SEN Ltd. Privacy Policy

SEN Ltd is committed to your privacy. This privacy notice explains our collection, use, disclosure, retention and protection of your personal information.

Scope

This privacy notice applies to any SEN Ltd website, application, service or tool (collectively “Services”) where this privacy notice is referenced, regardless of how you access or use them, including through mobile devices.

Personal information we collect

What is Personal Information?

Personal Information is information relating to an identified or identifiable natural person. An identifiable natural person is one who can be identified, directly or indirectly, by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social
identity of that natural person.

We do not consider personal information to include information that has been anonymised or aggregated so that it can no longer be used to identify a specific natural person, whether in combination with other information or otherwise.

We collect personal information from you when you use our Services.

How we use your personal information

We use your personal information to provide and improve our Services, provide you with a personalised experience on our sites, contact you about your account and our Services, provide you customer service, provide you with personalised advertising and marketing, and to detect, prevent, mitigate and investigate fraudulent or illegal activities.

Your choices about how we use your personal information

You have choices about how we use your personal information to communicate with you, to send you marketing information, how we provide you with customised and relevant advertising, and whether you want to stay signed into your account.

Ways you can access, control, and correct your personal information

We respect your right to access, correct, request deletion or request restriction of our usage of your personal information as required by applicable law. We also take steps to ensure that the personal information we collect is accurate and up to date. You have the right to know what personal information we maintain about you.

We will provide you with a copy of your personal information in a structured, commonly used and
machine readable format on request

If your personal information is incorrect or incomplete, you have the right to ask us to update it

You have the right to object to our processing of your personal information

You can also ask us to delete or restrict how we use your personal information, but this right is determined by applicable law and may impact your access to some of our Services

How we might share your personal information

We may disclose your personal information to other members of the SEN Ltd corporate family or to third parties. This disclosure may be required for us to provide you access to our Services, to comply with our legal obligations, to enforce our User Agreement, to facilitate our marketing and advertising activities, or to prevent, detect, mitigate, and investigate fraudulent or illegal activities related to our Services.

We attempt to minimise the amount of personal information we disclose to what is directly relevant and necessary to accomplish the specified purpose. We do not sell, rent or otherwise disclose your personal information to third parties for their marketing and advertising purposes without your consent.

How long we keep your personal information

We retain your personal information for as long as necessary to provide the Services you have requested, or for other essential purposes such as complying with our legal obligations, resolving
disputes, and enforcing our policies.

Cookies & Similar Technologies

When you visit or interact with our sites, services, applications, tools or messaging, we or our authorised service providers may use cookies and other similar technologies to help provide you with a better, faster and safer experience, and for advertising and marketing purposes. You can read our full User Cookie Notice for more information.

How do we protect your Personal Information

We protect your personal information using technical and administrative security measures to reduce the risks of loss, misuse, unauthorised access, disclosure and alteration. Some of the safeguards we use are firewalls and data encryption, physical access controls to our data centres, and information access authorisation controls. For more information about staying safe while buying and selling online, or to report an issue with your account please visit our Security Centre.

Global Privacy Standards

We have established a set of global privacy standards for all SEN Ltd. companies known as our Binding Corporate Rules (BCRs). They are our commitment to protect your personal information and honour our privacy obligations within our SEN Ltd corporate family. More information about our BCRs and our global privacy standards is available at our SEN Ltd Privacy Centre.

Data Controllers and Data Protection Officers

Learn more about who is your data controller, and is responsible for the collection, use, disclosure, retention and protection of your personal information in accordance with our global privacy
standards, this privacy notice, as well as any applicable national laws.

Other important Privacy Information

This section describes some additional privacy information related to your use of our Services that you may find important.

Contact Us

If you have a question or a complaint about this privacy notice, our global privacy standards, or our information handling practices, you can reach the Global Privacy Office in writing at: SEN Ltd. 20, Brookalnds Road, Riseley, Beds. MK44 1EE.

Your right to file complaints with a data protection supervisory authority remains unaffected.

Scope

This privacy notice also applies to the provision of SEN Ltd services through any SEN Ltd partner’s website, application, service or tool where it is referenced and where your listings and their content are published or advertised in accordance with the terms of this privacy notice.

