CLIQUE PRIVACY POLICY
Last updated: December 2024
1. IMPORTANT INFORMATION ABOUT CLIQUE
Privacy policy
This privacy policy gives you information about how CLIQUE Limited (“CLIQUE”) collects and uses your personal data, including any data you may provide CLIQUE when you register for an account on the CLIQUE website or app (the "CLIQUE Platform”) or use CLIQUE services (the “CLIQUE Services”).
CLIQUE operates the online fashion marketplace on the domain Cliquewithus.com and connects both borrowers with sharers and buyers with sellers on the CLIQUE Platform. CLIQUE’s mission is to reinvent ownership by providing all the short-cuts to a sustainable wardrobe through renting, lending, monthly refreshes, purchase or sale of pre-owned clothing via the CLIQUE Platform.
You are required to register as a member and create an account and profile in order to make full use of the CLIQUE Services (“Member”).
The CLIQUE Platform is not intended for children and CLIQUE does not knowingly collect data relating to children.
Controller
CLIQUE is a company registered in England and Wales with company number 15867502 and whose registered office is situated at 82a James Carter Road, Mildenhall, Suffolk IP28 7DE. CLIQUE is the data controller and is responsible for your personal information.
Defined terms
Any capitalised terms that are not defined in this policy are set out in CLIQUE Terms of Service(“Terms”).
For the purposes of this policy the following definitions are adopted:
1. Borrower: a Member who borrows Product(s) on the CLIQUE Platform from a Sharer;
2. Sharer: a Member who makes available Product(s) to borrow and Lends Products to Borrowers via the CLIQUE Platform;
3. Buyer: a Member who purchases Products on the CLIQUE Platform from a Seller;
4. Seller: a Member who makes available Products for Sale to Buyers on the CLIQUE Platform; or
2. INFORMATION CLIQUE MAY COLLECT ABOUT YOU
CLIQUE is committed to protecting your Information (as defined below) and your right to privacy. Personal data, or personal information means any information about an identified individual or information from which that person can be identified. It does not include anonymous information, namely information which does not relate to an identified or identifiable individual, or personal data rendered anonymous in such a manner that the individual is not or no longer identifiable.
CLIQUE may collect, process, use, store and transfer different types of personal data about you when you use the CLIQUE Services, access the CLIQUE Platform and/or when you otherwise deal with CLIQUE (the “Information”) which we have grouped together as follows:
Identity Data: includes first name, last name, date of birth, place of birth, clothes, accessories and shoe sizings, photographs, national insurance number, personal ID number, identity documents (e.g. passport), credit checks, personal characteristics and gender.
Profile Data: includes your username and password, profile picture, purchases or orders made by you, your interests, preferences, feedback and survey responses.
Contact Data: means the data CLIQUE uses to contact you including your billing address, delivery address, work address, email address and contact numbers.
Financial Data: means the bank account details, payment method and card association used to process payments for your orders. CLIQUE does not store or process your bank account details and card details; they are processed and stored via one of CLIQUE’s contracted third-party service providers. The bank account details and payment card details you provide via your browser when using the CLIQUE Services on CLIQUE webpages are encrypted via Hypertext Transfer Protocol Secure (HTTPS) and are then securely transferred to CLIQUE’s relevant third-party payment service provider to process your payment.
Usage Data: includes information about how you use the CLIQUE Services. This includes your browsing patterns and information including but not limited to how long you might spend on one of CLIQUE webpages on the CLIQUE Platform and what items you look at and the page that referred you to the CLIQUE Platform and the clickstream during your visit to CLIQUE website, page response times and page interaction information (clicks you make on a page).
Marketing and Communications Data: includes your preferences in receiving marketing from CLIQUE and your communication preferences including push notifications and other information relevant to CLIQUE Services, customer surveys and/or offers.
