Last updated 25/05/2022
Who we are
Tilt is a marketplace platform, developed by Retro Labs Ltd ("Tilt", "we", "us" or "our"), where sellers sell items through either live stream or video to buyers. By accessing and using the Services, you acknowledge that you have read, understood, and agree to be bound by the terms of this Policy.
For the purposes of United Kingdom and European Economic Area data protection law ("Data Protection Law"), the data controller is: [Retro Labs Limited [insert address and contact details]].
Automatic collection of information
When you access our Services, depending on your device settings our servers may automatically record information that your browser sends. For the Site and/or App, this data may include information such as your device's IP address, browser type and version, operating system type and version, language preferences or the webpage you were visiting before you accessed the Services, pages that you visit that we control, the time spent on those pages, the information you search for within our Services, access times and dates, and other statistics.
Information collected automatically is used only to identify potential cases of abuse and establish statistical information regarding the usage and traffic of the Services. This statistical information is not otherwise processed in such a way that would identify any particular user of the system.
Collection of personal information
You can access and use the Services without telling us who you are or revealing any information by which someone could identify you as a specific, identifiable individual. If, however, you wish to use some of the features on the Site or App, such a signing up to our mailing lists or creating an account, you may be asked to provide certain Personal Information (for example, your name and e-mail address).
We receive and store any information you provide to us when you create an account, make a purchase, or fill any online forms within the Services in compliance with data protection laws. When required, this information may include the following:
- Personal details such as name, country of residence, etc.
- Contact information such as email address, address, etc.
- Account details such as user name, unique user ID, password, etc.
- Payment information such as credit card details, bank details, etc.
- Geolocation data such as latitude and longitude.
- Any other materials you willingly submit to us such as articles, images, feedback, etc.
Some of the information we collect is directly from you via the Services. However, we may also collect Personal Information about you from other sources such as public databases and our joint marketing partners (at all times acting in compliance with Data Protection Laws). You can choose not to provide us with your Personal Information, but then you may not be able to take advantage of some of the features of the Services. Users who are uncertain about what information is mandatory are welcome to contact us at firstname.lastname@example.org.
Use and processing of collected information
In order to make the Services available to you, or to meet a legal obligation, we may need to collect and use certain Personal Information. If you do not provide the information that we request, we may not be able to provide you with the requested products or services. Any of the information we collect from you may be used for the following purposes:
- Create and manage user accounts
- Fulfil and manage orders by Sellers
- Deliver products or services by Sellers
- Improve our products and services
- Send administrative information (such as service updates, site maintenance and updates to policies)
- Send marketing and promotional communications (where you have opted in or we have a legitimate interest in contacting you)
- Respond to inquiries and offer support
- Request user feedback
- Improve user experience
- Post customer testimonials
- Deliver targeted advertising
- Enforce terms and conditions and policies
- Protect from abuse and malicious users
- Respond to legal requests and prevent harm
- Run and operate the App and Services
Processing your Personal Information depends on how you interact with our Services, however our processing typically falls within the following lawful reasons: (i) you have given your consent for one or more specific purposes;; (ii) provision of information is necessary for the performance of an agreement with you and/or for any pre-contractual obligations thereof; (iii) processing is necessary for compliance with a legal obligation to which we are subject; (iv) processing is necessary for the purposes of the legitimate interests pursued by us or by a third party.
In any specific case, we will be happy to clarify the legal basis that applies to the processing, and in particular whether the provision of Personal Information is an optional requirement, a legal requirement, or a requirement necessary to enter into a contract with you.
Billing and payments
In case of services requiring payment, we request credit card or other payment account information, which will be used solely for processing payments. Your purchase transaction data is stored only as long as is necessary to complete your purchase transaction. After that is complete, your purchase transaction information is deleted. Where necessary for processing future payments and subject to your prior consent, your financial information will be stored in encrypted form on secure servers of our reputed payment gateway service provider. We ensure that all direct payment gateways adhere to the latest security standards as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, MasterCard and PayPal. Sensitive and private data exchange happens over an SSL secured communication channel and is encrypted and protected with digital signatures. Our Services are also in compliance with PCI vulnerability standards in order to create as secure of an environment as possible for users. Scans for malware are performed on a regular basis for additional security and protection.
You are able to delete certain Personal Information we have about you from your account page. In some cases we may maintain a copy of the Personal Information in our records for the duration necessary to comply with our legal obligations and our obligations to our affiliates and partners. If you would like to delete your Personal Information or permanently delete your account, you can do so on the settings page of your account on the Site or App.
Disclosure of information
We may share your information with our trusted third parties that work with us to provide the Services, and any other affiliates and subsidiaries we rely upon to assist in the operation of the Services available to you. We do not share Personal Information with unaffiliated third parties, , and we only work with third parties whose privacy practices are consistent with ours and who abide by applicable data protection law. These third parties are given Personal Information they need only in order to perform their designated functions, and we do not authorize them to use or disclose Personal Information for their own marketing or other purposes.
We will disclose any Personal Information we collect, use or receive if required or permitted by law, such as to comply with a subpoena or similar legal process, and when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, to investigate fraud, or respond to a government request.
In the event, we go through a business transition, such as a merger or acquisition by another company, or the sale of all or a portion of its assets, your user account, and Personal Information will likely be among the assets transferred.
Retention of information
We will retain and use your Personal Information for the period necessary to comply with our legal obligations, resolve disputes, and enforce our agreements unless a longer retention period is required or permitted by law. We may use any aggregated data derived from or incorporating your Personal Information after you update or delete it, but not in a manner that would identify you personally. Once the retention period expires, Personal Information shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after the expiration of the retention period (and we will inform you at the time of your request if we no longer hold your Personal Information).
