data we collect and for what purposes we Process it when you use the services offered by us on the Platform. This data protection statement also contains important information on the protection of your Data, especially the statutory rights you have in connection with it.

Certain services on our Platform are offered by third-party suppliers. When you use these services, the data protection regulations of the third-party suppliers will then apply in addition to this data protection statement. Prior to your use of such services, the third-party suppliers may require you to provide permission under data protection law.

This data protection statement supplements the VOF Terms and Conditions (“Terms and Conditions”) that form the basis of your contract with VOF for the usage of the Platform (“Usage Contract”). In the event of discrepancy between the Terms and Conditions and this data protection statement, the provisions of the latter shall apply.

  1. 2Which of your data do we Process?

2.1 Connection to Website and App

When you connect to the Website or App, we Process the following data (logfiles), even if you are not logged in to the Website as a member:

  • the IP address of your device;
  • the browser used by your device;
  • the content and URLs you connect to;
  • the date and time of your connections

In the event of access via mobile devices, the following logfiles are also captured as part of your use of the VOF App:

  • model and manufacturer of your mobile device;
  • the operating system used by your mobile device (iOS, Android).

Without your express permission we will not use the personal data specified in this section, especially the IP address, unless such use is necessary (i) for the provision of our services and/or (ii) for security purposes, especially the prevention of cyber attacks such as data scraps and denial of service attacks and for preventing impermissible multiple applications.

2.2 Registration as member

In order to use our Platform, and especially to undertake commercial transactions via the Platform, to use the electronic payment system or to leave reviews and communicate with other members, you need a VOF account. For this purpose, you must register as a member on the Website or any App.

(a) Registering an account

You will be asked to enter the following details on our Website or App:

  • Email address (mandatory info for the use of the Platform)

An automatic email will be sent to this email address with a unique password. This password can be change in the “My Account” – “Account Details” setting.

Your member name will be visible to all visitors to the Website and users of the App. Other data you provide as part of the registration process will not be visible. Your member name can be a pseudonym and does not have to be the same as your real name.

2.3 Completion of your profile

After registering, you can add optional information to your profile. Go to “My settings” in your account.

  1. a) Account details

Under “Account details” you can add the following data:

  • First name and surname
  • Display name

(c) Addresses

Under “Addresses” you can add your Billing address and Shipping Address

We will process your data which is necessary to provide shipping services. The transferred data includes:

(d) Payment

Under “Payment Method” you can enter the details for payment method (card number, expiration date and CVC) to which payment is to be made by purchasers of the items you sell via the Platform. To make it easy to provide this information, you can save your account details under “Payment”. Otherwise your account details will of course not be visible to anyone.

2.4 Use of Platform for transactions

We will store and Process Data on your transactions on the Platform (e.g. item, price, time of transaction etc.). You can see this Data in the transactions overview of your account.

If you sell items on our Platform, we collect additional Data that you create when you offer the items for sale, particularly photos and video as well as text and other descriptions (e.g. brand, price, size, condition, colour etc.), payment methods accepted, location, item comments etc. This Data will be visible only to visitors to the Website and users of the App.

We might also ask you to provide us with a proof of payment authorization (i.e. bank statement, phone verification, PayPal account screenshot, credit card picture).

 

2.5 Use of the PayPal electronic payment system

Payment via PayPal

If you use the PayPal electronic payment system, PayPal will collect the payment information required according to the payment method selected. Payment will then be implemented via PayPal. To this extent, the data protection regulations of PayPal will apply. For more information on payment procedure and payment service providers, see no. 12 of our Terms and Conditions. If you use a credit card as your payment method, VOF will see only the last four digits of your card number. This information will be used by us solely for the purpose of confirming payment and preventing fraud.

2.6 Communication, comments and reviews

When you use our services, we also collect the following Data:

  • News that you share with other members via the Platform;
  • Comments you leave regarding items offered for sale by other members;
  • Reviews
  • Your communication with other users.

For technical reasons, this content generated by you will remain online after the end of your user agreement. Nonetheless your member name will not be visible and there will be a note stating that the content comes from a member who is no longer active.

2.7  Location data

When you register at VOF we will process the location data collected via your App or web browser (as part of your IP address). This data (your country, city) will be shown on your profile. You can edit information on your city at any time.

  1. Purposes for which we Process your Data

Insofar as not already specified under 2, we will Process your Data for the following purposes.

