Privacy Policy

1.    Personal data we collect

We collect, receive, store and otherwise process the following personal data about you:

• Account details: information that you provide to us directly when you register as a buyer or a seller (including your name, your username, your account password, your email address, and the addresses you provide for the delivery/collection of your items).
• Profile information: information related to your use of the app, including the date on which you registered for the app, your in-app notification preferences, any questions or answers you submit about listings, items you have selected to watch, the ratings or reviews given to you for the items you sell, or which you give for items you buy, and your sales or purchase history.
• Listing information: where you list items for sale, the description you provide for your items (including any videos or photos you choose to upload or tags you apply), details of your chosen type of sale (e.g. the minimum sale price and the daily percentage discount you choose to apply to your listing under a 10Day Sale or a Fire Sale); and your shipping information.
• Financial information: a record of the commissions we receive from your sales, where relevant. Our payment service provider also provides us with payment confirmation to notify us that your sale or purchase has been completed.
• Device, location and app-usage information: information we collect from and about the device you use to interact with Onro Services (such as your unique device ID, make and model information), your IP address, your location information (if enabled by you), your search queries on the Onro Services and how you interact with the Onro Services;
• Dispute/customer service information: we receive information from our logistics providers and from other users about disputes relating to the collection or delivery of the items you buy or sell, including details of complaints you make to our logistics provider. We also process records and copies of correspondence (including email addresses), if you contact us and/or we contact you; and
• Surveys and reviews: Your responses to surveys, and the content and details (e.g. date) of any product or service reviews you leave about Onro Services.

Sometimes, we also receive personal data from third parties. In particular:

• If new companies join our corporate group, the relevant records they hold about you may become subject to this Privacy Notice, to the extent permitted by law (e.g. subject to us obtaining new consents from you, if appropriate).
• We may obtain information about you from public sources, e.g. social media, particularly where you are using those to communicate with us (e.g. via Twitter); and/or from other third parties that hold information about you, for example so we can better understand your needs and interests.
• We may obtain information about you from people that contact us, e.g. other users with a complaint, or from regulators, government or law enforcement officials.

2.   How we use your personal data and our legal basis

We collect, use, store and otherwise process your personal data for the reasons set out below.  

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To perform, or take steps to enter into, a contract with you.

‍We use your personal data where needed to provide you with the services set out in our Terms and Conditions including:

• taking payments;
• for each purchase or sale, we will share the address you provide with our logistics partners to facilitate the delivery or collection of items you buy or sell;
• for each purchase, we will share the contact details and address you provide with the seller to facilitate the delivery or collection of items you buy, facilitate the response to any query raised, facilitate the processing of returns and refunds, as well as resolution of any disputes between the seller and the buyer regarding the purchased items;
• for each sale, we will share the contact details and address you provide with the buyer to facilitate the delivery or collection of items you sell, facilitate the response to any query raised, facilitate the processing of returns and refunds, as well as resolution of any disputes between the seller and the buyer regarding the sold items; and
• we show items for sale according to the sales terms you have chosen and using the product descriptions and photos which you provide.

If you do not provide the above information, we would not be able to provide our services to you. Mandatory fields in forms will be marked as such.  

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‍Where it is in our or a third party’s legitimate interests, if these interests are not overridden by your rights or interests.

‍We use your personal data where needed:

• to provide products and services to you (in cases where this is not done pursuant to a contract between us), in a fast and secure manner, including in connection with account opening and maintenance; enabling you to ask or answer questions about items listed for sale; allowing you to provide or receive ratings and reviews; to store your collection or delivery addresses (where you request us to); to allow you to provide additional information about items you offer for sale (such as videos, or tags); to facilitate the search function for sales items on the app; and to provide you with customer service assistance, including technical support with the Onro Services;
• to monitor and analyse the use of any accounts, products or services to detect, investigate, monitor, remediate, report and/or prevent security or cyber incidents, to prevent fraud or other violations of our Terms and Conditions, and for security-related statistical and trend analysis;
• to help us to improve and promote Onro Services, and to deliver a better service, including by estimating audience size and usage patterns, and testing and designing our services to better meet our users' (and prospective users') needs and preferences;
• to communicate with you and, if needed, to verify your identity when you contact us or when we contact you;
• to manage and administer our business, including sharing your personal data with our tax and other professional or technical advisors;
• to investigate and respond to any complaints about us or our business and to monitor and manage accounts in case of dispute or reports of user behavior or content which violates our terms;
• to respond to requests from any non-UK, non-EU or non-EU Member State governmental or regulatory authority or from any UK, EU or EU Member State governmental or regulatory authority, to the extent that we are not legally obliged to comply or respond to the request;
• to assign or subcontract, procure goods or services for, or to outsource any part of our normal business functions to third parties, such as IT service providers;
• for the establishment, exercise or defence of legal claims where relevant;
• to protect and enforce the rights, property or safety of us, our business, our users or customers or others; and
• to plan, prepare or put in place any restructuring of our company or our business, including any mergers, acquisitions or take-overs.

