- Important information and who we are
At Localise Ltd (“we”, “us”, or “our”) we are committed to protecting and respecting your privacy and Personal Data in compliance with the United Kingdom General Data Protection Regulation (“GDPR”), the Data Protection Act 2018 and all other mandatory laws and regulations of the United Kingdom.
The individuals from which we may gather and use data can include:
- Business contacts
and any other people that the organisation has a relationship with or may need to contact.
- Who is Your Data Controller
Localise Ltd is your Data Controller and responsible for your Personal Data. We are not obliged by the GDPR to appoint a data protection officer and have not voluntarily appointed one at this time. Therefore, any inquiries about your data should either be sent to us on email at firstname.lastname@example.org or sent in a letter to 71 – 75 Shelton Street, London, WC2H 9JQ, United Kingdom.
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
- Processing Data on Behalf of a Controller and Processors’ responsibility to you
In discharging our responsibilities as a Data Controller we have employees who will deal with your data on our behalf (known as “Processors”). Therefore, the responsibilities described below may be assigned to an individual, or may be taken to apply to the organisation as a whole. The Data Controller and our Processors have the following responsibilities:
- Ensure that all processing of Personal Data is governed by one of the legal bases laid out in the GDPR (see 2.2 below for more information on those bases);
- Ensure that Processors authorised to process Personal Data have committed themselves to confidentiality or are under an appropriate statutory obligation of confidentiality;
- Implement appropriate technical and organisational measures to ensure a level of security appropriate to the risk associated with the processing of Personal Data;
- Obtain the prior specific or general authorisation of the Controller before engaging another Processor;
- Assist the Controller in the fulfilment of the Controller’s obligation to respond to requests for exercising the data subject’s rights;
- Make available to the Controller all information necessary to demonstrate compliance with the obligations laid down in the GDPR and allow for and contribute to audits, including inspections, conducted by the Controller or another auditor mandated by the Controller;
- Maintain a record of all categories of processing activities carried out on behalf of a Controller;
- Cooperate, on request, with the supervisory authority in the performance of its tasks;
- Ensure that any person acting under the authority of the Processor who has access to Personal Data does not process Personal Data except on instructions from the Controller; and
- Notify the Controller without undue delay after becoming aware of a Personal Data Breach;
- Important information and who we are
- LEGAL BASIS FOR DATA COLLECTION
“Personal Data” means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of Personal Data about you which we have grouped together below. Not all of the following types of data will necessarily be collected from you but this is the full scope of data that we collect and when we collect it from you:
- Profile/Identity Data: This is data relating to your first name, last name, gender, date of birth.
- Contact Data: This is data relating to your phone number, addresses, email addresses, phone numbers.
- Marketing and Communications Data: This is your preferences in receiving marketing information and other information from us.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
- The Legal Basis for Collecting That Data
There are a number of justifiable reasons under the GDPR that allow collection and processing of Personal Data. The main avenues we rely on are:
- “Consent”: Certain situations allow us to collect your Personal Data, such as when you tick a box that confirms you are happy to receive email newsletters from us, or ‘opt in’ to a service.
- “Contractual Obligations”: We may require certain information from you in order to fulfil our contractual obligations and provide you with the promised service.
- “Legal Compliance”: We’re required by law to collect and process certain types of data, such as fraudulent activity or other illegal actions.
- “Legitimate Interest”: We might need to collect certain information from you to be able to meet our legitimate interests – this covers aspects that can be reasonably expected as part of running our business, that will not have a material impact on your rights, freedom or interests. Examples could be your address, so that we know where to deliver something to, or your name, so that we have a record of who to contact moving forwards.
- HOW WE USE YOUR PERSONAL DATA
- Our Uses
We will only use your Personal Data when the law allows us to. Set out below is a table containing the different types of Personal Data we collect and the lawful basis for processing that data. Please refer to section 2.2 for more information on the lawful basis listed in the table below.
Examples provided in the table below are indicative in nature and the purposes for which we use your data may be broader than described but we will never process your data without a legal basis for doing so and it is for a related purpose. For further inquiries please contact us.
