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Privacy policy

Privacy policy

This Policy describes in detail how our bulletin board ("administration" or "we") processes and protects the personal data of users on the platform called ESVOE.CLUB ("the Platform")

The Policy applies to both registered and non-registered users ("users" or "you"). The Policy applies regardless of the device from which you use our website and regardless of the communication channel through which you access.


PLEASE NOTE: By submitting personal data to us, you consent to its processing in accordance with this Policy.


1. Definitions

1.1. Personal data (hereinafter referred to as "data" or "information") means any information about the user which identifies the user, directly or indirectly, such as name, user ID, location information, online identifiers (indicators of user activity), or other information about the user.

1.2. Processing of personal data means any action or set of actions in relation to personal data, including collection, recording, systematisation, accumulation, storage, updating and modification, extraction, use, transfer (distribution, provision, access), blocking, removing and destroying - both with and without the use of automated data processing means.

2. What information do we collect about you?

2.1. By giving us access to personal data, you guarantee its accuracy and veracity as well as undertake to inform us of any changes in it.

2.2. You will be liable for any damage caused to the Platform or the person responsible for the Platform, as well as any other user, service provider or third party, if your personal data is inaccurate or incorrect.

2.3. If you fail to provide the data necessary to register or provide advertising services, or if you refuse further processing or request that your personal data be deleted, we are probably unable to continue to provide our Services to you or to remain in any other legal relationship with you.

2.4. The personal data you provide when using our Services or creating an account on the Platform:

·         name, first name, username;

·         contact details: telephone number, email, social media pages (hereinafter referred to as Contact Details);

·         the accounts and/or social media pages you use to log in, password, phone number or login details (hereinafter Login Details);

·         region, locality, street, house, flat, postal code, post office (hereinafter referred to as Address);

·         shipping method;

·         photos;

·         orders for goods, our Services, requests for consultation, calls, viewings (hereinafter Orders);

·         advertising material/announcements;

·         any other data you provide in an appeal, feedback, comment, complaint, application or other request;

·         any calls made through the Platform, chats on the Platform;

·         any activities on the Platform;

·         a unique set of letters and numbers (e.g. ID546787) that we assign upon registration.

2.5. If you need to provide us with personal data or other information about third parties (specify another recipient of the goods, provide details of guarantors and representatives), then you must obtain the consent of such persons for such a disclosure. Otherwise, this transfer of data is not permitted. It is not permitted to upload third parties' data or photo-images of third parties onto the Platform.

2.6. In individual cases, we may need to request additional personal data about you. In such cases we will send you a separate request and inform you about the purpose of the collection and processing.

2.7. Please also note that some of your data will be available to other users of the Platform: information you have posted, including advertisements, name, profile picture, contact details. We also include your promotional material/announcements as part of our email newsletters to our subscribers. You can make changes to your details in your personal account.

2.8. Personal data that we collect automatically when you use our Services or create an account on the Platform:

·         Data that is generated as part of one of your transactions (offers, purchases, sales) or that is linked to your account as a result of a transaction in which you participate, such as transaction amounts, time and place of transactions and method of payment.

·         Data that is generated as a result of your other activities while using our Services and that is linked to your account, such as when you put items in your shopping basket, add items to your watchlist, save sellers, searches or interests, or follow users.

·         Data about all other interactions with our Services, your advertising preferences and your communication with us.

·         IP address, selected time zone settings, geolocation, device type, browser type, session ID (interaction with the Platform, domain name of the website from which you accessed the Platform, the functions you use and pages viewed on the Platform, how you use the Platform, date and time of the request, and the actions you take, if any).

2.9. The personal data we collect in connection with the use of cookies and similar technologies.

·         You can read more about this in the Cookie Policy.

