You are not legally required to provide us with any Personal Data (defined below), but without it we may not be able to provide you with the full range of Platform or with the best user experience when using our Platform. To learn more about the choices available to you, please read Section 11 below.
1. The Personal Data we collect and process:
We collect contact information, technical data, profile data, communication data, content, and other data received from you or other third party sources. We use this personal data to provide, improve and secure our Service; for analytics, marketing and sales purposes; to comply with applicable laws; and to support our legitimate interests.
Specifically, we collect the following categories of data (which, to the extent it relates to an identified or identifiable individual, constitutes “Personal Data”), under the applicable lawful basis (in brackets), and use it for the following purposes:
a. Information you provide us
Your name, postal address and email address as well as a username and, if you’re a Seller, a store name and store description (contractual performance; legitimate interests; legal obligations; consent):
- We need to know these to register you as a User, secure your account and to authenticate you when you log into your account in the future (contractual performance).
- We need to know this information so that we or our Sellers can send you email confirmations of your order and verify your payment details, and to enable Sellers from whom you purchase an item on our Platform to process your orders, and send you items that you ordered (contractual performance).
- We also use your data for fraud prevention purposes (legitimate interests).
- We need this information so that we can respond to your queries and occasional complaints (contractual performance; legitimate interests).
- We may also keep a record of these to inform any future communication with us, to demonstrate how we communicated with you throughout, to ensure that we provide you with the best possible service.
- We also use this data to send you survey and feedback requests to help improve our services. It helps make our products or services more relevant to you (legitimate interests).
- Sometimes, we may need these details to send you communications that are required by law or necessary to inform you about our changes to the services we provide you (legal obligations; contractual performance).
- If you actively consent to receiving newsletters, marketing and promotional information from us, we will also process your email address for the purpose of providing you with these (consent).
Your (mobile) telephone number
- We ask for your phone number so that we can contact you in case we need to, for example if we need to contact you regarding the delivery of an item (contractual performance) and to identify you (fraud prevention).
Photographs (contractual performance)
- As a Seller you are required to upload photographs of the items you wish to sell over our Platform. We will display these photographs to other Visitors and Users on the Platform.
Your payment details (contractual performance, legitimate interests)
- For online payments and other transactions, we use Paypal as our third party payment service provider (“PayPal”). To enable Paypal to provide this online payment service, we collect and store certain identification data from users of the Platform. This identification data may include such personal data as your name and email address. Processing of any of your personal data by PayPal is covered by the PayPal privacy statement (available here).
- In addition, we may use this data for fraud prevention and detection purposes.
b. Personal data that is processed when you communicate with us (contractual performance, legitimate interests, consent):
- When you interact with our customer support representatives via email, telephone, bots, online or in person, we collect and process personal data, such as your name, address, phone number, email address and contact preferences so we can provide you with customer service and support (contractual performance).
- We also may create event logs that are useful in diagnosing product or app performance-related issues, and capture information relating to the support or service issue (legitimate interests).
- To improve customer service, subject to applicable laws, we may also record and review conversations with customer support representatives, and analyse any feedback provided to us through voluntary customer surveys to make sure we continuously improve that customer service (legitimate interests).
c. Information automatically collected or generated from your use of the Platform
(by cookies, web beacons and similar technologies)
We use a tool called “Google Analytics”, provided by Google and used by us to track and analyze the use of our Platform for internal purposes. To learn more about how Google uses data from our use of Google Analytics, we recommend you review Google’s policies located at: google.com/policies/privacy/partners. For additional information, please see Google Analytics’ opt-out web tool available at: https://tools.google.com/dlpage/gaoptout
When Visitors or Users interact with our Platform, we may automatically collect (by cookies, web beacons and similar technologies) certain information:
(a) technical information, including the Internet protocol (IP) address used to connect the respective computer to the Internet, login information, browser type and version, time zone setting, language preferences, browser plug-in types and versions, operating system, version, device information;
(b) information about the Visitor’s or User’s visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our Platform (including date and time); products viewed or searched for, the frequency and scope of use of the Platform, page interaction information (such as scrolling, clicks, and mouse-overs), the content viewed (including advertisements clicked on) and pages visited, communications with other Users and third parties, and cookie data.
Information about your device and how you use our Platform (including your IP address, device type) (legitimate interests)
- We use this data to continuously improve our Platform, to set default options for you, and to show you the correct content. We may also use it to develop, test and improve the systems, services and products we provide to you by recording your browser’s Session ID.