Social Media and Third-party Login Data: CLIQUE provides you with the option to register using social media account details, like your Apple, Meta, Google or third-party login account. If you choose to register in this way, CLIQUE will collect the Information described in the section called "Third-party logins" below. All information that you provide to CLIQUE must be true, complete and accurate, and you must notify CLIQUE of any changes to such Information.
Special category data: CLIQUE does 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). It is for you to decide whether you want to share such information in the content you submit through the CLIQUE Platform and share with others. However, CLIQUE may collect information about criminal convictions and offences when carrying out credit checks on CLIQUE Members.
Minors: CLIQUE takes steps to ensure that the CLIQUE Services are only used by those over 18 years of age and CLIQUE does not knowingly collect data from or market to children under 18 years of age. CLIQUE does not knowingly solicit data from or market to children under 18 years of age.
By using the CLIQUE Services, you represent that you are at least 18 years of age. If CLIQUE learns that Information from users less than 18 years of age has been collected, CLIQUE will deactivate the account and take reasonable measures to promptly delete such data from CLIQUE’s records.
If you become aware of any data CLIQUE has collected from children under age 18, please contact CLIQUE at [email protected].
3. HOW IS YOUR PERSONAL DATA COLLECTED?
CLIQUE uses different methods to collect data from and about you including through:
Your interactions with CLIQUE: You may give CLIQUE your personal data by filling in online forms or by corresponding with CLIQUE by post, phone, email or otherwise. This includes personal data you provide when you: use the CLIQUE Services or CLIQUE Platform; create an account on the CLIQUE Platform; request marketing to be sent to you; enter a competition, promotion or survey; or give CLIQUE feedback or contact CLIQUE.
Automated technologies or interactions: As you interact with the CLIQUE Platform, CLIQUE will automatically collect technical data about your equipment, browsing actions and patterns. CLIQUE collects this personal data by using cookies and other similar technologies. Please see CLIQUE’s cookie policy for further details. This information is primarily needed to maintain the security and operation of the CLIQUE Platform, and for CLIQUE’s internal analytics and reporting purposes. Most devices allow you to manage the use of location services through your settings menu. If you would prefer not to share your location, please disable use through your device directly. Additionally, parts of the CLIQUE Platform may use Google Maps/Earth services. For further information on using their services, please see the Google Maps/Earth Terms of Use and Privacy Policy. CLIQUE reserves the right to block certain IP addresses from accessing the CLIQUE Platform.
Third parties or publicly available sources: CLIQUE will receive personal data about you from various third parties such as public databases, joint marketing partners and social media platforms (such as Facebook or Instagram). Such information may include: social media profile information (your name, due date, gender, birthday, email, current city, state and country, user identification numbers for your contacts, profile picture URL and any other information that you choose to make public); marketing leads and search results and links, including paid listings (such as sponsored links); and information obtained when carrying out credit checks via credit agencies, such as Experian. Where CLIQUE needs to collect your Information by law, or under the terms of a contract CLIQUE has with you, and you fail to provide that Information when requested, CLIQUE may not be able to perform the contract CLIQUE has or is trying to enter into with you (for example, to provide you with CLIQUE Services). In this case, CLIQUE may have to cancel a product or service you have with CLIQUE, but CLIQUE will notify you if this is the case at the time.
4. HOW DO CLIQUE USE YOUR INFORMATION?
Legal basis: The law requires CLIQUE to have a legal basis for collecting and using your personal data. CLIQUE rely on one or more of the following legal bases: where it is necessary for CLIQUE’s legitimate business interests (“Business Purposes”) and your interests and fundamental rights do not override those interests; in order to enter into or perform a contract with you (“Contractual”); with your consent (“Consent”); and/or for compliance with CLIQUE legal obligations (“Legal Obligations”).
