Privacy Policy

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INTRODUCTION

BEHODL Ltd, a company established in England (company number 12624469) with its registered offices at 1st Floor, 81 - 83 Fulham High St, London SW6 3JA (“we”, “us”, or “our”) are committed to protecting and respecting the personal data that we hold. This privacy statement describes why and how we collect and use personal data and provides information about individuals’ rights. It applies to personal data provided to us, both by individuals themselves or by others on behalf of individuals. We may use personal data provided to us for the purposes described in this privacy statement or as made clear in another form before collecting personal data.

Personal data is any information relating to an identified or identifiable living person. When collecting and using personal data, our policy is to be transparent about why and how we process personal data.

We process personal data for numerous purposes, and the means of collection, lawful basis of processing, use, disclosure, and retention periods for each purpose differ, and are set out in the relevant sections below.

The personal data that is provided to us is provided either directly from the individual concerned, from a third party acting on behalf of an individual, or from publicly available sources (such as internet searches, and Companies House).​

Where we receive personal data from a third party that relates to an individual, we request that this third party inform the individual of the necessary information regarding the use of their data. Where necessary, reference may be made to this privacy statement.​

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SECURITY

We take the security of all the data we hold seriously. Staff are trained on data protection, confidentiality and security, and we maintain a culture of confidentiality.​

We have a framework of policies and procedures which ensure that we keep the data we hold secure.

All information you provide to us is stored on our secure servers. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask that you do not share your password with anyone.

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

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DATA THAT WE HOLD AND HOW WE USE IT

​We provide an online marketplace of Bitcoin rewards. You can search for merchants, and log-in to your profile. When you use our Service we will collect and process certain information about you. The exact data held will depend on the services to be provided.

Where we are legally permitted to do so, we shall notify you if we receive a request for a data subject to exercise their rights under GDPR, or if we are served with information from a supervisory authority.​

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WHAT DATA IS PROCESSED?​

The data that is processed is dependent on the service that is being provided and on the recipient of this service.

​We collect information from you when you voluntarily submit it to us and when you use the Site and Service. This can include information you provide when you register to use the Service, complete a form, make a transaction through one of our listed merchants via the affiliate link on our website, subscribe to our mailing lists or other marketing communications or take an action on the Service (such as when you perform a search, or engage in a transaction).​

We also collect information about the pages you look at on our Site and Service and/or the device you use to access the Site and Service.​

The list below sets out categories of personal information we collect about you and how we use that information. Unless we specifically state below that we are relying on your consent, our legitimate interests or a legal obligation to process your personal information, the lawful basis we are relying on to process your personal information is to perform a contract with you. This contract is governed by our Terms of Service. We will only rely on legitimate interests to process your personal information where your interests and fundamental rights do not override our interests.

Where we state below that we use your information to send you marketing communications, we may do so on the basis it is in our legitimate interests (where you are an account holder and we are informing you about our products and services), where we provide you with an opt-out option, or because you have consented to receiving such marketing communications from us. We will only send you marketing communications in accordance with your marketing preferences.​

1. Contact and identity details: When you open an account with us you will be asked to provide us with your contact information such as your name, your email address, your telephone number and addresses associated with your account. We will use your contact details so that we can communicate with you directly about the products you purchase and that you sell through the Service and about queries, issues or concerns you or other users have and to send you marketing communications. As a necessary part of participating in the Service, in order to Withdraw your account balance to a personal wallet, you will need to provide your wallet address. We may also ask you to provide copies of identification documents for the legitimate interests of verifying your details and helping prevent fraudulent access to the Service or use of your account, and to comply with KYC and AML requirements as required by our third-party exchange partner.

2. Comments and opinions: When you contact us directly, e.g. by email, phone, post or by completing an online form we will record your comments and opinions. We will also record comments and opinions you express when responding to surveys, entering competitions, taking part in promotions we run or that you post on our community boards or other message areas. We will use your comments and opinions to in the legitimate interests of addressing your queries, issues and concerns and improving our products and services. We will also use comments and opinions you express when posting on our community boards or other message areas, responding to surveys, entering competitions or taking part in other promotions, to determine products and services that may be of interest to you and to send you marketing communications.​

3. Transaction information: We keep records of the products you buy though the Service. We will use your transaction information and history to determine products and services that may be of interest to you and send you marketing. 

4. Website and app login details: Where you create an account with us we will hold your user name and password details in the legitimate interests of keeping your account secure. Where you are provided with the option to log-in using a social network, for example through Facebook sign- in, we will not be provided with your password or other account login details for those accounts. We will also collect device ID (Android ID, Apple ID, or your browser fingerprint). Browser fingerprints are based on your device type and browser type (including settings and version). BEHODL shall only use the above information in the legitimate interests of keeping your account secure. 

You are responsible for all actions taken with your user name and password, and we recommend that you do not disclose your user name and password to any third parties. If you lose control of your password, you may lose substantial control over your personally identifiable information and may be subject to legally binding actions taken on your behalf, so you should change such password immediately and notify us of any unauthorised access to your account.

