1.       INTRODUCTION

1.1    Itemdrop Ltd is dedicated to ensuring the privacy of our website users.

1.2    In this policy, "we","us" and "our" refer to Itemdrop Ltd. [For more information about us, see Section 13.] “You” and “your” refer to the user.

1.3    This policy applies where we act as a data controller with respect to your personal data; in other words, where we determine the purposes and means of processing that personal data.

1.4    We use cookies on our website. Insofar as those cookies are not strictly necessary for the provision of our website, we will ask you to consent to our use of cookies when you first visit our website.

1.5    Our website incorporates privacy controls affecting how we process your personal data.

PERSONAL DATA CONTROLS
https://itemdrop.co.uk/index.php?route=account/account.

2.       CREDIT

2.1    This document was created using a template from SEQ Legal (https://seqlegal.com).

3.       HOW WE USE YOUR PERSONAL DATA

3.1    In this Section 3 we have set out:

(a)    the general categories of personal data that we may process;

(b)    the purposes for which we may process personal data; and

(c)    the legal bases of the processing.

3.2    We may process data about your use of our website and services ("usage data"). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, and information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system and Google Analytics. This usage data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website and services.

3.3    We process "account data". Account data includes your name, address, phone number and email address. The source of account data is you. Account data may be processed for website operation, service provision, maintaining website and service security, and communication purposes. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business, and the performance of a contract between you and us.

3.4    We may process information that you post for publication on our website or through our services ("publication data"). Publication data includes your name only. The publication data may be processed for reviewing the products we offer. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business.

3.5    We may process information contained in any inquiry you submit to us regarding goods and/or services ("inquiry data"). Inquiry data may be processed for offering, marketing, and selling relevant goods and/or services to you. The legal basis for this processing is consent.

3.6    We may process information relating to our customer relationships, including customer contact information ("customer relationship data"). The customer relationship data may include your name, your contact details, and information contained in communications between us and you. The source of the customer relationship data is you. The customer relationship data may be processed to manage our relationships with customers, communicate with customers, keep records of those communications, and promote our products and services to customers. The legal basis for this processing is our legitimate interests, namely the proper management of our customer relationships.

3.7    We process information relating to transactions, including purchases of goods and services, that you enter into with us and/or through our website ("transaction data"). Transaction data includes your contact details (“account data” (See Section 3.3)), and transaction details. The transaction data is processed to supply the purchased goods and services and keep proper records of those transactions. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract and our legitimate interests, namely the proper administration of our website and business.

3.8    We may process information that you provide to us to subscribe to our email notifications and/or newsletters("notification data"). The notification data may be processed to send you the relevant notifications and/or newsletters. The legal basis for this process is consent.

3.9    We may process information contained in or relating to any communication that you send to us ("correspondence data"). Correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed to communicate with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users.

3.10  We may process any of your data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.

3.11  In addition to the specific purposes for which we may process your data set out in Section 3, we may also process any of your data where such processing is necessary for compliance with a legal obligation to which we are subject, or to protect your vital interests or the vital interests of another natural person.

3.12  Please do not supply any other person's data to us.

4.      PROVIDING YOUR PERSONAL DATA TO OTHERS

4.1    We may disclose your data to our insurers and/or professional advisers insofar as reasonably necessary for obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or an administrative or out-of-court procedure.

4.2    We disclose your account data to our delivery services; Royal Mail and APC insofar as reasonably necessary for delivery purposes only.

You can find information about the delivery services’ privacy policies and practices at:

Royal Mail Privacy Policy

APC Overnight Privacy Policy

4.3    We may disclose your name and address to our suppliers insofar as reasonably necessary for dropshipping purposes only (if applicable).

4.4    Financial transactions relating to our website and services are handled by our payment services providers, Paypal or Dojo. We will share transaction data with our payment services providers only to the extent necessary for processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds. You can find information about the payment services providers' privacy policies and practices at

Paypal Privacy Policy 

Dojo Privacy Policy

4.5    We do not disclose your inquiry data to any third-party suppliers of goods and services to enable them to contact you so that they can offer, market and sell to you relevant goods and/or services.

4.6    We disclose your notification data to our email delivery services; Brevo insofar as reasonably necessary for newsletter purposes only.

Brevo Privacy Policy

4.7    In addition to the specific disclosures of personal data set out in this Section 4, we may disclose your data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or to protect your vital interests or the vital interests of another natural person. We may also disclose your data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or an administrative or out-of-court procedure.

4.8    The hosting facilities for our website are provided by Hostinger and are situated in the UK.

Hostinger Privacy Policy

5.      INTERNATIONAL TRANSFERS OF YOUR PERSONAL DATA

5.1    We do not transfer your personal data to countries outside the European Economic Area (EEA).

6.       RETAINING AND DELETING PERSONAL DATA

6.1    Section 6 sets out our data retention policies and procedures, which are designed to help ensure that we comply with our legal obligations concerning the retention and deletion of personal data.

6.2    Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.

6.3    We will retain your personal data as follows:

(a)    Your enquiry data will be retained for a minimum period of 30 days following the date of enquiry and a maximum period of 365 days.