2.10. Personal data we receive from third parties

In some cases, we collect additional information about you from public sources (government registers) or from our partners and may generate new information about you from them. Such information may include:

·         identification data, i.e. the details of a public document that identifies you;

·         payment data, i.e. payment status, payment card number and order data from payment organisations;

·         real estate data, that is, information on the registration of rights to real estate from state registers;

·         vehicle data, etc.

2.11. Social media data you share with us:

·         We permit you to use social media or other single sign-on service providers with which you already have an account to create an ESVOE.CLUB account or to link your ESVOE.CLUB account to such a single sign-on.

2.12. The particular set of personal data processed about you depends on the Services you choose, the purposes of processing, how you interact with us, and your activity on the Platform.

3. Why are we collecting this information? Who and when the information is provided to?

3.1. We process your personal data in order to provide you with our Services. This includes the following purposes:

·         To provide customer service, including to create and manage user accounts, resolve technical difficulties and access various features;

·         To adapt offerings and experiences, including advertising on their own services or those of third parties;

·         To monitor general and individual user activity such as keyword searches, ad posting activity and deal making and to manage traffic on the website;

·         To communicate with users, including in relation to Service, customer service or authorised marketing communications, through any available communication channels;

·         To carry out research and development and analytical activities to improve our Platform;

·         To enforce compliance with the ESVOE.CLUB Terms and Conditions, taking into account anti-fraud and anti-bullying; and

·         To evaluate certain personal information factors, in particular to analyse and predict personal preferences, interests, behaviour and location.

3.2. We process your personal data to protect your vital interests or the vital interests of the other individual.

·         This includes preventing, detecting, mitigating and investigating unlawful acts that may result in a breach of your vital interests or the vital interests of the other individual.

3.3. We also process your personal data where necessary for the purposes of legitimate interests pursued by us or a third party, unless such interests override your interests or fundamental rights and freedoms. To reconcile our legitimate interests with your rights, we have put in place appropriate controls. On this basis, we process your data for the following purposes:

·         To participate in investigations and proceedings (including legal proceedings) carried out by courts, law enforcement authorities, public authorities or governmental, intergovernmental or supranational bodies, including for the detection, investigation and prosecution of unlawful acts, except where the law provides for this effect, and we may legitimately presume that disclosure is necessary to prevent imminent inconvenience or the reporting of suspected unlawful acts. In such cases we will only disclose what we consider necessary, for example your name, city, postcode, telephone number, email address, (previous) user name, IP address, fraud complaints, trading and listing history.

·         To protect the legitimate interests of third parties in relation to civil disputes, including the investigation of such disputes, unless we have a statutory duty to do so where we can legitimately assume that it is necessary to disclose data to such third parties to prevent imminent trouble.

·         To prevent, detect, mitigate and investigate fraud, security breaches and other prohibited or unlawful activities, including assessing the risks involved.

·         To monitor and improve the information security of our Platform, unless required by law.

·         To provide users with features that facilitate the processing of transactions (e.g. administering multiple delivery addresses).

·         To analyse telephone conversations with our customer service team that we have recorded with your consent.

·         To mail advertisements (in accordance with your communication settings in your ESVOE.CLUB account).

·         To the extent permitted by applicable law, without your consent, communicate with you by email (such as email or text message) or telephone to offer you vouchers, discounts and special offers, conduct opinion polls and questionnaires, and inform you about our Services. If you do not wish to receive marketing emails from us, you can also unsubscribe by clicking on the link in the email you receive. For technical reasons, it may take a few days to implement.

·         To customise the content of the page to display offers and services that you may like depending on your actions.

·         To claim or defend against legal actions, including those brought by one ESVOE.CLUB user against another ESVOE.CLUB user.

3.4. If necessary, we will share your personal data with processors and the following recipients for one or more of the purposes described above:

·         External service providers ESVOE.CLUB;

·         Other users;

·         Law enforcement authorities, courts, public authorities or public authorities, inter-governmental or supranational bodies;

·         Third parties involved in legal proceedings;

·         Payment service providers;

·         Credit agencies or bureaus, data verification services, risk assessment providers and collection agencies (e.g. information on late payments, defaults or other irregularities that may be relevant to your credit report or that we use to confirm your identity, risk model, establish credit limits or collect outstanding debts);

·         Other companies in the context of a company acquisition;

·         Other business partners (including business partners providing advertising services).