Where you consent.

‍If we rely on your consent to use your personal data, we will tell you why we want your personal data, what we will do with it, and – if relevant – we will identify third parties who will rely on the consent. We will make it clear to you when we are obtaining your consent. Where you provide consent, you can withdraw it at any time through the means indicated when we collect it, or by contacting us as set out below. We will also tell you what the consequences are if you withdraw your consent.

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Where we are required to pursuant to UK, EU or EU Member State applicable law.

‍We collect, use and store your personal data to meet or comply with our legal obligations under UK, EU or EU Member State law, including requirements relating to audit and reporting, maintenance of accounting and tax records, anti-money laundering (AML), sanctions and anti-terrorism laws and regulations and fighting crime.

We also use your personal data where this is not incompatible with the original purpose for which we obtained it, and for any other purpose that we specifically tell you about when we obtain personal data about you.

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3.   Sharing your personal data

We share personal data within our group and with:

• our third party service providers, including our IT service providers (e.g. for data hosting or IT development), consultants, payment services providers and logistics services providers;
• our professional advisors (accountants, lawyers, or tax advisors);
• law enforcement, regulatory, prosecuting, tax or governmental authorities, courts or other tribunals or dispute resolution bodies;
• prospective sellers or buyers as part of a sale or merger of our company, business or assets;
• to fulfil the purpose for which you provide it or which is otherwise disclosed to you at a later date; and

4.    International transfers of your personal data

If we transfer personal data to recipients outside of the United Kingdom or European Economic Area that are not subject to a European Commission adequacy decision under the UK government adequacy regulations or equivalent (in other words, official approval for us to transfer personal data to those recipients), we will where feasible put in place European Commission-approved standard contractual clauses, the UK Information Commissioner approved standard contractual clauses (or equivalent) in order to protect this personal data.  We might also rely on other permitted data transfer mechanisms such as relying on the relevant third party’s "binding corporate rules" (approved by UK or EU data protection authorities and put in place to protect your personal data). You have a right to ask us for a copy of the safeguard used (by contacting us as set out below). Note that those additional safeguards may not be usable in all circumstances, for example in the case of (i) disclosures to foreign authorities, (ii) where an urgent data transfer is necessary in your or another person's vital interests, or (iii) where you have expressly consented to the data transfers.

5.    How long we keep your personal data

We keep your personal data for as long as is necessary for the purposes for which we use it. When we assess that necessity, we consider the amount, nature and sensitivity of your personal data as well as the potential risk of any unauthorised use or disclosure.

By law, we can keep different personal data for different periods of time. For example, we can keep certain basic information for six years after you stop using the app as a seller or buyer for tax or dispute resolution purposes.

6.   Your rights

Depending on applicable law, you may have the following rights in respect of the personal data we process about you:

• to ask us for a copy of your personal data and to correct it;
• to require us to erase your personal data or to transfer it to other organisations;
• to object to some processing of your personal data (in particular, where it is processed for direct marketing purposes or because we have another legitimate interest in doing so (as explained above));
• to withdraw your consents;
• to restrict processing of your personal data; and
• in the case of personal data you provided, or which is used to perform a contract with you, to obtain a "portable"copy of that personal data and to ask us to share that information with another organisation.

These rights may be limited in some situations; for example, where we can demonstrate that we have legitimate grounds to process your personal data, or are prohibited from deleting mandatory records. Please also note that in some cases, we might not be able to delete your personal data except by also closing your user account.

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We may ask you to verify your identity and to provide other details to help us to respond to your request. If you wish to exercise these rights, please contact us at the email address provided below.  

7.    Links to third party sites

Onro Services may, from time to time, contain links to and from the websites or services of our partners, such as our payment provider Stripe, Inc our logistics provider Parcel2Go, or other third parties.

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If you follow a link to any of these websites, please note that these websites or services may have their own privacy policies and we do not accept any responsibility or liability for these policies, nor do we endorse such websites or services. We advise that you check any relevant terms before you submit any personal information to these third parties.

8.   Contacting us and complaints

If you have any questions about this Privacy Notice, or if you want to exercise your data protection rights, you may contact us at privacy@onro.com.

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We hope that we can satisfy any queries that you may have about the way we process your personal data. However, if you have unresolved concerns you also have the right to complain to the data protection authority in the country where you live, work or where you consider a breach has occurred. In the UK, the data protection authority is the Information Commissioner’s Office (ICO) (www.ico.org.uk).