- We also use this data to deliver relevant website content and advertisements to you (including suggestions and recommendations), to measure or understand the effectiveness of the advertising we serve to you, and to monetize our Platform;
- We may perform market research or measure website usage; and analyse traffic counts and website performance;
- We also use this information to perform network communications, to administer our Platform and to support internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes and as part of our efforts to keep our Platform safe and secure, for maintaining and analysing the function of the Platform’s features and offerings, advertisements, and e-mail communications, and to improve them when necessary.
Information about your geographic location
- When you visit the Platform, we use a software called GeoIP (https://www.maxmind.com/en/geoip2-services-and-databases) to determine your current location based on your IP address.
- WooCommerce allows shop owners to automatically geolocate customers and display tax rates and shipping methods specific to a customer’s location. This is IP specific
- We use your geographic location to automatically display the tax rates and shipping methods that are relevant for a Buyer according to his/her location.
d. Any of your personal data (legal obligation)
There may be situations where we are legally required to share your personal data, for example, when a court order is submitted to share it with law enforcement agencies or a court of law.
e. Anonymized or aggregated data
We may collect, use, and share anonymized or aggregated data such as statistical or demographic data for any purpose. Anonymized or aggregated data may be derived from your personal data but is not considered personal data, as this data does not relate to an identified or identifiable person. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific website feature. We may use anonymized or aggregated data indefinitely without further notice to you.
f. If you fail to provide Personal Data
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time, provided we are not prohibited from doing so by applicable law.
Vintage Granny limits access to your personal information by Vintage Granny personnel to those whom we believe reasonably need that information to provide products or services to you or in order to do their jobs.
g. 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 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 further acknowledgment or consent, in compliance with the above rules, where this is required or permitted by law.
2. Disclosure Of Your Information To Third Parties
We share your data with our affiliates; with our service providers and advisors; with third parties for the prevention of fraud; with the Seller or the Buyer that is the other party to a transaction, and in accordance with legal compliance.
We value your privacy and will not share your personal information except with the parties set out below for the purposes indicated in Section 1 above. We make sure they adhere to the same standards of data protection that we do.
- As part of the buying and selling process, we will facilitate the sharing of information between the two Users involved in the transaction, such as providing the Buyer’s shipping address and payment status to the Seller. As a Buyer, please be aware that the Sellers will process your personal data in accordance with their own privacy policies and are as such responsible for the protection of personal data under their control. Sellers may share certain personal data of a Buyer, such as name, address, and telephone number, with their shipping partners in order to fulfill their contractual obligations towards that Buyer.
- Where Vintage Granny acts as a Seller, we will share certain personal data of a Buyer, such as name, address and telephone number, with your information with some of our third party partners such as our shipping and payment partners to enable us to deliver the item to the Buyer. Such partners will process your personal information in accordance with their own privacy policies. In some instances, these partners, not Vintage Granny, are responsible for the protection of personal data of a Buyer, such as name, address and telephone number under their control. Vintage Granny is required to share such personal data in order to order to fulfill their contractual obligations towards the Buyer.
- Professional advisers, including lawyers, bankers, auditors and insurers based in Israel and other countries where our Users are based, in each case, where they provide consultancy, banking, legal, insurance and accounting services.
- We may use and share with third parties the information we collect from and receive about you in order to deliver content or advertising; to perform market research or measure website usage; and to analyze traffic counts, your interests and website performance.
- 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. If we believe that such change in control might materially affect your Personal Data then stored with us, we will notify you of this event and the choices you may have via e-mail or prominent notice on our Platform.
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.
Non-Personally Identifiable Information.
- We may also share aggregated or non-personally identifiable information that we collect under any of the above circumstances with our business partners, affiliates or other third parties to develop and deliver targeted advertising on our Platform and on websites of third parties. We may also share aggregated information with third parties, including advisors, advertisers and investors, for the purpose of conducting general business analysis. For example, we may disclose to our advertisers the number of visitors to our Platform and the most popular features or services accessed. This information does not contain any personal information and may be used to develop website content and services that we hope you and other users will find interesting and to customise content and advertising.
3. What Other Users May See
Users and Visitors may see certain data relating to you.
If you have an Account with our Platform, certain information on your user profile is visible to others: Other Buyers and Sellers as well as Visitors may see your user name. If you are a Seller, they may also see your store name and description, location, reviews and ratings you receive from Buyers, including their comments, information relating to items you have sold or are offering for sale, your store page and policies.
4. Cookies And Our Collaboration With Third-Party Ad Networks
Most browsers allow you to control cookies, including whether or not to accept them and to remove them. You may set most browsers to notify you if you receive a cookie, or you may choose to block cookies with your browser. However, if you refuse to accept cookies, you won’t be able to access and take advantage of many features of our Platform properly.
