This policy was last updated on 17/04/2022.
Recommerce Ltd t/a MobileAdvantage, takes your privacy and security very seriously. We want you to feel confident when using our services, which is why we are open about how we use your data and take all appropriate steps to secure it. You will find all the details you need in this Privacy Policy, but please do not hesitate to contact help@mobileadvantage.co.uk if you have any privacy-related questions.
- We only use your data for the purposes set out in this policy.
- We take all appropriate steps to protect your data.
- We will never sell your data to a third party.
- Whenever you have given us your consent to use your personal data (e.g. so we can send you special offers or news about our products and services that we think would be of interest to you), you can withdraw consent at any time.
- If we do not need your data anymore, we will either anonymise it (e.g. retain your data to help us assess how people use us so that we can improve our services but make sure that you can no longer be identified from that information) or we will securely delete it.
When you are using our website and services, the data controller is Recommerce Limited, a company registered in England and Wales under company registration number 10775061 and whose registered office address is on the 1st Floor, Atlantic House, Gomm Road, High Wycombe, HP13 7DJ.
How we collect and use your information
Your name and contact details
We collect your name and contact details when you create an account on our MobileAdvantage store and use them for the following purposes:
- Delivering items you have purchased and collecting items you are selling.
- Sending important service-related messages by text, email, post and push notifications (you can opt-out of any of these at any time in your account settings).
- Sending information about our latest offers, discounts, voucher codes, competitions and updates by text, email, post, social media and push notifications (again, you can opt-out of any of these at any time in your account settings).
- Fraud prevention and detection.
- Your date of birth and gender information. We may collect your date of birth and gender information when you create an account. We use this information for the following reasons:
- To determine which products, offers and services will be of interest to you, plus send you birthday treats like voucher codes.
Your payment information
This information is collected when you checkout on any of our sites and includes credit/debit card details, bank details or PayPal details depending on how you choose to pay or receive payment. We use this information to:
- Take payment for the products you have purchased.
- Pay you for items you have sold.
- Prevent and detect fraud.
- We do not store your credit or debit card details and ensure that any bank details that we need to hold are held subject to all appropriate security measures.
Your contact history with us
We may store and use any communications you have with us (i.e. when contacting our customer service team) for the following reasons:
- Provide customer service and support.
- Devise solutions to common customer problems.
- Train our customer service team.
- Your purchase history and saved items.
- In order to deliver the best possible service, we store information on your purchase history and saved items. This allows us to:
- Provide a personalised experience when using our website (including recommended products) using automated and computerised technology.
- Review, develop and improve the products and services we offer.
- Send marketing emails relevant to your interests.
- Information about your devices and how you use our services
- When you visit our site or send an email to us, we will automatically collect information about the device you’re using (i.e. mobile, computer, tablet, etc) as well as your operating system, access times, browser information (including type, language and history), your location data, settings and other data required to deliver the services described in this policy.
We use cookies and other technologies to collect this information and use it in the following ways:
- Provide you with a personalised browsing experience, including recommended products and services.
- Deliver adverts to you across the web.
- Research and data analysis.
- Developing new products and services.
- We apply all the safeguards outlined in this policy when combining your personal information with your device information.
In some instances, we may provide third parties with aggregated information and analytics in order to deliver and improve our service. This information will be anonymised so it cannot be used to identify you.
The law on data protection sets out a number of different grounds on which we can collect and process your personal information. The table below sets out when we rely on these different
grounds:
| Contractual obligations | When we enter into a contract with you, we need your personal data to be able to fulfil the contract e.g. if we agree to buy your phone, we will need your account details to be able to pay you and may also need your address details to arrange for our courier to collect your items. |
| Legal compliance | We may be required by law to retain some of your personal data e.g. fraud prevention. |
| Legitimate interests | We may use your personal data for our legitimate interests e.g. keeping details of your purchase history so that we can provide you with a personalised service. |
| Consent | Where you have given us your consent e.g. where you have ticked a box to say you would like to hear from us about special offers. |
Your rights over the way in which we use your data will vary depending on which ground we are relying upon. Please see the
Withdrawing consent or Your rights sections.
You can withdraw consent for us to send marketing messages at any time by:
- Using the unsubscribe links provided in our emails.
- Changing your preferences in the MyAccount section of our websites or app.
- Sending an email to help@mobileadvantage.co.uk
- Writing to Data Controller, 1st Floor, Atlantic House, Gomm Road, High Wycombe, HP13 7DJ.
Online advertising and marketing messages
Like most companies, we use online advertising to bring you our latest offers and encourage new customers to try our service.
To make sure you only see ads relevant to you, we use pixels, cookies (including both first-party and third-party cookies), mobile identifiers and services offered by companies like Facebook and Google, as well as the information you provided when creating your account.
You are free to opt-out of our marketing messages at any time by:
- Using the unsubscribe links provided in our emails.
- Changing your preferences in your account.
- Sending an email to help@mobileadvantage.co.uk
- Writing to Data Controller, 1st Floor, Atlantic House, Gomm Road, High Wycombe, HP13 7DJ.
Your rights
You have the following rights over the way in which we use your personal information:
The right to access any personal information we hold about you.
This means you can ask us whether we hold information about you and, if so, for us to provide you with certain details about that information, including the information itself. This is often referred to as a subject access request.
The right to request we delete the information we hold about you
(sometimes referred to as the right to erasure of your information or the right to be forgotten).
You can ask us to delete your information in certain circumstances e.g. where it is no longer necessary for us to hold it for the purposes for which we collected it, where we need your consent to use it and you have withdrawn that consent, where you object to us using your information for our legitimate interests and there are no overriding legitimate grounds for us to continue to do so.
