Privacy Policy 2in1 Cleans

We respect your privacy and is committed to protecting your personal data. This Policy will inform you as to how we look after your personal data when you visit and use the 2in1 Cleaning Platform and tell you about your privacy rights and how the law protects you. References to “we”, “us”, or “our” in this Policy mean 2in1 Cleaning. All defined terms used in this Policy but not defined herein are defined in the Terms of Use.

We ask that you read this Policy carefully.

This Policy is divided into the following sections:

Section 1: Privacy Policy

• Who we are, purpose of this privacy policy, and our processing role
• Contact details:
• Our collection and use of your personal data
• How we use your personal data and our lawful basis
• Transfers of your personal data out of the UK and EEA
• Marketing
• Your rights
• Keeping your personal data secure
• How to complain
• Changes to this Policy

Section 2: Cookies Policy

SECTION 1: PRIVACY POLICY

Who we are, purpose of this Policy and our processing role:

2in1 Cleaning Ltd operates the 2in1 Cleaning Platform which connects Customers with Service Providers that provide car cleaning, valeting and detailing services. For more information see: [insert link to about us page]

As such, we collect and use the personal data of three categories of data subjects:

1. Visitors to the 2in1 Cleaning Platform;
2. Customers with Authorised User Accounts on the 2in1 Cleaning Platform; and
3. Employees and authorised representatives of the Service Providers who are registered to sell their services via the 2in1 Cleaning Platform.

The 2in1 Cleaning Platform is not intended for use by children, and we do not knowingly collect data relating to children. If you are under the age of 18, you must not use the 2in1 Cleaning Platform.

We collect, use and are responsible for certain personal data about you. When we do so we are regulated under the UK GDPR (consisting of the UK Data Protection Act 2018, as amended and updated in light of the UK’s departure from the European Union) and the EU GDPR (the General Data Protection Regulation (EU) 2016/79, as amended from time to time), as applicable based on your location in the United Kingdom or the European Union,  and we are responsible as ‘controller’ of that personal data for the purposes of those laws.

Throughout the 2in1 Cleaning Platform, we may link to other websites owned and operated by certain trusted third parties to make additional products and services available to you, or provide external services. These other third party websites may also gather information about you in accordance with their own separate privacy policies. For privacy information relating to these other third party websites, please consult their privacy policies as appropriate.

Contact details:

If you have any questions about this Policy or our privacy or tracking practices, please contact us using the following details:

Full Name of Legal Entity: 2in1 Cleaning Ltd

Email Address: info@2in1cleans.co.uk

Postal Address: Flat 26 Aveley Court, 21 Detmold Road, London, England, E5 9NN

You have the right to make a complaint at any time to your local supervisory authority. If you are based in the United Kingdom, then this will be the Information Commissioner’s Office (the ICO), who is the UK regulator for data protection issues. For more information, please visit www.ico.org.uk.

If you are based in the European Union, please consult the following website to find out the details of your local supervisory authority, https://edpb.europa.eu/about-edpb/board/members_en.

We would, however, appreciate the chance to respond to your query and deal with your concerns before you approach a supervisory authority.

Our collection and use of your personal data:

We collect personal data about you when you access the 2in1 Cleaning Platform, create an Authorised User Account with us, purchase Cleaning Services via the 2in1 Cleaning Platform, contact us, send us feedback, post material to the 2in1 Cleaning Platform, sell and offer Cleaning Services for sale on the 2in1 Cleaning Platform and complete customer surveys or participate in competitions via the 2in1 Cleaning Platform.

We collect this personal data from you either directly, such as when you create an Authorised User Account with us, contact us or sell or purchase Cleaning Services via the 2in1 Cleaning Platform or indirectly, such as your browsing activity while on the 2in1 Cleaning Platform (see Section 2 – Cookies Policy below for more information on the cookies we use).

The personal data we collect about you depends on the particular activities carried out through the 2in1 Cleaning Platform.

If you are a Customer, we collect the following personal data:

• your name and email address;
• details of correspondence via phone, email, post or via communication facilities on the 2in1 Cleaning Platform;
• details of information uploaded by yourself on the 2in1 Cleaning platform;
• your Authorised User Account details, such as username, login details;
• IP address, login data, browser type and version, operating system and platform, and device data;
• transaction data such as details of any payments you make to Service Providers via our nominated payment provider;
• details of any feedback you give us by phone, email, post or via social media;
• information about the Platform Services we provide to you and the Cleaning Services you are interested in purchasing, or have purchased;
• usage data on how you use the 2in1 Cleaning Platform, and Platform Services; and
• your preferences in receiving marketing from us and your communication preferences.

If you are an employee or an authorised representative with an Authorised User Account in the name of a Service Provider that is registered to sell Cleaning Services via the 2in1 Cleaning Platform, we collect the following personal data:

• your name and email address;
• your role with the Service Provider;
• place of employment;
• details of correspondence via phone, email, post or via communication facilities on the 2in1 Cleaning Platform;
• your Authorised User Account details, such as username, login details;
• IP address, login data, browser type and version, operating system and platform, and device data; and
• usage data on how you use the 2in1 Cleaning Platform, and the Platform Services

If you are a visitor to the 2in1 Cleaning Platform, but do not have an Authorised User Account or have not purchased any products via the 2in1 Cleaning Platform, we only collect the following personal data about you:

• IP address, login data, browser type and version, operating system and platform, and device data;
• usage data on how you use the 2in1 Cleaning Platform, and Platform Services; and
• your preferences in receiving marketing from us.

