Your right to privacy
What does my right to privacy mean?
We all have things we like to keep private. Your right to privacy means that you are the one who decides what other people may know about you and that you have the right to be left alone if you want to. No one is allowed to read your letters, your e-mail, text messages or your diary without permission. Even information that you may think is boring, like your address or your date of birth, is protected by the right to privacy, because some people may try to use that information to harm you.
Tradem respects your privacy
You control your personal information
At all times, you have the right to ask us which information we hold about you. This is your legal right to be informed. If you are under 13, you can ask your parent/guardian to contact us about this. If you are over 13, you can do this yourself by sending an email to firstname.lastname@example.org or by clicking on the ‘Contact us’ button.
You also have the right to ask us to change any information about you that is not correct or to delete personal information we have about you. If you are under 13, you can ask your parent/guardian to contact us about this. If you are over 13, you can contact us yourself by sending an email to email@example.com, by contacting us through our webpage or by clicking on the ‘Contact us’ button.
Take your own privacy seriously
It is important that you follow these rules to stay safe:
- Never share your or your parent/guardian’s banking details or your pincode with anyone
- Do not share any personal details in places that everyone can see, such as the chats under items that are published on the website. If you need to share personal details with a buyer or seller, do this in the private chat that opens after a deal has been agreed. And make sure your responsible adult knows about it.
- Do not post pictures of yourself or other children on the website
We take your family’s privacy very seriously. If you have any questions about this policy or any other privacy related concerns, please contact us at firstname.lastname@example.org or click on the ‘Contact us’ button in the supervisor’s dashboard.
2. Your rights
At all times, you have the right to ask us which information we hold about you and your child under 13 and to access the information. This is your legal right to be informed. You can do this by clicking on the ‘download my data’ in your account, by clicking on the ‘Contact us’ button in the supervisor’s dashboard or by sending us an email at email@example.com.
You also have the right to ask us to restrict the processing of your data, or to change any information about you or your child under 13 that is not correct, or to delete the personal information we have about you. You can do this by sending us an email at firstname.lastname@example.org or by clicking on the ‘Contact us’ button in the supervisor’s dashboard. Please note that, if you request restriction of processing or deletion of your data, this may mean that we have to end our contractual relationship with you. If this is the case, we will discuss this with you before we proceed.
Please let us know if you have any comments or concerns about your use of the site and your privacy. In addition, if you think that we have violated any of your privacy rights, you have the right to lodge a complaint with the UK Information Commissioner’s Office. You can find more information about this on their website.
3. Tradem’s legal roles
Tradem is both the controller and the processor for most of the personal data we collect through your use of our services. A controller determines the purposes and means of processing personal data. A processor is responsible for processing personal data on behalf of a controller.
In some instances, the data collected by Tradem is processed and/or stored by another party, such as our payment provider and our content moderation partner. They may be the processor and/or the controller for some of the data. You can read more about this in this policy. Please also refer to ‘When and why we share personal information with others’ in section 8 for more information.
4. Which information we collect and why we need it
Visits to our website
Data processed by Google may be stored outside of the UK and/or EEA area. This transfer of data is protected under the EU-US Privacy Shield.
More information about how Google Analytics works, can be found here. You can also visit the Google Privacy Checkup, where you can review and adjust your Google privacy settings. If you don’t want Google Analytics to be used in your browser, you can install the Google Analytics browser add-on.
When you open an account with Tradem we ask you to provide personal details, such as your address, telephone number and payment details. We ask these details for the following reasons:
- So we can properly execute our contract with you and take payment for our services
- Our payment provider, MANGOPAY SA needs to perform an identity verification check for our eWallet service, which is required by law
- Not permitting any anonymous users on our site is also important for safeguarding reasons.
The first time you withdraw money from an eWallet, you will be asked to submit a photo of your photo ID (“enhanced identity verification”). This allows our payment provider, MANGOPAY, to perform an identity check, which is required by law. You may also agree to submit to an enhanced identity verification check voluntarily, before you withdraw any money from an eWallet.
The photo of your identity document will be collected by Tradem and forwarded to MANGOPAY; we will store it temporarily to ensure that the identity check is performed correctly and will delete it within 24 hours. MANGOPAY will retain a copy of the photo as they are required by law to do so.
