Privacy Policy - Website

Privacy Policy - Website

last updated: 20 December 2021

last updated: 20 December 2021

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Privacy Policy

last updated: 20 December 2021

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 ecoATM kiosk (“Kiosk”) and ecoATM website in the UK, https://uk.ecoatm.com, (“Website”), as well as other online or mobile services or applications (collectively, the “Services”). This Privacy Policy apply to your use of the Services.

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 Services 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 Services.

About this Policy

This Privacy Policy explains how and why we acquire and use your personal information when you visit use our Website and Services. 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

  • including the Internet Protocol (IP) address used to connect your computer to the Internet;
  • browser type and version;
  • geolocation data - We may use geolocation data to determine the city where you are located in order to define the settings of our Website and to determine which services are available to you, and to provide you with relevant advertising. We will not share your current location with third parties. If you do not want us to use your location, you should turn off the location services in your devices settings;
  • time zone setting;
  • browser plug-in types and versions;
  • ·operating system and platform;
  • Information about your visit, including the full Uniform Resource Locators (URL);
  • clickstream to, through and from our Website (including date and time); and 
  • products you viewed or searched for; page response times; download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number.

Marketing and Communications Data

  • Your preferences in receiving marketing from us, our third parties, and your communication preferences where you choose to receive marketing from us.

Information we receive:

When you use our Services, 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 or through the use of our Services. 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 or use our Services 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 Applications 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 or Applications, 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 and Services. 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:

  • to respond and/or deal with your request or enquiry including individual rights requests;
  • to communicate with you, including sending you information about products and services which we think may be of interest to you (where you have consented to receive such communications, or where it is otherwise lawful for us to do so). You are able to opt-out of such communications at any time by writing to us, using the contact information provided below;
  • to improve the Website/Applications by monitoring how you use it and to analyse trends in using and accessing our Website/Applications; 
  • to gather feedback to improve our services, for example our email alerts;
  • to respond to any feedback you send us, if you’ve asked us to;
  • to send email alerts to users who request them;
  • to allow you to access to our services;
  • to contact you in order to provide you with information about our other services if you request it; and
  • for compliance with our legal, regulatory and other good governance obligations.

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:

  • where an individual gives us their consent to process their personal data in a particular way;
  • where we need to process your personal data because it is necessary for the performance of a contract;
  • where it is necessary to comply with law;
  • where we need to protect the vital interests of a customer; or
  • where it is necessary for our legitimate interests and for the legitimate interests of another party.

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

Activities, Data Used and Legal Basis for Processing

  1. Activity: Administration of website, online and mobile services, applications, internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes

Data used: Identity, Contact Financial, Transactional, Technical, Aggregated, Marketing and communications

Legal basis for processing: Necessary for our legitimate interests for running our business and provision of website.

  1. Activity: Improving the Services/ Website

Data used: Identity, Aggregated, Technical, Usage

Legal basis for processing: Necessary for our legitimate interests of to help with website and online services and applications development

  1. Activity: Maintaining the Security of Website and Services

Data used: Identity, Contact, Technical, Usage

Legal basis for processing: Necessary for our legitimate interests of ensuring the security of our Services

  1. Activity: Marketing - to deliver relevant advertising to you and make offers to you

Data used: Marketing and communications, Contact, technical, Usage

Legal basis for processing: Consent- where you have opted in to receive marketing

  1. Activity: Complying with a court order, or to exercise or defend legal claims

Data used: Identity, Contact

Legal basis for processing: To comply with a legal obligation

  1. Activity: Complying with other disclosure requests from third parties where required and lawfully permitted

Data used: Identity, Contact, Aggregated, Technical, Usage

Legal basis for processing: 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:

  • our partner companies such as ecoATM, LLC;
  • third party suppliers;
  • law enforcement agencies, where this is requested;
  • third party payment providers such as Paypal and Bottomline;
  • With your consent, we can transfer your contact data to our commercial partners, in order for them to send you advertising. These commercial partners are expressly mentioned when we collect your consent; and/or
  • our insurers.

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 or other Services 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 safeguards to transfer your information:

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.

Your rights

You have the following rights under certain circumstances:

  • Right of access - To be provided with access to your personal information held by us. 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 erasure - To request that your personal data be deleted
  • Right to correction – to request that your data is updated
  • Right to object to processing - To request that we cease processing your personal information
  • Right to restrict processing - To request that we limit or restrict the ways in which we use your personal information
  • Right of Portability - To request that your data be transferred to a third party (data portability)

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:

  • retention in case of queries – for example, where you contact us to receive further information about the way we handle your data;
  • retention in case of claims - for the period in which you might legally bring claims against us which can be 7 years;
  • retention in accordance with legal and regulatory requirements - after your agreement with us has come to an end; and
  • to stay in touch about your requirements on an ongoing basis, where you have selected to receive these.

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 or Applications 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