Privacy Policy United Wardrobe

Version: July 2020

United Wardrobe B.V., hereinafter referred to as "United Wardrobe", is responsible for the processing of data as described in this Privacy Policy. United Wardrobe respects the privacy of its users.

This Privacy Policy applies to the processing of personal data of all users, being both buyers and sellers, when they make use of our website/websites (the "Website") and app/apps (the "App").

Privacy and Relevant Legislation

We consider your privacy to be of paramount importance. We comply with the General Data Protection Regulation ("GDPR") and other relevant legislation in the field of privacy (hereinafter collectively to be referred to as the "Relevant Legislation").

What is personal data?

The definition of personal data means all information by which you can be identified, directly or indirectly. This definition is in accordance with Relevant Legislation. This definition, for that matter, is in a broad sense: even dynamic IP addresses are considered personal data under certain circumstances.

Are you aged under 16?

United Wardrobe gears its services towards users over the age of 15. It is for this reason that when creating an account, the user is asked to declare whether he/she is 16 years or older, or, if he/she is younger than 16, whether permission has been granted by his/her parents/guardian for processing of his/her personal data.

How does United Wardrobe obtain your personal data?

The data that we process is derived directly from you, when you visit the Website, use the App, create an account, or buy/sell something. Other users can also provide information about you, like in reviews and ratings about you as a seller. In addition, we could get data via Facebook Login.

What personal data do we process and how is this data used?

United Wardrobe processes the personal data below, depending on the category of services that you use within our Website and App. We can also link this data to each other. Several of these personal data are visible via your public profile on the United Wardrobe platform.

Category: Use of the Website and App (iOS and Android)

(Personal) Data:Purpose(s):Principle(s):
Use of the Website:

Type of device, type of browser, date and time of the session, IP address and searching, browsing and buying patterns on the Website.

Use of the App:

Make and type of device, type of browser, operating system (including version), IP address, date and time of the session and searching, browsing and buying patterns in the App.

This data is used to:
  • Enable you to make use of our Website or App;
  • Carry out macro-analyses to improve user-friendliness and to track down and prevent fraud and security issues.
Data processing that is needed to enable you to make use of the Website or App, is necessary to execute the agreement with you.

In addition, we have a legitimate interest to improve and secure our services.

Category: Your account at United Wardrobe

(Personal) Data:Purpose(s):Principle(s):
Account registration:

First name and surname, email address, date of birth, gender, country, language, clothing and shoe size (optional), username (generated by United Wardrobe).

If you register via Facebook:

Facebook profile data: name and profile photo, date of birth, place of residence and email address.

This data is used to:
  • Enable you to make use of our service;
  • Check whether you are old enough to use our service;
  • Keep you updated on all your purchases and sales, changes in your favourite items and your search queries;
  • Keep you updated via our newsletter with products of interest to you based on your gender, sizes, language, favourite products and users whom you follow;
  • Address you appropriately in our communications.
Data processing that is needed to enable you to make use of the Website or App, is necessary to execute the agreement with you.

In addition, we have a legitimate interest to inform you in the correct way about your account activities. Besides, we have a legitimate interest to show you products on the Website and in the App that match up to your preferences.

We request your consent before sending the newsletter. Every newsletter contains a link with which you can unsubscribe from the newsletter again. You can manage your consent and preferences for all email messages in your account.

Refine the account yourself:

Profile and cover photo, photos of the products that you offer, your location, products that you save as favourites, users that you follow, your reactions for products that you offer, your holiday mode.

Account supplemented by other users:

Users who follow you (including quantity), reviews and rating by other users about you, reactions and tagging as favourite by other users for the products that you offer.

Account supplemented by United Wardrobe:

Searching, browsing and clicking habits (such as products that are viewed or saved as a favourite and search queries).

This data is used to:
  • Personalize your account;
  • Increase the reliability of your account, so that the chances of a successful purchase or sale is as big as possible;
  • Ensure that other users can find your products on the Website/in the App;
  • Ensure that other users know that, due to the holidays, you will need more time to send a sold item or to respond to messages;
  • Show other users which products are for sale within a radius of at least 2 km from them;
  • Optimize your feed based on your language, gender, preferences, sizes and favourite products/users.
By refining your account yourself, you give us consent to process that data. You can always revoke this consent, by modifying or deleting the data.

We have a legitimate interest to show you the best possible feed. In addition, we have a legitimate interest to process the data that other users provide about you (reviews, ratings, reactions), namely, to increase the reliability of accounts.

Chatting with other users:

Your public profile (including username and any profile photo) and chat messages.

This data is used to:
  • Enable you to make use of our service;
  • Analyse and improve the selling process;
  • Track down illegal content via automatic scans;
  • Draw up risk analyses on suspicious transactions.
Data processing that is needed to enable you to make use of the service, is necessary to execute the agreement with you.