Contact and/or identity details
When you register with Localise, you will be asked to provide us with your contact information such as your name, your email address, your telephone number and addresses associated with your account. We will use your contact details so that we can communicate with you directly about issues or concerns you or other users have and to send you marketing communications. As a necessary part of participating in the Service, you may share your contact details with any other user you deal with in Localise. We may also ask you to provide copies of identification documents which we will also use along with other contact information you provide for the legitimate interests of verifying your details and helping prevent fraudulent access to the Service or use of your account.
Comments and opinions
When you contact us directly (by email, phone, post or by completing an online form for example), we will store your comments and opinions. We will also store comments and opinions you express when responding to surveys, entering competitions, taking part in promotions we run or that you post in app or other related areas.
We will use your comments and opinions to in the legitimate interests of addressing your queries, issues and concerns and improving our products and services. We will also use comments and opinions you express when posting in app or any other related areas, responding to surveys, entering competitions or taking part in other promotions, to determine products and services that may be of interest to you and to send you marketing communications.
Linked Social Networks
If you choose to connect an account on a social network, such as Facebook, Twitter or Instagram to your Localise account, you are consenting to us collecting personal information from the social network in accordance with your privacy settings on that social network.
The connected social network may provide us with information such as your name, Facebook id, Twitter handle, profile picture, gender, username, user ID, age or age range, language, country, friends list, follower list and any other information you have agreed it can share.
We will use the personal information provided to help create a public profile for you on our Service and, where we provide the functionality, we will also use the information provided to assist you in sharing your experiences on our Service with your friends, followers or contacts on the connected social network.
We may also use the connection between the social network and our Service to provide you with updates on the social network that are relevant to any account you have with us or promotion you are taking part in. Such updates will only be provided with your consent. We will not post to your social network or to your friends, followers or contacts without your consent.
Your relationships with other users:
We may collect information regarding other users and or businesses that you are following on Localise which we use to prioritise items displayed to you in your search results or your timeline based on Localise’s internal algorithms and to determine other products and services that may be of interest to you. We also store information regarding any blocked or banned relationships associated with your account in the legitimate interests of enforcing our Terms of Service and managing user preferences regarding who they wish to communicate with on our Service.
Website and app login details:
When you register with Localise, we will hold your user name and password details in the legitimate interests of keeping your account secure. When and where you are provided with the option to log-in using a social network, for example through Facebook sign- in, we will not be provided with your password or other account login details for those accounts. We will also collect device ID (Android ID, Apple ID, or your browser fingerprint). Browser fingerprints are based on your device type and browser type (including settings and version). Localise will only use the above information in the legitimate interests of keeping your account secure.
You are responsible for all actions taken with your user name, passwords and access to your account and we recommend that you do not disclose your private information to any third parties. If you lose control of your account, you may lose substantial control over your personally identifiable information and may be subject to legally binding actions taken on your behalf, so you should notify us of any unauthorised access to your account.
We hold information about the preferences you set for notifications, marketing communications and how our service is displayed or what content is displayed to you through Localise. We will use your preference settings for the purpose of providing notifications, sending marketing communications, and displaying our Service in accordance with your choices.
Information about how you connect to and use our Site and Service:
We collect information about how you use Localise, such as the pages you view, the time you access Localise, and how long you use it for, the website from where you came to our Site or go to after leaving our Site (if applicable) and any selections and choices you make when using our Site and Service. We also collect information about any items you have searched for, listed, purchased, sold, bookmarked, liked or shared on the Site and Service.
We, and our third party analytics providers, process this data for the following purposes:
- to provide analytics data on the use of the Service, Site and App which we use for the legitimate interests of improving our Service, Site and App;
- to show you your timeline and search results on our Service and order such results in a way that is relevant to you using Localise internal algorithm based on your preferences and, where you have consented to us using your location data, your location;
- to display your items to the most relevant potential buyers using Localise’s internal algorithm;
- to send you tips and other notifications where we think this will improve your user experience of the Service;
- in the legitimate interests of determining the success of our marketing campaigns;
- to send you marketing about products and services we think may be of interest to you;and
- in the legitimate interests of detecting or preventing any breach of our Terms of Service.
