Privacy Policy
ROOMS2U LIMITED PRIVACY POLICY
Last updated: 24th October 2022
1. Our Company
Rooms2U Limited is a company registered in England and Wales
Company number: 11967528.
Registered office: 48 Arwenack Street, Falmouth, Cornwall TR11 3JH, UK
We respect your privacy and are committed to protecting it through compliance with this Privacy & Cookie Policy and Data Protection law. Before you use our website www.Rooms2U.com or the ROOMS2U Marketplace Web Application please take a few moments to read how we collect and use your personal data.
We may be both a data controller and data processor of personal data and may have a Data Processing Agreement with our partners and affiliates if necessary to ensure that your data is handled appropriately, correctly and in compliance with the General Data Protection Act 2018 (DPA) and the UK General Data Protection Regulation 2018 (GDPR
2. Data we collect
What personal data is collected including the types of information we may collect or that you may provide when you access or use the ROOMS2U app.
Please note that for the purposes of this Policy both the website www.Rooms2U.com and the ROOMS2U Marketplace Web Application developed for iOS, Android or any other mobile devices shall be referred to interchangeably as the “App”;
This policy explains:
· How we collect personal data.
· Why we collect personal data.
· How we use personal data;
· How personal data is shared and with who.
· What choices you have on how personal data is used;
· How long we store your personal data.
· Your rights concerning your personal data.
Only children over the age of 16 (this may vary in your jurisdiction) are allowed to give consent for the use of their data. We cannot ask for or process data from children under the age of 16 without consent from someone who holds parental responsibility for the child given in writing. However, only people over the age of 18 are allowed to use our website which means that we do not collect or process data from anyone under the age of 18.
3. What personal data is collected
We collect information from and about users of the App:
Directly from you when you provide it to us.
Automatically when you use the App.
We do not collect categories of data classed as sensitive data. Please visit the ICO website for more information on this type of data at https://ico.org.uk
4. Categories of Data
Personal information that you provide to us when you access, register with or use the App may include:
Name, gender, title
Postal address
e-mail address
Telephone number
Product specification preferences
Payment card details, CVV, and bank account details
IP addresses
If you are a business; e.g., a seller promoting your goods via the App, we may collect more information from you including photographs of items and specific details about the products or services you sell.
In addition, We may collect other information that is about you but individually does not identify you, such as age, gender or ethnicity.
5. This information may also include:
Information that you provide by filling in forms in the App. This includes information provided at the time of registering to use the App and requesting further services.
We may also ask you for information when you enter a contest or promotion sponsored by Us, when you complete user surveys and when you report a problem with the App.
Records and copies of your correspondence (including e-mail addresses and phone numbers), if you contact Us.
Your responses to surveys that We might ask you to complete for research purposes.
Details of transactions you carry out through the App and of the fulfilment of your orders, including abandoned shopping carts in the App.
Your correspondence within the App with other users.
6. Information from Third Parties
When you use the App or its content, certain third parties may use automatic information collection technologies to collect information about you or your device. These third parties may include:
Advertisers, ad networks and ad servers.
Analytics companies.
Your mobile device manufacturer.
Your mobile service provider.
3.5.2 These third parties may use tracking technologies to collect information about you when you use the App. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites, apps and other online services websites. They may use this information to provide you with interest-based (behavioural) advertising or other targeted content.
We do not control these third parties tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.
For information about how you can opt-out of receiving targeted advertising from many providers, see “CHOICES ABOUT HOW WE USE AND DISCLOSE YOUR INFORMATION”.
7. How personal data is collected
Automatic Information Collection and Tracking.
When you access and use the App, it may use technology to automatically collect:
When you access and use the App, We may automatically collect certain details of your access to and use of the App, including traffic data, location data, logs and other communication data and the resources that you access and use on or through the App.
Device Information. We may collect information about your mobile device and internet connection, including the device’s unique device identifier, IP address, operating system, browser type, mobile network information and the device’s telephone number.
Stored Information and Files. The App may also access metadata and other information associated with other files stored on your device. This may include, for example, photographs, audio and video clips, personal contacts and address book information.
Location Information. The App may collect real-time information about the location of your device. We do not, however, continually collect user location data nor do we collect location data without the user being aware of this. We store the location of a user at set points for example when a user chooses to update location and create/edit an item. Some of our location-enabled Services require your personal data for the feature to work. By accessing or using the App you consent to your data being used for this purpose. You can withdraw your consent at any time via the settings menu. Note, however, that opting out of the App’s collection of location information will cause its location-based features to be disabled.
