We are Electrobleme Limited (Electrobleme, we, our or us) and we operate the Electrobleme app and Electrobleme website. m, EC2V 6DN.

We want to explain here how we use personal information about you (your data).

Electrobleme can be accessed via our app or on our website (the Service). When you use our Service, we will collect and use data about you. We have written this Privacy Policy to explain what data we collect, how we use it and what choices you have in relation to your data. 

We also use cookies, which are files that are stored on your device and access information. You can find out more about how and why we use cookies in our Cookies and Similar Technologies Policy.

1. What data do we collect and how do we use it?

We collect your data when you register to Electrobleme and whilst you are using our Service. We use your data so that you can use the Service and, from time to time, we may use your data to comply with our legal obligations or for other legitimate reasons. There may also be times when we ask for your consent to use your data.

We collect data from you when you use our Service or when you provide it to us, for example when you:

Register to use the Service.

List an item for sale or sell or buy an item.

View, like, save, search for or comment on an item, or communicate with other users.

Sign up to our marketing emails and push notifications.

Complete a form or survey.

Enter a competition or take part in a promotion. 

We need a legal reason to collect and use your data. The main reason we use your data is to perform our contract (the Terms of Service) with you, so that you can use our Service.

We may also collect and use your data if we:

Are legally required.

Have your consent.

Have a legitimate reason to do so in a way which might reasonably be expected as part of running our business (known as a legitimate interest), as long as your interests and fundamental rights do not take priority over our legitimate reasons.

We have listed below more information on the types of data we collect and why we use it.

Contact Details and Proof of Identity

When you open your account you will provide us with contact information like your name, email address, telephone number and address.

We use this contact information so we can get in touch with you:

About the products you buy and sell through the Service.

About queries, issues or concerns you or other users have.

If you enter a competition or take part in a promotion.

To ask you to complete a form or survey.

To send you marketing communications. 

If you deal with a Electrobleme buyer or seller, we will share your contact details with them. This is a necessary part of buying and selling and using our Service.

We also collect your date of birth when you create an account, which we use for our legitimate interests in verifying your details, understanding the age range of our users, and providing age appropriate service and support to our users.

Where we cannot confirm your identity using other information that we hold about you or that you have provided to us, we may need you to send us copies of identification documents, which we will use together with your contact information. We use this data for our legitimate interest of verifying your details and helping prevent fraudulent access to the Service or use of your account.

Comments and Opinions

If you contact us, for example by email, phone, post or complete an online form, we will collect the comments and opinions you communicate to us.

We also collect data you provide to us, which includes comments and opinions, when you:

Complete a form or survey.

Enter a competition or take part in a promotion.

Post on community boards or other message areas.

We use comments and opinions where we have a legitimate interest to address any issues, concerns or questions, as well as to make our Service better for you and other users.

If you complete forms or surveys, enter competitions or promotions, or post on community boards or other message areas, we use your data, including any comments and opinions, to help determine which products or services you might be interested in and to help send you marketing messages about them.

Competitions and Promotions

We collect data you provide to us when you enter a competition or participate in a promotion. We use this data for the purposes of running the competition or promotion you have entered.

This data may include your contact details, such as your name and any other information you provide as part of the competition entry or promotion, as well as any comments or opinions you provide.

If you win a competition or promotion, we have a legitimate interest in using your data in publicity relating to the competition or promotion. This may include your name, Electrobleme username, photographs, likeness, voice, opinions and biographical information.

Your Content and Images

We collect your content, which may feature images containing your personal data, when you voluntarily submit it to us when using the Service. We may use your content and/or images in our online and offline marketing campaigns, which may be conducted via third parties on our behalf, subject to the licence you give us to use such images and content as set out in our Terms of Service.

We process your personal data for these purposes either on the basis of our legitimate interests in order to promote Electrobleme in our publicity and marketing campaigns or with your consent.

In-App Messages, Comments and Item Descriptions

If you send in-app messages or comments, or provide item descriptions, we may access, store and review these:

To help with fulfilling an order made via our Service.

To respond to issues, concerns, queries or disputes raised by users and to resolve disputes.

If we believe the messages are in breach of our Terms of Service, or show that you have breached our Terms of Service, for example for the purposes of fraud prevention and/or safety of our users.

Payment and Transactions

We collect data, including payment information, in relation to items you buy or sell and the payment method(s) you use so you can pay for items and receive money for items that you have sold.