​5. Your preferences: We hold information about the preferences you set for notifications, marketing communications and how our site is displayed or what content is displayed to you through our Service. We will use your preference settings for the purpose of providing notifications, sending marketing communications and displaying our Service in accordance with your choices. 

6. Information about how you connect to and use our Site and Service: We collect information about how you use our Site and Service such as the pages you view on our Site and Service, the time you access our Site and Service and how long you use it for, the website from where you came to our Site or go to after leaving our Site (if applicable) and any selections and choices you make when using our Site and Service. We also collect information about any items you have searched for on the Site and Service.

We, and our third party analytics providers, process this data for the following purposes:

  • to provide analytics data on the use of the Service, Site which we use for the legitimate interests of improving our Service, Site;
  • to send you tips and other notifications where we think this will improve your user experience of the Service;
  • in the legitimate interests of determining the success of our marketing campaigns;
  • to send you marketing about products and services we think may be of interest to you;
    and
  • in the legitimate interests of detecting or preventing any breach of our Terms of Service.

7. Information about your device: We collect information about the computer, tablet, smartphone or other electronic device you use to connect to our Service. This information can include details about the type of device, unique device identifying numbers, operating systems, browsers and applications connected to our Service through the device, your Internet service provider or mobile network, your IP address and your device’s telephone number (if it has one).

Typically, the information we collect about how you use or connect to our Service is associated with your device and not you as a named individual. However, if you are logged into a registered account you have with us this information may also be associated with you directly.

We use information about your device in order to optimise the presentation and functioning of our Service to you on your device and in the legitimate interests of ensuring that banned users are not able to access the Service by creating a new account.​

8. Information about your location: Where you give us consent, we will collect and use information about your location, sometimes together with other personal information, to provide features of the Service that are relevant to you and your location. For example, this can include allowing you to search for items that are for sale in your local area. If you change your mind about allowing us to use information about your location in the future, you can update your preferences in your device settings.​

Information about fraudulent or criminal activity relating to your account: We will use information about fraudulent or criminal activity relating to your use of our Service for the legitimate interests of detecting and preventing fraud or crime and to comply with our legal obligations. We may monitor, including by means of AI, the information you provide to detect potential fraud or breach of Terms of Service.

9. All personal information: We will use all the personal information we collect to monitor and improve our Service, App and Site and our procedures and processes. We also use the personal information we collect to help us develop new products and services. Our use of your personal information in this way will not result in information that was not previously publicly available being made public on our Service. We also use personal information we maintain about you to resolve disputes between users, to provide user support, to troubleshoot problems and enforce our Terms of Service and policies, including this Privacy Policy.

We shall not request from you any personal information, which is deemed sensitive data, including without limitation, information regarding religious or other beliefs, physical and mental health details, sexual life, racial or ethnic origin, trade union membership and/or offences, and we ask users of the Service not to supply us or any other user with any sensitive personal information, given the nature of the Service and that user profiles and comments are visible by other users. Where you do provide sensitive personal information to us on the Service you hereby confirm that you are deliberately making this information public of your own volition and accept that we may request that you remove such data from the Service.

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YOUR MARKETING PREFERENCES​

1. Email - From time to time we may contact you by email with information about our products and
services. If you do not want us to contact you by email, you can change your email marketing preferences by emailing us at hello@behodl.app and letting us know that you do not want to receive marketing emails from us. You can also unsubscribe from our marketing emails by clicking on the unsubscribe link in the emails we send to you.

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ADVERTISING AND THIRD PARTY WEBSITES​

We or our advertising partners may show advertisements to you on the Service or on other websites.

To do this we or our advertising partners may collect information about how you use the Service or the types of other web pages, content and ads you, or others who are using the device you connect to this Service, interact with, visit or view.

The information collected might also include the IP address of the device you connect to the Service.​

Such data may be exchanged between us and our advertising partners to measure the success of advertising campaigns.

We or our advertising partner use the information that is collected to make sure adverts you see either on the Service or other websites or apps (where our partner has advertising space) are more relevant to you.

The techniques our advertising partners use do not use obvious identifying information such as name, address, email address or telephone number. This information is used to recognise the device you are using but not to identify you as a named individual.

Typically cookies and similar technologies are used to provide this type of advertising. You can find out more about cookies and how to manage their use by reading our Cookies Policy.

You can also find out more about this type of advertising from www.youronlinechoices.com.

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HOW LONG DO WE HOLD DATA FOR?​

We retain the personal data processed by us in a live environment for as long as is considered necessary for the purpose(s) for which it was collected (including as required by applicable law or regulation, typically 6 years).​

In addition, personal data may be securely archived with restricted access and other appropriate safeguards where there is a need to continue to retain it.​

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SHARING PERSONAL DATA

​We will only share personal data with others when we are legally permitted to do so. When we share data with others, we put contractual arrangements and security mechanisms in place to protect the data and to comply with our data protection, confidentiality and security standards.

