What type of personal information do we collect?
3. We collect certain personal information about visitors and users of our Websites. The most common types of information we collect are things like: email addresses, other contact details, and web analytics data from our websites, our products.
How we collect personal information
4. We may collect personal information directly when you provide it to us, automatically as you navigate through the websites, products or through other people when you use services associated with us.
5. When you provide personal information to us via the Websites you're consenting to us collecting and using that information in line with this policy and the user terms of each of the Websites. You are likely to provide personal information when you complete membership registration and buy or provide items or services on our Websites, subscribe to a newsletter, email list, submit feedback, enter a contest, fill out a survey, or send us a communication. 6. If you choose not to provide personal information, we may not be able to provide you with our services and you may not be able to carry out transactions or access the full range of features available through our Websites.
Personal information we collect about you from others
7. Although we generally collect personal information directly from you, we may on occasion also collect information about you from other people (such as the payment provider account details required to process a transaction) and by using tracking technologies such as cookies, web beacons and other web analytics software or services.
How do we use personal information?
8. We may use your personal information in order for us to:
- To fulfil a contract, or take steps linked to a contract: in particular, in facilitating and processing transactions that take place on the Websites, like where you purchase an item from our marketplace.
- Where this is necessary for purposes which are in our, or third parties, legitimate interests. These interests include:
- operate the Websites and provide you with services described on the Websites
- customise our services and websites, like advertising that may appear on the Websites, in order to provide a more personalised experience
- update you with operational news and information about our Websites and services like to notify you about changes to our Websites
- provide you with information that you request from us or, where we have your consent to do so, provide you with marketing information about products and services which we feel may interest you
- carry out technical analysis to determine how to improve the Websites and services we provide
- monitor activity on the Websites, like to identify potential fraudulent activity and to ensure compliance with the user terms that apply to the Websites
- manage our relationship with you, like by responding to your comments or queries submitted to us on the Websites or asking for your feedback or whether you want to participate in a survey
- manage our legal and operational affairs
- provide general administrative and performance functions and activities.
- Where you give us consent:
- providing you with marketing information about products and services which we feel may interest you; and
- For purposes which are required by law.
- For the purpose of responding to requests by government, a court of law, or law enforcement authorities conducting an investigation.
When may we disclose your personal information?
9. We may disclose personal information to people like:
- subcontractors and service providers who assist us in connection with the ways we may use personal information (as set out above)
- our professional advisers (lawyers, accountants, financial advisers etc)
- regulators and government authorities in connection with our compliance procedures and obligations
- a purchaser or prospective purchaser of all or part of our assets or our business, and their professional advisers, in connection with the purchase
- other people where we are authorised or required by law to do so.
How do we store your personal information?
10. We store personal information on secure servers that are managed by us and our service providers, and occasionally hard copy files that are kept in a secure location. Personal information that we store is subject to security and access controls and data encryption where appropriate.
Choices regarding control of your personal information
11. Where we have your consent to do so (e.g if you have subscribed to one of our e-mail lists or have otherwise indicated that you are interested in receiving offers or information from us), we may send you marketing communications about products and services that we feel may be of interest to you. You can 'opt-out' of such communications if you would prefer not to receive them in the future.
12. If your e-mail address has changed and you would like to continue to receive our e-mails, you will need to access your account and update your e-mail address information in your account and sign-up again for those e-mails that you want to receive.
13. If we send e-mails with commercial content we will generally include an "unsubscribe" facility that you can use to opt-out of further communications – to opt-out, just follow the instructions in the e-mail. We might not include an opt-out facility in important operational and service-based e-mails concerning things like your purchases, the user terms, important updates and need-to-know messages. By using our Websites you agree that we do not need to include opt-out facilities in those messages.
14. You also have choices about cookies, as described below. By modifying your browser preferences, you have the choice to accept all cookies, to be notified when a cookie is set, or to reject all cookies. If you choose to reject cookies some parts of our Websites may not work properly in your case.
Cookies and web analytics
16. Generally speaking, when you visit our Websites, there's certain information that's recorded which is generally anonymous information and may not reveal your true super-hero identity. If you're logged into your account some of this information could be associated with your account. We're talking about the following kinds of details:
- your IP or proxy server IP
- basic domain information
- your Internet service provider is sometimes captured depending on the configuration of your ISP connection
- the date and time of your visit to the website
- the length of your session
- the pages which you have accessed
- the number of times you access our site within any month;
- the size of file you look at
- the website which referred you to our Websites
- the operating system which your computer uses.
When we need to update this policy
18. We may need to change this policy from time to time in order to make sure it stays up to date with the latest legal requirements and any changes to our privacy management practices. When we do amend the policy, the changes will be effective straightaway. We'll usually publish information about changes to be made to this policy on our Websites – but please be aware that it is your responsibility to check in and make sure you keep up to date with any changes to this policy.
If you're a user or visitor in the European Economic Area these rights also apply to you:
For the purposes of applicable EU data protection law (including the General Data Protection Regulation 2016/679 (the "GDPR"), we are a 'data controller' of your personal information.
How you can access your personal information
- You are also entitled to ask us to port your personal information (i.e. to transfer in a structured, commonly used and machine-readable format, to you), to erase it, or restrict its processing. You also have rights to object to some processing that is based on our legitimate interests, such as profiling that we perform for the purposes of direct marketing, and, where we have asked for your consent to process your data, to withdraw this consent as more fully described below.
- These rights are limited in some situations – for example, we can demonstrate that we have a legal requirement to process your personal information. In some instances, this means that we may retain some data even if you withdraw your consent.
- Where we require your personal information to comply with legal or contractual obligations, then provision of such data is mandatory: if such data is not provided, then we will not be able to manage our contractual relationship with you, or to meet obligations placed on us. In all other cases, provision of requested personal information is optional.
- If you have unresolved concerns you also have the right to complain to data protection authorities. The relevant data protection authority will be the data protection authority of the country: (i) of your habitual residence; (ii) of your place of work; or (iii) in which you consider the alleged infringement has occurred.
How can you contact us?