When you create a child account, we ask for certain details, such as their name, address and date of birth. We need this information for the following reasons:
- So we can properly execute our contract with you and provide our services to you and your child
- So we can ensure that our age policy is adhered to
We collect information about how members, both supervisors and children, use our website. For instance, we keep track of the transactions on the marketplace, payments, the number of logins, control settings, the amount and type of products offered, search activities and viewings of tutorials. We collect this information for the following reasons:
- so we can properly execute our contract with you and provide our services to you and your child
- so we can understand our users better and improve our service
We may use this information to publish general reports on certain trends we notice on our website, on the basis of anonymised, aggregate data. These reports will not contain any personal information about you or your child, unless you give us your explicit consent.
You and your child may use the chat functionality on the website, in order to communicate with each other or with other Tradem members. The content of these chats is processed by Tradem.
Please note that the chats appearing under published items on the marketplace are visible to all marketplace users, so make sure that your child does not share any sensitive information there. Tradem may monitor public chats, both through an automated monitoring mechanism and manually, on an ad-hoc basis. We do this for safeguarding purposes and to ensure compliance with our marketplace policies.
Chats between users that are negotiating or executing a deal are private. You may access these chats if you consider this necessary for the safety of your child. However, we ask you to use this functionality with restraint and carefully consider your child’s privacy. When you access a chat, we will notify the children engaging in it that they are being monitored.
Chats between you and your child are private.
Tradem is technically capable of accessing private chats. We have chosen not to encrypt private chats for safeguarding reasons. Please take this into account and use the chat functionality only for marketplace purposes.
Tradem takes the privacy of our users very seriously and will only access a private chat if this is absolutely necessary. This is for instance the case when we receive a complaint about a user or when we have reason to believe that your child is in danger. We may also be required by law to hand over content of private chats. Whenever Tradem accesses a private chat, we will notify the persons engaging in the chat, unless we are forbidden by law to do so.
Communication with Tradem
When you contact us through our website, social media, other websites or in response to an advertisement, we will collect the data necessary for responding to you in the appropriate way. We may use some of the data that we collect in our communications with you in anonimised form for training purposes, if you agree to this.
We will only collect and use your email address or phone number for our newsletter or other commercial messages from Tradem with your explicit consent. You can opt out at any time by clicking ‘unsubscribe’ in our newsletter or by emailing email@example.com.
5. Where we keep your information
Tradem stores all the data we collect and process in our database, which is stored by AWS, an Amazon company. We chose this company because they provide the highest levels of security and reliability in their industry. AWS does not have access to the information we store in our database. More information about their security and privacy policies and practices can be found here.
Some of the information that we collect on our website is processed by partner companies who help us provide you with the best service. See for a full list of these partners and information about their privacy policies section 9 ‘When and why we share personal information with others’ below.
Some of these partners store personal information outside of the UK and the EEA area and they are each required to comply with relevant privacy and data protection laws. You can find more information about this below, in section 9.
6. Who has access to your information
The people working for Tradem who help us to provide our services to you and your child have access to the general personal information we collect and process as described above, with the exception of payment details, which are stored by our payment partner, MANGOPAY SA. We ask all our employees to sign a code of conduct and we have a strong data protection policy in place, to make sure they handle all personal information very carefully.
In cases where Tradem has to handle sensitive information, for instance in situations of bullying or criminal investigations, we will make sure that information is kept separate and shared only on a need to know basis. Sensitive information will be deleted as soon as possible.
In some instances, we may need to ask our software development partner, Steelkiwi Inc., to help us retrieve information that is stored in our database. We have agreed with Steelkiwi Inc. that access to our database is limited to only those persons who need it to be able to help us with the provision of our services to you and your child.
7. How long we keep your information
We keep your information for as long as necessary, which generally is for as long as you use our service, or for other essential purposes such as complying with our legal obligations, resolving disputes, and enforcing our policies (“Retention Rules”). If you want us to delete some or all of your personal information, please contact us at firstname.lastname@example.org.
Subject to the Retention Rules, when you delete a child account, all the personal information associated with that account will be deleted by Tradem after 30 days.