3.1 Provision of our services

We will Process your Data for the purposes of performing the usage agreement, for providing the services used by you on our Platform

  • and for facilitating your buying and selling of items
  • for providing shipping services via our partners
  • for facilitating the electronic processing of payments for goods bought and sold on the Platform
  • for verifying your identity and details
  • for facilitating communication with other members
  • for sending you messages necessary for the provision of our services
  • for providing an overview of your transactions on the Platform (transaction history)
  • to show you offers from other members that might interest you (as described in the section 3.6 below)
  • to be able to offer our services free of technical errors and to be able to recognise and resolve any errors
  • to protect you in case we notice suicidal posts (as described in the section 3.7 below).

3.2 Legal rights, improvement of our Platform, prevention and detection of inadmissible activity, system security

We will also process your Data to protect the following legitimate interests of VOF and/or any third parties:

  • Resolution of disputes, enforcing our Terms and Conditions and the enforcement, exercise and upholding of our rights
  • Analysis and evaluation of usage of our Platform for the purposes of continual improvement of our products and services
  • Prevention, detection and prosecution of unlawful activity, especially fraud
  • For security purposes – by giving each member a “trust score” calculated using an algorithm and maintaining a black base of user’s personal data suggesting unlawful activities. The “trust score” indicates the likelihood of misuse of the Platform. Our algorithm takes into account users’ comments on a forum, messages to other users, items listed on the platform, transactions, reports on the user by other users, the user’s profile and contact information, the user’s violations of our Terms of Services, IP addresses, and browser fingerprints, other content the user provides us with. Where evaluation of the user reaches certain thresholds, the usage of the platform by the user is restricted or the user is asked to verify his / her telephone number
  • Guaranteeing the security of the Platform, the protection of the Data we hold and the detection of cyber attacks and other threats to the integrity of the Platform
  • Compliance with applicable tax obligations

3.3 Creation of anonymous user profiles

VOF will use the Data gathered during registration (see above under 2.2) and during profile creation (see 2.3), the Data on your forum activity (see 2.6), your logfiles (see 2.1) and your usage data as collected via cookies (see below under 8) to create an anonymous user profile (“User Profile”).

Unless permission is provided, VOF will under no circumstances use this User Profile in such a way as to allow a connection to be established between it and a specific person. This means that VOF will not be able to establish the member’s identity. VOF further guarantees that, without permission, anonymous user profiles will not be combined with users’ other personal Data for any technical, personal or administrative purpose.

VOF will create and use User Profiles in pursuit of the following legitimate interests:

  • We will use User Profiles to analyse and understand members’ behaviour. For essential and often-used services of the Platform, this understanding will enable us to improve existing services and/or add further services.
  • Members will receive personalised marketing messages based on the User Profile created. This means that users will receive marketing messages based on their interests and User Profile. Marketing messages will be sent on the basis of advertisers involved with the Platform and, provided permission has been granted, via email to the address provided on registration or to the mailbox held within the Platform account (messages or mailbox).

3.4 Email newsletter and other marketing emails

You can register for our newsletter and for other marketing emails (“Marketing Emails”). When you register, we will ask you for your permission to Process your email address for the purposes of sending you Marketing Emails containing the latest information on our products and services, especially with regard to goods available on the Platform, special offers and marketing campaigns. You will receive Marketing Emails only if you have given permission.

Your permission also includes your agreement that we may personalise the content of Marketing Emails in accordance with your needs and interests on the basis of any User Profile that may have been created for you (see 3.3). Where you have also permitted us to use cookies and to track your user behaviour on our Platform (see 8.2 below), this permission also includes Data on your use of our platform.

Your permission for the sending of Marketing Emails can be withdrawn by you at any time with future effect. In your VOF account, you can adjust your settings to block the sending of any further Marketing Emails. Alternatively you can click “Unregister” at the end of the Marketing Email. Withdrawal of permission will not affect the lawfulness of Processing carried out prior to withdrawal of permission.

3.5 Account verification for security purposes

We may request you to give us your phone number for the purposes of account verification. You will receive a code via a text massage sent to the phone number you have provided. You will not be able to continue using the App until you have entered the code. Until then, your usage of the Platform will be blocked. In addition, we encourage you to secure your account to verify it yourself via telephone number. Your phone number will not be visible to Platform users and will not be used by us for any other purpose, and especially not for marketing purposes.

We might also ask you to provide us with a proof of payment authorization (i.e. bank statement, phone verification, PayPal account screenshot, credit card picture).

