Introduction

Welcome to Collexchange Limited's (collectively referred to as “we”, “us” or “our”) privacy policy.

We are the operator of www.collexchange.co.uk (our “Website”) and the controller of any personal data processed via the Website.

We respect your privacy and are committed to protecting your personal data. This privacy policy will (amongst other things):

• describe the types of personal data that we collect when you visit our Website (regardless of where you visit it from and/or whether you purchase, bid for, list for sale and/or sell items via our Website);
• inform you as to how and in what circumstances we use, and look after your personal data once it is collected; and
• tell you about your privacy rights and how the law protects your personal data.

Important Information about who we are

Purpose of this Privacy Policy

This privacy policy aims to give you information on how we collect and process your personal data through your use of this Website, including any data you may provide through this Website when you:

• create an account on our Website;
• peruse the items listed on the Website;
• list, offer for sale and/or sell items via the Website (i.e. acting as a Seller):
  • upload information about you or the items that you wish to sell;
  • carry out an auction via the Website; and/or
  • once you have entered into a contract with a buyer, liaise with the buyer of the items as to the logistical terms for the delivery of such items to the buyer;
• bid for and/or purchase items via the Website (i.e. acting as a Buyer):
  • place a bid as part of an auction carried out via the Website;
  • purchase items via the Website; and/or
• purchase items via the Website; and/or
• once you have entered into a contract with a seller, liaise with the seller of the items as to the logistical terms for the delivery of such items to you.

 

This Website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy policy together with any other privacy policy or fair processing policy that we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact us using the details set out below.

Contact Details

If you have any questions about this privacy policy or our privacy practices, please contact our data privacy manager in the following ways:

Full name of legal entity: Collexchange Limited

Email address: data@collexchange.co.uk

Postal address: 23-25 Waterloo Place Warwick Street, Leamington Spa CV32 5LA

Company no. 14032478. VAT registered no. 434 2359 07

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review. This version was last updated on 8 February 2024.

It is important that the personal data we hold about you is accurate and current. We encourage you to review, update and correct the personal data that we hold about you. Please keep us informed if your personal data changes during your relationship with us.

Third-party links

Our Website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our Website, we encourage you to read the privacy policy of every website you visit.

 

The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

The exact kinds of your personal data which we may collect, use, store and transfer will depend on and align with the relationship that we have with you. In an effort to provide you with as much information as possible as to the types of personal data we may process about you, such personal data could include:

In respect of Sellers:

• Identity Data including your full name, username or similar identifier and confirmation that you are aged 18 years or older.
• Contact Data including billing address, delivery address (where items are returned to you), email address and telephone numbers.
• Financial Data including Stripe account details.
• Transaction Data including details about auctions you have carried out via the Website, items you have sold via the Website, commission that you have paid to us, payments made to you from Buyers, refunds you have paid to Buyers and other details of any other services you have paid for.
• Technical Data including internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
• Profile Data including your username and password, auctions carried out by you on the Website, your interests, preferences, feedback and survey responses.
• Usage Data includes information about how you use our Website and services.
• Marketing and Communications Data including your preferences in receiving marketing from us and your communication preferences.

 

In respect of Buyers:

• Identity Data such as your full name, username or similar identifier and confirmation that you are aged 18 years or older.
• Contact Data including billing address, delivery address (where items are returned to you), email address and telephone numbers.
• Financial Data including payment details.
• Transaction Data including details about bids that you have made as part of auctions carried out on the Website, items you have purchased via the Website, payments made by you to Sellers, refunds paid to you from Sellers and other details of any other services that you may have purchased from us.
• Technical Data including internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
• Profile Data including your username and password, auctions you have taken part in on the Website, your interests, preferences, feedback and survey responses.
• Usage Data includes information about how you use our website and services.
• Marketing and Communications Data including your preferences in receiving marketing from us and your communication preferences.

In respect of visitors to our Website who are not any of the above:

• Technical Data including internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our Website.
• Usage Data including information about how you use our Website and services.

 

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific Website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

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 provide you with access to the Website with you. In this case, we may have to cancel or suspend your account that you have with us but we will notify you if this is the case at the time.

 

How is your personal data collected?

We use different methods to collect data from and about you including through:

Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us or Sellers or Buyers by post, phone, email or otherwise. This includes personal data you provide when you:

• create an account on our Website;
• place orders for items via the Website;
• submit bids as part of auctions carried out via the Website;
• correspond with Buyers or Sellers (as appropriate) in relation to the purchase of items via the Website;
• request marketing to be sent to you; or
• give us feedback or contact us.

 

Automated technologies or interactions. As you interact with our Website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies.

Third parties or publicly available sources. We will receive personal data about you from various third parties as set out below:

a. Technical Data from the following parties:

• analytics providers; and
• search information providers

b. Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as Stripe and credit card providers.

 

How we use your personal data?