We may amend this privacy notice at any time by posting the amended version on this site including the effective date of the amended version. We will announce any material changes to this privacy notice through the SEN Ltd Message Centre and/or via email.

Personal information we collect

We collect personal information from you and any devices (including mobile devices) you use when you: use our Services, register for an account with us, provide us information on a web form, update or add information to your account, participate in a community board discussion chat, or when you otherwise correspond with us.

Some of this personal information, such as a way to identify you, is necessary to enter into our User Agreement. The provision of all other personal information is voluntary, but may be necessary in order to use our Services, such as the bidding, buying or selling information needed to conclude a transaction.

Financial information (such as credit card or bank account numbers) in connection with a transaction.

Postage, billing and other information used to purchase or send an item, as well as, where postal services are provided through one of our programs, information required to clear customs (such as
Tax ID or other identification numbers) and relevant postage information (such as tracking numbers and tracking updates).

In some instances, when you use our Services, you may provide age, gender, interests and favourites.

You may also provide us other information through a web form, by updating or adding information to your account, through your participation in community discussions, member-to-member communications, chats, dispute resolution or when you otherwise communicate with us regarding our Services.

Additional information we are required or authorised by applicable national laws to collect and process in order to authenticate or identify you or to verify the information we have collected.

Personal information we may collect using cookies and similar technologies

We use cookies, web beacons, unique identifiers and similar technologies to collect information about the pages you view, the links you click and other actions you take when using our Services,
within our advertising or email content.

For more information about our use of these technologies, and how to control them, see Cookies
and Similar Technologies.

Personal information collected from other sources

We supplement the personal information we collect directly with information collected from third parties and add it to your account information. For example, we collect and use demographic and
other information that is publicly available in an applicable jurisdiction, additional contact information, credit check information, and information from credit bureaus, as allowed by applicable
national laws

Social Media.

We allow you to share information with social media sites, or use social media sites to create your account or to connect your account with the respective social media site. Those social media sites may give us automatic access to certain personal information retained by them about you (e.g., content viewed by you, content liked by you and information about the advertisements you have been shown or have clicked on, etc.). If you provide us with access to any site with video content, then you agree that we can share your video viewing with, or obtain information about your video viewing from, third-party social media sites for at least two years or until you withdraw authorisation or connection to the social media site. You control the personal information you allow us to have access to through the privacy settings on the applicable social media site and the permissions you give us when you grant us access to the personal information retained by the respective social media site about you. By associating an account managed by a social media site with your account and authorising us to have access to this information, you agree that we can collect, use and retain the information provided by these social media sites in accordance with this privacy notice. We may also use plug-ins or other technologies from various social media sites. If you click on a link provided via a social media plug in, you are voluntarily establishing a connection with that respective social media site.

If you give us personal information about someone else, you must do so only with that person’s authorisation. You should inform them how we collect, use, disclose, and retain their personal
information according to our privacy notice.

How we use your personal information

We use the personal information we collect from you for a range of different business purposes and according to different legal bases of processing. The following is a summary of how and according to which legal bases we use your personal information.

We use your personal information to fulfil a contract with you and provide you with our Services, to comply with our legal obligation, protect your vital interest, or as may be required for the public
good. This includes:

To provide payment processing and account management, operate, measure and improve our

Services, keep our Services safe, secure and operational, and customise site content that includes items and services that you may like in response to actions that you take.

To contact you regarding your account, to troubleshoot problems with your account, to resolve a dispute, to collect fees or monies owed or as otherwise necessary to provide you customer service.

When contacting you for such purposes as outlined above, we may contact you via email, telephone,

SMS/text messages, postal mail and via mobile push notifications.

When contacting you via telephone, to ensure efficiency, we may use autodialed or pre-recorded calls and text messages as described in our User Agreement and as authorised by applicable law.

Message and data rates may apply.

To provide other services requested by you as described when we collect the information.

We use general location information to provide you with location based services (such as advertising, search results and other personalised content).

To prevent, detect, mitigate, and investigate fraud, security breaches or other potentially prohibited
or illegal activities.

To enforce our User Agreement, this privacy notice, or other policies, and to monitor restrictions on offers to buy or sell outside of SEN Ltd and member-to-member communications for violations of our policies or applicable laws.