Information about your device:
We collect information about the computer, tablet, smartphone or other electronic device you use to connect to Localise. This information can include details about the type of device, unique device identifying numbers, operating systems, browsers and applications connected to Localise through the device, your Internet service provider or mobile network, your IP address and your device’s telephone number (if it has one).
Typically, the information we collect about how you use or connect to Localise is associated with your device and not you as a named individual. However, if you are logged into a registered Localise account, this information may also be associated with you directly.
We use information about your device in order to optimise the presentation and functioning of our Service to you on your device and in the legitimate interests of ensuring that banned users are not able to access Localise by creating a new account.
Information about your location:
Where you give us consent, we will collect and use information about your location, sometimes together with other personal information, to provide features of the Service that are relevant to you and your location. For example, this can include allowing you to search content that is in your local area. If you change your mind about allowing us to use information about your location in the future, you can update your preferences in your device settings.
Information provided by other users:
Sometimes, other users of Localise provide information that is associated with you. Other users can provide information that is associated with you such as comments, feedback and likes relating to your items and recommendations to/interactions with you but this will not result in any information that was not already public, being made public. Where users of Localise want to invite you to use Localise or to share information with you about Localise, we will use personal information that they provide about you to assist them in doing this; we will only do this where they indicate that you have provided your consent for them to communicate with you in this way.
Information about fraudulent or criminal activity relating to your account:
We will use information about fraudulent or criminal activity relating to your use of Localise for the legitimate interests of detecting and preventing fraud or crime and to comply with our legal obligations. We may monitor, including by means of AI, the information you provide to detect potential fraud or breach of Terms of Service.
All personal information:
We may collect personal information from you which is deemed ‘sensitive data’, which may include information about your religious beliefs, physical and mental health details, sexual life or sexual orientation or racial or ethnic origin to comply with our government regulations or guidance or when you have explicitly consented to us collecting this type of information about you. Where you provide sensitive personal information to us on the Service you hereby confirm that you are deliberately making this information public of your own volition and accept that we may request that you remove such data from the Service.
- Marketing and Content Updates
You will receive marketing and new content communications from us if you have created an account and chosen to opt into receiving those communications. From time to time we may make suggestions and recommendations to you about goods or services that may be of interest to you.
If you do not want us to contact you by email, you can change your email marketing preferences by emailing us at email@example.com and letting us know that you do not want to receive marketing emails from us. You can also unsubscribe from our marketing emails by clicking on the unsubscribe link in the emails we send to you.
- Change of Purpose
We will only use your Personal Data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your Personal Data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your Personal Data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
- Our Uses
- YOUR RIGHTS AND HOW YOU ARE PROTECTED BY US
- What Control Do I Have Over Localise Ltd’s Use Of My Personal Data?
You may delete your account at any time – this will remove your account page from our systems and our related software.
We do not guarantee the ability to delete all stored data. If you would like us to delete/correct personally identifiable data, let us know and we will action your request as soon as practicable.
If your account information is protected by a password for your privacy and security. You need to prevent unauthorised access to your account and personal information by selecting and protecting your password appropriately and limiting access to your computer or device and by signing off after you have finished accessing your account.
You can access information associated with your account by logging into your account you created with us.
California Privacy Rights: Under California Civil Code sections 1798.83-1798.84, California residents are entitled to ask us for a notice identifying the categories of personal customer information which we share with our affiliates and/or third parties for marketing purposes, and providing contact information for such affiliates and/or third parties. If you are a California resident and would like a copy of this notice, please submit a written request to firstname.lastname@example.org.
- How Does Localise Ltd Protect Customers’ Personal Data?