If you do not want Us to collect this information do not access or use the App and delete the Rooms2U website and any stored cookies from your device’s browsing history.
We may also use these technologies to collect information about your activities over time and across third-party websites, apps or other online services (behavioural tracking).
Please read our Cookie Policy for further information
8. Why we collect your personal data.
Personal data is collected by Us for the following reasons:
To set up and operate your account on the App and to personalise your experience whilst using it. To fulfil and perform our obligations under our contract. Deal with enquiries and payment information. To comply with the law and to make sure you have a safe and secure environment when using our app and services.
9. Our Legal Basis for processing your personal data
Under the GDPR we must always have a lawful basis for using personal data. We use the following legal basis to collect and process your data.
Consent
If you would like to receive newsletters or marketing material from us, you need to give your consent. This consent must be an affirmative action, for example filling a tick box.
This applies to situations where you have expressly provided your consent to receive communications from us. You may also have consented to the use of cookies and other tracking technology.
Contract
We need to use certain categories of your personal data to perform our contract. This includes any pre-purchase, purchase and aftercare. This means we do not need to ask you for your consent to communicate with you about orders, order collections, after-sales service, set up and manage accounts, complete purchases or payments, record your purchase data, give you information about your account, including expiration and renewal notices and keep you updated with any changes in Our terms and policies and renewal notices.
Legitimate Interest
Legitimate interest is used as our legal basis and may in principle apply to any type of processing for any reasonable purpose which is of legitimate interest where you have provided your email address or other personal data to us, either online or offline. We may add you to Our database for emails to contact you about new products, news and events. Certain personal data is also needed for legitimate purposes to prevent fraud, security breaches, and legal violations, for Us to help recommend products to You and to understand more about our customer and targeted customer base as well as to help the Website to switch to the correct currency, language and delivery options if applicable. We may also use the personal data collected under this lawful basis to help us analyse and administer, improve and update the App to deliver a better user experience and to enhance our products and services. Provide you with the App and its contents, and any other information, products or services that you request from Us.
We may also have a legitimate interest to fulfil any other purpose for which you provide the information. Ensure that content from the App is presented most effectively for you and for your computer or device for accessing the App.
Legal Obligation
Certain personal data you provide us is necessary for us to fulfil Our legal obligations as a business, for example, verifying your age and appropriate use of the App, preventing fraud, and security breaches and complying with Our tax and accounting obligations where needed.
10. How we use your personal data
· We use information that We collect about you or that you provide to us, including any personal information, to:
· Improve the App and deliver a better and more personalized experience by enabling Us to:
· Estimate Our audience size and usage patterns.
· Store information about your preferences, allowing us to customize Our App according to your individual interests.
· Understand how you use the app to help us improve ease of use for you and other users
· Speed up your searches.
· Recognize you when you use the App.
We use location data for the following reasons:
· to provide information about items within a fixed distance from a user’s set location;
· to allow others to receive information about a seller’s items available within their search radius.
· We may also use your information to contact you about goods and services that We think may be of interest to you. If you do not want us to use your information in this way, please adjust your user preferences in your account profile.
Please contact us for more information.
11. Security and how we look after your data
We have implemented reasonable measures designed to secure your personal information from accidental loss and unauthorized access, use, alteration and disclosure.
The safety and security of your information also depends on you. Where We have given you (or where you have chosen) a password for access to certain parts of the App, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of the App like message boards. The information you share in public areas may be viewed by any user of the App.
We make every effort and take reasonable steps to make sure that your data and information are safe. We will do our best to protect your personal information. However, subject to GDPR on liability for personal data, we cannot guarantee the security of your personal information transmitted through the App. Subject to GDPR, any transmission of personal information is at your own risk and we are not responsible for the circumvention of any privacy settings or security measures we provide.
12. How personal data is shared and with who
You may provide information to be published or displayed (“Posted”) in public areas of the App (“User Contributions”). Your User Contributions are Posted and transmitted to others at your own risk. We cannot control the actions of third parties with whom you may choose to share your User Contributions. Therefore, We cannot and do not guarantee that your user Contributions will not be viewed by unauthorized persons.
We may disclose aggregated information about Our users, and information that does not identify any individual or device, without restriction.
In addition, We may disclose personal information that we collect or you provide:
· To Our subsidiaries and affiliates.
· To contractors, service providers and other third parties We use to support Our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which We disclose it to them. This also applies to payment processors, web app developers, digital marketing companies and the merchants and sellers with whom we work with.
· To a buyer of our business or another successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of the Company’s assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal information held by the Company about the App users is among the assets transferred.