3.6 Personalization of feed​

In order to show you the items that are relevant to you we will profile you and personalize your feed based on your gender, age, country, preferences, the information about category, brand, colour, condition, price, size of the purchased items and purchasing history. We have a legitimate interest to personalize your feed under Art. 6 (1)(f) of EU General Data Protection Regulation
 – our platform will be more convenient for our users and, due to personalization, you will see offers from other members that might interest you the most.

3.7 Reporting suicidal posts

In exceptional cases, where we notice suicidal posts on our platform, we may report them to the police. In such cases we will disclose your user name, e-mail address, name, IP addresses and last logins, telephone number (if verified), print screen / link of forum post or thread where the declaration of suicide appears. In such cases we disclose the data to protect your vital interests under Art. 6 (1)(d) of EU General Data Protection Regulation.

3.8. Contacting you for opportunities

We may contact you via e-mail or inbox message to offer you to share your content on our social media profiles or to participate in our marketing campaigns. This is to increase yours and VOF’s publicity or to provide you with earning possibilities which is a legitimate interest under Art. 6(1)(f) of General Data Protection Regulation.

3.9. Sharing your photos and other content on VOF‘s social media

If you allow us, we will post your content on our social media accounts. In this case we will use your content only for the said purpose based on your consent (Art. 6(1)(a) of the General Data Protection Regulation).

3.10 Conducting advertisement campaigns involving you 

If you consent to participate in our advertisement campaigns, we will use your telephone number to contact you with a proposal to participate in our advertisement campaign and give you more details about the project. If you provide your address and room photos we will use them to arrive at your place and film the advertisement. This data may be transferred to our partners (advertising agencies, directors) that are responsible for implementing the advertisement campaign. We will collect your date of birth, nationality and information about your business certificate or individual business activity status to complete and perform a contract between you and VOF. If you provide your consent, we may also use your name, age, city or story to include them in advertising campaign. We will use the mentioned data based on your consent (Art. 6(1)(a) of the General Data Protection Regulation) or to perform a contract between VOF and you in case one is concluded (Art. 6(1)(b) of the General Data Protection Regulation).

  1. Online security

Access to your account is protect by a password set by you. Do not disclose your password to anyone. Once you have finished using VOF, remember to log off by using the log-off button, especially if you’re using a public computer. Please note that the transfer of data via the Internet (e.g. via email) is not always totally secure and the prevention of access by third parties cannot be guaranteed.

We will take all technical and administrative security measures required to protect your Data from unauthorised loss and access as well as from unauthorised amendment, disclosure or deletion. Access to your Data is limited to those persons who require it for the purposes described in this data protection statement. Such persons are bound by the applicable data protection laws.

  1. Contract processing

VOF may appoint external service providers to provide specific services. These service providers will undertake data processing procedures on our behalf and at our instruction (contract processors). VOF will select contract processors carefully and in accordance with applicable data protection laws. It will also ensure that Processing is carried out in accordance with the provisions of any written contract and with statutory data processing regulations.

The procedures carried out on our behalf include:

  • the provision of the technical infrastructure for the Platform and the provision of server space
  • shipping services
  • online and usage analysis
  • account verification
  • customer service and enquiry processing
  • payment processing and escrow
  • trust in and security of the Platform (e.g. prevention of fraud and harassment).

The contract processors appointed by us may under certain circumstances be granted access to your personal Data but solely for the purpose of the data processing requested. Contract processors are also contractually required to ensure that the level of their data protection is at least equivalent to that provided by us. All Data processed on our behalf remains under our control. We continually monitor compliance with our instructions, with guaranteed levels of data security and with contractual agreements formed with the data processor.

Some of these service providers may be in countries outside the EU/EEA whose data protection levels are viewed within the EU/EEA as inadequate. We have nonetheless formed appropriate agreements with these service providers (or there are other guarantees in place) that ensure that all necessary measures will be taken to protect your data in accordance with the applicable requirements. If you have any questions about our service providers, please contact our Platform help centre. If your question is not answered there, please contact us via email at info@visionoffashion.co.uk As a minimum, we will always supply on request any additional information on the guarantees we have put in place (or where applicable a copy of this information via email).

