Effective Date : 20 March 2024
What does this privacy policy cover?
Your privacy is extremely important to listiwo.com We are committed to protecting your Personal Data (as that term is defined further below). We want to be transparent with you about how we collect and use your Personal Data in making our website and mobile applications (“Platform”) available to you and tell you about your privacy rights and how the law protects you.
Personal data we collect from you:
The Personal Data we collect directly from you is outlined in the table below.
“Personal Data” is information about an individual from which that individual is either directly identified or can be identified. It does not include ‘anonymised data’ (which is information where the identity of an individual has been permanently removed). However, it does include ‘pseudonymised data’ (which is information which alone doesn’t identify an individual but, when combined with additional information, could be used to identify an individual).
| Category of Personal Data | What this means | |
|---|---|---|
| Identity Data |
First name, last name, username or similar identifier and profile photo. In the event you decide to verify your account using our Listiwo.com Verified’ feature, we will also process a copy of your Identification Card with all information included on it (including your Identification Card number, date of birth, nationality, and gender). We use robust measures keep this information secure to prevent any fraudulent or malicious actions such as identity theft, phishing scams, non-delivery and payment scams. |
|
| Contact Data | Email address, telephone number(s). | |
| Location Data | Approximate location if you enable this feature via your device. | |
| Listings Data | Details about your previous and current listings on the Platform, as well as details of other users’ listings that you have viewed, and offers you have made for other users’ listings. | |
| Marketing Data | Your preferences in receiving marketing messages from us. | |
| Chat Data | Details of messages that you exchange with other users of the Platform through the ‘Chat’ feature, including any additional Personal Data you may disclose in such messages. | |
| Call Data | Recordings of calls between you and our teams, which are recorded for monitoring and training purposes. | |
| Behavioural Data | Inferred or assumed information relating to your behaviour and interests based on your activity on the Platform. This is most often collated and grouped into ‘segments’ on an aggregated basis. | |
| Technical Data | Internet protocol (IP) address, 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 or use our services. | |
Personal data we collect from other sources
In addition to the Personal Data that we collect directly from you (as described in the section immediately above this one), we also collect certain of your Personal Data from third party sources. These sources are set out in the table below.
| Third party source | Categories of Personal Data | |
|---|---|---|
| Social media platforms |
|
|
| Our affiliates |
|
|
| Analytics providers |
|
|
| Advertisers |
|
|
How we use your personal data and why
We will only use your Personal Data for the purposes for which we collected it as listed below, 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 update this Privacy Policy and we will explain the legal basis which allows us to do so (please refer to the ‘Changes to this Privacy Policy’ section further below).
What is our ‘legal basis’ for processing your Personal Data?
In respect of each of the purposes for which we use your Personal Data, applicable privacy laws require us to ensure that we have a ‘legal basis’ for that use. Most commonly, we will rely on one of the following legal bases:
- Where we need to process your Personal Data to meet our contractual obligations to you (for example, to provide you access to the Platform) (“Contractual Necessity”).
- Where we need to process your Personal Data to comply with our legal or regulatory obligations (“Compliance with Law”).
- Where we have your consent to process your Personal Data for a specific purpose (“Consent”).
We have set out below, in a table format, the legal bases we rely on when processing your Personal Data.
| Purpose | Categories of Personal Data | Why we do this | Our legal basis |
|---|---|---|---|
| Account creation |
|
To register you as a user on the Platform and manage your user account. | Contractual Necessity |
| Verification |
|
To verify your account through ‘Listiwo.com Verified’ if you choose to do so. | Contractual Necessity |
| Operation of our services |
|
To operate the Platform and enable your use of the Platform, including by allowing you to interact with other users of the Platform. To deliver other services that you have requested from us (including, for example, arranging a test drive through Listiwo.com Cars). |
Contractual Necessity |
| Analytics |
|
To understand how you and other users use the Platform and to segment our userbase into groups for marketing purposes. | Contractual Necessity |
| Marketing |
|
To send you marketing messages, where you have agreed to receive them. | Consent |
| Troubleshooting |
|
To track issues that might be occurring on our Platform and to address them. | Contractual Necessity |
| Fraud prevention |
|
To keep our Platform and associated systems operational and secure. | Compliance with Law |
Who we share your personal data with
The table below describes who we may share your Personal Data with and why we share it.