6.4    In some cases it is not possible for us to specify in advance the periods for which your personal data will be retained. In such cases, we will determine the period of retention based on the following criteria:

(a)    the period of retention of account data and publication data will be determined based on how long you are registered on our website.

(b)    the period of retention of correspondence data, customer relationship data and transaction data will be determined based on the success of the fulfilment of our contract with you in terms of providing you with goods and services.

(c)    the period of retention of notification data will be determined based on how long you are signed up to receive newsletters.

6.5  Notwithstanding the other provisions of this Section 6, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

7.       AMENDMENTS

7.1    We may update this policy from time to time by publishing a new version on our website.

7.2    You should check this page occasionally to ensure you are happy with any changes to this policy.

7.3    We will notify you of significant changes to this policy by email.

8.       YOUR RIGHTS

8.1    In Section 8, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.

8.2    Your principal rights under data protection law are:

(a)    the right to access;

(b)    the right to rectification;

(c)    the right to erasure;

(d)    the right to restrict processing;

(e)    the right to object to processing;

(f)    the right to data portability;

(g)    the right to complain to a supervisory authority; and

(h)    the right to withdraw consent.

8.3    You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned, and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply you with a copy of your personal data. Copies are provided free of charge, but a limit of 3 requests per day is applied. You can access your personal data by visiting:

ACCESS TO YOUR PERSONAL DATA LINK
https://itemdrop.co.uk/index.php?route=information/gdpr_request

8.4    You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.

8.5    In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data no longer necessary concerning the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or the establishment, exercise or defence of legal claims. You can request your right to be forgotten by visiting:

THE RIGHT TO BE FORGOTTEN LINK
https://itemdrop.co.uk/index.php?route=information/gdpr_forget_me

8.6    In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or reasons of important public interest.

8.7    You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or the exercise of any official authority vested in us;or the purposes of the legitimate interests pursued by us or by a third party.If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.

8.8    You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.

8.9    You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation unless the processing is necessary for the performance of a task carried out for reasons of public interest.

8.10  To the extent that the legal basis for our processing of your personal data is:

(a)    consent; or

(b)    that the processing is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into a contract, and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.

8.11  If you consider that our processing of your personal information infringes data protection laws, you have a legal right to complain with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.

8.12  To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.

8.13  You may exercise any of your rights concerning your personal data by written notice to us or in addition to the other methods specified in Section 8.

9.       ABOUT COOKIES

9.1    A cookie is a file containing an identifier(a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.

9.2    Cookies may be either "persistent" cookies or "session" cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.

9.3    Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.

10.    COOKIES THAT WE USE

10.1  We use necessary, preference and statistic cookies only. We do not use marketing cookies but our approved service providers may (see 11.1).

(a)    Necessary cookies help make a website usable by enabling basic functions like page navigation and access to secure areas of the website. The website cannot function properly without these cookies.

(b)    Preference cookies enable a website to remember information that changes the way the website behaves or looks, like your preferred language or the region that you are in.

(c)    Statistic cookies help website owners understand how visitors interact with websites by collecting and reporting information anonymously.

(d)    Marketing cookies are used to track visitors across websites. The intention is to display ads that are relevant and engaging for the individual user and thereby more valuable for publishers and third-party advertisers.

11.    COOKIES USED BY OUR SERVICE PROVIDERS

11.1  Our service providers use cookies and those cookies may be stored on your computer when you visit our website.

11.2  GOOGLE We use Google Analytics to analyse the use of our website. Google Analytics gathers information about website use using cookies. The information gathered relating to our website is used to create reports about the use of our website. Google Privacy Policy

11.3  FRAUDLABS We allow cookies from Fraudlabs for fraud prevention purposes only. Fraudlabs Privacy Policy

11.4  TRUSTPILOT We allow cookies from Trustpilot so that they can invite customers to write reviews about Itemdrop and verify them. Trustpilot Privacy Policy

12.    MANAGING COOKIES

12.1  Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:

(a)    Google Chrome

(b)    Mozilla Firefox

(c)    Opera

(d)    Microsoft Internet Explorer

(e)    Apple Safari

(f)    Microsoft Edge

12.2  Blocking all cookies will harm the usability of many websites.

12.3  If you block cookies, you will not be able to use all the features on our website. In particular, note that you may be prevented from making purchases of products if cookies are disabled.

13.    OUR DETAILS

13.1  This website is owned and operated by Itemdrop Ltd.

13.2  We are registered in England and Wales under registration number 9609845, and our registered office is at 8-10 Queen Street, Seaton, Devon, EX12 2NY

13.3  Our principal place of business is at 11 Marine Place, Seaton, Devon, EX12 2QJ

13.4  You can contact us:

(a)    by post, to the postal address given above;

(b)    using our website contact form;

(c)    by telephone, on the contact number published on our website;

(d)    by email, using the email address published on our website

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Update: June 2024 (Inclusion of Newsletter Provider Brevo and their Privacy Policy link)

Update: May 2024 (Change of Website Hosting Provider to Hostinger and their Privacy Policy link)

Update: June 2022 (Inclusion of Payment Provider Dojo and their Privacy Policy link)

Update: November 2021 (Inclusion of Review Site Trustpilot and their Privacy Policy link)

Update: April 2021 (Change of principal place of business)