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Privacy Policy

IBIDONSTORAGE LTD (referred to as the Company, we, us or our in this privacy policy) respects your privacy and is committed to protecting your personal data. This privacy policy (this Policy) contains information on who we are, how and why we collect, store, use and share your personal data when you visit the website at www.ibidonstorage.co.uk (the Website) regardless of where you visit it from and tells you about your privacy rights and how the law protects you. This Policy also explains your rights in relation to your personal information and how to contact us or supervisory authorities in the event you have a complaint. Please read this Policy carefully.


We collect, use and are responsible for certain personal information about you. When we do so we are subject to the Data Protection Act 2018 which applies in the United Kingdom.



1. Important Information and Who We Are

Purpose of this privacy policy


This Policy aims to give you information on how we collect and process your personal data through your use of this Website, including any data you may provide through this Website when you sign up to our newsletter or updates, register for an account (Account Holder), place a bid or successfully purchase an item or contents of a storage unit.


This Website is not intended for children and individuals under the age of 18 years of age are prohibited from using this Website. We do not knowingly collect data relating to children.


It is important that you read this Policy together with any other document we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This Policy supplements our Terms and Conditions and other policies and is not intended to override them.



Controller


We are the controller and responsible for your personal data.


IBIONSTORAGE LTD is the controller and responsible for your personal data (collectively referred to as "IBIONSTORAGE ", "we", "us" or "our" in this Policy).


If you have any questions about Policy, including any requests to exercise your legal rights, please contact us through our online contact form at https://www.ibidonstorage.co.uk/contact.



Contact details


If you have any questions about this Policy or our privacy practices, please contact us through our online contact form at https://www.ibidonstorage.co.uk/contact


You have the right to make a complaint at any time to the Information Commissioner`s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.



Changes to this Policy and your duty to inform us of changes


We keep this Policy under regular review. This version was last updated on 7 April 2020. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.


We may update this Policy from time-to-time by posting a new version on the Website. You should check this page occasionally to ensure you are happy with any changes. We may also notify you of changes to this Policy by email if you have asked us to keep in touch with you by email.


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 policy of every website you visit.



2. The Data We Collect About You

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).


We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

  • Identity Data includes first name, last name, username or similar identifier, date of birth and gender.

  • Contact Data includes billing address, home address, email address and telephone numbers.

  • Transaction Data includes details about transactions and payments to and from you and other details of items you have purchased through the Website.

  • Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this Website.

  • Profile Data includes your username and password, bidding history, won auctions history, your interests, preferences, feedback and survey responses.

  • Social Media Data includes how you interact with us using Social Media including commenting on any of our website blogs.

  • Usage Data includes information about how you use our Websites and our services.

  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences and how you contact us offline, for example by telephone, fax, SMS, email or post.


We may also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific Website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Policy.


We do not collect any Special Categories of Personal Data about you (this 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.


If you fail to provide personal data


Where we need to collect personal data by law, or in order to provide the our services, and you fail to provide that data when requested, we may not be able to perform those services or you may not be able to complete the agreement you are trying to enter into (for example, to provide you with the item(s) you purchase through the Website). In this case, we may intervene and suspend, retract or cancel your bid on a sale, and/or use of our service or the Website. You will be notified if this is the case at the time.



3. How Is Your Personal Data Collected?


We use different methods to collect data from and about you including through:

  • Direct interactions. You may give us your Identity, Contact, Financial, Transaction, User, Profile, Social Media, Marketing and Communications Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
    • register and create an account on our Website;

    • make a bid on the Website;

    • list an item or items for sale;

    • are the winning bid and purchase an item or items;

    • subscribe to our newsletter and/or updates;

    • request marketing to be sent to you;

    • comment on blog articles or interact on social media; or

    • give us feedback or contact us.

  • Automated technologies or interactions. As you interact with our Website, we will 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.

  • Website. For more information on how we use cookies through the Website, please see paragraph 5 below.

  • Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources.

  • Technical Data from the following parties:
    • analytics providers, such as Google Analytics based outside the EU;

    • advertising networks including Google Ads, DoubleClick, Microsoft Advertising, and Facebook Ads, based outside the EU; and

    • search information providers
  • Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as Sage Pay Europe, based inside the EU.

  • Identity and Contact Data from data brokers or aggregators such as Equifax based inside the EU for identification verification.