  1. Capture of public content by external search engines

Your member name, selected language, profile photo and the “About you” details in your profile (see 2.2. and 2.3 above), all other content published by you, e.g. items offered for sale, forum posts, comments on items (see 2.4 and 2.6 above) as well as the date of your registration and the time of your last log-on will be freely available online and thus included in external search engine results. We therefore advise you not to publish any addresses, mobile numbers, email addresses or other contact data or sensitive or private information.

  1. Disclosure of your Data to third parties 

VOF is statutorily obliged to provide personal and/or usage Data to investigative, criminal prosecution or supervisory authorities if and insofar as required for the avoidance of risk to the public and for the prosecution of criminal acts.

VOF may share your Data with third parties when transferring rights and obligations pertaining to the contractual relationship between you and VOF to such third parties in accordance with the Terms and Conditions https://visionoffashion.co.uk/terms-and-conditions-2/ in particular in the case of the transfer of a sector of activity, a merger through the foundation of a new company, a merger through absorption, de-merger or any change in control affecting VOF. Prior to such event VOF will inform you separately about the details of sharing your Data and will obtain your consent where legally necessary.

In all other cases your Data will be passed on to third parties only where you have granted permission or have yourself given third parties access to your Data (not including third parties that we have commissioned as contract processors, see 5 above).

  1. Use of cookies

8.1 Required cookies

Cookies are small text files that our Platform wants to place on your computer or other online devices such as tablets or smartphones. Provided your browser settings accept cookies, your browser adds the text in the form of a small file.
Unless stated otherwise elsewhere in this data protection statement, the cookies we use are necessary for the functionality and performance of our Platform. This includes cookies that enable you to register for the protected areas of our Platform, to buy an item or to use the electronic payment system. Most cookies are deleted from your device after the end of your browser session (session cookies). The information saved in the required cookies will be used by us solely to provide the services and functions requested.

8.2 Cookie consent

When you access our Platform, we will ask for your consent to place additional cookies on your device by showing you a cookie banner and obtaining your permission. These cookies are not strictly necessary for the functioning and performance of our Platform, but they do help us 

  • to recognise how many visitors visit our Platform and how they behave when they are here. This helps us to improve the functionality of our Platform, e.g. by ensuring that users can find what they are looking for (analytic/performance cookies) and by helping us
  • to recognise you when you re-visit our Platform. This helps us to personalise our content for you, greet you by your name and note your preferences (functional cookies) and
  • to capture your visit to our Platform and which pages you visit and which links you click on. We will use this information to better tailor our Platform, and the advertising we show you, to your interests. If you have given us your permission to send you Marketing Emails (see 3.4 below), we will also use this information to send you personalised Marketing Emails (targeting cookies).

The cookie banner will tell you why we use cookies. In continuing to use our Platform after we have displayed the cookie banner, you consent to our using cookies for the aforementioned purposes (“Cookie Consent”). 

Further information on cookie usage by VOF and on how you can withdraw your consent or decline to accept cookies can be found below.

8.3 Managing your cookie settings

You can configure your browser to decline some or all cookies or to ask for your permission before accepting them. If however you decline cookies, some of our services may have restricted functionality. For information on how to adjust or change your browser settings, visit www.aboutcookies.org or www.allaboutcookies.org. If you use multiple devices to access our Platform (e.g. smartphone, tablet, computer etc.) you must ensure that each browser is adapted to each device in accordance with your cookie preferences.

8.4 Use of third-party cookies


When you use VOF online services, you may be targeted with cookies or web beacons from other providers for the purposes of gathering information. This may be for the purposes of range measurement or the activation of contextual advertising or targeting campaigns. On the basis of your permission for the use of cookies, we will also evaluate user profiles under a pseudonym. No personal identification will be possible. These third-party tracking technologies and their use are not controlled by us.


You can prevent storage of, and tracking by, such third-party cookies by adjusting your browser settings.

 

8.5 Description of Cookies

 

For overview of the cookies We use on the Platform, please refer to our Cookies Policy.

 

  1. Right of amendment


As we are constantly developing our services, we reserve the right to change this data protection statement at any time subject to the applicable regulations. Any changes will be published promptly on this page. Regardless of the aforementioned, you should check this page regularly for any updates.
 