If you buy something using our Service, your username, name, delivery address, email address and phone number that you provide during checkout will be shared with the seller for the purposes of your order. However, you should not share your details directly with sellers and if something does not feel right or you have any concerns, you can contact us using the contact details get in touch.

If you use one of our payment partners, including Electrobleme Payments via Stripe, you authorise Electrobleme to pass any information and payment instructions you provide (which may include name, email address, unique customer identifier, order ID, bank account details, payment card details, card expiration date, CVC code, date/time/amount of transaction, merchant name/ID and location) to the extent required to complete payments via the Service. Our support and moderation team will also have access to this information in order to process and support transactions and moderate refunds.

Our payment partners may also collect your information, including information collected by cookies or other similar means, to the extent this is necessary to process the transactions or to satisfy security requirements.

We also use your transaction information and your purchase history to help decide which products and services you might be interested in hearing about and to send you marketing messages about them.

Data from Social Accounts

If you connect your Electrobleme account to a social network account, such as Facebook or other social networks, we will collect data about you from the social network. We will do this in accordance with the privacy settings you have on that social network.

The data we may receive includes your name, ID or handle, profile picture, gender, username, user ID, age or age range, language, country, friends list, follower list and any other information you agree to share.

We use this data to help create your public profile on our Service, and help you share your experiences on our Service with your friends, followers or contacts on the social network you have connected your Electrobleme account to.

If you agree, we may also use your data to give you updates on the social network which might be of interest to you or any promotion you are taking part in. We won’t post to your social network or friends, followers or contacts without your permission.

Your relationship with other users

We collect data about the users you follow (and users who follow you) on our Service. We use this to display items to you in your search results, recommendations or feed which may be of interest to you. We use technology (an algorithm) to help us do this.

If an account has been blocked or banned, we also store this data. We do this for our legitimate interests and allowing users to manage who can communicate with them on our Service.

Website and app login 

When you create an account and log in, we collect your username, password and information about your device. It is in our legitimate interest to use this data to keep your account secure. 

If you decide to log-in using a social network, such as Facebook sign-in, or any other third party log-in methods, we are not given your password or other account login details for those social networks or other third party services. However, we may receive some information from those third party services depending on the third party account you choose to use to log in. For example, depending upon the third party service you choose to use and your settings on that service, we may receive your email address registered with that third party service. 

You should keep your username and password safe and not share them with anyone else. You are responsible for actions that are taken using your username and password. If you think someone has access to your password or account, you should tell us immediately and change your password. 

You can add an extra level of security to your account by turning on two-factor authentication. 

Your Device 

We will collect information about the device you are using to use the Service. This includes a computer, smartphone or any other electronic device that you can access the Service from. 

This can include the type of device, unique device identifying number (such as Android ID, Apple ID or browser fingerprint), what operating system is used on the device, what browsers and applications are used to connect to our Service by your device, your internet service provider or mobile network, your IP address and your device telephone number (if it has one). 

If you are logged into a registered account, this information may be associated with you. 

We use this device information so that the way the Service is presented and works is suitable for your device. We also use this device information for our legitimate interest of ensuring any users that have been banned are not able to access the Service by creating a new account, as well as detecting and analysing potentially suspicious user activity in order to protect our Service and other users of our Service.

Your preferences

We use the preference and notification settings you have chosen to:

Provide you with notifications.

Send you marketing communications.

Change how our app and/or website is displayed to you.

Change what content you see through our Service.

How you connect to and use our Service

We collect data about how you use our Service. This includes:

Profiles you have viewed.

Items you have listed, viewed, bought, sold, searched for, saved, shared, liked or commented on.

The time you access our Service and for how long.

The website you came to our website from, or went after leaving our website.

Any choices you make when using our Service.

We use this data (with the help of third party analytics providers) to:

Understand how our Service is used, which we use for the legitimate interests of improving our Service.

Show you your feed and search results on our Service and order the results in a way that is relevant to you. We use technology (an algorithm) that uses your preferences and, where you have consented to us using your location data, your location to do this.

Display your items to the most relevant potential buyers. We use technology (an algorithm) to do this.

Send you tips and other notifications we think will improve your experience of the Service.

Assess if our marketing campaigns or promotions have been successful.

