Privacy Policy - Website (last updated: 5/3/2019)

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 operates the Gazelle kiosk (“Kiosk”) and Gazelle website in the UK,  https://uk.gazelle.com, (“Website”). This Privacy Policy may use the term “Services” to describe the functionality and use of Website.

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 Website and 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 shouldn’t use the Website.

About this Policy

This Privacy Policy explains how and why we acquire and use your personal information when you visit our Website. When you use any of our kiosk services, please refer to the privacy policy for the Kiosk and if you use any of our other websites, again 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

Contact Data

Address, email address and telephone numbers.

Usage Data

Marketing and Communications Data

Information we receive:

When you use our Website, we may automatically collect information in order to allow us to operate and provide the Services, analyse and improve how our Services are used and provide a personalised experience for our users.

We may receive information about you if you use any of our other websites that we operate (such as ecoATM.com and gazelle.com) or the other services we provide, such as our kiosk. In this case we will have informed you when we collected that data that it may be shared internally and combined with data collected on this Website. Please refer to the applicable privacy policy where you have used one of our other sites or services. We also work closely with third parties (including, for example, business partners, sub-contractors in technical, payment, verification and delivery services, advertising networks, analytics providers, search information providers) and may receive information about you from them. You may ask us to provide you with information about our services or about services offered jointly with or on behalf of other organisations by sending us an e-mail to ecoatmlegal@ecoatm.com

As you interact with our Website we may automatically collect technical data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive technical data about you if you visit other websites employing our cookies. Please see our Cookie Policy for further details.

You may give us information about you so we can provide the Services, which may be provided by filling in forms on our Website or by corresponding with us by phone, e-mail or otherwise. This includes information you provide when leave us your feedback, search for a product, download any content from our Website, enter a promotion or survey and when you report a problem with our site. Information you give us will not be made public on the Website unless otherwise stated.

We shall not request from you any personal information, which is deemed special category personal  data, including without limitation, information regarding religious or other beliefs, physical and mental health details, sexual life, racial or ethnic origin, trade union membership and/or offences, and we ask that you do not to supply us with any sensitive personal data

Cookies

Our Website uses cookies to distinguish you from other users of our Website. This helps us to provide you with a good experience when you browse our Website and also allows us to improve our Website. For detailed information on the cookies we use and the purposes for which we use them see the Cookies Policy.

How we Use the Information we Collect

We use your information in the following ways:

Please note that should you make use of one of our Kiosks to receive additional services, you will be provided with a further privacy notice in respect of such services.

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

Administration of website, 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 website.

Improving the service/ Website

Identity, Aggregated, Technical, Usage

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

Maintaining the Security of Website

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 disclosure 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 share also 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 players or marketing prospects might be one of the transferred assets).

 Transferring your Information

The data that we collect from you via our Website 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:

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 contact us at 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 legal claims.

Third Party websites

Our Website may, from time to time, contain 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 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 us by email at ecoatmlegal@ecoatm.com to withdraw your consent or click the “unsubscribe” link contained 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

 

Cookie Policy

This policy explains what cookies we use and why we use them. We recommend that you read the policy fully. For more details about your personal data please refer to our Privacy Policy, above.

What are Cookies?

Cookies are small text files that are stored by the browser (for example, Internet Explorer) on your computer or device. You can think of cookies as providing a memory for the website, so that it can recognise you when you come back and respond appropriately.

They are not harmful to your devices (like a virus or malicious code) and allow you to use many of the useful features of our websites (like remembering your favourites).

Cookies have a lifetime. Some only last until you close your browser or a short time. These are called “session cookies.” Some last longer though, for example, to enable a website to recognise you when you return to them. These are called “persistent cookies.”

Cookies placed directly by a website owner (like us) are known as “first-party cookies” and most modern websites also use technology provided by other people/businesses, for example to provide online advertising. Cookies placed by other parties are known as “third-party cookies.” When visiting our website, you may receive both first-party cookies and third-party cookies. These third-parties are responsible for setting out their own cookie and privacy policies, so please check their websites for more information about their cookies and how to manage them. The third-party cookies may include:

Google Analytics 360

Google Tag Manager

Facebook Tags

Criteo Tags

Google Adwords

Session Cam

Google Search Console

ShareASale

Optimizely

Youtube

How we use Cookies?

We use cookies to understand your use of our Website; improve your user experience and enable personalised features and content; optimise our advertisements and marketing; and to enable third-party advertising companies to assist us in serving ads specific to your interests.

The types of cookies that we use are:

Strictly necessary cookies: These cookies are essential to enable you to move around our website and use its features, such as accessing secure areas of the website. These cookies prevent crashes, display information, fix bugs and ensure the security of our website. Without these cookies, some functions of the website cannot be provided.

 

Functionality cookies: These are cookies that allow our website to remember choices you make (such as your user name, language or the region you are in) and to provide enhanced, more personal features. These cookies can remember changes you have made to text size, fonts and other parts of web pages you can customise. They may also be used to provide services you have asked for, such as watching a video or commenting on a blog.

Performance cookies: These cookies collect information about how you use our websites, for example which pages you go to most often and if you get an error message. These cookies are used to improve how our website works.

