Privacy Policy

PRIVACY AND COOKIES POLICY OF DONEDEAL.IE

Contents

1. Introduction
2. How we collect information relating to the Website
3. Purposes for which we hold your information
4. Cookies
5. Disclosure of information to third parties and advertising
6. Security, transfer and control of personal data
7. Access to information and updating, verifying and deleting personal data
8. Changes to the Privacy and Cookies Policy
9. Links
10. Access by children
11. Questions or Comments

1. Introduction
Welcome to the Donedeal.ie website. Whether you are an advertiser or another user of this website, access to or use of this website (which includes our blog and all pages consisting of or containing the donedeal.ie address, for example, cars.donedeal.ie, blog.donedeal.ie, hello.donedeal.ie, and any page that is enabled for use by a mobile device) (the “Website” or “Donedeal.ie”) and the provision of our advertising services on the Website are subject to you accepting the Agreement (defined below).

The Agreement consists of the Terms and Conditions of Use, this Privacy and
Cookies Policy and all other policies (hello.donedeal.ie/legal-policies) appearing on the Website (the “Agreement”), all of which you should read carefully before you start to use the Website.

Please review these terms and conditions carefully. By accessing and using the Website, you confirm that you have read, understand and accept the Agreement and that you agree to abide by its terms and conditions each time you access and use the Website. If you do not agree to all of the Agreement you should not use the Website.

The Website is a website operated by Done Deal Limited (“we”, “us” or “our”). We are incorporated in Ireland under company number 419073 and our registered office is at Crescent House, Crescent Quay, Wexford, Y35 HE67. Our VAT number is IE6439073E.

The services which are made available on the Website by us from time to time will, amongst other things, allow you to create, publish and manage written advertisements (i) for goods for sale or for wanted goods; (ii) for the provision of services; (iii) to contact other users of the Website; (iv) to post comments on the DoneDeal blog; (v) to search our database for advertisements regarding a specific product, service, seller and/or in a specific location; (vi) to forward advertisements to people you know; (vii) to invite people you know to view the Website; (viii) to download or copy portions of information, data, text, sound, photographs, graphics, video, messages and other materials; and (ix) to view third party material and receive short service messages (SMS) as part of the SMS Service (defined below) and other items displayed on the Website (the “DoneDeal Service”).

We respect your right to privacy and aim to comply with our obligations under the Data Protection Acts of 1988 and 2003 currently in force in Ireland. The purpose of the Privacy and Cookies Policy is to outline how we deal with any personal data that we collect from you or that you provide to us while visiting the Website. We use your information only as set out in the Privacy and Cookies Policy. Naturally, if you are not satisfied with the Privacy and Cookies Policy you should not use the Website.

The Privacy and Cookies Policy (together with the Terms and Conditions of Use and any other documents referred to in them) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

By visiting the Website, you are accepting the terms of the Privacy and Cookies Policy and you permit the collection and use of your personal data as outlined in the Privacy and Cookies Policy.

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2. How we collect information relating to the Website
When registering or during your time as a user of the Website you will be asked to provide information to us. We will inform you at the time of collecting other information from you whether you must provide the information to use the Website or a particular DoneDeal Service or whether the provision of information requested by us is optional. We will inform you at the time of collecting information from you whether the information that you provide to us will be accessible to other users of the Website or by third parties so that you can decide whether to
provide the information to us.

We may collect and process the following data about you:
a. if you contact us, we may keep a record of that correspondence;
b. information that you submit when you register for the Website including your name, email address and telephone number;
c. information that you submit when you use the Website, for example, in response to a blog post, in a message to us, when posting an advertisement, entering a competition or through any website communication channel;
d. the functionality that you use through the Website including comments on our blog; or
e. details of transactions you carry out through the Website.

Such information is only collected from you if you voluntarily submit it to us, and is only kept for as long as it is required for us to provide you with the DoneDeal Service, to comply with law or our contractual obligations, or for reasonable record-keeping purposes.