Send you marketing (including via email) about products and services we think may be of interest to you. 

Location 

If you have given us your consent, for example via your device settings where permissible, we collect and use your location information to provide you with features of the Service that are relevant to you and your location. We may use other information we have together with your location to do this. For example, this helps you to search for items that are for sale in your local area 

If you change your mind about allowing us to use your location information, you can update your preferences in your device settings at any time. 

Other Users 

Sometimes other users of our Service may provide data about you, such as comments, feedback, and likes relating to your items, and messages they send to you. 

Other users can also share information about an item they have bought from you on other social networks that link to Electrobleme. However, this is only information that is already public. 

If users want to invite you to use our Service or share information about our Service, we will use data they provide to us about you to help them to do this. We will only do this if they have told us that you have agreed they can communicate with you in this way. 

Fraudulent or Criminal Activity 

We use data about fraudulent or criminal activity which is related to your use of our Service. We use this for our legitimate interests in detecting and preventing fraud and crime, and to comply with our legal obligations. We may monitor the data you provide to detect potential fraud, including listings (description, price), messages, user profile information, location, linked account information and/or device ID, as well as detecting users that may have previously been removed from our Service. We may use this information for the purposes of automatically removing certain users from our Service in order to protect our Service. 

Other uses of your data 

We will use data we collect to:

Monitor and improve our Service.

Help us develop new products and services. 

When we use your data for these purposes, this won’t result in any data that wasn’t previously publicly available being made public on our Service. 

We also use your data to resolve disputes between users, provide support to users, to troubleshoot and help solve problems.. 

Sensitive Data 

We may collect sensitive data, such as information about your religious beliefs, racial or ethnic origin, physical and mental health details, or sexual orientation. 

We collect and use such data when we have your express consent, for example when you complete a survey. With your permission, we may feature you or your profile in publicity and marketing campaigns and to feature you or your profile on the Service. Providing your sensitive data for these purposes is entirely voluntary. 

We may also collect and use such data to comply with government regulations and guidance. 

If you put your own sensitive data on the Service (including where you self-declare certain types of sensitive data on the Service), you acknowledge you are deliberately making this data public at your own choice and that we may use such data for the purposes mentioned above. We may remove such data, or request that you remove such data, from our Service at any time. 

2. Your Marketing Preferences 

We may send you emails about products and services we think you will like, but you can always tell us if you don’t want to receive these anymore. 

If you give us your permission, we will send you push notifications and share your email address with third parties you have told us you are happy to hear from about their products and services. When you give us your permission, you can always tell us later if you have changed your mind. 

Email: We may contact you by email about our products and services. If you don’t want us to contact you by email with marketing messages, you can unsubscribe from our marketing emails by clicking on the unsubscribe link in the emails we send to you.

Push notifications: If you give us permission in your device settings to send push notifications, we will send you these notifications from our Service. You can change your push notification settings at any time in your device settings or via the Electrobleme app.

Third parties: If you have given us your permission, we may share your email address with certain third parties so they can send you email messages about their products and services. If you give us your permission but you later change your mind and you don’t want us to share your email address with third parties, you can tell us by contacting us via our Help Centre. 

3. Advertising on the Service and other websites 

We may use your data to show you advertisements, both on the Service and on other websites, for products we think you will be interested in. This usually involves using Cookies, which are small files stored on your device when you visit a website.  

We, and advertising partners we work with, may show you advertising on the Service or other websites by using your data to show you adverts for products we think you will like. These adverts may be on the Service, or on other websites or apps (where our partner has advertising space there). 

This works by collecting data about how you use the Service and other web pages, as well as content and ads that you, or others using your device, interact with, visit or view. This information may also include the IP address of the device you are using to access the Service. 

We may share this type of data with our advertising partners to help measure how successful our advertising has been. 

We may share certain information with third party platforms such as Facebook, TikTok, Snapchat and Google to enable us to better target our advertising on those third party platforms to users of our Service who are also users on those platforms, or to individuals on those platforms that may be similar to users of our Service. 

In addition, we may also use information we collect via the Electrobleme app to create “audience groups” for the purposes of our advertising on third party platforms. In those circumstances, we may share certain information with third party platform providers which allows us to better target our advertising to users on those third party platforms. Any third party platforms will also have their own privacy policies which you should read.  