Targeting or advertising cookies: These cookies are used to drive online advertising that is relevant to you by building up a picture of what you are interested in from your use of the internet. The cookies can limit the number of times you see an advert and help to measure the effectiveness of any advertising. They remember that you have visited a website and this information may be shared with other organisations or advertisers. Quite often targeting or advertising cookies will be linked to website functionality provided by the other organisation.

Cookie

Name

Purpose

Type of Cookie

Google Analytics

_utma
_utmb
_utmc
_utmv
_utmz

These cookies are used to collect information about how visitors use our site. We use the information to compile reports and to help us improve the performance of our website and our business. The cookies collect information in an anonymous form, including the number of visitors to the site, where visitors have come to the site from and the pages they visited.
Click here for an overview of privacy at Google

Performance

Microsoft.NET

ASP.NET_SessionId

BNES_ASP.NET_SessionId

This is a general platform session cookie used to maintain an anonymous user session.
Visit the Microsoft website to see how this cookie works.

Strictly Necessary

Facebook Tags

Facebook

Authentication

Security, site and product integrity

Advertising, recommendations, insights and measurement

Site features and services

Performance

Analytics and research

These cookies help us provide, protect and improve our advertising campaigns in Facebook Products, such as: personalizing content, tailoring and measuring ads, and providing a safer experience to the consumers we want to reach to be a part of our community.

 

All details for each of the sections of cookies can be found at the following links:

https://www.facebook.com/policy/cookies/

 

Advertising

Criteo Tags

Criteo

Also identified in Google Analytics Section

These cookies are used to retain user preferences, store information for things like shopping carts, and provide anonymised tracking data to third party applications like Google Analytics. These cookies are used to provide a better experience to our consumers. More detail on these third party cookies can be accessed here:

https://www.criteo.com/cookie-policy/

 

 

 

Advertising

SessionCam

sc.UserId

sc.Status

sc.ASP_NET_SESSIONID

sc.ASP_NET_SESSIONID

SessionCamTestCookie

sc.OptOut

We use SessionCam to watch recordings of visitors to identify usability issues for our users. As part of this we record mouse movements, clicks, mobile gestures, form input, scrolling.

To find out more about how they uses cookies, please see https://sessioncam.com/privacy-policy-cookies/

 

Performance

Google Adwords

Google Ads

Preferences

Security

Process

Advertising

Session State

Analytics

These cookies are used to help provide, protect and improve advertising carried out via Google more effective in terms of allowing our website to remember changes in your behaviour on the site, for example how many times you have viewed an advert or clicked on it.

 

To find out more about these cookies please see:

https://policies.google.com/technologies/ads)

 

Advertising

ShareASale

_ga
_gat

__cfduid

 

We use these cookies on our User Interface pages (on our web properties) with the purpose of pursuing our legitimate interests of improving and optimising usability for our clients.

 

These are used as analytic cookies by Google Analytics, please find more information here. (Link to https://www.shareasale.com/PrivacyPolicy.pdf)

Server software session cookie

See Privacy section 2.2.2 for additional cookie tags.

Advertising

Optimizely

optimizelyEndUserId

optimizelyRedirectData

 

These cookies enable us to provide enhanced functionality and personalization by tracking user actions, and delivering consistent experiences across page loads.

To find our more about these cookies please see: https://www.optimizely.com/legal/cookie-policy/

Strictly Necessary

Google Search Console

webmaster search console

search console

 

Helps to monitor, maintain, and troubleshoot the site's presence in Google Search results.

Strictly Necessary

Youtube

checkForYoutubeIframes

 

Validates & allows for YouTube videos to play on our website.

Functional

 

Social Sharing

We may also embed social sharing icons throughout our Website. These sharing options are designed to enable users to easily share our content with their friends using a variety of different social networks. These social sharing sites may set a cookie when you are logged into their service, please refer to the relevant cookie policy of that site.

What are your choices regarding Cookies?

It is worth noting that our website (along with most others) wouldn’t work very well without the strictly necessary cookies, so we don’t provide you with an ability to opt-out of these cookies. But you can remove them by using your browser settings. Keep in mind that certain features of our site may not be available to you.  By continuing to use our websites you are agreeing to our use of cookies. To manage all cookies placed on your computer, mobile phone or tablet device through your web browser settings, please consult your browser's guide or visit www.allaboutcookies.org or www.aboutcookies.org for more information. Some browsers are more sophisticated than others in managing these technologies, so if you want greater controls, it would be worth comparing a few of them. To manage cookies on your mobile phone please refer to your user manual.

Please note: if you restrict cookies, you may experience a loss of functionality while on the Website.

Changes to this Policy

We keep this policy under regular review. We may change this Policy from time to time by updating this page in order to reflect changes in the law and/or our privacy practices. The date at the top of this policy will be updated accordingly.

We encourage you to check the date of this policy when you visit the Website for any updates or changes. We will notify you of any modified versions of this Policy that might materially affect the way we use or disclose your personal information.

This policy only extends to the Website and does not, therefore, extend to your use of, provision of data to and collection of data on any website not connected to us to which you may link by using the hypertext links within this website.

Contact/address details

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

Updated 8/19/2019