CLIQUE has set out below a description of all the ways CLIQUE plan to use the various categories of your personal data, and which of the legal bases CLIQUE rely on to do so. CLIQUE have also identified what CLIQUE legitimate interests are where appropriate.
|
Purpose |
Legal Basis |
Comment |
|
Fulfilment and management of any orders and payments in connection with the CLIQUE Services and administration and management of your account |
Contractual |
CLIQUE may use your Information or pass it onto other Members in order to enable the CLIQUE Services including the rental of items |
|
Sending administrative information to you |
Business Purposes (to develop CLIQUE products/services) and/or Legal Obligations and/or Contractual |
CLIQUE may use your Information to send you product, service and new feature information and/or information about changes to CLIQUE Terms and policies |
|
Sending you marketing and promotional communications |
Business Purposes (to develop CLIQUE products/services and grow CLIQUE business) and/or Consent |
CLIQUE and/or CLIQUE third-party partners may use your Information for CLIQUE marketing purposes, if this is in accordance with your marketing preferences. You can opt-out of CLIQUE marketing messages, see below for further details.
|
|
Facilitating account creation and the sign in process |
Consent |
If you choose to link your account with CLIQUE to a third party account (such as your Google or Facebook account), CLIQUE use the information you allowed CLIQUE to collect from those third parties to facilitate account creation and logon process. |
|
Request feedback |
Business Purposes (to study how customers use CLIQUE products/services, to develop them, grow CLIQUE business and inform CLIQUE marketing strategy) and/or Consent |
CLIQUE may use your Information to request feedback and to contact you about your use of the CLIQUE Platform |
|
Protecting the CLIQUE Services |
Business Purposes (for running CLIQUE’s business, provision of administration and IT services, network security, to prevent fraud and phishing scams) and/or Legal Obligations |
CLIQUE may use your Information as part of CLIQUE’s efforts to keep the CLIQUE Services safe and secure (for example, for fraud monitoring and prevention). This includes reviewing, scanning or analysing communications between Members on the CLIQUE Platform, either by automated or manual methods |
|
Enforcing CLIQUE Terms and policies |
Business Purposes (for running CLIQUE business and recover debts due to CLIQUE), Legal Obligations and/or Contractual |
|
|
Responding to legal requests and preventing harm
|
Legal Obligations
|
If CLIQUE receives a legal request from a third party, CLIQUE may need to inspect the Information CLIQUE holds to determine how to respond
|
|
Other purposes compatible with the above purposes
|
Business Purposes |
CLIQUE may use your Information for other Business Purposes, such as data analysis, identifying usage trends, determining the effectiveness of CLIQUE promotional campaigns and to evaluate and improve the CLIQUE Services, products, services, marketing and your experience |
CLIQUE will only use your Information for the purposes for which CLIQUE collected it, unless CLIQUE reasonably considers that CLIQUE needs to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact CLIQUE. If CLIQUE needs to use your Information for an unrelated purpose, CLIQUE will notify you and CLIQUE will explain the legal basis which allows CLIQUE to do so. Please note that CLIQUE may process your Information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Consent
You will be required to give Consent to certain processing activities before CLIQUE can process your Information. Where applicable, CLIQUE will seek Consent from you when you first submit Information to or through the CLIQUE Services.
If you have previously given your Consent you may freely withdraw such Consent at any time. You can do this by emailing [email protected].
If you withdraw your Consent, and if CLIQUE does not have another legal basis for processing your Information, then CLIQUE will stop processing your Information and delete it together with your Account.
If CLIQUE does have another legal basis for processing your Information, then CLIQUE may continue to do so, subject to your legal rights.
Please note that if CLIQUE needs to process your Information in order for you to use the CLIQUE Services and you object or do not provide Consent to CLIQUE processing your Information, the CLIQUE Services will not be available to you.
Direct Marketing
If you have given Consent to marketing, CLIQUE may contact you about CLIQUE products, services, promotions and special offers. If you no longer wish to receive such information you can withdraw your Consent at any time by unsubscribing from the communications via the link available in each communication.
CLIQUE may also analyse your Identity Data, Contact Data, Technical Data, Usage Data and Profile Data to form a view which products, services and offers may be of interest to you so that CLIQUE can then send you relevant marketing communications.