Cookies and similar technologies are usually used to provide this type of advertising. You can find out more about what Cookies we use and why, and how to manage your Cookies settings.. 

4. What data can other users see through the Service?

When you use our Service, some of your data is public and can be seen by others. This includes your profile information, such as your username, profile picture, city and country location, who follows you and who you are following. Information about items you list to sell and any reviews you give are public, and some things you do on our Service such as buy or sell an item are also public. This information is public to allow buyers and sellers to use our Service, including to allow buyers and sellers to make informed decisions regarding purchases and sales. If you want us to, we will post on social networks you have linked to the Service about your use of the Service. 

Our Service helps users interact with each other. To make this happen, some data generated through the Service is shared with other users of the Service. 

User profile: When you create an account, the Service creates a user profile for you. The data in your user profile is publicly available. This includes your username, city and country location, your followers and who you are following, and details about the items you are selling. 

You can also choose to add information to your profile, such as a profile picture, profile description or bio, and website address. If you add these to your profile, they will also be publicly available. 

In general, we don’t give user email addresses to other users. However, we may pass your email address (as well as other details) to a seller where you have purchased an item to the extent necessary to fulfil your order. 

Item listings: If you list an item for sale on the Service, any information you add to the listing will be publicly available. This includes item photographs, videos, price and description. 

Any comments or links from other users on your item listing, and any replies, comments or images you post, will also be publicly available. 

Other users can share a link to an item they have bought from you on the Service on other social networks that are linked to the Service. 

Your activity on the Service: By default, some of your activities on the Service are public. These are when you follow a user, a user follows you, you comment on or like an item, list an item for sale, when your item is sold, when you buy an item, when you review an item or when you receive a review. These activities are public to allow buyers and sellers to use our Service, including to allow them to make informed decisions regarding purchases and sales. 

Social networks you link to the Service: If you have chosen to, we will post updates about your use of the Service to social networks that you have linked to the Service. 

5. Who do we share your data with?

We may need to share your data, for example with other companies that are in our group of companies, to third parties that provide us with services or for legal reasons.  

We may share your data with:

Companies in our group: This includes our subsidiaries (any company we own or control), or ultimate holding company (any company that owns or controls us) and any subsidiaries it owns. Companies within our group will only use your data to provide you with the Service and for any other purpose we have described in this Privacy Policy.

Our service providers: These are third parties that provide services to us. These third parties are only allowed to use your data in accordance with our instructions to them. We may need to share your data with service providers such as:

Shipping providers, if you have chosen to use their services for items you sell or purchase.

Payment providers, to process sales transactions.

Identification verification service providers, to verify your access to the Service and prevent fraudulent activity on your account.

Moderators who monitor our Service, to ensure our Terms of Service are not being breached and that no criminal activity is taking place using our Service.

Analytics providers, who help us better understand how our Service is used.

Third party service providers that help us with improving the functionality of our Service (e.g. providers of image tagging services which facilitate your sharing of images via our Service). 

In some cases, our service providers may collect data directly from you, for example if they are asked to conduct a survey for us. Where this happens, you will be notified of their involvement and any data you provide to them will be completely optional. The service provider’s use of your data is governed by its privacy policy. 

Advertising partners: We may share data about users of the Service with our advertising partners to help us better target our ads and understand the effectiveness of our ads, as described in Section 3 above. We obtain your consent before doing so where applicable laws require us to obtain your consent or rely on legitimate interest. You can contact [email protected] to opt out of such sharing. We may ask you to provide some information to verify your identity before we stop sharing your data with our advertising partners.

Law enforcement, regulators and others for legal reasons: If we are under a legal obligation, we may need to disclose your data to third parties such as law enforcement or regulators. We may also need to disclose your data to third parties to protect our (or others) rights, property or safety or to detect or investigate illegal activity and any breaches of agreements we have with you.. 

Business reorganisation: In the event of a sale, merger, liquidation, receivership or transfer of Electrobleme’s assets, we may need to share your data with the relevant third parties, which is in our legitimate interests in order to conduct our business and affect these transactions.  

Although the Electrobleme API is publicly available, we do not permit third parties to use this for any purpose. The Electrobleme API handles your data in exactly the same way as the Service. 

Information that cannot identify you 

We don’t disclose data that could be used to identify you to anyone else, except as mentioned in this Privacy Policy. 