· To fulfil the purpose for which you provide it. For example, if you give Us an e-mail address to use the “e-mail a friend” feature of the App, We will transmit the contents of that e-mail and your e-mail address to the recipients.
· For any other purpose disclosed by us when you provide the information.
· For any other purpose when you give your consent.
· To comply with any court order, law or legal process, including responding to any government or regulatory request.
· To enforce Our rights arising from any contracts entered into between you and us.
· If We believe disclosure is necessary or appropriate to protect the rights, property, or safety of the Company, Our customers or others. This includes exchanging information with other companies and organizations for fraud protection and credit risk reduction.
13. What choices you have concerning how personal data is used
We aim to provide you with choices regarding the personal information you provide to us. This section describes mechanisms We provide for you to control certain uses and disclosures of your information. You may need to adjust the settings on your device to restrict the collection of information by the App but this may prevent you from accessing all of the features of the App.
Tracking Technologies. You may be able to set your browser or device to refuse all or some browser cookies or to alert you when cookies are being sent. If you disable or refuse cookies or block the use of other tracking technologies, some parts of the App may then be inaccessible or not function properly.
Location Information. You can choose whether or not to allow the App to collect and use real-time information about your device’s location through the device’s privacy settings. If you block the use of location information, some parts of the App may then be inaccessible or not function properly. For example, users can only allow manual geolocation (rather than using their device’s auto-locating functionality), and the provision of at least one piece of location data (i.e. their search location) is a requirement for the App to function.
Promotion by the Company. If you do not want Us to use your e-mail address or other contact information to promote Our own products or services, you can opt out by logging into the App and adjusting your user preferences in your account profile by checking or unchecking the relevant boxes or by sending Us an e-mail stating your request to [email protected]
Disclosure of Your Information for Third-Party Advertising and Marketing. We do not share your personal information with unaffiliated or non-agent third parties for advertising and marketing purposes
We do not control third parties' collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way.
14. Your Data Protection rights
Under the Data Protection Legislation, you have the following rights, which we will always strive to uphold:
· The right to be informed about our collection and use of your personal data. This Policy should tell you everything you need to know, but you can always contact Us to find out more or to ask any questions.
· The right to access personal data we hold about you.
· The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete.
· The right to restrict the processing of your personal data.
· The right to object to us using your personal data for a particular purpose or purposes.
· The right to withdraw consent. This means that, if we are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time.
· The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
· Rights relating to automated decision-making and profiling. However, we do not use your personal data in this way.
You can review and change your personal information by logging into the App and visiting your account settings page.
Please contact us at [email protected] if you would like to exercise any of your rights or request access to, correct or delete any personal information. We will do this free of charge.
Please bear in mind that deleting your personal data will also delete your account.
We will respond to a request to access, correct or delete any data within 30 days.
We do not have to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.
If on your request, We refuse to amend, correct or delete your personal information, We will set out our reasons for not doing so and provide you with details of how you may complain about Our refusal.
If you delete your User Contributions from the App, copies of your User Contributions may remain viewable in cached and archived pages or might have been copied or stored by other users of the App. Proper access and use of information provided on the App, including User Contributions, is governed by Our terms of use.
15. How long personal data is kept
We will only retain personal data for as long as necessary.
When your account is deleted, all personal data relating to private users will be deleted as soon as reasonably practical and possible.
Personal data relating to sellers/merchants that are subscribers to the App for commercial purposes will be deleted when their personal information is no longer necessary for bookkeeping, audit or official purposes.
16. Changes to Our Privacy Policy
We may update this Policy from time to time. If We make material changes to how We treat Our users’ personal data, We will post the new privacy policy on this page with a notice that the Policy has been updated.
The date this Policy was last revised is identified at the top of the page. You are responsible for periodically visiting this page to check for any changes to this Policy.
17. How to contact us
If you have any questions about our privacy policy, the data we hold on you, or you would like to use one of your data protection rights or you would like to correct any inaccurate data, opt-out or cancel your consent. Please do not hesitate to contact us; we have one month to respond to your request.
Your data is important and we take our legal responsibilities seriously. We are more than happy to deal with any issues or questions you may have concerning your data.
If you would like to use any of your rights, please contact us at
Rooms2U Limited
48 Arwenack Street
Falmouth
Cornwall
TR11 3JH
United Kingdom
Or email us at [email protected]
How to contact an appropriate authority
If you wish to make a complaint or you feel that we has not addressed your concerns satisfactorily, you may contact the Information Commissioner’s Office (ICO) at
Information Commissioner's Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Telephone: 0303 123 1113
For more detailed information on your data protection rights, please visit the UK ICO website at https://ico.org.uk