Effective Date: 24/11/2023
Your privacy is extremely important to Dubizzle Group. 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.
WHO WE ARE AND HOW TO CONTACT US
Who we are
How to contact us
You can contact us by emailing: firstname.lastname@example.org.
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
First name, last name, username or similar identifier and profile photo.
In the event you decide to verify your account using our ‘Dubizzle 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), as well as a photo of your face for identification purposes. 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.
|Email address, telephone number(s).
|Approximate location if you enable this feature via your device.
|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.
|Your preferences in receiving marketing messages from us.
|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.
|Recordings of calls between you and our teams, which are recorded for monitoring and training purposes.
|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.
|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.
Special categories of personal data
We do not knowingly collect any ‘special categories of personal data’ about you (this includes, for example, details about your race or ethnicity, religious or philosophical beliefs, political opinions, information about your health, genetic and/or biometric data, and information about criminal offences and convictions).
What happens if you refuse to provide necessary Personal Data?
You do not have to provide any Personal Data to us. However, where we need to process your Personal Data either to grant you access to the Platform or to comply with applicable law, and you fail to provide that Personal Data when requested, we may not be able to provide you access to the Platform. For example, we need your email address in order to register your account on the Platform.
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
HOW WE USE YOUR PERSONAL DATA AND WHY
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.
|Categories of Personal Data
|Why we do this
|Our legal basis
|To register you as a user on the Platform and manage your user account.
|To operate the Platform and enable your use of the Platform, including by allowing you to interact with other users of the Platform.
|To understand how you and other users use the Platform and to segment our userbase into groups for marketing purposes.
|To send you marketing messages, where you have agreed to receive them.
|To track issues that might be occurring on our Platform and to address them.
|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.
|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 Dubizzle 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.
|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 affiliated companies may require access to your Personal Data as they help us operate the Platform and manage user data.
|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 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).
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
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.
YOUR RIGHTS IN RELATION TO YOUR PERSONAL DATA
Under some circumstances, you may have certain rights in relation to your Personal Data. For example, you may have the right to:
- Request access to your Personal Data. This allows you to receive a copy of the Personal Data we hold about you, and to check that we are lawfully processing it.
- Request the correction of your Personal Data. This allows you to ask for any incomplete or inaccurate information we hold about you to be corrected.
- Request the erasure of your Personal Data. This allows you to ask us to delete or remove your Personal Data from our systems where there is no good reason for us to continue processing it.
- Object to the processing of your Personal Data. This allows you to object to our processing of your Personal Data for a specific purpose (for example, for marketing purposes).
- Request the transfer of your Personal Data. This allows you to request the transfer of your Personal Data in a structured, commonly-used, machine-readable format, either to you or to a third party designated by you.
- Withdraw your Consent. This right only exists where we are relying on your Consent to process your Personal Data. If you withdraw your Consent, we may not be able to provide you with access to the certain features of our Platform. We will advise you if this is the case at the time you withdraw your Consent.
Please note that not all of the rights listed above may be available to you, and some rights may only be exercisable in specific circumstances.
How to exercise your rights
If you want to exercise any of the rights described above, please contact us.
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 your 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.
We try to respond to all legitimate requests within one month of receipt. Occasionally, it may take us longer than a month if your request is particularly complex or if you have made a number of requests. In this case, we will notify you and keep you updated.
Although we will typically not charge a fee for exercising your rights described above, we reserve the right to charge a reasonable fee in some circumstances (for example, if your request is unreasonable or if you submit an excessive number of requests).
If you are unsatisfied with our response to any issue that you raise with us, you may have the right to submit a complaint to the data protection authority in your jurisdiction.
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