Transfer of information
Depending on your location, data transfers may involve transferring and storing your information in a country other than your own. We take steps to ensure that all transfers are secured in accordance with applicable data protection laws, for example where your information is transferred outside the UK or the European Economic Area, we take all steps reasonably necessary to ensure that your data is subject to appropriate safeguards, such as relying on a recognised legal adequacy mechanism, and that it is treated securely and in accordance with this Policy. If any such transfer takes place, you can find out more contacting us via the information provided in the contact section.
Data protection rights under GDPR
If you are a resident of the United Kingdom (UK) or the European Economic Area (EEA), you have certain data protection rights and Tilt aims to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Information. If you wish to be informed what Personal Information we hold about you and if you want it to be removed from our systems, please contact us.
In certain circumstances, you have the following data protection rights:
- You have the right to request access to your Personal Information that we store and have the ability to access your Personal Information.
- You have the right to request that we correct any Personal Information you believe is inaccurate. You also have the right to request us to complete the Personal Information you believe is incomplete.
- You have the right to request the erase of your Personal Information under certain conditions of this Policy.
- You have the right to object to our processing of your Personal Information.
- You have the right to seek restrictions on the processing of your Personal Information. When you restrict the processing of your Personal Information, we may store it but will not process it further.
- You have the right to be provided with a copy of the information we have on you in a structured, machine-readable and commonly used format.
- You also have the right to withdraw your consent at any time where Tilt relied on your consent to process your Personal Information.
You have the right to complain to a Data Protection Authority about our collection and use of your Personal Information (see here). The Information Commissioner is the supervisory authority in the UK and can provide further information about your rights and our obligations in relation to your personal data, as well as deal with any complaints that you have about our processing of your Personal Information.
How to exercise these rights
Any requests to exercise your rights can be directed to Tilt through the contact details provided in this document. Please note that we may ask you to verify your identity before responding to such requests. Your request must provide sufficient information that allows us to verify that you are the person you are claiming to be or that you are the authorized representative of such person. You must include sufficient details to allow us to properly understand the request and respond to it. We cannot respond to your request or provide you with Personal Information unless we first verify your identity or authority to make such a request and confirm that the Personal Information relates to you.
Privacy of children
We do not knowingly collect any Personal Information from children under the age of 18. If you are under the age of 18, please do not submit any Personal Information through the Services. We encourage parents and legal guardians to monitor their children's Internet usage and to help enforce this Policy by instructing their children never to provide Personal Information through the Services without their permission. If you have reason to believe that a child under the age of 18 has provided Personal Information to us through the Services, please contact us.
The Services use "cookies" to help personalize your online experience. A cookie is a text file that is placed on your hard disk by a web page server. Cookies cannot be used to run programs or deliver viruses to your computer. Cookies are uniquely assigned to you, and can only be read by a web server in the domain that issued the cookie to you.
Do Not Track signals
Some browsers incorporate a Do Not Track feature that signals to online services you visit that you do not want to have your online activity tracked. Tracking is not the same as using or collecting information in connection with the Services. For these purposes, tracking refers to collecting personally identifiable information from consumers who use or visit the online service as they move across different services over time. Our Services do not track visitors over time and across third-party Apps. However, some third-party apps may keep track of your browsing activities when they serve you content, which enables them to tailor what they present to you.
We may display online advertisements and we may share aggregated and non-identifying information about our customers that we or our advertisers collect through your use of the Services. We do not share personally identifiable information about individual customers with advertisers. In some instances, we may use this aggregated and non-identifying information to deliver tailored advertisements to the intended audience.
We may also permit certain third-party companies to help us tailor advertising that we think may be of interest to users and to collect and use other data about user activities on the Services. These companies may deliver ads that might place cookies and otherwise track user behaviour.
We offer electronic newsletters to which you may voluntarily subscribe at any time. We are committed to keeping your e-mail address confidential and will not disclose your email address to any third parties except as allowed in the information use and processing section or for the purposes of utilizing a third-party provider to send such emails. We will maintain the information sent via e-mail in accordance with applicable laws and regulations.
In compliance with the CAN-SPAM Act and other EU and UK data protection laws, all e-mails sent from us will clearly state who the e-mail is from and provide clear information on how to contact the sender. You may choose to stop receiving our newsletter or marketing emails by following the unsubscribe instructions included in these emails or by contacting us. However, you will continue to receive essential transactional emails.
Links to other resources
The Services may contain links to other third party resources that are not owned or controlled by us. Please be aware that we are not responsible for the privacy practices of such other resources or third parties. We encourage you to be aware when you Services and to read the privacy statements of each and every resource that may collect Personal Information.
We secure information you provide on computer servers in a controlled, secure environment, protected from unauthorized access, use, or disclosure. We maintain reasonable administrative, technical, and physical safeguards in an effort to protect against unauthorized access, use, modification, and disclosure of Personal Information in its control and custody. If you have any questions in respect of our security practices please contact us using the details in this form.
Changes and amendments
We reserve the right to modify this Policy from time to time at our discretion and will notify you of any material changes to the way in which we treat Personal Information. When we do, we will revise the updated date at the bottom of this page. We may also provide notice to you in other ways at our discretion, such as through the contact information you have provided. Any updated version of this Policy will be effective immediately upon the posting of the revised Policy unless otherwise specified.
If you would like to contact us to understand more about this Policy or wish to contact us concerning any matter relating to individual rights and your Personal Information, you may do so via the contact form or send an email to email@example.com.← Back to TILT