Vinted Privacy Policy

Last Updated: 2021-05-25

Welcome to the Vinted Platform, which is offered by Vinted UAB (“Vinted”). The Vinted platform allows consumers in Canada to sell consumer goods to other consumers within Canada (the “Platform”).

By using our website(s) at vinted.ca and/or application available on **Apple IOS and Android **and by providing us with personal information, for the purposes of Canadian law only, you consent to the terms of this privacy policy (“Privacy Policy”), or, if permitted under local privacy law, understand that we process it on the basis of our legitimate business interests or performance of a contract, such as our Terms of Use, or legal obligation.

If you do not agree with any of the terms of this Privacy Policy, please do not use our website or submit any personal information to us.

This Privacy Policy includes the following sections. You should read the entire policy; however, you may use the links below to be directed to the information you are seeking:

1. Who We Are. Vinted operates an online platform on which consumers may sell goods to other consumers.
2. Purpose. This Privacy Policy explains how we collect, use, and disclose personal information. If we tell you of different or additional privacy policies or practices (e.g. when we collect more information), those additional policies also apply.
3. The Information We Collect. The information we collect depends on how you interact with us and our Platform. This section sets out what personal information we collect.
4. How We Use Personal Information. How we use information depends on how you interact with us and our Platform. This section sets out how we use the information we collect.
5. Cookies And Other Tracking Technologies. For information on how we use cookies and other technologies and your ability to opt out of some practices, please visit our Cookie Policy.
6. Legal Basis For Processing. We process personal information with your consent except as otherwise permitted or required by law. Where permitted by law, we may also process your information pursuant to a contract, due to a legal obligation, or pursuant to our legitimate interests.
7. How We Share Information. We may share personal information with service providers and members of the Vinted Group that help us process the information as described in this Policy. We may also share information for legal reasons, such as an investigation or to protect our rights, or if we enter a business transaction.
8. What About Information I Disclose Publicly?. If you choose to post information to a public portion of the Platform, you should know we cannot control who sees it or how they use it. You should think carefully about what you post publicly.
9. We May Transfer Personal Information To Other Countries. We may transfer personal information to other countries. Personal information in another country may be subject to access requests by governments and law enforcement in that country.
10. Security. While we take measures to help protect personal information, no security measures can provide absolute protection. We cannot promise the security of any information you provide to us.
11. Retention Period. We retain personal information that we collect as long as necessary to fulfill the purposes for which it was collected or to meet any legal requirements, as further described in this section.
12. Your Legal Rights. Subject to certain limits, you have a right to access, correct, erase, object to, or restrict the processing of your personal information, or transfer it. You may withdraw your consent.
13. Your Choices. You can opt out of our marketing communications.
14. Changes To Our Privacy Policy. We may change this Privacy Policy, so you should review it frequently.
15. Children. We do not intend to knowingly collect personal information from any child under thirteen (13) years of age.
16. Complaints To The Regulator. While you can complain to a regulator where you live, if you have concerns, we would be happy to discuss them with you first.
17. Links. Our website may link to other websites operated by other companies. We are not responsible for these websites.
18. Company Contact Information/Data Protection Officer. You can contact us at** **privacy@vinted.ca.

1. Who We Are

Vinted offers an online platform that consumers in Canada may use to sell consumer goods to other consumers in Canada.

Vinted, UAB is a company incorporated in Lithuania with a registered office at Švitrigailos st. 13, LT-03228 Vilnius, Republic of Lithuania.

2. Purpose

This Privacy Policy outlines the privacy practices of Vinted UAB. (“Vinted”, “we”, “our”, or “us”). This Privacy Policy explains when and why we collect personal information, for example, about people who register to use our Platform. It explains how we use this information, when we share it with others, and how we help keep it secure.

Vinted is a “data controller”. This means that we are responsible for deciding how we hold and use personal information about you. We are required under applicable laws to notify you of the information contained in this Privacy Policy. Whether through this Privacy Policy or otherwise, we aim to provide a good understanding of why and where we process personal information and the rights our visitors have.

