When it comes to your personal data, safety and transparency take top priority here at Seclo. To help you understand what information we collect about you, how we use it, and what rights you have, we’ve prepared this detailed Privacy Policy.

1. General

This Privacy Policy applies to the online platform Seclo (“Website”) and to the associated app (“App”) (the Website and the App are jointly referred to as the “Site”).

The Site is operated by Seclo B.V., Stationsplein 45, 3013 AK Rotterdam, the Netherlands. The operator is further referred to as “We”, “Us” or “Seclo”. More details about how to get in contact with us can be found at the end of this Privacy Policy under No. 8.

We take your privacy extremely seriously. All personal data will be collected, stored and used by us in accordance with the European Union General Data Protection Regulation No. 2016/679 (“GDPR”) and/or other applicable statutory regulations.

The services offered by us via the Website and/or App can function only if we collect, store, transfer, delete and/or otherwise use (“collect and use”) specific data relating to you (“personal data” or “data”). Personal data means all information relating to an identified or identifiable natural person such as your name, date of birth, address, or email address.

This Privacy Policy describes which of your data we collect and for what purposes we collect and use it when you use the services offered by us on the Site, including Seclo Pro service for professional sellers (“Pro User”). This Privacy Policy also contains important information on the protection of your data, especially the statutory rights you have in connection with it.

Certain services on our Site are offered by third-party suppliers. When you use these services, the data protection regulations of the third-party suppliers will then apply in addition to this data protection statement. Prior to your use of such services, the third-party suppliers may require you to provide permission under data protection law.

Under applicable data protection laws, Seclo is obligated to inform you about data processing and Seclo fulfills this obligation within this Privacy Policy. This Privacy Policy and any parts of it are not meant as contractual clauses and do not become part of the General Terms and Conditions (“GTC”) as a contract that is concluded with registered users. Under applicable data protection laws, Seclo can process data that is necessary for the performance of a contract with you or necessary for taking steps at the request of you prior to entering into a contract (Art. 6 (1) (b) GDPR). References to the GTC should at all times be understood as information on data processing (Art. 13 and 14 GDPR) and never as clauses that become part of the GTC. By using the Site and our services, you enter into a legally binding contract between you and Seclo conditions of which are described in the GTC.

2. Why and how do we collect and use your personal data?

2.1. To enable you to use the Site, allow us to provide our services and perform our GTC

We collect and use your personal data to allow you to use our Site, to provide our services and to perform a contract (GTC) with you and especially to undertake commercial transactions via the Site, to use the electronic payment system or to leave reviews and communicate with other members. To use these services, you need a Seclo account. For this purpose, you must register as a member on the Site.

Most of your personal data is required to perform a contract (GTC) with you. In case you do not provide us with this personal data, we will not be able to conclude and execute a contract (GTC) with you. Part of your data is required to fulfill our legal obligations when you are a member of our Site. In case you do not provide us with this personal data, we will not be able to comply with legal requirements and provide our services.

This data is also used for the improvement of the Site in order to make it a better experience for our members (see 2.2.12).

We collect and use your personal data for these purposes until the deactivation of your Seclo account or for 5 years of inactivity on your account.

2.1.1. To enable registration on the Site

2.1.2. To authenticate you via Google, Facebook or Apple ID

2.1.3. To enable you to set up your profile information

2.1.4. To show other members relevant information regarding your activity on the Site

2.1.5. To enable you to list your items

2.1.6. To enable notifications on the Site for you

2.1.7. To enable you to communicate with other members

2.1.8. To enable you to leave reviews to other members on the Site

2.1.9. To receive reviews from other members

2.1.10. To enable you to post in the forum and discuss with our community

2.1.11. To send you important communication regarding the Site

2.1.12. To determine that you are a professional seller and notify you about it

2.1.14. To provide you with customer support service

2.1.15. To resolve any purchase-related disputes between members

2.1.16. To retain temporarily your deactivated account

2.2. To improve your experience when using the Site

We collect and use your personal data in order to improve your experience when using the Site by enabling you to personalize your feed and search results, providing you relevant suggestions and keeping your previous searches, sending you notifications and otherwise making the use of Site more pleasant.

