Melloo

Privacy Policy

Last updated on 23 September 2020

We ask that you read this Privacy Policy carefully as it contains important details about what personal data Melloo Ltd (“Melloo”, “Melloo Marketplace”, “us”, “we”, or “our”) collects and processes when you use our website and services, including the options we offer you to access, maintain and control it.

By providing us with your data, you warrant to us that you are 18 years of age and over.

Introduction

For the purpose of the Data Protection Act 1998 and the General Data Protection Regulation 2016/679 (once in force on 25th May 2018 – both “Data Protection Law”), the data controller is Melloo Ltd (registration number 08852773). We have appointed a Data Protection Officer who is in charge of privacy related matters for us. If you have any questions about this privacy policy, please contact the Data Protection Officer using the details below.

Contact Details
Name of Legal Entity: Melloo Ltd
Data Protection Officer: Jeremy Henley
Email Address: hello@melloo.uk
Postal Address: 2 Norman Court, Lordship Lane, East Dulwich, London, SE22 8JT

If you are not happy with any aspect of how we collect and use your data, we should be grateful if you would contact us so that we can try to resolve the issue for you.

It is very important that the information we hold about you is accurate and up to date. Please let us know if at any time your personal information changes by making the necessary changes on your Melloo account or by emailing us at hello@melloo.uk

What Data do we Collect about You

Personal data means any information capable of identifying an individual. It does not include anonymised data.

We may process certain types of personal data about you as follows:

  • Identity Data may include your first name, last name, username, title, date of birth and gender
  • Contact Data may include your billing address, delivery address, email address and telephone numbers
  • Financial Data may include your bank account, payment card details and PayPal account
  • Transaction Data may include details about payments between us and other details of purchases made by you
  • Technical Data may include your login data, internet protocol addresses, browser type and version, browser plug-in types and versions, time zone setting and location, operating system and platform and other technology on the devices you use to access this website
  • Profile Data may include your username and password, profile picture, purchases or orders, your interests, preferences, feedback and survey responses
  • Usage Data may include information about how you use our website, products and services
  • Marketing and Communications Data may include your preferences in receiving marketing communications from us and our third parties and your communication preferences
  • Aggregated Data may be processed from your personal data but this data does not reveal your identity and as such in itself is not personal data. An example of this is where we review your Usage Data to work out the percentage of website users using a specific feature of our site. If we link the Aggregated Data with your personal data so that you can be identified from it, then it is treated as personal data

Sensitive Data We do not collect any Sensitive Data about you. Sensitive Data refers to data that 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. We do not collect any information about criminal convictions and offences.

Where we are required to collect personal data by law, or under the terms of the contract between us and you do not provide us with that data when requested, we may not be able to perform the contract (for example, services to you). If you don’t provide us with the requested data, we may have to cancel a product or service you have ordered but if we do, we will notify you at the time.

How we Collect your Personal Data 

We collect data about you through a variety of different methods including:

Direct interactions: You may provide data by filling in forms on our site (or otherwise) or by communicating with us by post, phone, email or otherwise, including when you:

  • Order our products or services
  • Register an account on our site
  • Subscribe to our service or publications
  • Request resources or marketing be sent to you
  • Enter a competition, prize draw, promotion or survey; or give us feedback

Automated technologies or interactions: As you use our website, we may automatically collect Technical Data about your equipment, browsing actions and usage patterns. We collect this data by using cookies, server logs and similar technologies. We may also receive Technical Data about you if you visit other websites that use our cookies. Please see our Cookie Policy for further details.

Third parties or publicly available sources: We may receive personal data about you from various third parties and public sources as set out below:

  • It Analytics providers such as Google based outside the EU
  • Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as PayPal based outside the EU
  • Identity and Contact Data from data brokers or aggregators based inside or outside the EU
  • Identity and Contact Data from publicly availably sources such as Companies House and the Electoral Register based inside the EU

How we Use your Personal Data

We will only use your personal data when legally permitted. The most common uses of your personal data are:

  • Where we need to perform the contract between us
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests
  • Where we need to comply with a legal or regulatory obligation

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us using the above contact details.

Comply with a Legal or Regulatory Obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to marketing communications via email. You have the right to withdraw consent to marketing at any time by contacting us.