3. The Information We Collect

The types of personal information we may collect includes:

• Registration Information- If you register using your email address, we may collect your first name, last name, email address, gender, and clothing and shoe size. If you register using your Facebook Account, we may collect your first name, last name, email, FB token, Facebook ID, and the time your account was created. If you register using Apple, we may collect your User ID, first name, last name, email (if access was given), and the time your account was created.
• User Login Information- When you log in to the platform, we collect your login credentials and the time you login.
• Personalization Information- Information to allow you to personalize and receive our services, including material we send you through email or push notices. This includes gender, clothing size, shoe size, delivery address (street, number, addition, postal code, city, province, country), first, last name, display name (optional), email address, phone number, language & country, favourite products and users, preferences, and searches and clicks on the Platform.
• Communication Information- When you communicate with us or agree we can communicate with you, we collect your first name, gender, email address, the content of your messages or other feedback you provide, and the content of our responses to you.
• Tutorial Information- When you use our tutorial feature, we collect gender, clothing size, shoe size, language, if you receive our newsletter, and the date and time of your subscription to the newsletter.
• To-do list Information- If you create a To-Do List, we collect the information you place on that list. This may include the User ID of other users you choose to follow and the time you follow them, the product ID of the items you favourite or add and the time you do so, and whether you add a profile or cover photo.
• Account Refinement Information- Information you provide to refine and use your account, such as profile and cover photo, photos of the products that you offer, your location, products that you save as favourites or add to a wishlist, users that you follow, users that follow you, your reactions for products that you offer, and your vacation mode setting.
• User Communication Information- Information to allow you to communicate with other users, both through public posts and private communications. For public messages, this includes user ID, product ID, and message content. For private messages, this includes, sender user ID, recipient user ID, timestamp, if it's read, and, in some circumstances, message content. We will only review private messages under the following or similar circumstances: (i) the seller has not sent the parcel and/or the seller is not responding and we review the latest activity, (ii) one of the users has reported abuse and we are required to investigate the matter; (iii) your order has not been completed after 30 days from acknowledgment of the order and/or tracking information has been provided.
• Feedback Information- Reviews, ratings, reactions, and tagging as a favourite for the products that are offered on the Platform.
• Showing Items- information on the products you show on the Platform such as your profile and cover photo, photos of the products, category, colour, original price, size, description, tags, brand, selling price, package size, location information, and reactions for the products you have offered.
• Cart Data- The products you place in your cart, the price you pay or bid, and as applicable, when you delete them or pay for them, including the relevant timestamp.
• Bidding Data- Information about your bids for products on the Platform, such as the item you bid on, the amount you bid, when you bid, if and when the bid is accepted, and if and when it is deleted. We also collect this information on counterbids and bundling discounts.
• Agreements Between Users- If you make a purchase from another user, we collect information about your agreement with them, such as your and their first and last names, details relating to the payment transaction (e.g. method of payment and time of transaction), address, product information, amount, and date of purchase or sale.
• Order Details- Information about the orders you make and their fulfillment, such as when an order is shipped, when an order is received, when the order has been completed, when the order is ready to be paid out, if applicable, when the order has been cancelled, first name and surname, account number, details relating to the payment transaction (e.g. method of payment and time of transaction), address, product information, amount, and date of purchase or sale, and additional details for bidding or bundling discounts, including the amount of the placed or accepted bid/bundle or counterbid (including date) and ID of the product or products to which the bid or bundle/counterbid relates.
• Pending Order Details- We collect tracking data for pending orders (such as track-and-trace codes), contacts/communications with the respective buyer and seller, and other interaction data.
• Return and Refund Information- Information on returns or refunds that you request, such as when the request is made, if and when it is accepted, Payment ID, Buyer ID (user ID), order ID, refund status, amount, and Payment Service Provider ID.
• Nearby Sellers/Location Information- If you are a seller, if you agree to the use of the “nearby sellers” tool, your default address is used to calculate and display your distance from a given buyer. Your address is not provided to the buyer. For buyers, your address is used to determine your distance from sellers that have enabled this option. You may alternatively choose to use your current location. We collect location information to show you other users whose products are for sale within a radius of at least 2 km from you.
• Vacation Information- The platform allows you to indicate that you are on vacation, and other users may expect a slow response time and delayed shipping of purchased items.
• Push Notice Information- Your preferences for push notices, whether your User ID has received a particular notice, and when it was received.
• Shopping Credit Information- Your phone number, account details, and amount of shopping credit.
• Platform Use Information- Information gathered or created by your use of the Platform, including your communications with other users, that is contained in your profile (including user name and profile photo), your public chat messages, and account details such as phone number and any shopping credit.
• Payment Information- Payment status, user ID (buyer ID and seller ID), buyer location (IP address), amount, payment method, payment service provider payment ID, first and last name of buyer and seller, and for payouts, date of birth and bank account number of the recipient.
• Know Your Client Information- Information required to enable our payment service provider to meet regulatory “know your client” or anti-money laundering obligations, which may include first & last name (update), date of birth, Stripe account ID, and know your client status.
• Shipping Information- Information to arrange shipping and delivery, including first & last name, email address, parcel size, selected shipping mode and method, return address (street, number, addition, postal code, city, province, country), delivery address (street, number, addition, postal code, city, province, country), and for pickup orders, pickup point address. For buyer/seller meet-ups, when you click “current location”, latitude and longitude linked to either your current location or an address, as you specify.
• Direct Marketing Information- Information used to send you newsletters (email address) and to personalize newsletters based on your gender, sizes, language, favourite products, and users whom you follow.
• Advertising Information- For sellers, the information on the listings you place, including item size and images.
• **Financial Information- **First name and last name, country, and order identification number (sellers) or transaction identification number (buyers).
• Device and Browsing Information- Information related to your device, browser, and your browsing on the Platform: type of device, type of browser, date and time of the session, IP address, operating system, and browsing and buying patterns on the Website/App.
• Security Checks– Information you provide while communicating with other users and information you provide which may require fraudulent checks to be completed, i.e. reviewing purchases and shopping credit data against your account information, including any blocking of IP address. All information processed under this remit is to ensure the Terms of Use are followed and to prevent any fraudulent dealings.