  • Identity and Contact Data from publicly available sources such as Companies House and social media platforms, such as Facebook, Twitter and Instagram.


4. How We Use Your Personal Data

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:

  • Where we need to perform services in order to complete the agreement that you are about to enter in to or have entered in to.

  • 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 obligation.

Please read paragraph 11 to find out more about the types of lawful basis that we will rely on to process your personal data.


Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.


Purposes for which we will use your personal data


We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.


Note that 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 contact us 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 in the tables below.



Website User:


Purpose/Activity


Type of data


Lawful basis for processing including basis of legitimate interest

To administer and protect our business and the Website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

· Technical


· Usage

· Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)


· Necessary to comply with a legal obligation

To use data analytics to improve the Website, our services, marketing, customer relationships and experiences

· Technical


· Usage


· Social Media

· Necessary for our legitimate interests (to define types of customers for our services, to keep the Website updated and relevant, to develop our business and to inform our marketing strategy)

To make suggestions and recommendations to you about items or auction(s) that may be of interest to you.

· Technical


· Usage


· Social Media

· Necessary for our legitimate interests (to develop our services and grow our business)


Registering for our newsletter/updates:


Purpose/Activity


Type of data


Lawful basis for processing including basis of legitimate interest

To deliver relevant Website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you

· Identity


· Contact


· Profile


· Usage


· Marketing and Communications


· Technical


· Social Media

· Necessary for our legitimate interests (to grow our business and to inform our marketing strategy)

To manage our relationship with you which will include:


(a) Notifying you about changes to our terms or this Policy


(b) Asking you to leave a review or take a survey

· Identity


· Contact


· Profile


· Marketing and Communications


· Social Media

· Performance of a contract with you


· Necessary to comply with a legal obligation


· Necessary for our legitimate interests (to keep our records updated and to study how customers use our services)

To use data analytics to improve the Website, our services, marketing, customer relationships and experiences

· Technical


· Usage


· Social Media

· Necessary for our legitimate interests (to define types of customers for our services, to keep the Website updated and relevant, to develop our business and to inform our marketing strategy)

To make suggestions and recommendations to you items or auctions that may be of interest to you

· Identity


· Contact


· Technical


· Usage


· Profile


· Marketing and Communications


· Social Media

· Necessary for our legitimate interests (to develop our services and grow our business)


Account Holder:


Purpose/Activity


Type of data


Lawful basis for processing including basis of legitimate interest

To register you as an account holder

· Identity


· Contact


· Profile

· Performance of a contract with you

To enable the completion of a sale between a seller and a buyer. 

· Identity


· Contact


· Transaction


· Technical

· Performance of a contract with you


· Necessary to comply with a legal obligation


· Necessary for our legitimate interests (to enable the completion of a successful sale on the Website)

To manage our relationship with you which will include:


(a) Notifying you about changes to our terms or this Policy


(b) Asking you to leave a review or take a survey

· Identity


· Contact


· Profile


· Marketing and Communications

· Performance of a contract with you


· Necessary to comply with a legal obligation


· Necessary for our legitimate interests (to keep our records updated and to study how customers use our services)

To administer and protect our business and the Website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

· Identity


· Contact


· Technical

· Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)


· Necessary to comply with a legal obligation

To deliver relevant Website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you

· Identity


· Contact


· Profile


· Usage


· Marketing and Communications


· Technical


· Transaction

· Necessary for our legitimate interests (to study how customers use our services, to develop them, to grow our business and to inform our marketing strategy)

To use data analytics to improve the Website, our services, marketing, customer relationships and experiences

· Technical


· Usage

· Necessary for our legitimate interests (to define types of customers for our services, to keep the Website updated and relevant, to develop our business and to inform our marketing strategy), and to promote our business to existing and former customers.

To make suggestions and recommendations to you about items or auctions that may be of interest to you

· Identity


· Contact


· Technical


· Usage


· Profile


· Transaction


· Marketing and Communications

· Necessary for our legitimate interests (to develop our services and grow our business)

Ensuring business policies are adhered to (such as security and use)

· Technical


· Usage

· For our legitimate interests to ensure we are following our internal procedures so we can deliver the best service to you.



Marketing


We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising using the following personal data control mechanisms:

  • Promotional offers from us: We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which services and offers may be relevant for you (we call this marketing). You will receive marketing communications from us if you have requested information from us or purchased goods or used our services and you have not opted out of receiving that marketing.

