UGC and Cookie Policy

PRIVACY AND COOKIE POLICY


LAST UPDATED 22 MAY 2018



Introduction

www.trendeo.com (“Site”) together with our mobile application TRENDEO (“App”) (together the “Platform”) is provided, owned and operated by TC Fashion Markets Limited ("we", "our" or "us"). We are committed to protecting the privacy of our users. This privacy and cookie policy ("Privacy and Cookie Policy") (together with our Terms of Use and any documents referred to in it (“Terms”)) is intended to inform you how we gather, define, use and process your personal information, including but not limited to your name, email address, post address and other contact details ("Personal Information"). Please use this Privacy and Cookie Policy to help you decide whether and how you wish to use our Platform and our services. Please take a moment to read it carefully. It applies to both customers and sellers, and, with regard to transparency provisions according to General Data Protection Regulation (GDPR), to other individuals whose data we may process except for our employees.

All your Personal Information shall be used in accordance with the GDPR. For the purposes of the GDPR, TC Fashion Markets Limited of 2-8 Victoria Avenue Bishopsgate, London, EC2M 4NS, England is the data controller, where you are using our services through the TRENDEO portal.

The basis for the processing of your data

TRENDEO processes your data for the performance of the contract that you have entered into for the use of the TRENDEO service, which is governed by the clauses comprising our Terms of Use, and/or in order to take steps at your request to enter into this contract.

In addition, some data is processed based on TRENDEO’s legitimate interest, notably web and app analytics for the purposes of enhancing web and app performance, website logs etc. to prevent fraudulent or other malicious activities, website visitor logs for cybersecurity and/or error tracking purposes.

We may ask for your consent in other cases where we process your data. Such consent can be revoked at any time by contacting us at info@trendeo.com.

What information do we collect?

When you visit our Platform, or contact us by email or telephone, we may collect the following information:

  • Personal information that you choose to share with us when you register for services, emails, newsletters and alerts or by searching for a product, purchasing a product via our Platform or reporting a problem you have had with our Platform.
  • If you choose to correspond with us through email, we may retain the content of your email messages together with your email address and our responses.
  • Financial information such as any personal bank or credit card details that you use to transact with us.
  • Information about the way our Platform has been used by you and others – collected on an aggregate basis.
  • Your IP address and other technical information (such as the browser you are using - further information is in the further text under “Our policy on cookies”) may be collected when you interact with our Platform – for example create a profile, subscribe to our emails, ask or answer a question etc.
  • Information from Facebook, Instagram, Snapchat and Twitter, as profile pictures, friends or contacts in the case you choose social networks for signing up. A separate consent will be needed for gathering this data. When it comes to the format of this consent, it is designed by said social media. Such consent can be withdrawn at any time by deleting the linked account and create a new one, or by changing your settings in the social media’s own privacy settings.

It is important that all the Personal Information you give us when you register as a user or otherwise when you use the Platform is truthful and accurate. This includes, by way of example only, ensuring that we have your correct contact (including email) details at all times.

How do we use the information you provide to us?

In general terms, we use Personal Information to provide you with the services you request, carry out any obligations we have under our Terms of Use, allow for Vendors to process any transactions, provide customer services and for customer research. We may also use the Personal Information we collect to notify you about important changes to our Platform.

We may also use this Personal Information to ensure the efficiency and improve our Platform including through troubleshooting, data analysis, testing, research and surveys and as part of our efforts to keep our Platform safe and secure. We may also use this Personal Information to investigate, prevent or take any necessary action regarding any illegal activities or the breach of any of our Terms.

We may use personal information we collect to notify you about new products we think you will find valuable, or to deliver customised content that we feel may be of interest to you. We may also pass your personal information to selected third parties who offer their products for sale via our Platform. PLEASE NOTE THAT THIS WILL ONLY BE DONE IF YOU HAVE CONSENTED TO RECEIVING SUCH COMMUNICATIONS AT THE POINT OF REGISTRATION (VIA AN OPT-IN BOX) OR AT ANY TIME THEREAFTER.

Opt out of receiving emails

You can unsubscribe from our regular emails at any time by clicking on the Unsubscribe link in the footer of the email you have received. Please allow 48 hours for your email address to be removed from our system.

Our policy on Cookies

In common with other commercial websites, our Platform utilises a standard technology called “cookies” (see explanation below, “What Is A Cookie?”) and web server logs to collect information about how our Platform is used. This helps us to provide you with a good experience when you browse our Platform and also allows us to improve our site. Information gathered through cookies and web server logs may include the date and time of visits, the pages viewed, time spent at our Platform, and the websites visited just before and just after our Platform. By continuing to browse the Platform, you are agreeing to our use of cookies.