To learn how we collect information through automatic means, please view our Cookie Policy.

4. How We Use Personal Information

We may use the personal information we collect for various purposes associated with the operation and promotion of our Platform and the transactions that take place on it. These include:

We may also use or disclose information we collect as required or permitted by law, or with your consent. We may also use it to enforce any agreement you have with us, including our Terms of Use.

We may use personal information to produce anonymous, non-identifiable information and to use or disclose such non-identifiable information in any way that we deem appropriate.

5. Cookies And Other Tracking Technologies

Vinted uses cookies and other technologies to collect information when you visit our Platform. We use these technologies to collect information such as your device and browser type, the date and time of your use sessions, your IP address, what you search for, your operating system, and your browsing and buying patterns on the Platform. We use this information to improve our Platform and services, including to analyze Platform usage to improve user-friendliness and to track down and prevent fraud and security issues. If you are suspended from the Platform, we may use your IP address to enforce the suspension.

We may work with third parties, including Google, to collect this information. We utilize Google Analytics and Google Tag Manager to track user information such as user location as inferred from IP address, the amount of time a visitor spends on our Platform, which pages are more frequently accessed, how the Platform is accessed (either directly, a search engine, or from a link), what sort of software is used (e.g.: operating system, browser type, etc.), as well as demographics. Google Analytics uses IP addresses to determine unique visitors and general geolocation data. Google offers an opt-out mechanism here (https://tools.google.com/dlpage/gaoptout/) and offers the ability to alter your ad settings here (https://www.google.com/settings/ads/anonymous).

For more information about cookies, tracking, and how we use tracking technologies on our website, please visit our Cookie Policy.

6. Legal Basis For Processing

For the purposes of Canadian law, we process your personal information with your consent except where otherwise permitted or required by law. We may also process your personal information on one or more of the following legal bases (as identified in section 4 (How we use personal information) above):

Contract. The processing is necessary for our performance of the contract you have agreed to enter with us. If you do not provide your personal information to us, we will not be able to carry out our obligations under the terms of your contract.

Legal Obligation. The processing of your personal information is necessary for the purposes of complying with applicable regulatory, accounting, and financial rules and obligations and to make mandatory disclosures to government bodies and law enforcement.

Legitimate Interests. We are permitted to process your personal information if it is based on our “legitimate interests”, where we have good, sensible, practical reasons for processing your personal information, which is in the interests of Vinted and doesn’t outweigh your rights as data subjects. To do so, we have considered the impact on your interests and rights and have placed appropriate safeguards to ensure that the intrusion on your privacy is reduced as much as possible. In jurisdictions where “legitimate interests” are not a basis on which personal information may be processed, by providing us with personal information for an identified purpose, you consent to our processing it for that purpose. Where personal information is processed based on legitimate interests, e.g. for the purposes of direct marketing, you have the right to object to such processing at any time and free of charge. See the section entitled “Your Legal Rights” to find out how. If you object to us processing your personal information, we must demonstrate compelling grounds for continuing to do so.

Consent. For the purposes of Canadian law, your consent may be express or implied. Sometimes we want to use your personal information in a way that is entirely optional for you, such as to send you our promotions and news. On these occasions, you do not have to provide your consent. You can withdraw this consent at any time, subject to legal and contractual restrictions.

7. How We Share Information

Vinted will not share personal information with any third parties for the third parties’ use for their direct marketing purposes without your consent.