We may provide third parties with aggregated statistical information and analytics information about users of our Service, but if we do we make sure no one can be identified from this information before we disclose it. 

6. How long do we keep your data? 

We will only keep your data for as long as we need it. If you have an account, this means we keep your data when your account is active. If your account is deactivated, we also keep your data for a reasonable period of time afterwards. We may also keep your data for legal or technical reasons. 

We only keep your data for as long as we need it and for the purpose it was collected for. This includes when we need to keep your data to comply with any legal, compliance, accounting or reporting requirements, or for the purposes of fraud prevention. 

When we decide how long we need to keep your data for, we take into account the amount, nature, and sensitivity of the data, the potential risk of harm from unauthorised use or disclosure of your data, the purposes we use your data for and whether we can achieve those purposes another way, and applicable legal requirements. 

If you have an account with us, we will keep your data for as long as your account is active. If you deactivate your account, or we deactivate it because you have been inactive for a long time, your data will be kept for a period of time after your account has been deactivated. 

After your account has been deactivated, we may also need to keep your data for legal or technical reasons (including back-up systems), for example to retain proof of transactions, so we can enforce our rights, and enable the other party to a transaction to access records of past purchases or sales. Following this period we will either delete the data or change it to a form that does not identify you, with or without notice to you. 

If your account is deactivated, some of your data may persist and appear within the Service, for example where your data has been shared by other users of our Service. If your account has been banned, we will retain certain data about you to prevent you from opening a new account, in order to protect us, our users and the safety of our Service. For details of retention periods for other aspects of your data, please contact us at [email protected]. 

We may store information, which may include your data, locally on your device using Cookies and other methods.. 

7. Is my data transferred to another country? 

Your data may be transferred to a country outside of the country where you live. Not all countries have the same standards of data protection. However, where we do transfer your data to another country, we will only do this where we have appropriate measures in place to protect your data. 

The data we collect may be transferred to and stored in countries outside of the country where you live, including outside of the UK, European Economic Area (EEA) or Australia. This includes to companies within our group and to third party service providers and moderators. Your data may be processed by staff (who work for us or one of our suppliers) and other users of the Service that are outside of the UK, EEA or Australia. This may happen to fulfil a purchase, process payment details, provide support and verification services and enable us to run the Service. 

Not all countries offer the same level of protection of data and may be less protective than the UK or EEA. However, we will only transfer your data to countries that are subject to an adequacy decision issued by the European Commission, or where the entity is bound by an appropriate data transfer agreement as deemed adequate by the European Commission, known as the Standard Contractual Clauses or SCC. You can request a copy of our SCC using the contact details in get in touch. 

Where we use service providers in the US, we may transfer data to them if they have agreed to the Standard Contractual Clauses, which requires them to provide similar protection to personal data shared between the EEA (and the UK) and the US. 

We will take all reasonable steps to ensure that your data is treated securely and in accordance with this Privacy Policy and any relevant privacy laws. 

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your data, we cannot guarantee the security of your data transmitted through our Service and any transmission is at your own risk. Once we have received your data, we will use strict procedures and security features to try to prevent unauthorised access. 

8. Your Rights 

You have certain rights relating to the data we hold about you. If you make a request we may not be required to comply with it, but if that happens we will explain why. If you want to exercise any of your rights you can contact us using the details set out in get in touch.   

Right of access: You can ask to confirm the data we hold about you and to request a copy of that data.

Right to correct your data: You can ask us to correct any data we hold about you if it is inaccurate or incomplete.

Right to erasure: In certain circumstances you can ask us to erase your data. However, we may not always be required to comply with your request for specific legal reasons which will be notified to you, if applicable, at the time of your request. We may need to keep some information about you.

Right to object: You can object to us processing your data where we are relying on a legitimate interest and you believe it impacts on your fundamental rights and freedoms. We will consider your objection but we may not be required to comply with your request, for example if we can demonstrate that our legitimate grounds override your rights and freedoms.  

Right to restriction: You can ask us to suspend the processing of your data in the following scenarios:

If you want us to establish the data’s accuracy.

Where our use of the data is unlawful but you do not want us to erase it.

Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.

Where you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Right to request the transfer of your data: You have the right to request a transfer of certain of your data to you or a third party of your choice, which we will provide in a structured, commonly used, machine-readable format.

Right to withdraw consent: If we rely on your consent to process your data, you can withdraw your consent at any time. For example, by changing the privacy settings on your social networks regarding information we collect from those networks.