Cookies & Cookie Policy
For more information about the cookies CLIQUE use and how to change your cookie preferences, please press “Cookie Policy” in the footer of the www.cliquewithus.com.
5. DISCLOSURES OF YOUR PERSONAL DATA
CLIQUE only shares and discloses your Information in the following situations for the purposes set out above in “4. How do CLIQUE use your Information?":
Contractual: To share information with Members to enable usage of the CLIQUE Services including renting, lending, purchase or sale of Items. When a Borrower submits a request (or a Buyer submits an offer), CLIQUE will provide the relevant Sharer/Seller with the Borrower/Buyer's full name, cancellation history, reviews and any other information the Member has agreed to share. Once the Sharer/Seller has accepted the borrow request/offer, CLIQUE will share the requesting Borrower/Buyer's information to co-ordinate the delivery of the item such as the Borrower/Buyer's phone number and address. CLIQUE will never share your billing or payment information with other Members.
Compliance with Legal Obligations: CLIQUE may disclose your Information where CLIQUE is legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order (including in response to public authorities to meet national security or law enforcement requirements). CLIQUE may disclose your Information where CLIQUE believes it is necessary to investigate, prevent, or take action regarding potential violations of CLIQUE policies, suspected fraud or criminal activity, situations involving potential threats to the safety of any person or illegal activities, or as evidence in litigation in which CLIQUE is involved. Such Information may be disclosed to government bodies, including but not limited to HMRC, the National Crime Agency and relevant police forces.
Third-Party Service Providers: CLIQUE may share your Information with third-party vendors, service providers, contractors or agents who perform services and require access to such information to do that work. Examples include: data analysis, email delivery, hosting services, customer service, search information providers, delivery service providers, analytic providers, developers, credit reference agencies, ID verification service providers and marketing agencies. They will only have access to your Information to the extent that they need to perform those services. They are required to keep your Information confidential and may not use it other than as CLIQUE ask them to and always in accordance with this policy. The third parties CLIQUE use include but are not limited to: Stripe, DIXA, Google Analytics, Instagram, Facebook, delivery partners and various Google APIs. In some cases, the Information provided to CLIQUE varies and is controlled by the specific service or as authorised by you via your privacy settings for that service. For more information on how these companies handle your personal data, please refer to their privacy policies.
Business transfers: CLIQUE may share or transfer your Information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of CLIQUE business to another company.
Business partners: Provided you have given CLIQUE Consent to do so CLIQUE may share your Information with CLIQUE business partners to offer you certain products, services or promotions. CLIQUE will get your express opt-in consent before CLIQUE share your Information with any third party for marketing purposes. You can ask CLIQUE or third parties to stop sending you marketing messages at any time by logging into the CLIQUE Platform and checking or unchecking relevant boxes to adjust your marketing preferences, by following the opt-out links on any marketing message or SMS sent to you or by sending an email to [email protected].
With your Consent: CLIQUE may disclose your Information for any other purpose with your Consent.
Aggregated and anonymous information: CLIQUE may disclose aggregated, anonymous information (i.e. information from which you cannot be personally identified), or insights based on such anonymous information, to selected third parties, including (without limitation) analytics and search engine providers to assist CLIQUE in the provision of services.
6. VISIBILITY OF PERSONAL DATA
Some of your profile information will be visible to other Members when you interact such as your profile photo and delivery address.
Information which will be publicly available to users on your profile will be your first and second name and profile picture.
Listings that are publicly visible will show any information relating to the Listing (e.g. description, item availability, Sharer profile picture and name).
Reviews from Sharers/Borrowers will be published and visible on your public profile.
Always think carefully before disclosing your Information or other information to other users or otherwise posting Information on the CLIQUE Platform.
CLIQUE does not control the content of communications made between users (although you can make a complaint about another user by contacting CLIQUE using the information provided in the “13. Contact and complaints” section below).