We use this personal data to:

• create and manage your Authorised User Account with us, both when you are an employee or representative of a Customer or Service Provider registered on the 2in1 Cleaning Platform;
• verify your identity;
• provide the 2in1 Cleaning Platform Services to you;
• allow Service Providers to offer and sell Cleaning Services to Customers;
• customise the 2in1 Cleaning Platform and its content to your particular preferences and requirements;
• notify you of any changes to the 2in1 Cleaning Platform or to the Platform Services that may affect you; and
• improve our Platform Services.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific 2in1 Cleaning Platform feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Policy.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

How we use your personal data and our lawful basis for processing your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• If you are an employee or authorised representative of a Service Provider registered to sell Cleaning Services on the 2in1 Cleaning Platform, or a Customer who has purchased Cleaning Services via the 2in1 Cleaning Platform, we will process your personal data to perform the contract we are about to enter into or have entered into with you or your company;
• Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests; or
• Where we need to comply with a legal obligation.

When we process your personal data, we are required to have a lawful basis for doing so. There are various different lawful bases on which we may rely, depending on what personal data we process and why.

Please see the below for more information on the lawful basis that we may rely on:

• consent: where you have given us clear consent for us to process your personal data for a specific purpose
• contract: where our use of your personal data is necessary for a contract we have with you, or because you have asked us to take specific steps before entering into a contract
• legal obligation: where our use of your personal data is necessary for us to comply with the law (not including contractual obligations)
• legitimate interests: where our use of your personal data is necessary for our legitimate interests or the legitimate interests of a third party (unless there is a good reason to protect your personal data which overrides our legitimate interests)

Further information—the personal data we collect, when and how we use it

For further details on when we collect personal data, the type of data we collect as well as the lawful basis we rely on, please read the following table:

Who we share your personal data with

If you are a Customer on the 2in1 Cleaning Platform, we may share your personal data such as identity, contact and transactional data with the Service Providers on the website and our payments provider partner, Stripe. For more information on how Stripe processes your personal data, please see their Privacy Policy.

Some of these third party recipients may be based outside the United Kingdom and European Economic Area — for further information including on how we safeguard your personal data when this occurs, see ‘Transfer of your information out of the UK and EEA’ below.

We will share personal data with law enforcement or other authorities if required by applicable law.

Where we do share your data with third parties, we will always ensure that such third parties are bound by a contract setting out how they are authorised to process data on our behalf and which contains provisions regarding data security and confidentiality, as required by applicable privacy laws.

Transfer of your personal data out of the UK and EEA

We may transfer your personal data to the following which are located outside the United Kingdom (UK) and European Economic Area (EEA). Where we transfer your personal data outside of the UK and the EEA, we will only do so for the purposes mentioned in this Policy and any contract that we have entered into with you or the entity that you are representing.

Countries outside of the UK and the EEA do not have the same data protection laws as the UK and EEA. Therefore, when making such a transfer of data, we will always rely on a safeguard mechanism under the UK GDPR and/or the EU GDPR. We will only transfer your personal data to a country which the European Commission or the UK authorities have given a formal adequacy decision/regulation that confirms this third-country provides an adequate level of data protection similar to those which apply in the UK and EEA. If the third-country does not have an adequacy decision awarded to it, any transfer of your personal information will be subject to entering into the European Commission’s Standard Contractual Clauses (the SCCs) which are designed to help safeguard your privacy rights and give you remedies in the unlikely event of a misuse of your personal data.

Transfers of personal data from the EEA to the UK shall be done on the basis of an adequacy decision awarded by the European Commission to the UK in June 2021.

If you would like further information please contact us using the details provided at the start of this Policy. We will not otherwise transfer your personal data outside of the UK and the EEA or to any organisation (or subordinate bodies) governed by public international law or which is set up under any agreement between two or more countries.

Marketing

We would like to send you information about the 2in1 Cleaning Platform, our Platform Services, the Cleaning Services on sale and any special offers, which may be of interest to you. Where we have your consent or it is in our legitimate interests to do so, we may do this by post, email, telephone, text message (SMS) or automated call.

We will ask whether you would like us to send you marketing messages when you provide consent to such marketing, or where you have purchased products from us.

If you have previously agreed to being contacted in this way, you can unsubscribe at any time by:

—contacting us using the detail provided at the beginning of this Policy;

—using the ‘unsubscribe’ link in emails; or

—updating your marketing preferences on the 2in1 Cleaning Platform within your Authorised User Account.

Your rights

Under the UK GDPR and the EU GDPR, you have a number of important rights free of charge. In summary, those include rights to:

• fair processing of information and transparency over how we use your use personal data
• access to your personal data and to certain other supplementary information that this Policy is already designed to address
• require us to correct any mistakes in your personal data which we hold
• require the erasure of personal data concerning you in certain situations
• receive the personal data concerning you which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to a third party in certain situations
• object at any time to processing of personal data concerning you for direct marketing
• object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you
• object in certain other situations to our continued processing of your personal data
• otherwise restrict our processing of your personal data in certain circumstances

For further information on each of those rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights under the General Data Protection Regulation.

For further information on each of those rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights under the General Data Protection Regulation.

If you would like to exercise any of those rights, please email or write to us using the details provided at the beginning of this Policy.

We will require information from you to allow us to identify you. We will endeavour to respond to all requests with 30 days of receipt.

Keeping your personal data secure

We have appropriate security measures in place to prevent personal data from being accidentally lost, or used or accessed in an unauthorised way. We limit access to your personal data to those who have a genuine business need to know it. Those processing your personal data will do so only in an authorised manner and are subject to a duty of confidentiality.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

Changes to this Policy

This Policy was last updated on 10th January 2021.

We may change this Policy from time to time, when we do, we will update this Policy on the 2in1 Cleaning Platform. It is your responsibility to ensure you are always up to date of the latest policy in force.