Privacy Policy - Kiosk

Introduction

ecoATM International Limited (“ecoATM UK”, “we”, “us” and/or “our”), with a business address of 5A Frascati Way, Maidenhead SL6 4UY, is an affiliate of ecoATM, LLC, with a business address of 10121 Barnes Canyon Rd, San Diego, CA 92121, and operates the Gazelle kiosk (“Kiosk”) in the UK, to purchase used consumer electronics, such as tablets, mobile phones, or MP3 players (“Devices”). This Privacy Policy may use the term “Services” to describe the functionality and use of the Kiosk, as well as use of associated services, such as contacting our customer support team.

We collect personal information to provide you with the products and services you request as well as information on other products and services offered by or through us. We are committed to protecting the privacy of your personal information.

ecoATM UK will be the controller in respect of any personal data collected through the use of the Kiosk and Services, which means we control the way information is used and processed.  We may be contacted via the following email address: ecoatmlegal@ecoatm.com

Please read this Privacy Policy carefully before submitting any information about yourself to us. If you do not wish to have your personal data processed as described in this policy, you should not use the Kiosk or Services.

About this Policy

This Privacy Policy explains how and why we acquire and use your personal information when you use our Kiosk Services. When you use any of our websites, please refer to the privacy policy for that website.

Types of Information Collected and Processed

We may collect, store, and use the following categories of personal information about you:

Identity Data

Title, first name, last name, username or similar identifier, date of birth, identification card number and gender, copy of your driver’s license and related details such as your name, address, place of birth, driver number, and photograph,

Contact Data

Address, email address and telephone numbers.

Financial Data

Bank account and payment card details.

Transaction Data

Details about payments to and from you and other details of the transaction in which you used the Kiosk. These include:

Technical Data

Marketing and Communications Data

 

Fair and lawful processing

We are required by law to process personal data only if we have a lawful basis to do so. The lawful basis are specifically set out within data protection law and any processing which we do must fit within one of those basis. We cannot create a new reason because what we want to do does not fit within the lawful basis set out in the data protection law. The types of lawful basis that exist are:

We have set out in the table below examples of how we use your personal information and the lawful basis for doing so as described in this policy.

Activity

Data used

Lawful basis for processing

Providing our Kiosk service to you and device trade in

Identity, Contact Financial, Transactional, Technical

Performance of Contract

Necessary for our legitimate interests to provide our services

Internal administration of Kiosk, internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes

Identity, Contact Financial, Transactional, Technical , Aggregated, Marketing and communications

Necessary for our legitimate interests for running our business and provision of Kiosk.

Improving the service

Identity, Aggregated, Technical, Usage

Necessary for our legitimate interests of to help with product development,

Maintaining the Security of Kiosk

Identity, Contact, Technical, Usage

Necessary for our legitimate interests of ensuring the security of our Services.

Marketing - to deliver relevant advertising to you and make offers to you

Marketing and communications, Contact, technical, Usage

Consent- where you have opted in to receive marketing

Complying with a court order, or to exercise or defend legal claims

Identity, Contact

To comply with a legal obligation

Complying with other requests from third parties where required and lawfully permitted

Identity, Contact, Aggregated, Technical, Usage

To comply with a legal obligation

 












































Disclosing your information

We may disclose your information to third parties from time to time, the categories of recipients are as follows:

We may also share your personal data in the event that our business, or substantially all of its assets are acquired by a third party, (in which case personal information about customers might be one of the transferred assets).

 

Transferring your Information

The data that we collect from you at the Kiosk may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. Such staff maybe engaged in, among other things, the provision of support services.

If data is transferred by us from within the EEA to a jurisdiction outside the EEA, it is done so in accordance with applicable data protection laws. We rely on the following appropriate safegaurds to transfer your information:

a. Model Clauses: The European Commission has adopted standard contractual clauses (also known as Model Clauses), which provide safeguards for personal information that is transferred outside of Europe. We may use these Model Clauses when transferring personal information outside of Europe.

b. Privacy Shield: We may rely on the EU-US Privacy Shield to transfer personal information to some of our third party service providers in the United States, where they are certified to receive such information under the Privacy Shield Program.

Your rights

You have the following rights under certain circumstances:

• Right to request correction - to make changes or corrections to your information to make sure it is accurate and up to date;

• Right to object to processing - ask us to stop processing your information;

• Right to request access - receive a copy of the information we hold about you - you may request details of personal information which we hold about you at any time (a Data Subject Access Request or DSAR). No fee will be required, although reasonable fees can be charged for manifestly unfounded or excessive requests;

• Right of portability - transfer your information to a third party; and

Where you have provided consent for data processing, you can withdraw this consent at any time.

If you have any requests to exercise your data information rights you can send an email to ecoatmlegal@ecoatm.com.  

You have the right to lodge a complaint about us to the UK Information Commissioner's Office (https://ico.org.uk/) or the relevant authority in your country of work or residence.)

Security

We take commercially reasonable steps to protect and secure information about you from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction.

Retention of information

We may keep your details on record for as long as is reasonably necessary for the purposes for which it may use your personal data, as set out above and as allowed in accordance with applicable data protection law.

The criteria we use to determine data retention periods for your personal data includes the following:

Please note that we reserve the right to retain certain information for our own record-keeping (for example, to ensure that you do not receive marketing communications that you have opted-out of receiving) and to defend ourselves against any claims.

Third Party websites

We may, from time to time, provide you with links to and from the websites of others, to include partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these privacy policies before you submit any personal data to these websites.

Marketing

We will send you marketing according to what you have indicated you would like to receive. We determine your marketing preferences during the sign up process. If you would like to stop receiving marketing, to do this you will need to contact ecoatmlegal@ecoatm.com by email to withdraw your consent or click the “unsubscribe” link in the direct marketing email you may have received. Please note that if you do withdraw your consent and there is no alternative lawful reason which justifies our processing of your personal data for a particular purpose, it may mean that you cannot receive some marketing communications.Changes to this Privacy Policy

We will occasionally update this Policy as our business and products evolve. If we make changes, we will provide notice of such changes by revising the date at the top of this Policy and, in some cases, we may provide you with more prominent notice (such as sending you a notification). We encourage you to review this Policy from time to time to stay informed about our information practices and the ways you can help protect your privacy.

Contact us

If you have questions, concerns or suggestions, please feel free to send an email to: ecoatmlegal@ecoatm.com

You can also address questions, comments and requests to: ecoATM International Ltd., 5a Franscati Way, Maidenhead, Berkshire, SL6 4UY

Last updated May 4, 2019