We are concerned with keeping your data secure and protecting it from inappropriate disclosure. Any Personal Data collected by us is only accessible by a limited number of employees who have special access rights to such systems and are bound by obligations of confidentiality. If and when we use subcontractors to store your data, we will not relinquish control of your Personal Data or expose it to security risks that would not have arisen had the data remained in our possession. However, unfortunately no transmission of data over the internet is guaranteed to be completely secure. It may be possible for third parties not under the control of Localise Ltd to intercept or access transmissions or private communications unlawfully. While we strive to protect your Personal Data, we cannot ensure or warrant the security of any Personal Data you transmit to us. Any such transmission is done at your own risk. If you believe that your interaction with us is no longer secure, please contact us.
- Opting Out Of Marketing Promotions
You can ask us to stop sending you marketing messages at any time by You can ask us to stop sending you marketing material at anytime by unsubscribing or mailing us at email@example.com.
Where you opt out of receiving these marketing messages, we will continue to retain other Personal Data provided to us as a result of interactions with us not related to your marketing preferences.
- How to Request your Data and the Process for Obtaining it
You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, if your request is clearly unfounded, we could refuse to comply with your request.
We may need to request specific information from you to help us confirm your identity and ensure you have the right to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
- What Control Do I Have Over Localise Ltd’s Use Of My Personal Data?
- YOUR DATA AND THIRD PARTIES
- Will We Share Your Data With Third Parties?
We may share non-Personal Data with third parties. We may share your Personal Data with subcontractors (only when necessary and with your consent) or affiliates (subject to confidentiality obligations to use it only for the purposes for which we disclose it to them and pursuant to our instructions).
We may also share Personal Data with interested parties in the event that Localise Ltd anticipates a change in control or the acquisition of all or part of our business or assets or with interested parties in connection with the licensing of our technology.
- Will We Share Your Data With Third Parties?
- HOW LONG WILL WE RETAIN YOUR DATA FOR?
We will only retain your Personal Data for as long as reasonably necessary to fulfil the purposes we collected it for. We may retain your Personal Data for a longer period than usual in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
- AGE LIMIT FOR OUR USERS
You must not use Localise Ltd unless you are aged 16 or older. If you are under 16 and you access Localise Ltd by lying about your age, you must immediately stop using Localise Ltd.
This website is not intended for children and we do not knowingly collect data relating to children.
- INTERNATIONAL TRANSFER OF DATA
Your information may be stored and processed in the US or other countries or jurisdictions outside the US where Localise Ltd has facilities. We are currently storing data in the EU and so, by using Localise Ltd, you are permitting and consenting to the transfer of information, including Personal Data, outside of the US.
- NOTIFICATION OF CHANGES AND ACCEPTANCE OF POLICY
All uses of the word “including” mean “including but not limited to” and the enumerated examples are not intended to in any way limit the term which they serve to illustrate. Any email addresses set out in this policy may be used solely for the purpose for which they are stated to be provided, and any unrelated correspondence will be ignored. Unless otherwise required by law, we reserve the right to not respond to emails, even if they relate to a legitimate subject matter for which we have provided an email address. As a matter of common sense, you are more likely to get a reply if your request or question is polite, reasonable and there is no relatively obvious other way to deal with or answer your concern or question (e.g. FAQs, other areas of our website etc.).
Our staff are not authorised to contract on behalf of Localise Ltd, waive rights or make representations (whether contractual or otherwise). If anything contained in an email from a Localise Ltd address contradicts anything in this policy, our terms or any official public announcement on our website, or is inconsistent with or amounts to a waiver of any Localise Ltd rights, the email content will be read down to grant precedence to the latter. The only exception to this is genuine correspondence expressed to be from the Localise Ltd legal department.
- Changes to this policy
- Notice to you
- Contacting us
In the event that you have a complaint about our treatment of your personal information, you have the right to lodge a complaint with the supervisory body, the Information Commissioner – ico.org.uk. Details of how do to this are set out in the “for the public” section. However Localise welcomes the opportunity to resolve any complaint and we would suggest you first refer your complaint firstname.lastname@example.org prior to making a complaint to the Information Commissioner.