Vinted may provide personal information to Vinted service providers, vendors, subcontractors, and professional advisers (who are located in North America, the UK, or the EU and bound by privacy obligations) to assist us in carrying out the uses of information described in this Privacy Policy.

For example, we use services from third parties that help us by:

• providing cloud and hosting services,
• processing payments and refunds,
• providing and maintaining tools for customer relationship management,
• providing customer support services to our users,
• delivering a purchase,
• helping us gather and analyze analytical data,
• enabling us to collect feedback from you,
• providing a phone verification service,
• providing IT security, maintenance, and technical services, and
• providing communication and newsletter sending services.

When you make a purchase from another user, they receive the following personal information: first and last name, shipping method, delivery address (street, number, addition, postal code, city, province, country) or pickup point (address), order price, paid shipping costs, and shipping label.

We may also share your personal information with third parties if we have reason to believe that disclosing such information is necessary to:

• conduct investigations of possible breaches of law,
• identify, contact, or bring legal action against someone who may be violating an agreement they have with us,
• protect our rights, safety, or property, or
• carry out any other purpose permitted or required by law.

We may also share your personal information when we investigate security breaches or cooperate with government authorities pursuant to a legal matter. We reserve the right to transfer any personal information we have in the event that we merge with or are acquired by a third party or should any such transaction be proposed.

Additionally, we share data within the Vinted group for the performance of the purposes set out in this Privacy Policy.

Vinted may share your data with third parties when transferring rights and obligations pertaining to the contractual relationship between you and Vinted to such third parties in accordance with the Terms of Use (available via the https://vinted.ca/en/terms-and-conditions), in particular in the case of the transfer of a sector of activity, a merger through the foundation of a new company, a merger through absorption, de-merger, or any change in control affecting Vinted.

8. What About Information I Disclose Publicly?

The Platform permits you to publicly share or otherwise submit ideas, photographs, information about items you wish to sell or purchase, information about your location, questions, comments, suggestions, or other content including personal information (collectively, “User Content”). Others may have access to this User Content and may have the ability to share it with third parties. Please think carefully before deciding what information you share, including personal information, in connection with your User Content.

Please note that Vinted does not control who will have access to the information that you choose to make public and cannot ensure that parties who have access to such publicly available information will respect your privacy or keep it secure. Similarly, you should be careful what information you share directly with another user using any chat or messaging features on the Platform. You should be especially careful when you share your location or choose to meet another user. You should not share your payment information directly with other users.

We are not responsible for the privacy or security of any information that you make publicly available on the Platform or share with other users or what others do with information you share with them on the website. We are not responsible for the accuracy, use, or misuse of any User Content that you disclose or receive from third parties through the website.

9. We May Transfer Personal Information To Other Countries

We may also hold your personal information on select third-party cloud-based servers in the United States or other jurisdictions. We may also use service providers in other countries to process or store personal information. This means that some or all of the personal information we collect may be stored or processed on servers located in Canada, the UK and European Economic Area, the United States, and the Netherlands. These countries’ data protection laws may differ from those of the jurisdiction in which you live. Personal information processed or stored in another jurisdiction may be subject to access requests from governments, courts, or law enforcement in accordance with the laws of that jurisdiction.

Subject to applicable laws in such other jurisdictions, we will use reasonable efforts to ensure that appropriate protections are in place to require the data processor in that country to maintain protections on the personal information that are consistent with those that apply in Canada and compliant with applicable data protection laws.

10. Security

Our security is intended to help protect against accidental or unlawful destruction, accidental loss or alteration, unauthorised disclosure or access, and any other unlawful forms of processing.

We use technical, physical, and organizational measures to help protect against accidental or unlawful destruction, accidental loss or alteration, unauthorised disclosure or access, and any other unlawful forms of processing. Personal information may be accessed by persons within our organization or our third-party service providers or third parties (such as law enforcement) who require such access to carry out the purposes indicated above, or who are otherwise permitted or required by applicable law.

Personal information we collect is maintained in Canada.

Although we have taken measures to protect our Platform, our computer systems, and personal information that we have collected from unauthorized use, access, disclosure, misuse, alteration, or destruction, no security measures can provide absolute protection. As a result, while we are committed to protecting your personal information, we cannot ensure or warrant the security of any information you provide to us.

11. Retention Period

We retain personal information that we collect as long as necessary to fulfill the purposes for which it was collected or to meet any legal requirements, including applicable limitation periods. We have retention standards which meet these requirements.

Most of the information we collect is retained for the life of your account until it is either deleted or has been inactive for a period of 2.5 years. After this, your account is closed. When your account is closed, we will either delete or render anonymous most of the associated information. We may keep certain records longer where permitted or required by law. For example, we may retain Financial Information for up to 10 years.