You must respect the privacy of others and you must not disclose any personal details about other people including your family, friends, acquaintances, or other persons that may be misleading or cause them harm or offence. It is your responsibility to obtain their prior express permission in respect of any submission of their Information at any time.
To change your privacy settings on the CLIQUE Platform, please login and do so via your profile settings.
Once you have shared your content or made it public, that content may be re-shared by other users.
You may review, modify, update, correct or remove any Information you have submitted to the CLIQUE Platform at any time. If you remove information that you posted to the CLIQUE Platform, copies may remain viewable in cached and archived pages of the CLIQUE Platform, in the log of account details that CLIQUE maintains for security purposes or if other users or third-party APIs have copied or saved that information.
7. INTERNATIONAL DATA TRANSFERS
CLIQUE may transfer, store, and process your Information in countries other than your own but will take all reasonable steps to ensure it is protected.
Whenever CLIQUE transfers your Information outside of the UK, CLIQUE will take all reasonable measures that CLIQUE can to protect your Information in accordance with this policy and applicable law.
To the extent that any transfer of your Information outside of the UK is required, CLIQUE ensures a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
· CLIQUE will only transfer your Information to countries that have been deemed to provide an adequate level of protection for personal data.
· Where CLIQUE uses certain service providers, CLIQUE may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK.
8. DATA SECURITY
CLIQUE aims to protect your Information through a system of organisational and technical security measures. CLIQUE has implemented appropriate technical and organisational security measures designed to protect the security of any Information CLIQUE processes.
Although CLIQUE will do its best to protect your Information, transmission of Information to and from the CLIQUE Platform is at your own risk. You should only access CLIQUE services within a secure environment.
All personal information is encrypted in transit and at rest. Your payment information is also encrypted in transit and at rest by CLIQUE third party.
CLIQUE has put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where CLIQUE is legally required to do so.
9. HOW LONG DOES CLIQUE KEEP YOUR INFORMATION?
CLIQUE will only keep your Information for as long as it is necessary for the purposes set out in this policy, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements).
CLIQUE may retain your Information for a longer period in the event of a complaint or if CLIQUE reasonably believe there is a prospect of litigation in respect of CLIQUE’s relationship with you.
To determine the appropriate retention period for Information, CLIQUE consider the amount, nature and sensitivity of the Information, the potential risk of harm from unauthorised use or disclosure of your Information, the purposes for which CLIQUE process your Information and whether CLIQUE can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
By law CLIQUE have to keep basic information about CLIQUE customers (including Contact Data, Identity Data and Financial Data) for six years after they cease being customers for tax purposes.
In some circumstances you can ask CLIQUE to delete your data: see"12. Your Legal Rights" below for further information.
In some circumstances CLIQUE will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case CLIQUE may use this information indefinitely without further notice to you.
When CLIQUE have no ongoing Business Purpose to process your Information, CLIQUE will either delete or anonymise it, or, if this is not possible (for example, because your Information has been stored in backup archives), then CLIQUE will securely store your Information and isolate it from any further processing until deletion is possible.
10. THIRD-PARTY WEBSITES
CLIQUE is not responsible for the safety of any information that you share with third-party providers who feature or advertise, but are not affiliated with, the CLIQUE Services. The CLIQUE Platform may feature links to third-party websites and contain advertisements from third parties that are not affiliated with CLIQUE and which may link to other websites, online services or mobile applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you.
CLIQUE cannot guarantee the safety and privacy of data you provide to any third parties. Any data collected by third parties is not covered by this policy. CLIQUE is not responsible for the content or privacy and security practices and policies of any third parties, including other websites, services or applications that may be linked to or from the CLIQUE Platform.
You should review the policies of such third parties and contact them directly to respond to your questions. Anything you share on the publicly available part of the CLIQUE Platform will also be catalogued by third-party search engines. CLIQUE is not responsible for their use of your information or the accuracy of it.
11. THIRD-PARTY LOGINS
If you choose to register or log in to the CLIQUE Platform using a social media account or third-party website (e.g. Amazon), CLIQUE may have access to certain Information about you.