We use the following cookies:
  • PHPSESSID: This cookie stores the TRENDEO internal session ID and hence keeps the user logged-in and enables the platform to keep track of session data (e.g. shopping cart) across multiple pageviews
  • _locale: The default market of the user
  • source: Enables the TRENDEO platform to track users from affiliate channels and to reward affiliate partners fairly
  • mc_cid: Enables TRENDEO to analyse the efficiency of direct marketing campaigns
  • Discount_Modal: Remembers the user decision to hide the subscription overlay
  • bq_AddToCart, fbq_initiateCheckout, fbq_ViewContent, fbq_Purchase: Used for more accurate and reliable analytics data for facebook advertising
We allow the following third parties to place cookies for our users:
  • Facebook: for more accurate and efficient advertisements on Facebook.
  • Google Adwords: for more accurate and efficient advertisements on Google.
  • Google Analytics: for traffic and user behaviour analysis.
  • Stripe: for valid and safe payments processing.
  • AWIN: for accurate and efficient affiliate marketing.
  • Criteo: for accurate and efficient retargeting.
  • MailChimp: for more accurate and efficient direct marketing campaigns.

We use cookies to:

  • remember you when you visit this Platform to keep track of your browsing patterns and to build up a profile of how you and other users use the Platform.
  • make our Platform work as efficiently as possible.
  • facilitate transactions and administer services to you and other users of our Platform.
What is a cookie?

A cookie is a very small text document, which often includes an anonymous unique identifier. When you visit a website, that site's computer asks your computer for permission to store this file in a part of your hard drive specifically designated for cookies. Each website can send its own cookie to your browser if your browser's preferences allow it, but in order to protect your privacy, your browser only permits a website to access the cookies it has already sent to you, not the cookies sent to you by other sites. Find out more about the use of cookies on www.cookiecentral.com.

How do we use information we collect from cookies?

As you browse our Platform, the Platform uses cookies to differentiate you from other users to prevent you from seeing unnecessary advertisements or requiring you to log in more often than is necessary. Cookies, in conjunction with our web server's log files, allow us to calculate the aggregate number of people visiting our Platform and to determine which parts of the Platform are most popular. This helps us gather feedback to constantly improve our Platform and better serve our users.

Third Party Cookies

On occasion, we will issue a cookie by a third party to help us operate the Platform - these are sometimes known as “web beacons” or “clear gifts”. These cookies cannot be used to identify an individual; they can only be used for statistical purposes, for example, in providing you with advertisements that are more relevant to your interests.

For example, third party vendors such as Google, show our ads on sites on the internet and use cookies, to serve ads based on your prior visits to our Platform and to determine which advertisements and promotions users have seen and how users responded to them and to serve advertising to our Platform. Analytics data may also be used to this effect.

For this purpose, we may disclose generic, aggregated or anonymised data relating to your visits and use of our Platform, but we will not disclose any of your Personal Information which identifies you directly, i.e. we will not disclose your contact details such as your email address, name, address or telephone number.

The third party companies that generate these cookies have their own, very strict, privacy policies but we don't have access to these cookies; other than allowing them to be served, we have no role to play in these cookies at all (although we may use statistical information arising from these third party cookies and provided to us by third parties, to improve our Platform experience).

You may opt out of Google's use of cookies by visiting the Google advertising opt-out page. For more information on opting out of third party companies' use of cookies please visit the Network Advertising Initiative website.

How do I remove or block cookies?

Most browsers allow you to remove any cookies and/or block any new cookies being set. To turn off cookies, look at the “help” menu on your browser. However, please note, that switching off cookies may restrict your use of the Platform and/or delay or affect the way in which it operates.

Your third party accounts

We may link your account with a third party (such as Facebook or Twitter) to our services to enable certain functionality, which allows us to obtain information from those accounts (including your profile picture, friends or contacts). A separate consent will be needed for gathering this data. When it comes to the format of this consent, it is designed by the respective social media platform. Such consent can be withdrawn at any time by deleting the linked account and creating a new one, or by changing your settings in the social media’s own privacy settings.

The information we may obtain from those services often depends on your settings or their privacy policies.

Sharing personal information with third parties

We treat the security and method of processing your Personal Information very seriously, and we will never sell your Personal Information under any circumstances.