The right to correct or update any personal information we hold about you.
If you cannot correct the information yourself through your MobileAdvantage account, please contact us with your queries and/or the updated information.
The right to restrict our processing of your information
This might apply where, for example, you have objected to us processing your data on the grounds of our legitimate interest, but we are checking whether there are any grounds to override your objection.
The right to withdraw consent for any usage of your personal information, including the delivery of marketing messages, at any time (which you can do by changing your preferences in MyAccount or by contacting us.
You can exercise any of these rights by:
- Sending an email to help@mobileadvantage.co.uk
- Writing to Data Controller, 1st Floor, Atlantic House, Gomm Road, High Wycombe, HP13 7DJ.
- You can also update your marketing preferences (including opting out of receiving marketing) in MyAccount.
We hope that we can resolve any queries or concerns you may have about our use of your information, but you can also contact the Information Commissioner at ico.org.uk/concerns/ or telephone: 0303 123 1113 for further information about your rights and how to make a formal complaint.
How we store and protect your information
We store your information on our secure systems operated, as well as systems operated by third parties (who may also process your anonymised information on our behalf).
Your information is stored for as long as you have a MobileAdvantage account, or as long as it is needed to provide the services outlined above. If required, we may also keep your information to comply with any applicable laws or internal company policies.
Sharing your information
We appreciate the trust you place in us to handle your personal data correctly, which is why we promise not to sell your personal data to any third party under any circumstances.
However, we will need to share it with carefully selected companies and organisations in order to fulfil the services outlined in the ‘how we collect and use your information section above.
Here is a full list:
- Other companies within the Recommerce Ltd group (but only those located within EEA)
- To employees, agents and other third parties (some of whom may be located outside of the EEA) who help us deliver our services, including but not limited to: administering your account, arranging the collection and delivery of products and providing assistance with any queries you may have.
- To companies who help us tailor our services to your needs and recommend products and services you may be interested in.
- To any party to whom we transfer our rights and duties to after a change of ownership.
- To anyone the law requires us to share data with.
- Rental – If we provide a rental scheme, then the partner we choose to deliver our rental service.
In order to fully administer our services, we may also share your information with the following third parties:
Credit Reference Agencies: when considering whether to accept an application and thus enter into a Credit Agreement, we may search records held at Credit Reference Agencies. Details of our search and application may be added to the aforementioned records, and other organisations searching your records will be able to see these details. By renting a phone from us, you agree to this taking place.
Your CRA records may also be updated with details of your agreement with us, the payments you make and any default or failure to adhere to our terms. Other organisations will be able to access these details and they may be used to:
- Trace and recover debts
- Detect money laundering and fraud
- Manage your accounts
- Your payment behaviour may be reported to Credit Reference Agencies, which may affect your credit score. Our credit application search will place a footprint on your credit file, which will be visible to other lenders and organisations. The records held by Credit Reference Agencies will be linked to the data of your spouse, any joint applicants and other financial associates.
Any data shared with Credit Reference Agencies will be processed in accordance with their own privacy policies. Credit References Agencies may create or add details of your application to their own records and this information may be used to make credit decisions about you, those you are linked to financially and, if relevant, your business.
For more information on the Credit Reference Agencies we work with and their approach to using and sharing personal data, please visit https://www.transunion.co.uk/crain
Suppliers and Subcontractors: Our rental partner may share information with the suppliers and subcontractors they use to provide their service. This includes software providers, data storage providers and business consultants.
Fraud Prevention & Identity Verification Agencies: We may check your details with fraud prevention agencies. If your details are false, inaccurate or we suspect fraud, this information may be recorded. Fraud prevention agency records are accessible to other organisations making decisions on credit and insurance agreements for you and members of your household.
Payment Service Providers: Use a PCI-compliant secure credit card processor and do not save your full credit card number on their information systems.
Regulators & Legal Authorities: We may disclose necessary information with authorities such as the police, tax agencies or other authorities if required to do so by law or if you have requested us to do so. For example: we may be legally required to disclose your information for anti-money laundering purposes.
Debt Collection Agencies: Your information may be shared with third-party debt collection agencies if we need to collect unpaid debts. The debt collection agencies may process your personal data in line with their own privacy policies, or on our behalf.
Sale of the Company: If we or a partner are acquired by a third party, personal information about customers and employees will be transferred as an asset.
We may also share non-personally identifiable information publicly, for example information to show trends about the general use of our service. However, it will not be possible to personally identify you from this information.
Your information and countries outside the EEA / UK
In some instances, we may need to transfer your data to a company or organisation outside of the EEA / UK. These transfers will only be made with the appropriate safeguards in place so that your personal data receives an adequate level of protection. In so far as the receiving country does not have an adequacy decision from the European Commission / UK Government, we will put in place measures such as standard contractual clauses to ensure that your personal data is treated by those parties outside of the EEA / UK in a way that is consistent with and which respects data protection legislation.
Your data and other websites
Our website may contain links to other websites. If you visit one of these websites, you will be subject to their privacy policy rather than ours. We highly recommend viewing the privacy policy of any website you visit to determine the information they collect and how they use it.
Changes to this policy
We may change this policy from time to time. If we make any major changes, we’ll post a notification on our website.
Questions about this policy
If you have any questions or feedback about our privacy policy, please email us at: help@mobileadvantage.co.uk or send a letter to Data Queries, Recommerce Ltd, 1st Floor, Atlantic House, Gomm Road, High Wycombe, HP13 7DJ.