A specific applicable legal basis for the collection and use of your data is described in each section below.

2.2.1. To enable your preferences regarding your feed and search results

2.2.2. To personalize your feed and search results

2.2.3. To prioritize good value items by reputable sellers

2.2.4. To suggest you relevant items

2.2.5. To improve search results on the Site

2.2.6. To save your recent searches

2.2.7. To help you to get more attention to your listings

2.2.8. To suggest a price when an item listing is created

2.2.9. To enable notifications about your favorite items

2.2.10. To notify sellers when you favorite their items

2.2.11. To allow you to follow other members

2.2.12. To improve our Site

2.2.13. To conduct surveys

2.2.14. To conduct interviews

2.2.15. To enable you to share your user journey

2.2.16. To enable automatic content translation

2.3. To ensure the security of your account and the Site

 

Seclo strives to ensure that the accounts of our members and the Site itself would be secure and protected from cyber attacks, unauthorized access and other related risks.

2.3.1. To track visits to the Site for security purposes

2.3.2. To help you avoid using a compromised password

2.3.3. To let you reset your password

2.3.4. To verify your account in case of suspicious actions related to your account

2.3.5. To carry out e-mail verification

2.3.6. To carry out payment source security check

2.3.8. To ensure that listings comply with our Authenticity Policy

2.3.9. To carry out account ownership check

2.3.10. To enable you to report inappropriate behaviour or content

2.3.11. To report suicidal posts

 

2.4. To supervise compliance with and enforce GTC

Seclo actively supervises compliance with and enforce GTC for the purpose of ensuring the security of your account and the Site.

2.4.1. To calculate trust score

2.4.2. To enforce spam filtering

2.4.3. To moderate your activity on the Site

2.4.4. To issue and enforce warnings

2.4.5. To delete or hide items that violate Seclo GTC

2.4.6. To detect and lock compromised accounts

2.4.7. To suspend members

2.4.8. To enforce bans

2.4.9. To enforce IP blocks

 

2.5. To enable your payments for items

 

Payments on the Site are carried out via payment service providers that provide payment processing and escrow services.

Most of your personal data is required to perform a contract (GTC) with you. In case you do not provide us with this personal data, we will not be able to conclude and execute a contract (GTC) with you (Art. 6 (1) (b) of the GDPR). Part of your data is required to fulfill our or our payment service providers’ legal obligations when you are a member of our Site (Art. 6 (1) (c) of the GDPR). In case you do not provide us with this personal data, we or our payment service providers will not be able to comply with legal requirements and we will not be able to provide our services.

This data is also used for the improvement of the Site in order to make it a better experience for our members (see 2.2.12).

2.5.1. To allow you to make a purchase or add a payment card for payment purposes

2.5.2. To allow you to add a bank account for withdrawal purposes

2.5.3. To enable you to pay and receive payments on our Site

2.5.4. To implement Know Your Customer (KYC) checks on our Site

2.5.5. To carry out Politically Exposed Persons (PEP) checks on our Site

2.5.6. To issue refunds

2.5.7. To transfer your information to a Pro User

2.5.8. To keep financial records

 

2.6. To enable shipment of items purchased on the Site

 

Seclo strives to make the shipping of items purchased on the Site as smooth and convenient as possible by offering shipping methods on the Site.

Most of your personal data is required to perform a contract (GTC) with you. In case you do not provide us with this personal data, we will not be able to conclude and execute a contract (GTC) with you.

This data is also used for the improvement of the Site in order to make it a better experience for our members (see 2.2.12).

2.6.1. To enable you to ship or receive items

2.6.2. To track your parcel

 

2.7. To carry out marketing activities

 

Seclo seeks to involve our members in marketing campaigns and it benefits our members. At the same time, we wish to present you with marketing material that is both relevant and engaging.