Subject to the Retention Rules, when you end your membership with Tradem and opt for ‘delete my account’, we will delete all personal information of you and your child after 30 days.
For some of the data that is processed by other parties (see section 9 below), different timelines apply. Please refer to their privacy policies for more information.
8. When and why we share personal information with others
MANGOPAY SA (payments)
Some of your personal details such as phone number, payment details, date and place of birth and address, are shared with our payment provider, MANGOPAY SA, who will perform an identity verification (Know Your Client – KYC), which is required by law.
The photo of your identity document collected in order to perform enhanced identity verification by MANGOPAY will be stored temporarily to ensure that the identity check is performed correctly and will be deleted by Tradem within 24 hours. MANGOPAY will retain a copy as they are legally required to do so.
Note that MANGOPAY only performs KYC on the responsible adults signing up to Tradem, NOT on the children trading on the website.
Payment and transaction details of all the deals in which payment is made through the eWallet facility are also shared with MANGOPAY.
Besedo (content moderation)
Content posted on the marketplace is moderated by a company called Besedo. We use content moderation in order to enforce our policies and to protect our users against fraud and bullying.
Besedo makes sure all content transmitted to them is protected (“encrypted”) and stored in their database within the EU/EEA area. Only a limited number of Besedo employees have direct access to the data we submit to them. Besedo does not transfer data to anyone else. The only third party involved with handling the data we transmit to them is their hosting provider, Amazon AWS. This is the same hosting provider that Tradem uses.
Zendesk (customer service)
All the data relating to your communication with the Tradem customer service, including log information such as type, number and length/duration of communications, as well as content of communications, will be collected and processed through the Zendesk customer service functionality. Zendesk adheres to the highest security standards and does not share any of the information processed for us with other parties, other than to be able to provide their services to us or because of a legal obligation.
Some information that Zendesk processes on our behalf may be stored in servers outside of the UK and the EEA area, in the United States. Personal data is transferred by Zendesk on the basis of Zendesk’s approved binding corporate rules available on Zendesk’s Privacy and Data Protection website, or pursuant to the EU-U.S. or Swiss-U.S. Privacy Shield frameworks. Tradem has signed a Data Protection Agreement with Zendesk in order to ensure that we and they comply with the relevant European legislation in this respect.
In the supervisor’s dashboard you can manage the notifications we send to you with regard to your child’s activity. All information relating to these notifications, such as contact details, timing, number of notifications and content of notifications is processed by the company that provides us with a notification service, Twilio. Twilio adheres to the highest security standards and does not share any of the information processed for us with other parties, other than to be able to provide their services to us or because of a legal obligation.
Some information that Twilio processes on our behalf may be stored in servers outside of the UK and the EEA area, in the United States. Personal data is transferred by Twilio on the basis of Twilio’s approved binding corporate rules available on their privacy website.
Sendgrid (email marketing)
We use the Sendgrid email marketing service (provided by Twilio) to manage our email newsletter list. If you have given your consent to be included in this list, we will process your email address and all the information of our communications with you through our newsletter in our Sendgrid account.
Sendgrid adheres to the highest security standards and does not share any of the information processed for us with other parties, other than to be able to provide their services to us or because of a legal obligation.
Some information that Sendgrid processes on our behalf may be stored in servers outside of the UK and the EEA area, in the United States. Sendgrid is Privacy Shield certified. By complying with the Privacy Shield Principles, Sendgrid can lawfully transfer personal data from the EU and Switzerland to the US.
We may be ordered by law enforcement agencies to hand over personal details we have stored about you or your child. We will publish a yearly report on our website with information about how many information requests from law enforcement agencies we received and how we responded to them (no user private data will be published in these reports).
Other Tradem members
We do not share any of your personal information with other members. We also ask of all our users to keep their own information private. We only use the address(es) you provide us with to indicate to potential buyers in which region (four first digits of the postcode) an item is located. This limited location functionality can be switched off at any time.
After a deal is agreed for a delivery via post, we will share the buyer’s address with the seller. Also, if a buyer has to return an item to seller under the Tradem Protection scheme, we will share the seller’s address with them.