‘Other Data’
Like most websites, we gather statistical and other analytical information collected on an aggregate basis of all visitors to the Website. This data comprises information that cannot be used to identify or contact you, such as demographic information regarding, for example, browser types, alphanumeric IDs, operating system, traffic data, location data, IP addresses, information regarding the volume and status of data transmission, click-through statistics, the name of the domain and host from which you access the Internet, the date and time you accesses portions of the Website, and other anonymous statistical data involving the use of the Website (“Other Data”). This is statistical data about our users’ browsing actions and patterns, and we do not use them to identify any individual, except if required by the law or for the purposes of fraud protection, IT security and credit risk reduction.

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3. Purposes for which we hold your information

Personal Data
Users of the DoneDeal Service use the Website to create, publish and manage advertisements for goods for sale and wanted goods and to write comments on the DoneDeal Blog (http://blog.donedeal.ie/). These advertisements and comments can then be accessed and read by other users of the Website. If you choose to place an advertisement using the DoneDeal Service, we will display a limited amount of personal information, such as your name and telephone number, so that interested parties may contact you. Additionally, we may use your email address to contact you on behalf of interested parties wishing to respond to your advertisements by email. We maintain a record of any conversations you have with other users of the Website through the DoneDeal safe mail service in connection with any advertisements. We
monitor and retain such information for the security and safety of our users. We may use your advertisements, and the advertisements that you view, to personalise the website and identify popular buy and sell sections. We may also display recently posted advertisements and recently sold goods to users of the Website.

We will process any personal data that you provide to us for the following purposes:

a. to provide you with the services you have ordered;
b. to carry out our obligations arising from any contracts entered into between you and us;
c. to deliver and maintain a high quality service and to improve and develop the services provided and the Website generally;
d. to allow you to access the Website and to participate in interactive features of our service, when you choose to do so;
e. to provide you with information, products or services that you request from us or that we feel may interest you, where you have consented to be contacted for such purposes;
f. to provide you with our newsletter through our partner Newsweaver, where you have subscribed to receive it (for further information please see http://www.newsweaver.com/PrivacyPolicy);
g. to contact you if required in connection with your order or to respond to any
communications you might send to us;
h. to inform you about changes to our service, our agreement with you or website that we believe will be of interest to you;
i. as the Website is being continually and actively developed we might contact you to get feedback on the service provided;
j. for the purposes of compiling statistics;
k. to determine whether you are in compliance with the Agreement and to impose sanctions where necessary;
l. as proof of identity before we disclose personal information to you that we hold about you (in order to establish that we are disclosing the personal information to you and not to someone holding themselves out to be you);
m. to process payments from or to you;
n. compare information for accuracy, and verify it with third parties;
o. for safety purposes (including maintaining a register of restricted users), to provide you with customer support and to resolve technical or other problems (where you have contacted us through our Customer Support (hello@donedeal.ie or support@donedeal.ie);
and
p. to determine whether you or other users are in compliance with our agreement relating to the DoneDeal Website, including the policies appearing on the Website.

If you avail of our services offered on the Website we may use your email address to send you updates or news regarding the DoneDeal Service. If you do not wish to receive emails of this type, please contact us.

Other Data
We use the Other Data gathered from visitors to the Website in an aggregate form to get a better understanding of where our users come from and to help us better design and organise the Website.

Clicking on DoneDeal emails, banners, hyperlinks or plugins
If you view or click on emails that we have sent you, or on banners, hyperlinks or plugins we have placed on the Website or other websites, both the fact that you have done so, as well as the address of the website you were on when you did so, will be information you voluntarily submit it to us that we will record. This is all non-personally identifiable information. We will use this information to track and analyse how successful those emails, banners, hyperlinks or plugins are in engaging with you. We are constantly innovating to improve the Website and the DoneDeal Service, which means we may create new ways to collect information from you. If we do, we will tell you about any new information we are collecting through updates to the Privacy and Cookies Policy.