The types of cookies we use are set out below:
- Performance Cookies: This type of cookie helps us to secure and maintain our Service, and remembers your preferences for features on the Service such as language and currency preferences, so you don’t have to re-set them at every visit.
- Analytics Cookies: Every time someone visits our Service, the analytics services we use generate cookies which can tell us whether or not you have visited the Platform in the past, and provide additional information regarding how visitors use our Service (such as where Visitors tend to click on our Service, or how often they visit). Your browser will tell us if you have these cookies and, if you don’t, we generate new ones.
- Registration Cookies: When you register and sign into our Platform, we generate cookies that let us know whether you are signed in or not, and maintain your login session. While you are signed into our Platform, we combine information from your Registration Cookies with Analytics Cookies, which we could use to learn, for example, which pages you have visited.
- Third Party Integration Cookies: Within our Platform, third parties may also set their own cookies. They do this to track the performance of their applications that are integrated with our Platform, or to customize their services for you. Because of how cookies work, we cannot access these cookies, nor can these third parties access the data in other cookies that we use on our Platform.
We use WooCommerce cookies. These cookies store information on the items a Visitor views during a session and the items in a Buyer’s cart. These cookies are stored for the duration indicated here: https://docs.woocommerce.com/document/woocommerce-cookies/#store-front-end and do not contain any personal data. More information can be found here: https://docs.woocommerce.com/document/woocommerce-cookies/
We use the Mailchimp_landing_site cookie. More information can be found here: https://mailchimp.com/legal/cookies/
Google Ads and Other Advertising Networks
- Google’s use of advertising cookies enables it and its partners to serve ads to you based on you visit to our sites and/or other sites on the Internet.
We use the “visitor action pixels” from Facebook Inc, or, if you are based in the EU, Facebook Ireland Ltd., (“Facebook”) on our Platform. This allows user behavior to be tracked after site visitors have been redirected to our Platform by clicking on a Facebook ad. This enables us to measure the effectiveness of Facebook ads for statistical and market research purposes. The data collected in this way is anonymous to us, i.e. we do not see the personal data of individual users. However, this data is stored and processed by Facebook. Facebook may link this information to your Facebook account and also use it for its own promotional purposes, in accordance with Facebook’s Data Usage Policy https://www.facebook.com/about/privacy/. You can allow Facebook and its partners to place ads on and off Facebook. A cookie may also be stored on your computer for these purposes. The legal basis for the use of this service is our legitimate interests. You can object to the collection of your data by Facebook pixel, or to the use of your data for the purpose of displaying Facebook ads by contacting the following address: https://www.facebook.com/settings?tab=ads.
We engage in service and promotional communications, through e-mail, SMS and notifications.
Service Communications: We may contact you with important information regarding our Platform. For example, we may send you notifications (through any of the means available to us) of changes or updates to our Platform, billing issues, service changes, log-in attempts or password reset notices, etc. You can control your communications and notifications settings from your Account settings. However, please note that you will not be able to opt-out of receiving certain service communications which are integral to your use (like password resets or billing notices).
Promotional Communications: We may also notify you about new features, additional offerings, events and special opportunities or any other information we think our users will find valuable. We may provide such notices through any of the contact means available to us (e.g. phone, mobile or e-mail), through the Platform, or through our marketing campaigns on any other sites or platforms.
Mailchimp uses email tracking. Email tracking tells us when you opened an email and what links you clicked on. We use this information to improve our communications, and include general information such as open and click-through rates to inform communications planning and reporting.
If you do not wish to receive such promotional communications, you may notify Vintage Granny at any time by sending an e-mail to email@example.com, changing your communications preferences in your Account settings, or by following the “unsubscribe”, “stop”, “opt-out” or “change e-mail preferences” instructions contained in the promotional communications you receive.
6. Transfers of Personal Data
We store your data in Israel and in the European Union.
We are an Israeli private company headquartered in Tel Aviv, Israel. Please be aware that we may need to transfer your information, including your Personal Data, to Israel, the European Union, the United Kingdom and other jurisdictions as necessary for the proper delivery of our Platform through certain third parties that we use to operate and manage the Platform, including VULTR.
Further, in order for us to ensure that Sellers can deliver the purchased items to a Buyer, we have to share the Buyer’s name, contact information and certain other personal data as necessary for the delivery of the item with the relevant Supplier that might be located in another jurisdiction. Simply put, in some cases we cannot provide you with our services and perform our contract with you without moving your personal data around the world. If you are a resident of the EU (or any other jurisdiction that applies privacy in the same manner as GDPR), the transfer of your personal data to such third country is based on GDPR Article 49(1)(b).
Whenever we transfer your personal data out of the EEA or the UK, 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.
- Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
Please Contact us at firstname.lastname@example.org if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA or the UK.