Purposes for Processing your Personal Data
Set out below is a description of the ways we intend to use your personal data and the legal grounds on which we will process such data. We have also explained what our legitimate interests are where relevant.

We may process your personal data for more than one lawful ground, depending on the specific purpose for which we are using your data. Please email us at hello@melloo.uk if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out below:

  • To register you for a free account
  • To subscribe you to a paid account
  • To provide communications regarding your account
  • To provide email support
  • To send email marketing
  • To personalise your Melloo experience
  • To facilitate communication between you and a buyer and/or creator
  • To facilitate transactions between you and a buyer and/or creator
  • Website statistics

Marketing Communications

You will receive marketing communications from us if you have:

(i) requested information from us or purchased goods or services from us; or

(ii) if you provided us with your details for us to send you marketing communications; and

(iii) in each case, you have not opted out of receiving that marketing.

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by emailing us at hello@melloo.uk at any time.

Where you opt out of receiving our marketing communications, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.

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 find out more about how the processing for the new purpose is compatible with the original purpose, please email us at hello@melloo.uk

If we need to use your personal data for a purpose unrelated to the purpose for which we collected the data, we will notify you and we will explain the legal ground of processing.

We may process your personal data without your knowledge or consent where this is required or permitted by law.

Disclosures of your Personal Data

We use a select number of trusted external service providers for certain technical data processing and/or service offerings. These service providers are carefully selected and meet high data protection and security standards. We only share information with them that is required for the services offered and we contractually bind them to keep any information we share with them as confidential and to process Personal Data only according to our instructions:

  • Secure Hosting Infrastructure for servers and databases and logs
  • To receive payments
  • To receive and reply to your messages after you contact us
  • To send you our newsletter emails after you signup
  • Track and analyse data from website visits
  • Connecting data from the Google AdWords advertising network with actions performed on this Application.
  • Track and analyse data from website visits
  • To monitor payments and for accountancy

We may have to share your personal data with the parties set out below for the purposes set out above:

  • Service providers who provide IT and system administration services
  • Professional advisers including solicitors, accountants, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services
  • HM Revenue & Customs, regulators and other authorities based in the United Kingdom and other relevant jurisdictions who require reporting of processing activities in certain circumstances
  • Third parties to whom we sell, transfer, or merge parts of our business or our assets

We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.

International Transfers

We share your personal data within our company which involves transferring your data outside the European Economic Area (EEA).

Countries outside of the European Economic Area (EEA) do not always offer the same levels of protection to your personal data, so European law has prohibited transfers of personal data outside of the EEA unless the transfer meets certain criteria.

Many of our third parties service providers are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, we do our best to ensure a similar degree of security of data by ensuring at least one of the following safeguards is implemented:

  • We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission; or
  • Where we use certain service providers, we may use specific contracts or codes of conduct or certification mechanisms approved by the European Commission which give personal data the same protection it has in Europe; or
  • Where we use providers based in the United States, we may transfer data to them if they are part of the EU-US Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US

If none of the above safeguards is available, we may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time.

Please email us at hello@melloo.uk if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

Data Security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know such data. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Data Retention

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

By law, we have to keep basic information about our customers (including Contact, Identity, and Transaction Data) for six years after they cease being customers for tax purposes.

In some circumstances, you can ask us to delete your data: see below for further information.

In some circumstances, we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

Your Legal Rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. These include the right to:

  • Request access to your personal data
  • Request correction of your personal data
  • Request erasure of your personal data
  • Object to processing of your personal data
  • Request restriction of processing your personal data
  • Request transfer of your personal data
  • Right to withdraw consent

You can see more about these rights at:
https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights

If you wish to exercise any of the rights set out above, please email us at hello@melloo.uk. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your 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.

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Changes to this Policy and your Duty to Inform us of Changes

This version was last updated on the date shown at the bottom of this policy.

We reserve the right to make changes to this privacy policy at any time by giving notice to its Users on this page. It is strongly recommended to check this page often, referring to the date of the last modification listed above.

Please keep us informed if your personal data changes during your relationship with us. It is important that the personal data we hold about you is accurate and current.

Third-party Links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

Change Cookie Settings 

You can set your browser to refuse all or some browser cookies or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of our website may become inaccessible or not function properly. For more information about the cookies we use, please see visit our Cookie Policy.

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