2.7.1. To send you marketing emails

2.7.2. To personalize marketing messages

2.7.3. To contact you for publicity and/or earning opportunities

2.7.4. To conduct advertisement campaigns involving you

2.7.5. To enable us to post your content on our social media accounts

2.7.6. To allow you to see personalized advertisements

2.7.7. To evaluate the efficiency of promotional campaigns

2.7.8. To manage our social media profiles

2.7.9. To enable you to participate in Seclo’s referrals program

 

2.8. For legal purposes

 

2.8.1. To handle your requests related to personal data

2.8.2. To provide information to law enforcement and other state institutions

2.8.3. To defend our rights against chargebacks

2.8.4. To comply with the Dutch law

2.8.5. To defend the rights and interests of Seclo

 

3. Recipients of personal data

Seclo transfers or shares personal data with service providers only insofar as necessary and allowed in accordance with applicable laws. Service providers to which your personal data are transferred or shared with for specific purposes are described under 2 above. In addition, we appoint the following service providers that, as a result, receive personal data as recipients of data.

We constantly conduct and improve technical maintenance of the Site to protect the security and confidentiality of personal data we process and to perform certain business-related functions that help make our services available and functional. For this reason, we transfer your profile data to service providers which provide cloud and hosting services, IT security, maintenance and technical services, communications services.

The following service providers are established outside the European Economic Area, which may result in your data being transferred outside the European Economic Area. In these cases the personal data is protected by the service providers entering into the EU standard contractual clauses for the transfer of data as approved by the European Commission:

  1. Amazon Web Services, Inc. (USA);
  2. Google LLC (USA);
  3. Apple Inc. (USA);

We transfer personal data to attorneys, attorney assistants, notaries, bailiffs, auditors, accountants, bookkeepers, debt collectors, consultants, translation agencies, IT service providers, insurance companies, archiving services that provide services to Seclo.

Seclo is statutorily obligated to provide personal and/or usage data to investigative, criminal prosecution or supervisory authorities if and insofar as required for the avoidance of risk to the public and for the prosecution of criminal acts.

Seclo may share your data with third parties when transferring rights and obligations pertaining to the contractual relationship between you and Seclo to such third parties in accordance with the GTC (available via the link https://www.seclo.eu/terms_and_conditions), in particular in the case of the transfer of a sector of activity, a merger through the foundation of a new company, a merger through absorption, de-merger or any change in control affecting Seclo. Prior to such an event, Seclo will inform you separately about the details of sharing your data and will obtain your consent where legally necessary.

 

4. What you should know when you interact with a Pro User

Joint Controllership of Seclo and Pro User – Essence of the Arrangement

Within sections 2.1.6, 2.1.7, 2.1.8, 2.1.9, 2.1.14, 2.5.3, 2.5.7, 2.6.1, 2.8.1 your personal data for this purpose will be processed jointly between Seclo and Pro User, you are informed about Seclo and operators of commercial accounts (“Seclo Pro Users”) processing data as so-called “joint controllers”. This means that Seclo and Seclo Pro users are together responsible for fulfilling certain legal obligations when they process personal data as joint controllers. There is not a joint controllership for all data processing, but only for certain purposes and certain phases of processing that are explained further in the individual sections of this privacy policy (see 2.1.6, 2.1.7, 2.1.8, 2.1.9, 2.1.14, 2.5.3, 2.5.7, 2.6.1, 2.8.1).

Within this section, we would like to inform you about the essence of the arrangement on joint responsibilities that we entered into with Seclo Pro users, in accordance with Art. 26 (2) sentence 2 of the GDPR. Since there are two controllers, we want to explain to you who is responsible for what.

Contact Point for questions and exercising rights: In case of questions or when you want to exercise one of your data subject’s rights, you can contact the designated contact point (Art. 26 (1) sentence 3 GDPR) under the following email address: dpo@seclo.eu

In general, Seclo and Seclo Pro users are both responsible for fulfilling legal obligations under the GDPR. Notwithstanding that, Seclo and Seclo Pro users agreed to certain responsibilities that apply when we act as joint controllers. Seclo is responsible for:

  • serving as a contact point (Art. 26 (1) sentence 3 GDPR) for you;
  • handling the communication centralized with you regarding data subject’s rights (Art. 15 GDPR, Art. 16 GDPR, Art. 17 GDPR, Art. 18 GDPR, Art. 20 GDPR);
  • providing you information about the data processing (Art. 13 GDPR and Art. 14 GDPR);
  • informing you about our essence of the arrangement (Art. 26 (2) sentence 2 GDPR), which we are doing within this section;
  • informing you about data breaches associated with high risks to your rights and freedoms (Art. 34 (1) GDPR), in case such a data breach occurs.