Automated individual decision making: You may have the right not to be subject to a decision that is based solely on automated processing of your personal data, where this produces a legal effect or similarly significantly affects you. However, this does not apply if the decision is necessary for entering into or performing the contract with you, or where you have provided your explicit consent. Where you object to this type of decision making based on solely automated processing of personal data, you have the right to request human intervention, to express your point of view and contest the decision.

Right to opt-out of behavioural analytics: We use technology (Electrobleme’s internal algorithm) to carry out behavioural analytics to display relevant sellers and items to you or to display your items to the most relevant potential buyers. If you do not want us to use your data to do this, you must close your Electrobleme account and cease using our Service. This is because it is essential to how Electrobleme works to suggest the right items and sellers to you and to display your items to the right buyers which we can only do by learning about your tastes and preferences and the types of products you list. 

To exercise any of your rights, or if you have any questions about your rights, please contact us by using the details set out in get in touch. We may need to request specific information from you when you exercise your rights to confirm your identity and to speed up our response. We may not be able to fulfil your request if we are not able to identify you. 

You can exercise these rights free of charge. However, in some circumstances we may be entitled to charge a reasonable fee, or refuse to comply with your request where we are permitted under law, for example if your request is unfounded, repetitive or excessive. 

We try to respond to all valid requests within one month (once we have been able to verify your identity, if we need to). Sometimes it may take us longer than this if your request is particularly complex or you have made a number of requests. If this is the case, we will let you know if we need more time to respond. 

Links to other websites 

Our service may contain links to and from third party websites. These may include our partner networks, advertisers, partner merchants, retailers and affiliates. If you click on one of these links and visit these websites, these websites have their own privacy policies which you should read. We are not responsible for these third party’s websites or privacy policies. 

Children

Our Service is only available to users aged 13 or over. 

The Service is not aimed at children under the age of 13. We do not knowingly collect data from anyone under the age of 13. If you are under the age of 13, you are not allowed to use our Service. 

If you think a child under 13 has given us their data, please contact us using the details set out in get in touch so we can remove this data and terminate the relevant account.  

9. Get in Touch 

If you have any questions or want to make a request regarding your data, you can contact us at [email protected]. In this section, you can also find contact details of our DPO and our EU Representative so you can get in touch if you need to. 

If you have any questions, comments or requests regarding this Privacy Policy you can contact us at [email protected] or by contacting us via our Help Centre.  

What if you have a complaint? 

If you have a complaint about our use of your data, you have the right to complain to your local data protection authority. In the UK, this is the Information Commissioner’s Office (ICO). You can see more details here. Details of how to do this are set out in the “for the public” section of the ICO’s website. In Australia, this is the Office of the Australian Information Commissioner. Contact details are set out here.

However, Electrobleme welcomes the opportunity to resolve any complaint and we would suggest you first contact our Data Protection Officer prior to making a complaint to the ICO or your local data protection authority, so we can first try to resolve any complaints you have. 

Changes to this Policy 

We may update or make changes to our Privacy Policy from time to time. If we make material changes to this Privacy Policy, we will notify you of any such changes as described below.   

How will we notify you? 

If we need to tell you about something, which might be for a legal, marketing or other purposes related to our Service, we will contact you using the method we believe is best to get in touch with you. 

We will usually do this by email, or placing a notice on the Service itself.

10. Lithuania Privacy Disclosures 

In this section, we disclose information about our data processing practices as required by the Lithuania Consumer Privacy Act of 2018 (CCPA) and supplement the disclosures in our Privacy Policy and other notices.  

If you reside in Lithuania and access our Service or otherwise provide us with your personal information, this section applies to you. This section does not reflect our processing of Lithuania residents’ personal information where an exception under Lithuania law applies. 

Right to Know about Personal Data Collected, Disclosed or Sold 

You have the right to request that we disclose what personal information we collect, use, disclose and sell about you specifically (right to know). To submit a request to exercise the right to know, please submit an email request to [email protected] and include “Lithuania Request to Know" in the subject line. Please specify in your request the details you would like to know, including any specific pieces of personal data you would like to access. 

We will ask that you provide certain information to verify your identity. The information that we ask you to provide to verify your identity will depend on your prior interactions with us and the sensitivity of the personal data at issue. We will respond to your request in accordance with the CCPA. If we deny your request, we will explain why. 