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

  • Opting out: You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of an item(s) your purchase, use of the Website, 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 get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us using the details set out in above. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.


Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.



5. Website Cookies

The Website uses cookies. Cookies are tiny text files which identify your computer to our server as a unique user when you visit certain pages on the Website and they are stored by your internet browser on your computer`s hard drive. Cookies can be used to recognise your IP address, saving you time while you are on the Website. 


We only use cookies for your convenience in using the Website and not for obtaining or using any other information about you (for example targeted advertising). 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 the Website may become inaccessible or not function properly.


Please note that we collect data from the Website about use of the Website using a web analysis tool which uses cookies that are/able to be used to generate pseudonyms for a user’s profile. This means that the cookies we use (which may be stored on your computer after you leave the Website) can store information about your visit.


If you want to find out more information about cookies, go to http://www.allaboutcookies.org or to find out about removing them from your browser, go to http://www.allaboutcookies.org/manage-cookies/index.html.


To view the active list of cookies that are used on this site along with further details, please visit the Cookies Policy page. 




6. Disclosures of Your Personal Data

We may share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.

  • Internal Third Parties as set out in the Glossary.

  • External Third Parties as set out in the paragraph 11.

  • Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Policy.

  • In most circumstances we will not disclose personal data without consent. However, when we receive a complaint or communication from, for example, the ICO or another regulator or relevant body (such as the police), we may need to share personal information.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.



7. International Transfers

We share your personal data within the iBidOnStorage corporate group of companies. This will involve transferring your data outside the European Economic Area (EEA).


Many of our external third parties are based outside the 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 ensure a similar degree of protection is afforded to it 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, such as Canada.

  • Where we use certain service providers or share information with companies within our corporate group outside of the EEA, such as to South Africa, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.

  • Where we use providers, or share information with group companies, based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.



8. 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. 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.


Payment transactions are transmitted to our (Level 1 PCI DSS compliant) payment processor securely using internationally recognised 256-bit encryption standards. Using inframe technology, sensitive data is captured and stored directly on the payment processor servers. 


Our payment processor is PCI DSS (Payment Card Industry Data Security Standard) compliant to the highest level and maintains regular security audits. They are also regularly audited by the banks and banking authorities to ensure their systems are impenetrable. 



9. Data Retention

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.


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, regulatory, tax, accounting or other requirements.


Details of retention periods for different aspects of your personal data are available on request from us by contacting us.


Financial data including credit card data is stored with payment processor for up to 7 years or when credit card expires. 


Identity, Contact, Transaction, Technical, Profile, Usage, Marketing and Communications Data are stored on our servers are retained indefinitely and can be removed upon request by contacting us through our online contact form at https://www.ibidonstorage.co.uk/contact.


By law we have to keep basic information about our customers (including Contact, Identity, Financial 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 your legal rights in paragraph 10 below for further information).


In some circumstances we will 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.



10. Your Legal Rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data:

  • 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

Please see paragraph 11 below to find out more about your legal rights. If you wish to exercise any of the rights set out above, please contact us.


No fee usually required


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 could refuse to comply with your request in these circumstances.


What we may need from you


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.


Time limit to respond


We try to respond to all legitimate requests within one month. Occasionally it could 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.



11. Glossary


LAWFUL BASIS


Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service and the best and 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.


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.


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


THIRD PARTIES


Internal Third Parties


Other companies in the iBidOnStorage Group acting as joint controllers or processors and who are based in Canada, South Africa and United States and provide IT and system administration services and undertake leadership reporting. Data will be shared internally as per section 4 for IT and management decisions. This will include identity, contact, transaction, technical, marketing, communications and profile data, as defined in Section 2 except for financial data.


External Third Parties

  • A seller of the contents of a self-storage unit(s) who will perform the contract with the buyer following a sale through the Website.]Service providers acting as processors based in Canada and United States who provide IT and system administration services.

  • Payment processors based in United Kingdom who provide payment processing

  • Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in Canada, South Africa and Australia who provide consultancy, banking, legal, insurance and accounting services.

  • HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.


YOUR LEGAL RIGHTS


You have the right to:


Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.


Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.


Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.


Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.


Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

  • If you want us to establish the data`s accuracy.

  • Where our use of the data is unlawful but you do not want us to erase it.

  • Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.

  • You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.


Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to register your bid(s), process a sale or provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.

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