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4. Cookies
The Website uses ‘cookies’. A cookie is a little piece of data stored by the browser on the hard drive of your computer, at the request of our server. Cookies contain information that is transferred to your computer’s hard drive. On revisiting the Website our computer server will recognise the cookie, giving us information about your last visit. We may use cookies (including flash cookies) to deliver content specific to your interests and to save your personal preferences so you do not have to re-enter them each time you connect to the Website. Our cookies are not available to other websites. Cookies help us to improve the DoneDeal Service and to deliver a better and more personalised service. They enable us:

a. to estimate our audience size and usage pattern;
b. to store information about your preferences, and so allow us to customise the Website according to your individual interests; and
c. to speed up your use of the DoneDeal Service and searches.; and
d. to target DoneDeal banners and advertisements to you when you are on certain other websites (this is often known as ‘Interest-Based Advertising’, ‘Online Behavioural Advertising’ or ‘Digital Marketing Re-targeting’) – we do this using a variety of digital marketing networks and ad exchanges, and advertising technologies like web beacons, pixels, ad tags, cookies, and mobile identifiers, and the banners and advertisements you will see will be based on your previous use of DoneDeal (for example, your DoneDeal search history, the content you read on DoneDeal, etc.) or on DoneDeal banners or ads you’ve previously clicked on.

You are always free to decline our cookies, if your browser permits, by activating the setting on your browser which allows you to refuse the setting of cookies. You are always free to ask your browser to indicate when a cookie is being sent. You can also delete cookie files from your computer at your discretion. Note that if you decline our cookies or ask for notification each time a cookie is being sent, this may affect your use of the Website. For information on how to control your cookies go to www.allaboutcookies.org.

We also participate in the Google Adsense programme and we allow Google and other third parties that participate in Google Adsense to use a type of cookie on our Website called the “DoubleClick DART”. Please note that Google is a third party and Section 5 below applies to Google’s use of cookies via the Website. Google uses cookies to serve ads to you on the Website. A persistent cookie gets entered by your web browser into the cookie folder on your computer’s hard drive. A persistent cookie remains in that cookie folder, which is maintained and governed by your web browser, after you close your browser program. The DoubleClick DART cookie is a
persistent cookie used by Google in the ads served on the websites of its partners, such as websites displaying AdSense ads or participating in Google certified ad networks. The DoubleClick DART cookie consists of the name of the domain that set the cookie (‘ad.doubleclick.net’), the lifetime of the cookie, and a ‘value’. DoubleClick’s DART technology used by Google generates a unique series of characters for the ‘value’ portion of the cookie.

When you visit a Google partner’s website and either view or click on an ad, a DoubleClick DART cookie may be dropped on your browser. The manner in which the DoubleClick DART cookie works enables Google and its partners to display ads to you on the Website and/or other sites on the Internet. You may opt out of the use of the DoubleClick DART used by Google. Instructions on how to opt-out are available from Google and are set out in this Google ad and content network privacy policy: http://www.google.com/policies/technologies/ads/ and more information regarding the “DoubleClick DART cookie” please visit: http://www.doubleclick.com/privacy/faq.aspx

We also work with Criteo to deliver advertisements by displaying products and/or personalized banners that you might be interested in, based on your recent browsing behaviour. We allow Criteo to place cookies on our Website and Criteo may also send its own cookies to your cookie file. The cookies allow Criteo to apply its personalised retargeting technology owned by Criteo (or members of its group) based on behavioural retargeting that allows Criteo to retarget users and display to them dynamic personalised banners or creative advertisements used to promote the Website or the DoneDeal Service (“Personalised Banners”).

Criteo only employs anonymous cookies for Personalised Banners, the cookie is a means by which information relating to internet activity is recorded. Criteo will collect and use this data in accordance with all applicable laws and regulations (including but not limited to laws governing privacy and data protection). The data collected and used by Criteo is at its sole discretion and will only contain non-personal data. This data will be anonymous and will not contain the name,
address, telephone number, email address or IP address of the visitors. Criteo’s privacy policy will be available at the following address http://www.criteo.com/en/solutions/privacy-policy. Criteo’s Privacy Policy includes information for users on how to opt-out of being cookie retargeted.