In addition, we have a legitimate interest to improve and secure our service.

Category: Buying, selling and returning products

(Personal) Data:Purpose(s):Principle(s):
Buy, sell and return:

First name and surname, account number, details relating to the payment transaction (e.g. method of payment and time of transaction), address, product information, amount, and date of purchase or sale.

We only process IBAN data of users who made purchases or sales before 26 July 2020.

Additional details for bidding or bundling discount:

Amount of the placed or accepted bid/bundle or counterbid (including date) and ID of the product or products to which the bid or bundle/counterbid relates.

This data is used to:
  • Establish the agreement between the buyer and seller;
  • Process the payment;
  • Ensure that the seller can ship the product and the buyer can return the product;
  • Refund and/or transfer additional compensation (if appropriate) to the Buyer;
  • Fill in the IBAN number in advance to facilitate creating a Stripe profile;
  • Conduct any fraud investigation.
The data processing needed to establish the agreement between the buyer and seller, the processing of payments, and ensuring that the product can be sent, is necessary to execute the agreement with you.

In addition, we have a legitimate interest to secure our service.

Shipment:

Shipping method selected by the buyer (home delivery service or pick-up point) and courier company, shipping label, tracking code and shipment status.

This data is used to:
  • Facilitate the shipment of products between the buyer and seller;
  • Update the status of the shipment (shipped/received) in connection with payment to the seller.
The data processing needed to facilitate the shipment and to pay the seller, is necessary to execute the agreement with our users.
Additional details for providing shopping credit:

Mobile telephone number.

This data is used to:
  • Provide you with shopping credit;
  • Verify the shopping credit to the receiver via a text message;
  • Conduct any fraud investigation.
The data processing needed to pay out the shopping credit, is necessary to execute the agreement with you.

In addition, we have a legitimate interest to secure our service.

Completing pending orders:

Tracking data of the shipment (such as track-and-trace codes), contact with the respective buyer and seller and other interaction data. If tracking data does not provide a solution and the buyer and seller do not respond to our contact attempts for a long time, we will consult the chat history to find out the order status. We will always inform the buyer and seller of this in advance.

This data is used to:
  • Complete orders whose status is still pending after thirty (30) days.
This data processing is necessary to execute the agreement with our users, i.e. to complete the orders properly through the platform.
Data for our financial administration:

First name and surname, country and order identification number (sellers) or transaction identification number (buyers).

This data is used to:
  • Enter records in our financial administration;
  • Provide to the Tax and Customs Administration.
We are legally obliged to maintain a financial administration and to provide this information to the Tax and Customs Administration.

Category: Support

(Personal) Data:Purpose(s):Principle(s):
When you contact us:

Username, email address, contents of your message and contents of our response to you.

This data is used to:
  • Answer your questions;
  • Offer you support with our services;
  • Ensure that you can use our services;
  • Improve our service as a result of questions and feedback from users.
The data processing needed to ensure that you use our service, is necessary to execute the agreement with you.

In addition, we have a legitimate interest to help you with any questions and to improve our service as a result of questions and feedback that we receive.

Category: cookies and similar technology

A complete overview of our cookies can be found in our Cookie Statement. This also includes the retention period of these cookies.

Retention period

Personal data is deleted as soon as it is no longer required for the aforementioned purposes. In any case, we maintain the following retention periods:

  • Account data: your personal data is deleted at the latest two (2) years after deletion of your account. If you no longer use your account, we will delete your data at the latest two and a half (2.5) years after the last use. Prior to that we will try to send a message requesting whether you want to retain your account. To this end, we will use the email address provided by you.
  • Data for the Tax and Customs Administration: we are obliged to retain data in our financial administration for seven (7) years for the Tax and Customs Administration.

After expiry of the aforementioned terms, we may retain certain personal data to comply with legal retention obligations and for fraud investigations. For such event, we will retain the data separately and encrypted and only use same for the aforementioned purposes.

Who has access to your personal data?

Below we will explain in which cases we share information internally and externally.

Internally

We only provide access to your personal data to our employees if they require same to implement their work. All our employees are subject to confidentiality.

External Controllers

To bring about the purchase or sale of products via the Website and App we must share some data with external parties. These parties act as Controllers within the meaning of Relevant Legislation. This concerns the following parties:

  • Payment Provider: We have partnered with Stripe (Stripe Inc. / Stripe Payments Europe Ltd.), a third-party payment processor. We only share data with this third party which is necessary to facilitate payments. You share most of the data yourself by creating a Stripe account when making a payment. In some cases, Stripe will compile a risk assessment (a Know Your Customer survey) with regard to the seller, if Stripe is statutorily required to do so. United Wardrobe is not involved in this survey and has no access to the data used in this survey.

    Any personal information that you provide to the aforementioned payment provider(s) will be processed in accordance with their own privacy policy.

