1. What kind of information does ADWAY use?
There are two general categories of information we collect and/or ask for.
Information you give us
We process data we receive from you. For instance, when you register as a User or when you contact our Customer Support department.
Account information. If you wish to sell or buy on our Online Platform, you have to create an Account. To do this, you need to choose a password and enter your email address. You can also create a ADWAY Account via a social media account such as Facebook. We will then receive basic information from and retained by that social media account, such as your email address. We may also receive information about your status updates and content you viewed or clicked on using that social media account. You can control the data you allow us to have access to through the privacy settings of the relevant social media website.
Profile information. In addition, to enable you to use our Service and enable us to perform the Service, we will ask you to provide certain information, such as your full name, email address, telephone number and address. This information is required for us to contact you and for the proper functioning of the platform.
Communication information. When you contact our Customer Support or when they contact you, we collect information about the reason of such contact and all information you provide to us over the phone or email. This also includes any notifications we receive from others about you or the Lots you offered or bought. Through our Online Platform you are also able to communicate with other Users. We may review, scan or analyse such communications for fraud prevention, risk assessment, investigation and support purposes.
Other information. We may ask you to provide us with feedback about our Service through an email or online survey. We greatly appreciate any feedback and will only process personal data (such as your email address or User ID) which may be collected by us or by our service provider for internal analytical purposes to enhance our Services.
Information we collect automatically
When you use our Online Platform, we collect information about your activities such as clicks, bids and information about your device to provide you with the best possible Service.
Usage information. We keep interest profiles, qualifications and characteristics of Users, so we know what type of User you are, your location and what Lots you like. Such information enables us to find out what you are interested in and to personalise our Service for you. For instance, based on your browsing behavior we may offer you targeted marketing emails. If you do not wish to receive such emails, you can unsubscribe from the link in your email or by adjusting your Account settings.
Log data. We automatically collect certain information sent by your internet browser when you use our Online Platform, even if you have not created an Account or are logged in. That information includes, among other things: details about how you’ve used the Platform (including links to third party applications), IP address, access times, hardware and software information and information about the device you used.
2. For what purposes does ADWAY use the information?
Below you can read for what purposes we use your personal data.
The provision of our Service
We use your data firstly in order to fulfill our contractual obligations to you, and to ensure that our Service is provided to you in the best possible way. In this regard we use your data to:
- enable you to access and use our Online Platform, including payment features
- display the Online Platform in a format that corresponds with your internet browser and the device you use
- provide customer service to you via email
- send you status updates, invoices and/or payment reminders by email, SMS, Whatsapp, any other direct messaging or push notifications
- keep our internal administration in order
To provide, personalise, measure and improve our advertising and marketing
We want to make our Online Platform attractive to all of our Users. Therefore it is in our (legitimate) interest to find out what you click on and what you think about our Service. In this light we process your data to:
- show you suggestions (such as interesting Lots) and targeted advertisements (on other websites) based on your activities on our Online Platform
- offer and/or inform you about extra services, events, offers, promotions and benefits
- maintain contact via mail, telephone or SMS (or any other direct messaging) or for answering questions
- invite you to provide us with feedback about our Service
- draw up anonymised statistical information that we use for target group and market analysis and for improving navigation on our Online Platform
In order to optimise our Service and marketing activities, we may make use of cross-device tracking via a User ID number (User ID) assigned to you during registration. This User ID is a unique and persistent string of numbers representing you as a user of the Online Platform. Cross-device tracking enables us to track your behaviour across multiple devices that are linked to each other and to combine the data to provide you with personalised content on those various devices. For instance, we may show you personalised content on your computer based on your behaviour on our mobile application. You can manage the way your devices share the data by adjusting the privacy settings on each device separately.