However, subject to the need to perform the contract with you based on our Terms of Service and our legitimate interests, we may disclose your Personal Information to selected third parties including but not limited to the following situations:

  • to serve to your purchasing requirements, to the sellers of the products when ordering a purchase on the TRENDEO website/App. Details of your name, email and address will be disclosed;
  • to facilitate our business, including, by way of example only, sending email communications; sending email communications by third parties would require your consent.
  • to any supplier to assist us in improvement, maintenance or otherwise of our Platform, network and security;
  • if we buy or sell any business or assets, in which case we may disclose your Personal Information to the seller or buyer of such business or assets, as appropriate;
  • to analytics and search engine providers that assist us in the improvement and optimisation of our site.
  • if we are under a duty to disclose or share your Personal Data to comply with any legal obligation or in order to enforce or apply our terms and conditions and other agreements or protect the rights, property, or safety of our users, or others. This includes exchanging information with other companies and organisations for fraud protection and credit risk reduction.

We may also disclose your Personal Information to third parties in accordance with your authorisation as expressed via ‘opt-ins’.

Please note: by posting any Personal Information in any publicly accessible area of our Platform, such information may be collected by third parties over which we have no control. We strongly recommend all users keep postings anonymous. We are not responsible for the use of such information by such third parties.

Please exercise all due care and consideration before disclosing any Personal Information that will be disclosed on public areas. You should also avoid disclosing any Personal Information that may be used to identify you (such as your name, age, home or work address or name of your employer) especially if you disclose any sensitive Personal Information such as:

  • racial or ethnic origin;
  • political beliefs;
  • philosophical or religious beliefs;
  • membership of a trade union or political party;
  • physical or mental health;
  • sexual life; or
  • the commission of criminal offences or proceedings
Your rights

You have the right to ask us not to process your personal data for marketing purposes. We will inform you if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes.

The GDPR gives you the right to access information held about you. Should you have any queries about any Personal Information which we hold about you, your right of access can be exercised in accordance with the GDPR.

If you are unable to update your own Personal Information, you have the right to obtain without undue delay the rectification of inaccurate personal data concerning you, including the right to have incomplete personal data completed e.g. by means of providing a supplementary statement.

You have the right to erasure of your data, which you can exercise by means of the deactivation of your account. We are not required to delete the information important for the establishment, exercise or defence of legal claims, or that we need to retain in order to comply with the law.

You have the right of restriction of processing, where the data is wrongfully processed but should not be erased for a reason listed in Article 18 (1) of the GDPR.

Until a download option has been developed based on universally recognised standards, you may exercise your right of data portability by obtaining your data by sending us an email request.

You can exercise your rights at any time by writing to us at: TC Fashion Markets Limited, 2-8 Victoria Avenue Bishopsgate, London, EC2M 4NS, England. Alternatively email us on info@trendeo.com

It is your responsibility to provide us with accurate and truthful data. We cannot be liable for any information that is provided to us that is incorrect.

Storage limitation

We will normally store your information as long as your TRENDEO account remains active, which includes the history of your purchases. Purchase history may be deleted after 6 years. If you have created an account with us, we will assume that this has been done for further purchases and will keep account data for an indefinite period, subject to your erasure request.

If you have sent us an email or other correspondence, we will retain your information until we are satisfied it is outdated or no longer relevant, subject to your exercise of the right to erasure

Our duty to notify you of any unauthorised access

If we become aware of any unauthorised access to your Personal Information we will inform you at the earliest practical opportunity once we have established what was accessed and how it was accessed.

What about other websites linked to our Platform?

We are not responsible for the practices employed by websites linked to or from our Platform nor the information or content contained therein. Often links to other websites are provided solely as pointers to information on topics that may be useful to the users of our Platform.

Please remember that when you use a link to go from our Platform to another website, our Privacy and Cookie Policy is no longer in effect. Your browsing and interaction on any other website, including websites which have a link on our Platform, is subject to that website's own rules and policies. Always read over those rules and policies before proceeding.

Where we store your personal data

The data that we collect from you 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 may be engaged in, among other things, the fulfilment of your order, the processing of your payment details and the provision of support services. However, we will not disclose your Personal Information to any entity outside of the United Kingdom that is in a jurisdiction that does not have a similar regime to the Act or an implemented and enforceable privacy policy similar to this Privacy and Cookie Policy. We will take all steps reasonably necessary to ensure that your Personal Information is treated securely and in accordance with this Privacy and Cookie Policy.

All Personal Information you provide to us is stored on secure servers and we shall hold a SSL Certificate. However, payments to Vendors shall be processed via either Paypal or Stripe directly and you should refer to their respective policies regarding their encryption and security. We shall not be processing any payments. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Your consent and changes to our Privacy and Cookie Policy

If we change our privacy or cookie policies and procedures, we will post those changes on our Platform to keep you aware of what information we collect, how we use it and under what circumstances we may disclose it. By continuing to access our Platform after any change is posted, you agree to any such change to our Privacy and Cookie Policy. If you do not agree with such changes, you should stop using our Platform.

Contact and complaints

Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to info@trendeo.com.

You may always launch a complaint regarding our processing of your data with ico.org.uk