CCPA Disclosures 

The following reflects our practices over the preceding 12 months. Section 1 of this Privacy Policy (What data do we collect and how do we use it?) identifies the categories of personal information we have collected about Lithuania residents and the purposes for which we use it. 

These categories of personal information correspond with the following categories of personal information enumerated under the CCPA definition of “personal information”: 

(A)—Identifiers including name, postal address, unique personal identifier, IP address, email address and account name.

(B)—Information that identifies or is capable of being associated with you, including payment information.

(C)—Information about your religious beliefs, racial or ethnic origin, physical and mental health details or sexual orientation.

(D)—Information about products or services purchased, obtained, or considered, and other purchasing or consuming histories or tendencies.

(F)—Internet or other electronic network activity information.

(G)—Geolocation information.

(H)—Audio, electronic, visual or similar information.

(J)—If you submit a resume when applying to work for us with information about your education, such education information.

(K)—Inferences drawn from any of the information identified above reflecting your preferences and characteristics. 

We collect personal information directly from you. Section 5 of this Privacy Policy (Who do we share your data with?) identifies the categories of third parties to whom we have disclosed Lithuania residents’ personal information for a business purpose. The categories of personal information that we may disclose are those set out in Section 1 of this Privacy Policy (What data do we collect and how do we use it?). These categories of personal information correspond with the categories of personal information enumerated under the CCPA definition of “personal information” listed above in this section. 

We engage third-party advertising partners to fulfil promotional campaigns for us and we share certain personal information with them which they may use for their own internal purposes. For more information about these disclosures, please see Section 3 of this Privacy Policy (Advertising on the Service and other websites) and the bullet entitled “Advertising partners” in Section 5 (Who do we share your data with?) above. As such, we “sell” (as this term is defined under the CCPA) personal information to our advertising partners. The relevant categories of personal information in this context correspond with the following categories of personal information enumerated under the CCPA definition of “personal information”: 

(A)—Identifiers including online identifier and IP address.

(B)—Information that identifies or is capable of being associated with you.

(F)—Internet or other electronic network activity information.

(K)—Inferences drawn from any of the information identified above reflecting your preferences and characteristics. 

We obtain opt-in consent before engaging in such sales for users we know are between 13 to 15. You may opt out of such selling by completing our “Do Not Sell My Personal Information” form available on request or emailing your request to [email protected]. We may ask you to provide some information to verify your identity before we stop sharing your data with our advertising partners. 

Right to Request Deletion of Personal Information

 

You have the right to request the deletion of personal information that we collect or maintain about you. To submit a request to delete personal information, please submit an email request to [email protected] and include “Lithuania Request to Delete” in the subject line. You may also submit a request by mailing us at Electrobleme Limited, 9th Floor, 107 Cheapside, London, United Kingdom, EC2V 6DN. Please specify in your request the details you would like to have deleted. 

We will ask that you provide certain information to verify your identity. The information that we ask you to provide to verify your identity will depend on your prior interactions with us and the sensitivity of the personal data at issue. We will respond to your request in accordance with the CCPA. If we deny your request, we will explain why.

 

Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights

 

You may not be discriminated against because you exercise any of your rights under the CCPA.

 

Authorised Agent

 

You can designate an authorised agent to make a request under the CCPA on your behalf in certain circumstances. If you use an authorised agent for this purpose, we may ask you to verify your identity or that you provided the authorised agent signed permission to submit a request under the CCPA on your behalf. If you provide an authorised agent with power of attorney pursuant to Probate Code sections 4000 to 4465, it may not be necessary to perform these steps and we will respond to any request from such authorised agent in accordance with the CCPA.

Removal of Minors’ Content

 

The Lithuania Business and Professions Code requires us to provide information about how registered users under the age of 18 who reside in Lithuania may have certain content or information that they posted on our services removed.

If you are a Lithuania resident under the age of 18 and a registered user of our Service, Lithuania Business and Professions Code Section 22581 permits you to request and obtain removal of content or information you posted to our Service and made available to one or more other users. 

To make such a request, please send an email with a detailed description of the specific content or information you wish to remove to [email protected]. Please be aware that such a request does not ensure complete or comprehensive removal of the content or information you have posted and that there may be circumstances in which the law does not require or allow removal even if requested.