Ensure and maintain a trusted and safe Online Platform
Of course it is also in our legitimate interest to ensure and maintain a trusted and safe Online Platform. We may also have to process and store your data to comply with legal obligations. For these reasons we process personal data to:
- prevent, trace and counter fraud or any other unlawful use of the Online Platform or Service
- register, mediate and resolve possible disputes or irregularities
- comply with our legal obligations, such as keeping records, and comply with any duties in the context of criminal or other investigations by competent authorities
- enforce our Terms and Conditions and other policies
- use prediction models based on which we may decide to ask for a form of payment security or to obstruct your Bid or payment. For example, we use your bidding, buying or selling history and location to predict the chance on the purchase agreement being cancelled. Based on the outcome of the model, we may ask you to verify your credit card before placing a Bid as a safety measure.
3. When will information be provided to third parties?
When you buy or sell Lots
When you buy or sell Lots on the Online Platform, other Users may gain access to data such as your name, address, email address and phone number, as this may be necessary for the conclusion or execution of the transaction (including delivery and pick up). For example, if you conclude a Purchase Contract with another User, your address, email address and phone number will be provided for communication purposes and for arranging pick up or shipment of Lots. The provision of contact information may also be necessary before a transaction has been concluded, for instance to enable Users to arrange a viewing with other Users directly. In the event of any issues between you and another User, we may also provide information that is relevant for the other User to solve the issue with you directly.
With your consent
We may also provide your data to others if you have consented thereto. For example, another User might want to refund you directly. In those situations we ask for your permission to share your financial data with that User.
When certain services are provided by third party service providers
We may also engage processors. These are third parties that perform services for us and, in that context, also process personal data. For example, processors may provide us with payment, advertising, customer or sales support services, support us in sending emails or analysing feedback and assist us in securing the Online Platform against fraud. Processors have a duty to maintain confidentiality and may only use the specific data for providing services to us on our instructions.
Third parties to whom we provide your data may be located outside the European Economic Area or they may use servers that are located outside the European Economic Area. The level of protection may be lower in those countries than in the European Economic Area. In such event and where necessary we will ensure that there is a legal basis for such a transfer and that adequate protection of your data is provided as required by applicable law, for example, by using standard agreements approved by relevant authorities and by requiring the use of other appropriate technical and organisational information security measures.
When we are (legally) obliged to or need to enforce our Terms and Conditions
We may also disclose your data to third parties:
- if we feel obliged to do so, for instance in the event of disputes or if your User material is manifestly unlawful
- to comply with statutory obligations, such as court orders
- to cooperate with authorities such as the police or tax authorities
- to enforce performance of the ADWAY Terms and Conditions
4. How do we secure your information and how long do we store it?
We take the security of your data seriously and have security procedures and technical restrictions in place to protect your data from unauthorised access, destruction or alteration. In addition to the security measures on our end, such as encryption of your data, we highly recommend you to carefully select a password and make sure to keep your login details secret.
5. How can you control your information?
You can adjust your information associated with your Account by visiting your account settings.
If you’d like to know what information we have about you, you may ask us to provide you with an overview of your personal data. You may also ask us to delete your personal data. You can do this by sending an email to firstname.lastname@example.org. Please clarify in the subject whether it is a request to access or deletion. This makes it easier for us to help you as soon as possible. Bear in mind that ADWAY may ask you for additional information to determine your identity, such as a copy of your ID card. Furthermore, please know that we may need to retain certain information to comply with national law or regulations (for example to comply with applicable tax laws), to prevent and counter fraud, resolve any disputes, to enforce our Terms and Conditions. Furthermore, in certain cases you may ask us to restrict or to object to certain processing.
When you have provided your consent for certain use of your data by us, e.g for sending you marketing emails, you can easily withdraw your consent. You can do so through your Account or by clicking on an ‘unsubscribe’ link in an email.
6. What should you do in case of a privacy violation?
If you think we have infringed your privacy rights, we kindly ask you to notify us by sending an email to email@example.com. This enables us to investigate the matter as soon as possible. You can also lodge a complaint at the relevant national supervisory authority.
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You can also send request via contact form.