4. What rights do you have?

4.1. You may withdraw your consent to us processing your personal data at any time. As a result, we can no longer process your personal data on the basis of this consent in the future. Withdrawal of consent will not affect the lawfulness of processing based on consent prior to withdrawal.

4.2. You have the right to access your personal data that we process. Your right of access must not adversely affect the rights and liberties of others. Your right of access may be restricted by national law.

4.3. You have the right to obtain correction of inaccurate personal data concerning you from us without undue delay. Given the purposes of the processing, you have the right to have incomplete personal data supplemented, including by submitting a supplementary request.

4.4. You have the right to request that we delete personal data concerning you under certain conditions (for example, when the personal data is no longer needed in connection with the purposes for which it was processed or when it is no longer required for prevailing legitimate grounds, such as fraud detection/prevention), unless the processing is necessary to exercise the right to freedom of expression and information, to comply with legal obligations, for reasons of public interest or to establish, exercise or defend legal requirements. The right to delete personal data may be restricted by national law.

4.5. You have the right to receive the personal data that you have provided to us in a structured, commonly used and machine-readable format, and you have the right to transfer this data to another controller ("right of data portability").

4.6. You have the right to lodge a complaint with the supervisory authority. As a general rule, you can contact the supervisory authority at your usual place of residence, place of work or at the location of the controller.

4.7. If your personal data is processed on the basis of our legitimate interests, you have the right to object to the processing of your personal data on grounds relating to your particular situation.

5. How long do we keep your data?

5.1. Your personal data will be stored by us and our service providers in accordance with applicable data protection laws to the extent necessary for the purposes of processing set out in this Privacy Policy. We will subsequently delete your personal data or take steps to appropriately anonymise the data, unless we are required or permitted to retain your personal data longer (for example, for legal, tax, accounting or auditing purposes or to detect and prevent fraudulent or illegal activities on ESVOE.CLUB).

5.2. The retention period for personal data may vary depending on the Services we provide and our legal obligations under applicable national law.

6. How do we protect your data?

6.1. We follow developments in information security and privacy technology in order to process and protect your personal data from unauthorised access, alteration, disclosure or destruction by the most up-to-date means possible. For some of the processing, we use pseudonymisation through the use of a unique User ID. All personal data is stored by the Controller on secure servers, unless we involve processors or other controllers in the processing.

6.2. The Controller restricts any access to your personal data to only those personnel, processors or other data processors that need to process that data in order to perform their job or contractual duties. Appropriate agreements for the protection and confidentiality of your data have been signed with them, which stipulate liability for breach of these obligations.

6.3. We conduct periodic reviews and risk assessments of the personal data collection, storage, processing and security measures applied by the Controller.

6.4. We also monitor and moderate data on the Platform in order to effectively counteract any abuse to protect bona fide users and protect them from breach of rights and freedoms as well as property loss.

7. Final provisions

7.1. The user acknowledges and agrees that the user's registration on the Platform, creation of an account and subsequent use of the Platform, any of its services, functionality means the user's unconditional agreement with all clauses of this Policy and unconditional acceptance of its terms.

7.2. The user's continued use of the Platform following any amendments to the Policy shall constitute their acceptance of such amendments and/or additions.

7.3. The user undertakes to review the text of this Policy on a regular basis in order to become acquainted with the amendments to this Policy in a timely manner.

7.4. We reserve the right, at our sole discretion, to modify and/or amend this Policy at any time without prior and/or subsequent notice to user. A new version of this Policy becomes effective on the date it is published on the Platform, unless otherwise stipulated in the new version of this Policy.