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5. Disclosure of information to third parties and advertising
We may provide Other Data to third parties, where such information is combined with similar information of other users of the Website. For example, we might provide third parties with aggregate anonymised information regarding the number of unique users who visit the Website, the demographic breakdown of our community users of the Website, or the activities that visitors to the Website engage in while on the DoneDeal Website. The third parties to whom we may provide this information may include potential or actual advertisers, providers of advertising
services (including website tracking services), commercial partners, sponsors, licensees, researchers and other similar parties.

We use third-party advertising companies to serve ads when you visit the Website. These companies may use information (not including your name, address, email address or telephone number) about your visits to this and other websites in order to provide advertisements about goods and services of interest to you on the Website or on other third party websites that you visit. Further information about the use of cookies in delivering these advertisements is contained in Section 3 above.

We may also use such aggregate anonymised information to help advertisers reach the kind of audience they want to target (for example, women in the southeast of Ireland) when displaying advertisements on the Website. We may make use of the personal data we have collected from you to enable us to comply with our advertisers’ wishes by displaying their advertisement to that target audience. By continuing to access, browse and use the Website, you will be deemed to have agreed to these practices.

We will not disclose your personal data to third parties unless you have consented to this disclosure or unless the third party is required to fulfil your order (in such circumstances, the third party is bound by similar data protection requirements). We will disclose your personal data if we believe in good faith that we are required to disclose it in order to comply with any applicable law, a summons, a search warrant, a court or regulatory order, or other statutory or regulatory requirement. For the avoidance of doubt, we reserve the right to provide access to any data contained on our database to An Garda Síochána where such data is required for the
prevention, detection or investigation of offences or the apprehending or prosecution of offenders. We may provide such data, where we receive a written authorisation in advance from a member of An Garda Síochána and on the strict understanding that the data is being provided solely for use by a member of An Garda Síochána for the purposes identified to us in advance. We also reserve the right to provide remote access to our database to authorised members of An Garda Síochána on an ongoing basis where such access, and the conditions of such access, have been agreed to by us in advance. Such access is provided in the interests of the safety and security of our users.

We reserve the right to disclose your personal data (such as your name, address and contact details) to authorised inspectors of the Irish Society for the Prevention of Cruelty to Animals (“ISPCA”), the Dublin Society for the Prevention of Cruelty (“DSPCA”) or the Ulster Society for the Prevention of Cruelty (“USPCA”) where we receive a written request from an authorised inspector for such data and we are satisfied that such a disclosure is in the legitimate interests of the body requesting the data for the purposes of the prevention of cruelty to animals. In such circumstances, we shall only disclose the personal data on the strict understanding that the personal data is being provided solely for use by authorised inspectors of the ISPCA, DSPCA or USPCA for the specific purposes identified to us in advance and may not be disclosed to any third parties without our prior approval. By continuing to access, browse and use the Website, you will be deemed to have agreed to the disclosure of your personal data on that basis.

Please note that if you post personal information on public sections of the Website then you are consenting to giving a third party user of the Website permission to use that data; we are not responsible for the manner in which any such third party may choose to use that data.

If you provide personal data to us, you understand and agree that we may disclose your personal data to the following third parties:

a. to our hosting provider which acts as our agent;
b. to our payment processing service providers;
c. if you have indicated at any time while using the DoneDeal Service that you are satisfied to receive information or promotions from selected third parties about goods and services which may be of interest to you, you consent to us sending you such offers or information. If you wish to opt out of receiving such offers, please contact us;
d. any member of our group of companies, which means our subsidiaries, our ultimate holding company and its subsidiaries;
e. to a prospective seller, shareholder or buyer of some or all of the shares in Done Deal Limited, the Website and/or any of our businesses;
f. to a third party if we are under a duty to disclose or share your personal data with that third party in order to comply with any legal obligation, or in order to enforce or apply the Agreement with you or any other relevant agreements, or to protect the rights, property or safety of Done Deal Limited, the Website and/or any of our businesses, our customers or others. This includes exchanging information with third parties for the purposes of fraud protection, IT security and credit risk reduction and statutory or other investigative bodies, where such bodies have the statutory authority to request such personal data or you have given your consent for us to disclose your personal data in this manner.

We will notify you when information about you may be provided to third parties in ways other than explained in the Privacy and Cookies Policy and you will have the option to prevent such information sharing at the time that we notify you.