The CLIQUE Platform offers you the ability to register and log in using certain social media account details (like your Meta or Twitter logins) and third-party website providers. Where you choose to do this, CLIQUE will receive certain information from your social media or third-party provider. The Information CLIQUE receives may vary depending on the social media or third-party provider concerned, but will often include your name, email address, friends list, profile picture as well as other information you choose to make public. If you log in using Meta, CLIQUE may also request access to other permissions related to your account, such as friends, check-ins, and likes, and you may choose to grant or deny CLIQUE access to each individual permission.
The Information that you post, transmit, or otherwise make available on the social media platform may be viewed and/or used by other users of those networks and CLIQUE have no control over such viewing and use and cannot prevent further use of such information by third parties.
In the event you choose to link your CLIQUE profile with a social media or third-party account, the information you provide to CLIQUE in the process may be included on your CLIQUE profile. Additionally, your contacts on the social media platform(s) (“Friends”) may be able to see your activity on the CLIQUE Platform.
A link to your public profile on the social media site may be added to your CLIQUE profile and other users may be able to see any Friends or links (e.g. friends of friends) via that social network you may have in common with them.
When you interact with CLIQUE through social media networks, you acknowledge that CLIQUE may access your Information that is held by that account, solely in accordance with your social media privacy settings. Any links to social media are not under CLIQUE control and remain solely your responsibility. You acknowledge that any information posted via social media through the CLIQUE Platform, or any third party you allow to access your content, is done entirely at your own risk and that by posting to a public platform you make that information visible to third parties who can use that information at their discretion.
Please note that CLIQUE does not control, and is not responsible for, other uses of your Information by your third-party social media provider. CLIQUE recommends that you review their privacy policy to understand how they collect, use and share your Information, and how you can set your privacy preferences on their sites and apps.
12. YOUR LEGAL RIGHTS
You have certain rights under applicable data protection laws. These may include the right, under certain circumstances:
· to withdraw consent as set out above (see "Your Consent to processing"). Please note however that this will not affect the lawfulness of the processing before its withdrawal;
· to request access and obtain a copy of your Information;
· to request rectification or erasure of your Information;
· to restrict the processing of your Information;
· if applicable, to data portability; and
· to object to the processing of your Information.
If you wish to exercise any of the rights set out above, please contact CLIQUE at [email protected]. CLIQUE will consider and act upon any request in accordance with applicable data protection laws.
CLIQUE may need to request specific information from you to help confirm your identity and ensure your right to access your Information (or to exercise any of your other rights). This is a security measure to ensure that your Information is not disclosed to a person who does not have the right to receive it. CLIQUE may also contact you to ask you for further information in relation to your request to speed up your response.
No fee usually required. You will not have to pay a fee to access your Information (or to exercise any of the other rights). However, CLIQUE may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, CLIQUE could refuse to comply with your request in these circumstances.
Time limit to respond. CLIQUE tries to respond to all legitimate requests within one month. Occasionally it could take CLIQUE longer than a month if your request is particularly complex or you have made a number of requests. In this case, CLIQUE will notify you and keep you updated.
13. CONTACT AND COMPLAINTS
CLIQUE welcomes your feedback and questions on this policy. If you wish to contact CLIQUE about this policy, about your Information or any other questions, please email CLIQUE at [email protected].
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). CLIQUE would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact CLIQUE in the first instance.
14. CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM CLIQUE OF CHANGES
CLIQUE keeps the CLIQUE privacy policy under regular review. If you do not agree to any changes to this policy then you must immediately stop using the CLIQUE Services. In the event CLIQUE makes any significant changes to this policy, CLIQUE will use CLIQUE best endeavours to inform you of such changes in advance in writing.
It is important that the personal data CLIQUE holds about you is accurate and current. Please keep CLIQUE informed if your personal data changes during your relationship with CLIQUE, for example a new address or email address.