SHALLET – PRIVACY POLICY

This Privacy Policy along with the Terms and Conditions set out the basis upon which Shallet Limited (Shallet, we and/or related terms such as us and our) the owner and operator of the Shallet e-commerce platform including the ShalletApp and the ShalletStock agency website www.shallet.org (together, the Shallet Service) agrees to provide the Shallet Service to a user (you and/or related terms such as your).

Please read this Privacy Policy carefully, as it explains the collection and use of your personal information when you use the Shallet Service, including our use of cookies and similar technology as explained in our Cookies Policy.  If you do not understand anything please contact us.

Our registered office is at 240-241 High Holborn, London WC1V 7DN and we are registered in England & Wales with company number 10066333 with VAT registration number GB2434 409 23.

Version number 1 dated December 6, 2016

  1. This Privacy Policy

1.1 When providing the Shallet Service we wish to protect the privacy of our users and other individuals.  This Privacy Policy will help you to understand when we collect personal information and how we use that personal information.  It also explains your rights in relation to that collection and use.

1.2 We may update this Privacy Policy from time to time by posting changes here, so please check this page regularly.  The effective date of this version of the Privacy Policy is shown above.

1.3 As set out in the Terms and Conditions you must be at least 18 years old (or the of age of majority in your country of residence if higher) to use the Shallet Service.  We do not knowingly collect personal information from children through the Shallet Service.

  1. Collection of personal information

2.1 We collect certain personal information when you register an account with Shallet via the ShalletApp but also when you choose to provide it to us in connection with the Shallet Service: including by uploading photographs, posting information and submitting other content for us to display or by otherwise contacting us by email, letter or telephone.

2.2 The types of personal information we may collect include:

(a) contact information, such as name and surname, postal address, e-mail address and mobile number;

(b) password and user ID;

(c) photographs and other content you submit which identify you or things about you;

(d) details of what and when you buy or sell on the ShalletApp;

(e) sales revenue and other details of our sales agency activity on your behalf through the ShalletStock agency website; and

(f) any identification, anti-money laundering or fraud-protection checks which we may operate.

Please be aware that, unless specified otherwise, any bank or payment account information: such as credit card and IBAN code will be provided directly to and held by a third party payment processor acting on our behalf.

2.3 Your name and surname may be viewed by all other users of the Shallet Service.  If you include your personal information in photographs which you upload to the Shallet Service this may be viewed by anyone using the Shallet Service or as part of any commercial exploitation of that photograph.  Please do not include any personal information that you are not happy to be viewed so widely.  We recommend that you do not include the personal information of anyone else without their permission.

2.4 We also collect certain information, by automated means, when users visit the ShalletStock agency website or use the ShalletApp which may include:

(a) technical information such as the Internet Protocol (IP) address, browser and device characteristics (including operating system and any plug-ins) and language preferences of the user; and

(b) usage details for the website such as the website address of the sites visited immediately before and after using the website, information on actions taken on the website such as records of the parts of the website visited, services used and the dates and times of visits, and user location.

For more information please see our Cookies Policy.

2.5 We may also receive personal information from third-party services such as your social media accounts (e.g. name, date of birth, email address and any other information which you have made publicly accessible). We will ask your permission before we access your personal information in this way.

2.6 If we require you to provide additional information for any purpose we will provide notice explaining why and how we will use that information.

  1. Use of personal information

3.1 We may use the personal information we collect as set out above in order to:

(a) create and manage your account;

(b) offer and provide the Shallet Service including:

(i) allowing you to buy or sell on the ShalletApp;

(ii) allowing us to conduct sales agency activity on your behalf through the ShalletStock agency website;

(c) respond to and communicate with you about your requests, questions and comments;

(d) administer and help diagnose technical and operational issues that may arise with the ShalletApp and ShalletStock agency website;

(e) otherwise operate, evaluate and improve our business (including the development of new services, the management of our communications, the analysis of sales, marketing and advertising, the tailoring or personalization of services and performing accounting, auditing, billing, reconciliation and collection activities);

(f) perform market and consumer research, trend analysis, anonymization and data aggregation;

(g) process any disputes or claims we receive in connection with the Shallet Service;

(h) comply with and enforce our Terms and Conditions and other legal rights including blocking or taking other action against offensive, disruptive or inappropriate access or use and other protective steps;  

(i) identify, prevent or act against fraud and other criminal or unlawful activity; and

(j) comply with and enforce applicable legal and regulatory requirements and requests and relevant industry standards.