12. Your Legal Rights

You have rights under data protection laws in relation to your personal information. To help protect against fraudulent requests, and in compliance with the local data protection legislation, we may ask you for specific information to allow us to confirm that the person making the request is you or is authorized to access your information before granting your request. For example, we may require you to verify your identity before you access your personal information. You can exercise these rights free of charge by contacting us (please see Section 19: Company Contact Information of this Privacy Policy). Please be aware that there are exceptions and exemptions that apply to some of these rights, which we will apply in accordance with the data protection laws.

You have the right to:

Access your personal information. You have a right (subject to limited exceptions under relevant data protection laws) to request access to your personal information. Individuals may send requests to review their personal information contained in Vinted files to the Vinted privacy officer using the contact information provided in the below section, “Company Contact Information/Data Protection Officer”. To help us find the information, please give us as much information as possible about the type of personal data you would like to see.

Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no sufficient reason for us continuing to process it. You may also ask us to delete or remove your personal information where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully, or where we are required to erase your personal information to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your interests, rights, and freedoms, as permitted under the local data protection laws. You also have the right to object to our processing of your personal information for profiling and direct marketing purposes.

Request restriction of processing of your personal information This enables you to ask us to stop the processing of your personal information in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful, but you do not want us to erase it; (c) 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; or (d) you have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it, as allowed under the local data protection laws.

Request the transfer of your personal information to you or to a third party. We will provide to you, or a third party you have chosen, your personal information in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or if we used the information to carry out a contract with you.

Withdraw consent at any time if we are relying on consent to process your personal information, in accordance with the applicable data protection legislation and subject to applicable exceptions. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. For individuals subject to Canadian law, if you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us using the contact methods and details set out in the below section “Company Contact Information/Data Protection Officer”.
To unsubscribe from our marketing email and/or newsletters, you can also click the “unsubscribe” button at the bottom of the email newsletter. It may take up to 24 hours for this unsubscribe to take place.

Notwithstanding the general terms of this Privacy Policy, the collection, use, and disclosure of personal information may be made outside of the terms herein to the extent required by applicable law or with your consent. Vinted may disclose personal information to another entity purchasing (including, but not limited to, for diligence purposes prior to purchase) the assets of (or otherwise acquiring) Vinted provided that entity abides by this or a similar privacy policy.

13. Your Choices

You have a choice to receive marketing communications from us or not. If you do not want to receive direct marketing communications from us about the products, promotions, information, or services we offer, then you can select your choices by ticking the relevant boxes or exercising the unsubscribe mechanism provided in emails. You can also change your preferences at any time by contacting us by email at privacy@vinted.ca. You may opt out of our push notifications by visiting Settings on the Platform and changing relevant settings.

14. Changes To Our Privacy Policy

From time to time, we may make changes to our Privacy Policy. By accessing or using the Platform or by providing us with personal information after such changes, you consent to this Privacy Policy for the purposes of Canadian law only, as revised. We will inform you on our website when changes are made. Please periodically review this Privacy Policy so that you know what personal information we collect, how we use it, and with whom we may share it. The date of the most recent revision will be published on this page.

15. Children

Our website is not directed at children, and we do not intend to knowingly collect personal information from any child under thirteen (13). We will delete any personal information collected that we later determine to be from a user younger than the age of thirteen (13). Despite this, if you are the parent or legal guardian of a child under thirteen (13) who has provided us with personal information themselves, you may ask to review or delete this information by contacting us at privacy@vinted.ca

16. Complaints To The Regulator

You have the right to make a complaint at any time to a supervisory authority in your local jurisdiction. We would, however, appreciate the chance to deal with your concerns before you approach a supervisory authority, so please contact us in the first instance.

17. Links

The Platform may contain links to information at other websites. When you click on one of these links, you are moving to another website. Once you leave our Platform or are redirected to a third-party website or application, you are no longer governed by the Privacy Policy or our Terms and Conditions. We encourage you to read the privacy statements of these linked sites as their privacy policy may differ from ours. We are not responsible for the privacy practices or the content of any website(s) owned and operated by any third party.

18. Company Contact Information/Data Protection Officer

If you have any questions regarding this Privacy Policy or any Personal Information you have submitted to us, or if you would like to:

• access Personal Information that you have already provided to us so that you can correct or update it or request that it be deleted;
• exercise another of your rights; or
• submit a complaint, or report any violation of this Privacy Policy,

Please advise us by contacting privacy@vinted.ca. You may also contact our Data Protection Officer by writing to dpo@vinted.ca.