  1. Duration of storage of your data 


Unless stated otherwise on this data protection statement or provided for by statute, we will save

  • the personal Data specified under 2.1 for 30 days from the date of its collection
  • in case we become aware of a violation of VOF Terms & Conditions of use or that Data specified under 2.1 is necessary for legal proceedings related to VOF – we will store the personal Data specified under 2.1 for 1 year following the moment we became aware of the aforementioned circumstances or for the duration of the said legal proceedings, depending on which one of these periods is longer – we will do this for the purposes of legitimate interest of VOF (to ensure the security of our Platform) (Art. 6(1)(f) of the EU General Data Protection Regulation)
  • in case you had transactions concluded via the platform – we will store your personal Data for 13 months following the date of the transaction for the purposes of our legitimate interests (to protect our rights and interests in case a chargeback dispute is initiated against us) (Art. 6(1)(f) of the EU General Data Protection Regulation)
  • where applicable under law, for tax reporting purposes: your full name and address, the place of commencement of transportation or dispatch and destination, timing and amount of your turnover for a period of 6 years (or other period prescribed by applicable law) from the moment of relevant data collection
  • all other personal Data specified in this data protection statement for three months from the date of deletion of your VOF account or for three months after five years of inactivity on your account (or from the moment you have been blocked in case you have violated the Terms & Conditions)
  • in case you have been blocked for a violation of VOF’s Terms & Conditions
    – your Data (email, address, IBAN, phone numbers) will be stored for 2 (two) years following the moment you have been blocked. We will do this for the purposes of legitimate interest of VOF and our users (to ensure the security of our Platform and other users) pursuant to Art. 6(1)(f) of the EU General Data Protection Regulation.
  • We will contact you if your items are inactive for 18 months. If you do not, within 7 days, make a choice, to keep these old listings, we will delete your items.

We may store your personal Data longer than the above mentioned periods to the extent that your personal Data is necessary for compliance with our legal obligations, in particular statutory retention periods, and for the establishment, exercise or defence of legal claims.

  1. Your statutory rights regarding your Data

Under statutory data protection provisions, you have the right at any time:

  • to be informed of the Data we Process and to demand a copy of the data concerned (right to be informed). All the Data that you have actively provided for us on the Platform (2.2 to 2.6) can also be accessed by you at any time in your VOF account;
  • to demand the correction of inaccurate Data and, subject to the nature of the Processing, the completion of incomplete Data (right to rectification). All the Data that you have actively provided us with on the Platform (2.2 to 2.6) can also be amended by you yourself at any time in your VOF account (except sent messages and any forum posts or reviews); 
  • subject to just cause, to demand the deletion of your Data (right to deletion);
  • to demand restriction of the processing of your Data, provided the statutory criteria are met (right to restrict processing);
  • subject to the statutory criteria being met, to receive the Data you have provided in a structured, current and machine-readable form and to transfer this Data to another processor or, where technically feasible, to have it transferred by VOF (right to data portability); and
  • to be subject to decision-making not wholly reliant on automated Processing, unless the statutory conditions for such automated decision-making are met. VOF does not currently operate automated decision-making
  • to object to the processing of data – only where the processing is based on a task carried out in the public interest or in the exercise of official authority vested (Art. 6 (1)(e) of the EU General Data Protection Regulation) or legitimate interest (Art. 6 (1)(f) of the EU General Data Protection Regulation ), including profiling, based on the same data processing grounds as explained in other sections of this statement (right to object). 

You also have the right on exceptional grounds to opt out of the statutory Processing of your Data. Where your personal Data are Processed for direct marketing purposes, you can object to such Processing (right to object).

You further have the right to withdraw at any time any permission you have provided as part of registering for or using our services. Such withdrawal will not affect the lawfulness of Processing carried out prior to withdrawal and based on the permission granted. Where permission for cookies is concerned, you can use the deregistration and deactivation mechanisms set up for the various services (see data protection statement for the individual services under 8.2 and 8.4 of this Website). This will result in a permanent deactivation cookie being placed in your browser, thereby signalling to us that your browser should not be subject to such data capture. Please note that, if you remove all cookies that have been placed in your browser, the deactivation cookie too will be deleted. To above process will have to be completed by you again if you use our Platform with another device or another browser.

You can withdraw your permission for the sending of our newsletter by adjusting your VOF account settings to block the sending of any further Marketing Emails. Alternatively you can click “Unregister” at the end of the Marketing Email.

To exercise any of the rights specified in this section, you can contact VOF using the contact details below. Regardless of any other legal remedy, you also have the right at any time to submit a complaint to the supervisory authorities.

  1. Our contact details

If you have any queries regarding the Processing of your data as part of your use of the Platform, or regarding your rights, please contact our data protection officer at info@visionoffashion.co.uk

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