We use your personal information to pursue our legitimate interests where your rights and freedoms do not outweigh these interests. We have implemented controls to balance our interests with your rights. This includes to:

Improve our Services, for example by reviewing information associated with stalled or crashed pages experienced by users allowing us to identify and fix problems and give you a better experience.

Personalise, measure and improve our advertising based on your advertising customisation
preferences.

Contact you via email or postal mail in order to offer you coupons, discounts and special promotions, poll your opinions through surveys or questionnaires and inform you about our Services, as authorised by applicable law.

Contact you about public policy matters, or other current events, related to your ability to use our Services. This could include an invitation to join a petition, letter writing, call or other sort of public

policy related campaigns.

Deliver targeted marketing, service updates and promotional offers based on your communication
preferences.

Measure the performance of our email marketing campaigns (e.g. by analysing open and click rates).

Measure sellers’ performance (e.g. by using shipment tracking information that sellers and shipping providers send or provide through SEN Ltd).

Monitor and improve the information security of our site and mobile applications.

With your consent, we may use your personal information to:

Provide you with marketing via telephone calls, SMS/text.

Provide you with marketing from other SEN Ltd corporate family members.

Provide you with marketing from third parties.

Customise third party advertising you might see on third party websites.

Use your precise geo-location to provide location based services.

Use your sensitive personal information to facilitate transactions in certain categories.

You have the right to withdraw your consent at any time.

We may use technologies considered automated decision making or profiling. We will not make automated-decisions about you that would significantly affect you, unless such a decision is necessary as part of a contract we have with you, we have your consent, or we are required by law to use such technology.

Your choices about how we use your personal information

Marketing

If you do not wish to receive marketing communications from us, you can contact us indicating your communication preferences using the method described within the direct communication from us or contact us as described in the Contact Us section below. Keep in mind, we do not sell, rent or otherwise disclose your personal information to third parties for their marketing purposes without your consent.

Advertising

If you do not wish to participate in our advertising personalisation programs, you can opt-out by following the directions provided within the applicable advertisement, or through the programs
described in our User Cookie Notice. The effect of an opt-out will be to stop personalised advertising, but it will still allow the collection of personal information as otherwise described in this
privacy notice. We do not allow third parties to track or collect your personal information on our sites for their own advertising purposes, without your consent.

Staying Signed in

When you sign in to your account on our Services, we give you the option to stay signed in to your account for certain amount of time. If you are using a public or shared computer, we encourage you not to choose to stay signed in. You or any other user of the computer/browser you signed in on will be able to view and access most parts of your account and take certain specific actions during this signed in period without any further authorisation. The specific actions and account activities that you or any other user of this computer/browser may take include:

Ways you can access, control and correct your personal informationAccess, correction and deletion of your personal information

You can see, review and change most of your personal information by signing in to your account or contacting SEN Ltd directly. Please, update your personal information immediately if it changes or is inaccurate. Keep in mind, once you make a public posting, you may not be able to change or remove it.

We will honour any statutory right you might have to access, modify or erase your personal information. To request access and to find out whether any fees may apply, if permitted by applicable national laws, please contact us following the instructions in the Contact Us section below. Where you have a statutory right to request access or request the modification or erasure of your personal information, we can still withhold that access or decline to modify or erase your personal information in some cases in accordance with applicable national laws.

If you request that we stop processing some or all of your personal information or you withdraw (where applicable) your consent for our use or disclosure of your personal information for purposes set out in this privacy notice, we might not be able to provide you all of the Services and customer support offered to our users and authorised under this privacy notice and our User Agreement.

Upon your request, we will close your account and remove your personal information from view as soon as reasonably possible, based on your account activity and in accordance with applicable
national laws.

How we might share your personal information

We may disclose your personal information to the following parties for the following purposes:

SEN Ltd corporate family members, who may use it to:

Provide joint content and services (like registration, transactions and customer support)

Help detect, investigate, mitigate and prevent potentially fraudulent and illegal acts, violations of our User Agreement and data security breaches
Provide you personalised advertising

Improve their products, sites, applications, services, tools and marketing communications.