All other responsibilities under the GDPR are fulfilled both by Seclo and Seclo Pro users. Those other duties do mostly not involve you as a data subject directly, but rather general obligations of joint controllers such as maintaining security measures and keeping a record of processing activities. For data processing out of scope of the joint controllership, both Seclo and Seclo Pro users are independently and separately responsible and the information provided in this section does not apply.

 

5. Use of cookies

Seclo uses cookies and similar technologies on the Site. You can find out more by visiting our Cookie Policy.

6. Right of amendment

As we are constantly developing our services, we reserve the right to change this Privacy Policy at any time subject to the applicable regulations. Any changes will be published promptly on this page. Regardless of the aforementioned, you should check this page regularly for any updates.

 

7. Your statutory rights regarding your personal data

7.1. What rights do you have?

Subject to conditions, limitations, and exceptions established by statutory data protection provisions, you have the right at any time:

  • to be informed of the data we collect and use and to request access or demand a copy of the data concerned (right to access). All the data that you have actively provided for us on the Site (2.1, 2.5, and 2.6) can also be accessed by you at any time in your Seclo account;
  • to demand the correction of inaccurate data and, subject to the nature of the collection and use, the completion of incomplete data (right to rectification);
  • subject to just cause, to demand the deletion of your data (right to deletion);
  • to demand restriction of the collection and use of your data, provided the statutory criteria are met (right to restrict processing);
  • subject to the statutory criteria being met, to receive the data you have provided in a structured, current, and machine-readable form and to transfer this data to another data controller or, where technically feasible, to have it transferred by Seclo (right to data portability);
  • to object to the collection and use of data – only where the collection and use is based on a task carried out in the public interest or in the exercise of official authority vested (Art. 6 (1)(e) of GDPR) or legitimate interest (Art. 6 (1)(f) of GDPR), including profiling, based on the same data collection and use grounds as explained in other sections of this statement (right to object). You also have the right to at any time object to the collection of your personal data for direct marketing purposes;
  • to withdraw at any time any permission you have provided to us. Such withdrawal will not affect the lawfulness of the collection and use carried out prior to withdrawal and based on the permission granted. You can withdraw your permission for the sending of our newsletter by adjusting your Seclo account settings to block the sending of any further Marketing Emails. Alternatively, you can click “Unregister” at the end of the Marketing Email;
  • not to receive discriminatory treatment while exercising your rights.

To exercise any of the rights specified in this section, you can contact Seclo and submit your request using the contact details (8 below). Regardless of any other legal remedy, you also have the right at any time to submit a complaint to the supervisory authorities.

 

7.2. How will we verify your request?

 

Your request must provide sufficient information that allows us to reasonably verify you are the person or an authorized representative of a person whose personal data we have collected (name, surname, your public profile URL, your e-mail, other information we may request for verification purposes), describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it, provide a confirmation under a penalty that you are the individual whose personal data is the subject of the request.

If your request is submitted by an authorized agent, a written permission and information that verifies the identity of the agent must be enclosed with the request.

We cannot provide you with the information or exercise your other rights if we cannot verify your identity or authority to make the request and confirm the information relating to you.

In order to verify your identity, we may request you to provide additional information about yourself. We will only use this information and information provided in the request to verify your identity or authority to make the request.

 

8. Our contact details

If you have any queries regarding the collection and use of your data as part of your use of the Site, or regarding your rights, please contact our data protection officer at dpo@eu.nl.

Seclo data protection officer:

Seclo, B.V.

Stationsplein 45

3013 AK Rotterdam

The Netherlands

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