Personal data held by us may be transferred to:

• Third party organisations that provide applications/functionality, data processing or IT services to us. We use third parties to support us in providing our services and to help provide, run and manage our internal IT systems. For example, providers of information technology, cloud based software as a service providers, identity management, website hosting and management, data analysis, data back-up, security and storage services.

• Third party organisations that otherwise assist us in providing goods, services or information. In particular, we may share the personal information you provide to us with shipping providers (where you have chosen to use their services in relation to any items you sell), identity verification service providers (in order 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 being adhered to that no criminal activity is taking place using our Service), third party payment providers (for the purposes of processing any sales transactions you have consented to) and Site or Service analytics providers. In some cases, our service providers may collect information directly from you (e.g. if they are asked to conduct a survey for us), and in these cases you will be notified of the involvement of the service provider, and all information disclosures you make will be strictly optional. If you provide additional information to a service provider directly, then their use of your information is governed by their applicable privacy policy.

• BEHODL and group businesses.

• Auditors and other professional advisers.

• Law enforcement or regulatory agencies or those required by law or regulations.

Occasionally, we may receive requests from third parties with authority to obtain disclosure of personal data, such as to check that we are complying with applicable law and regulation, to investigate an alleged crime or to establish, exercise or defend legal rights. We will only fulfil requests for personal data where we are permitted to do so in accordance with applicable law or regulation.​

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LOCATIONS OF PROCESSING

Where possible, personal data resides within the UK territory but may be transferred to, and stored at, a destination outside the European Economic Area (EEA). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. We will take all reasonable steps to ensure that your data is treated securely, in accordance with this privacy statement.

​We have taken steps to ensure all personal data is provided with adequate protection and that all transfers of personal data outside the EEA are done lawfully. Where we transfer personal data outside of the EEA to a country not determined by the European Commission as providing an adequate level of protection for personal data, the transfers will be under an agreement which covers the EU requirements for the transfer of personal data outside the EU.

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INDIVIDUAL’S RIGHTS

Individuals have certain rights over their personal data and data controllers are responsible for fulfilling these rights as follows:

• Individuals may request access to their personal data held by us as a data controller.

• Individuals may request us to rectify personal data submitted to us or, where appropriate, contact us via the relevant website registration page or by amending the personal details held on relevant applications with which they registered.

• Individuals may request that we erase their personal data

Where we process personal data based on consent, individuals may withdraw their consent at any time by contacting us or clicking on the unsubscribe link in an email received from us.

Individuals may have other rights to restrict or object to our processing of personal data and the right to data portability.

​Individuals may request information about, or for human intervention into, any automated data processing that we may undertake.

If you wish to exercise any of these rights, please contact us at hello@behodl.app.

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OUR POLICY TOWARDS CHILDREN

BEHODL is a General Audience Site and our Service is only available to persons aged 13 and over.

​The Service is not directed to persons under 13 and we do not knowingly collect personal information from children under 13. Children under 13 years of age are prohibited from providing any personal information to the Site. If you become aware that your child has provided us with personal information without your consent, then please contact us using the details below so that we can take steps to remove such information and terminate the child’s account.

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INFORMATION ABOUT CHILDREN

As set forth above, the Services allow (but do not require) users to submit information about their children. Such information may include your child’s or children’s name(s), age(s), size(s), gender(s) and photos of your child or children. Submitting information about your child or children is always optional. We urge you to exercise caution when submitting information about your child. If you choose to submit your child’s name or a photo of your child, we may use that information to customise your experience in using the Services (such as by displaying the child’s name and photo in your private profile or in connection with search results), but we do not display or disclose your child’s name or photos of your child to other users or members of the public. If you choose to submit other information about your child (i.e., age, size or gender), we may display such information on your public profile (which may be accessed by other users and visitors of the Services) or otherwise use such information to facilitate your discussions and transactions with other users. You may adjust your sharing preferences with respect to information about your child’s age, size and gender in the account settings page of the App.

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COMPLAINTS

We hope that you won’t ever need to, but if you do want to complain about our use of personal data, please send an email with the details of your complaint to hello@behodl.app. We will look into and respond to any complaints we receive.

You also have the right to lodge a complaint with the UK data protection regulator, the Information Commissioner’s Office (“ICO”). For further information on your rights and how to complain to the ICO, please refer to the ICO website https://ico.org.uk/concerns

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DATA CONTROLLER AND CONTACT INFORMATION

The data controller for BEHODL and its associated businesses is BEHODL (the limited partnership registered in England under registration no. 12624469 and with its registration address at 1st Floor, 81 - 83 Fulham High St, London SW6 3JA.

If you have any questions about this privacy statement or how and why we process personal data, please contact us at hello@behodl.app. 

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CHANGES TO OUR PRIVACY STATEMENT

​Updates to this privacy statement will appear on this website. This privacy statement was last updated on 26th June 2021.

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