  • Seller/Buyer: to establish the sale, we also have to share some data with the seller who ships the product and with the buyer if the product is to be returned.

  • Tax and Customs Administration: We are legally obliged to include (part of) the personal data in our financial administration, which must be shared with the Tax and Customs Administration. The Tax and Customs Administration will process this personal data in accordance with its own privacy policy.

Processors

We make use of several parties who process personal data in support of our services. These parties act as Processors within the meaning of Relevant Legislation and only process the data on our instruction, so not for their own purposes. We make use of the following Processors:

  • SaaS storage providers: these parties provide (Software-as-a-Service for) the storage of our data. For example, we make use of Amazon Web Services.
  • Data Management and Research: these parties supply services relating to the data. For example, we make use of data management platforms, media and advertising agencies and research institutes.
  • **Customer contact software: **these parties make it possible to contact our users. For example, we use software to collect feedback, for handling queries and complaints, and to remind users about products sold.
  • Accounting system: we use an accounting software package.

Parcel services

We use various parcel services to create shipping labels and to ship products. We only share the data necessary for these services with these parties. For example, we make use of PostNL, Sendcloud, UPS, Shippo, Mondial Relay and Bpost. Some of these parcel services act as Processors and some act as Controllers themselves. We have written agreements with all these parcel service providers regarding the processing of your personal data.

Change of company

If we are taken over or if we merge with another company, it may be necessary that your personal data will be inspected or taken over by the new company. They are obliged to uphold the conditions of this Privacy Policy. If changes occur in the way that we process your personal data, we will communicate this to you in advance.

Does United Wardrobe sell my data to third parties?

No! United Wardrobe will not sell your personal data to third parties and will only make this available to third parties in the aforementioned cases.

Export of personal data outside the EU

Personal Data may be transferred to parties outside the EU, if one of our Processors is located outside the EU. The personal data will only be transferred to countries or parties who offer an adequate level of protection which complies with European standards.

Transferring data outside the EU will always take place in accordance with Relevant Legislation (Chapter 5 of the GDPR).

Security of your personal data

We believe that the security of your personal data is of paramount importance. So, we take appropriate technical and organisational measures to protect your personal data against destruction, loss, alteration, unauthorised disclosure, unauthorised access or forwarding.

United Wardrobe itself processes personal data on a secured platform in highly secured databases, hosted by AWS on servers in the European Union. The infrastructure is continuously monitored by AWS and by us with regard to attacks and abuse. United Wardrobe provides a secure connection to the end user, which is identified by a small green lock in your browser. In the event of a data breach, we have an internal procedure in place for documenting and reporting a data breach.

In addition, you can take your own measures to protect your account:

  • Use a strong password (e.g. use capital and lower-case letters, numbers, and other characters or choose a password in the form of a sentence);
  • Please notify us in good time about changes and incidents in your personal data;
  • Be careful with disclosure of personal data via our service;
  • If you are using a public computer, please log out after visiting our Website.

Privacy conditions of third parties

When you make use of the services of external parties via our Website or App, for example, social media networks, then the privacy conditions of those third parties apply. We have no influence on the privacy policy of these parties. We recommend that you read the privacy conditions and settings of those external parties carefully.

Amendments to this Privacy Policy

We constantly seek ways to improve our services. This means, our Privacy Policy could be amended from time to time. If significant amendments are made, then a notification of this will be placed on our Website and in our App along with the updated Privacy Policy.

Your rights and our contact details

You have a number of rights in respect of your personal data. For example, you have the right to:

  • Request us to correct or update your data. You can also do so yourself via your account;
  • Request to have your data deleted from our database. If we are obliged to do so based on the Relevant Legislation, we will do so and, where possible, forward your request to the recipients of your data;
  • Request a copy of all your personal data that we have processed. We may process the personal data that we collect in the context of our agreement, or that we process with your consent, or forward at your request to another data controller;
  • Withdraw your consent for processing your data. This only applies to processing based on your consent and has no effect on the validity of the processing carried out prior to the moment that you withdraw your consent;
  • Lodge an objection with us against processing your data (in whole or for specific purposes) and to request us to limit the processing of your data;
  • Submit a complaint to the Dutch Data Protection Authority, if you think that we process your data unlawfully.

Some of the above rights may be exercised via your own account, such as modifying certain data or deleting your account. In respect of the other rights, please contact our support dept. via support@unitedwardrobe.com.

We will make every effort to comply with your request within thirty (30) days. In order to verify your identity, we will ask you to identify yourself. If you have any further questions about United Wardrobe's Privacy Policy, please send an email to our support dept.: support@unitedwardrobe.com.

United Wardrobe B.V.

Vinkenburgstraat 2A
3512 AB Utrecht
The Netherlands

Chamber of Commerce no.: 64193632