We reserve the right to transfer information (including your personal data) to a third party in the event of a sale, merger, liquidation, receivership, purchase or transfer of all or substantially all of the business or assets related to the Website or all or part of Done Deal Limited provided that the third party agrees to adhere to the terms of the Privacy and Cookies Policy.

You agree that you have access to other users’ personal information when you use the Website, or as a result of any related communication or transaction. You agree that you will only use another user’s personal information to contact the person for the purposes of buying or selling the goods or services to which the users’ personal information is connected. If the other user subsequently agrees that you may use their personal information for any other purpose then that is a matter for you and the other person to agree. Unless you have the other Website user’s express permission or our express written permission you may not disclose or contact another user for any purpose other than to conduct transactions for goods or services advertised on the Website.

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6. Security, transfer and control of personal data
We will take all reasonable steps (including appropriate technical and organisational measures) to protect your personal data that we hold in accordance with the Privacy and Cookies Policy. However, the nature of the internet is such that we cannot guarantee or warrant the security of any information you transmit to us via the internet. No data transmission over the Internet can be guaranteed to be 100% secure and any transmission is at your own risk. You acknowledge that we are not responsible for any intercepted information sent via the internet and you hereby
release us from any and all claims arising out of and related to the use of intercepted information in any unauthorised manner.

If we have given you (or where you have chosen) a password which enables you to access certain parts of the Website, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

You should be aware that when you voluntarily disclose personally identifiable information and agree to make that information public on the Website (e.g., name, telephone number) via advertisements, blog postings, tweets or in other areas of the Website, then that information, along with any substantive information disclosed in your communication, can be collected, correlated and used by third parties. These third parties or other website users may use your information to send you unsolicited messages. Such activities are beyond our control. Please do not post any personal information on the Website that you wish to keep private.

It may be necessary to transfer your personal information to other group companies or service providers located in countries outside of the European Economic Area (EEA), including but not limited to the United States. This may happen where our servers or suppliers and service providers are based outside of the EEA or where you use our services and products while visiting countries outside of the EEA. The data protection and other laws of these countries may not be as comprehensive as those in Ireland or the EU but in these instances we will take steps to ensure that your privacy rights are respected. You agree that we may transfer your personal data
on that basis.

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7. Access to information and updating, verifying and deleting personal data
At any time, you can make a written request to have access to all the personal data that we hold about you. You may inform us of any changes in your personal data and, in accordance with our obligations under the Data Protection Acts of 1988 and 2003, we will update or delete your personal data accordingly. To make this request or to have your personal data updated, amended or removed from our database, please use contact us here and we will provide this information to you and may request a small administrative charge.

8. Changes to the Privacy and Cookies Policy
Any changes we may make to the Privacy and Cookies Policy in the future will be posted on this page and may be, where we consider it appropriate, notified to you by e-mail. You should visit this page periodically to review any changes to the Privacy and Cookies Policy.

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9. Links
When you pay us you will leave the Website and you will instruct one of our payment processing service providers (which include PayPal and various mobile telephone companies) to make a payment to us on your behalf. Please note that these providers have their own privacy policies and terms of use and that we do not accept any responsibility or liability for these policies, their terms or for the activities on those websites.

We may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates as well as third party websites to which we have no affiliation. Users of the Website may post links to other websites also. If you follow a link to any of these websites, please note that these websites have their own privacy policies and terms of use and that we do not accept any responsibility or liability for these policies or for the activities on those websites.

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10. Access by children
If you are aged 18 or under, you must get one of your parent's or a guardian’s permission before providing personal data to us by using the Website. If you do not have this permission, you should not use the Website. We may ask you at any time to confirm and produce this permission in writing.

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11. Questions or Comments
If you have any questions, concerns, comments or complaints about the Privacy and Cookies Policy and/or our collection or use of personal information, or if you wish us to stop processing your personal information for any particular purpose or purposes, then please contact us at support@donedeal.ie, or send a letter to Done Deal Limited, Crescent House, Crescent Quay, Wexford,Y35 HE67, Ireland.

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