7. Data Retention
We retain your data for as long as necessary for the performance of our Service or for supporting and exercising our legitimate interests, and in accordance with our legal obligations.
Vintage Granny will retain your information only for as long as is necessary for providing you our Platform or for as long as your account is active, for satisfying any legal, accounting, or reporting requirements, or for the relevant term under the respective statute of limitation that may apply to the relationship between you and us.
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 requirements.
If you have any questions about our data retention policy, please contact us by email at email@example.com.
8. How do We Secure Your Information?
We secure your Personal Data using [industry-standard] administrative, technical, and physical measures.
We consider data security a top priority and we do our best to keep your Personal Data secure. 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. Such measures include:
- Encrypting many of our services using SSL.
- Employing firewalls and intrusion detection systems.
- Practicing administrative, technical, and physical security procedures to help protect the information you provide us.
- We use CloudFlare to protect our Platform and your Personal Data.
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 personal data breach (whether such breach is actual or a probable threat) and will notify you and any applicable regulator of a breach where we are legally required to do so.
Please keep in mind that no method of transmission over the Internet, or method of electronic storage, is 100% secure. As a result, although we strive to protect your personal information, we cannot promise or guarantee that such information will be immune from any wrongdoings, malfunctions, unlawful interceptions or access, or other kinds of abuse and misuse.
If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please immediately notify us of the problem by contacting us in accordance with the “Contact Us” section above.
9. Protection of Children’s Privacy
Our Service is not directed towards children under the age of 16.
Our Platform are not directed to children under sixteen (16) years. We do not knowingly collect Personal Data from children and do not wish to do so.
If it comes to our attention through reliable means that a registered user is a child under sixteen (16) years of age, we will make all efforts to promptly delete any Personal Data stored with us with regard to such child.
10. Rights To Access Personal Data
- You have the right to request access to your Personal Data held by us. This enables you to receive a copy of the personal data we hold about you. Upon your request, we will verify that you are the person making this request and in order to do so, we may request identification documents from you.
- You also have the right to request correction of your Personal Data held by us. We reserve the right to verify the accuracy of the new data you provide to us.
11. Rights of individuals in the European Economic Area
Individuals have certain rights concerning their Personal Data. You may exercise these rights by contacting us.
If you reside in the European Union (or any other jurisdiction that applies privacy in the same manner as GDPR), you have certain rights under European Data Protection Law with respect to your personal data. 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, if applicable, will be notified to you 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: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) 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; or (d) 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 provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, or to delete your account, please contact us under firstname.lastname@example.org.
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 may refuse to comply with your request in these circumstances.
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.
We try to respond to all legitimate requests within one month. Occasionally it may 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.
If you do not reside in the European Union but you believe that you have a right to restriction of processing or a right to object to processing under your local laws, please contact Vintage Granny at email@example.com.
12. Rights of California Residents
We may collect personal information about California residents who are afforded additional rights under the California Consumer Privacy Act, Cal. Civ. Code §§ 1798.100 et seq. (the “CCPA“)). California residents have the right to request that Vintage Granny (i) provide you with access to the Personal Information that we hold about you, (ii) correct your Personal Information, (iii) delete your Personal Data, and (iv) cease or restrict disclosures or sales of your Personal Data to third parties. You may request any of these by contacting us via email at firstname.lastname@example.org. Upon your request, we will verify that you are the person making this request and in order to do so, we may request identification documents from you.
You also have a right against discrimination for exercising any of these rights, which Vintage Granny is committed to upholding and honoring.
13. Contact Us
You can contact us with any questions regarding privacy and data protection.
Our full details are: Vintage Granny Ltd.
Email address: email@example.com
If you are an EU resident, you have the right to make a complaint at any time to the relevant supervisory authority. We would, however, appreciate the chance to deal with your concerns before you approach such authority, so please contact us in the first instance.
We may update this policy from time to time.
15. Additional Notices
If one provision of this policy is invalid, the rest of the policy remains valid.
If any provision of this Policy is deemed invalid by a court of competent jurisdiction, the invalidity of such provision shall not affect the validity of the remaining provisions of this Policy, which shall remain in full force and effect, provided, however, that in such event this Policy shall be interpreted so as to give effect, to the greatest extent consistent with, and permitted by, applicable law, to the meaning and intention of the excluded provision as determined by such court of competent jurisdiction.
16. Governing Law and Jurisdiction
This Policy shall be governed by the laws of the State of Israel, without respect to its conflict of laws principles. We each agree to submit to the personal and exclusive jurisdiction of the courts located in Tel Aviv, Israel, and waive any jurisdictional, venue, or inconvenient forum objections to such courts.