3.2 If we use the information we obtain about you in other ways we will provide notice to you, including where we provide specific notice at the time of collection.

3.3 We are based in the United Kingdom.  We may transfer the personal information we collect about you to countries outside the European Economic Area (EEA) including the United States of America (USA).  Those countries may not have data protection laws that provide the same level of protection as the EEA.  When we transfer your information to such other countries, including the USA, we will protect that information as described in this privacy policy and in accordance with applicable law.  We will always ensure that an adequate level of protection is in place to protect your personal information.

3.4 Whenever and wherever we collect, process or use personal information, we take steps to ensure that it is treated securely and in accordance with this Privacy Policy.

  1. Disclosure of personal information

4.1 We may share the personal information we collect as set out above with:

(a) third parties who perform services on our behalf, or with whom we otherwise enter into arrangements, where this is necessary in order for us to provide the Shallet Service to you or to our other users, e.g. the service providers hosting and managing the ShalletApp and the ShalletStock agency website;

(b) other users of the Shallet Service e.g. so that you can trade with them on the ShalletApp and we can conduct sales agency activity on your behalf with them through the ShalletStock agency website;

(c) companies that are affiliated with us through common ownership; and

(d) anyone who buys some or all of our business or business assets (including in the event of a reorganization, dissolution or liquidation).

4.2 We may also disclose information about you:

(a) if we are required to do so by law, regulation or legal process (such as a court order);

(b) in response to requests by government agencies including the police and law enforcement authorities; or

(c) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation of suspected or actual illegal, unlawful or harmful activity.

  1. Retaining personal information

We will keep your personal information for as long as is necessary for the relevant purposes as set out in this Privacy Policy or as is otherwise agreed with you or as we are required, or it is necessary or appropriate for us, to do for legal or regulatory reasons.

  1. Direct marketing

If you have opted in to allowing us to contact you by email to market and promote our goods and services, we may personalise such communications using the personal information we hold.  If you no longer wish to receive direct marketing from us you may at any time request us to stop sending this to you.  If you wish to do this please contact: support@shallet.org.

Please be aware that we are able to process an opt out request only for a specific e-mail address.  So, if you have more than one e-mail address or if you have changed your e-mail address, your opt out request may not be processed properly.  If you believe you have opted out, but continue to receive e-mails from us, please contact us.

  1. Links

We are not responsible for the privacy practices of other sites or apps which are accessible from the Shallet Service.  We encourage you to be aware when you leave the Shallet Service, and to read the privacy and cookie policies of other sites or apps that collect or use personal data.  This Privacy Policy applies only to personal data collected by us, Shallet Limited.

In particular, where the Shallet Service has been integrated with third party services, such as the platforms operated by a third party payment provider or your social media accounts, please be aware that the privacy and cookie policies of those third party service providers will apply.

  1. Security

We always do our best to protect your personal information.  We take appropriate technical and organizational steps to prevent any unauthorized or illegal processing and any loss, destruction or damage.  You should be aware, however, that, no data transmission over the Internet or any other public computer network is ever completely secure and that such transmissions are largely outside our control.

  1. Access and corrections

You have the right to request a copy of the information that we hold about you.  If you would like a copy of some or all of your personal information, please contact us.  We may make a small charge for this.  To help protect your privacy and maintain security, we may take steps to verify your identity before granting you access to the information.  We want to make sure that your personal information is accurate and up to date.  Please contact us if you want us to correct or remove information that you believe is inaccurate.

  1. Contacting us

If you wish to contact us please use our postal address at: 240-241 High Holborn, London WC1V 7DN, United Kingdom or send an email to support@shallet.org.

Shallet Limited is a U.K. private limited company

Address: 240-241 High Holborn London,
WC1V 7DN

Company’s registration number: 10066333

VAT number: 243 4409 23

Contact: support@shallet.org