We require all recipients of your Personal Data to implement appropriate security measures to adequately protect it, consistent with our policies and any data security obligations applicable to us. We do not permit our third-party service providers who process your Personal Data on our behalf to use it for their own purposes, and only permit them to process your Personal Data for specified purposes in accordance with our instructions.
| Recipients | Why we share it |
|---|---|
| Other users of the Platform |
We need to share some of your Personal Data with other users of the Platform when you wish to transact with them through the Platform. By placing an advert or submitting a review/rating on our Platform, that information and any Personal Data associated with your account profile (including your username, profile picture and Listiwo.com Verified status) will be publicly accessible to, and may be copied and shared externally by, all other users of our Platform. Such information may also appear in third party search engine results (for example, Google search results). Please ensure that you are comfortable with such information being publicly available before submitting it on our Platform. |
| Service providers | Our service providers provide us with a range of services which are necessary for the operation of the Platform (for example, IT, system administration services, or marketing services), and may have access to your Personal Data as a result. |
| Our affiliates | Listiwo.com is part of the FillsBase Group, which operates other consumer platforms and share technology with FillsBase. Our affiliated companies may require access to your Personal Data as they help us operate the Platform and manage user data. |
| Professional advisers | Our lawyers, bankers, auditors, insurers and other advisers may require limited access to your Personal Data when they provide consultancy, banking, legal, insurance and accounting services to us. |
| Public authorities | Public authorities may require us to disclose user data to them under certain circumstances, where required by law (for example, in the event of a police investigation). |
| Acquirer(s) | We may share your Personal Data with third parties in the event of any reorganisation, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, so that any potential acquirer(s) may continue operating the Platform. Where that is the case, we will ensure that any such recipient(s) continue to use your Personal Data in accordance with this Privacy Policy. |
Data transfers
We may transfer your Personal Data to jurisdictions outside of the country in which you are located that may not be deemed to provide the same level of data protection as your home country, as necessary for the purposes set out in this Privacy Policy. We will always ensure that any such cross-border transfers of your Personal Data comply with applicable requirements.
How we keep your personal data secure
We have put in place appropriate security measures to prevent your Personal Data from being accidentally lost or altered, or used or accessed in an unauthorised way.
We limit access to your Personal Data to those employees and other staff who have a business need to have such access. All such persons are subject to a contractual duty of confidentiality.
We have put in place procedures to deal with any actual or suspected Personal Data breach. In the event of any such breach, we have systems in place to mitigate any impact to your privacy and to work with relevant regulators.
How long we store your personal data
We will only retain your Personal Data for as long as we reasonably need to use it for the purposes set out in this Privacy Policy, unless a longer retention period is required by applicable law (for example, for regulatory purposes).
Under some circumstances, we may anonymise your Personal Data so that it can no longer be associated with you. We may retain such anonymised data indefinitely.
Our data retention policies are reviewed at regular intervals and comply with all applicable requirements.
Marketing Communications
You can ask us to stop sending you marketing messages at any time by logging in to the Platform and checking or unchecking relevant boxes to adjust your marketing preferences, or by following the “Unsubscribe” link included at the bottom of any marketing email you receive from us.
Our policy on minors
This Platform is not intended to be used by minors, and we do not actively monitor the age of our users.
However, if you become aware that a minor has been using the Platform in breach of this restriction, please contact us if you would like us to remove their Personal Data from our systems.
Third party links
This Platform may include links to third party websites and applications. Clicking on those links will take you off-Platform and may allow third parties to collect or share your Personal Data. We do not control these third-party websites and applications and are not responsible for their privacy practices. When you leave our Platform, we encourage you to read the privacy policy of every website and application you visit.
Changes to this privacy policy
We reserve the right to update this Privacy Policy at any time, with or without notice to you.
Where that is the case, we will update this page to display the revised Privacy Policy and may also under certain circumstances notify you (for example, by email).