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

Performance of a Contract: this means that we process your personal data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Legitimate Interests: this means that we process your personal data where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. “Legitimate Interest” means the interest of our business in conducting and managing our business to enable us to give you the best services and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Comply with a Legal Obligation: this means that we process your personal data where it is necessary for compliance with a legal obligation that we are subject to (for example, to ensure that we and none of the users of our Website are breaching any laws or regulations through their offering to sell, selling and/or purchasing certain types of items via the Website).

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

 

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

 

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us and you have not opted out of receiving that marketing.

For the avoidance of doubt, Sellers will not send any marketing communications to Buyers or prospective Buyers.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

Opting out

You can ask us or third parties acting on our behalf to stop sending you marketing communications at any time by logging into the Website and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you or by contacting us at any time.

 

Cookies

Our Website uses cookies to distinguish you from other users of our Website. This helps us to provide you with a good experience when you browse our Website and use our services and also allows us to improve our Website and services.

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer's hard drive.

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

We use the following cookies:

Strictly necessary cookies. These are cookies that are required for the operation of our Website. They include, for example, cookies that enable you to log into secure areas of our Website or make use of the Services on our Website.

Analytical or performance cookies. These allow us to recognise and count the number of visitors and to see how visitors move around our Website when they are using it as well as how you are using the Services available via the Website. This helps us to improve the way our Website and our services work, for example, by ensuring that users are finding what they are looking for easily.

Functionality cookies. These are used to recognise you when you return to our Website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).

 

List of cookies we collect

The table below lists the cookies we collect and what information they store.

Cookie Name	Cookie Description
FORM_KEY	Stores randomly generated key used to prevent forged requests.
PHPSESSID	Your session ID on the server.
GUEST-VIEW	Allows guests to view and edit their orders.
PERSISTENT_SHOPPING_CART	A link to information about your cart and viewing history, if you have asked for this.
STF	Information on products you have emailed to friends.
STORE	The store view or language you have selected.
USER_ALLOWED_SAVE_COOKIE	Indicates whether a customer allowed to use cookies.
MAGE-CACHE-SESSID	Facilitates caching of content on the browser to make pages load faster.
MAGE-CACHE-STORAGE	Facilitates caching of content on the browser to make pages load faster.
MAGE-CACHE-STORAGE-SECTION-INVALIDATION	Facilitates caching of content on the browser to make pages load faster.
MAGE-CACHE-TIMEOUT	Facilitates caching of content on the browser to make pages load faster.
SECTION-DATA-IDS	Facilitates caching of content on the browser to make pages load faster.
PRIVATE_CONTENT_VERSION	Facilitates caching of content on the browser to make pages load faster.
X-MAGENTO-VARY	Facilitates caching of content on the server to make pages load faster.
MAGE-TRANSLATION-FILE-VERSION	Facilitates translation of content to other languages.
MAGE-TRANSLATION-STORAGE	Facilitates translation of content to other languages.
_gat	Google Analytics, it allows to see how people navigate throughout the website
_ga	Unique users
_gid	Analytics identifier and it expires after 24 hours

You can also find more information about Google Analytics cookie usage on websites here. 

The duration for which each cookie will remain on your browser is set out in the table above.

We do not share the information collected by the cookies with any third parties.

You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our Website and/or services.

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 you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

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 knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

 

DISCLOSURES OF YOUR PERSONAL DATA

We may share your personal data with the parties set out below for the purposes set out in the table above.

• Where you are a Buyer, a Seller in order to facilitate and/or complete a sale of items or resolve a dispute or complaint in relation to the same.
• Where you are a Seller, a Buyer in order to facilitate and/or complete a sale of items or resolve a dispute or complaint in relation to the same.
• Service providers acting as processors who provide services such as IT, payment processing and system administration services.
• Professional advisers acting as processors or controllers including lawyers, bankers, auditors and insurers who provide services such as consultancy, banking, legal, insurance and accounting services.
• HM Revenue & Customs, regulators and other authorities acting as processors or controllers who require reporting of processing activities in certain circumstances or whom we may need to liaise with in order to confirm you have in place the necessary permits, licences, certificates and/or registrations in order to sell or purchase certain types of items.
• 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 privacy policy.

 

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.

 

INTERNATIONAL TRANSFERS

We do not transfer your personal data outside the UK).

 

DATA SECURITY

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. 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 any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

 

Data Retention

How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

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, regulatory, tax, accounting or other requirements.

Details of retention periods for different aspects of your personal data can be requested from us by contacting us on data@collexchange.co.uk.

In some circumstances you can ask us to delete your data: see the “Request erasure of your personal data” section of Your Legal Rights below for further information.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

 

Your Legal Rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:

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 will be notified to you, if applicable, 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:

• If you want us to establish the data's accuracy.
• Where our use of the data is unlawful but you do not want us to erase it.
• 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.
• 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, please contact us.

No fee usually required.

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 could refuse to comply with your request in these circumstances.

What we may need from you

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.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could 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.