Members of our SEN Ltd corporate family will use your personal information to send you marketing communications only if you have consented to receive such communications from them or if
otherwise permitted by the law.

Service Providers and financial institutions partners as follows:

Third party service providers who help us to provide our Services, payment processing services, assist us in providing customised advertising, to assist us with the prevention, detection, mitigation,
and investigation of potentially illegal acts, violations of our User Agreement, fraud and/or security breaches, bill collection, affiliate and rewards programs, co-branded credit cards and other business operations.

Third party financial institutions with whom we partner to offer financial products to you, for them to provide joint content and services (such as, registration, transactions and customer support).

These third party financial institution partners will use your personal information to send you marketing communications only if you have requested their services.

Third party postage providers (e.g., DHL, UPS, USPS, etc.) with whom we share delivery address, contact information and shipment tracking information for the purposes of facilitating the delivery of items purchased and other delivery related communications.

Third party providers of websites, applications, services and tools that we cooperate with so that they can publish or advertise your listings and their content on their websites or in their applications, services and tools. If we transfer personal information along with the content of your listings to third party providers, this will be solely on the basis of an agreement limiting use by the third party provider of such personal information to processing necessary to fulfil their contract with us and obligating the third party provider to take security measures with regard to such data.

Third party providers are not permitted to sell, lease or in any other way transfer the personal information included in your listings to third parties.

Law enforcement, legal proceedings and as authorised by law

To comply with our legal requirements, enforce our User Agreement, respond to claims that a listing or other content violates the rights of others, or protect anyone’s rights, property or safety.

To law enforcement or governmental agencies, or authorised third-parties, in response to a verified request or legal process relating to a criminal investigation or alleged or suspected illegal activity or any other activity that exposes us, you, or any other of our users to legal liability. We will only disclose information we deem relevant to the investigation or inquiry, such as name, city, state, postcode, telephone number, email address, User ID history, IP address, fraud complaints, bidding and listing history.

To credit agencies or bureaus as authorised by applicable national laws (e.g. information on late or
missed payments or other defaults on your account that may be reflected in your credit report or
file).

To third parties involved in a legal proceeding, if they provide us with a subpoena, court order or substantially similar legal basis, or we otherwise believe in good faith that the disclosure of information is necessary to prevent imminent physical harm or financial loss or to report suspected illegal activity.

To provide customer services, including to help service your account or resolve disputes (e.g., billing or transactional disputes)

To facilitate the processing of payment cards when you pay within our Services with a payment card and we use PayPal to process your payment

To facilitate delivery and related services for purchases you made using PayPal

Change of Ownership

If we are subject to a merger or acquisition with/by another company, we may share information with them in accordance with our global privacy standards. Should such an event occur, we will require that the new combined entity follow this privacy notice with respect to your personal information. If we intend to handle your personal information for any purposes not covered in this privacy notice, you will receive prior notification of the processing of your personal information for the new purposes.

How long we keep your personal information

Our specific retention times for personal information are documented in our regional records retention schedules. How long we retain personal information can vary significantly based on
context of the Services we provide and on our legal obligations. The following factors typically influence retention periods:

How long is the personal information needed to provide our Services? This includes such things as maintaining and improving the performance of our products, keeping our systems secure, and
maintaining appropriate business and financial records. This is the general rule that establishes the baseline for most of our data retention periods.

Is the personal information sensitive? If so, a shortened retention time is generally appropriate.

Have you provided consent for a longer retention period? If so, we will retain data in accordance
with your consent.

Are we subject to a legal, contractual, or similar obligation to retain your personal information?

Examples can include mandatory data retention laws in the applicable jurisdiction, government orders to preserve data relevant to an investigation, or personal information retained for the
purposes of litigation.

After it is no longer necessary for us to retain your personal information, we will dispose of it in a secure manner according to our data retention and deletion policies.

Data Controllers and Data Protection Officers

If you reside in the United Kingdom you are contracting with SEN Ltd. 20, Brooklands Road, Riseley Beds.

The company you are contracting with is your data controller, and is responsible for the collection, use, disclosure, retention and protection of your personal information in accordance with our global privacy standards, this privacy notice, as well as any applicable national laws.

Your data controller may transfer data to other members of the SEN Ltd corporate family who have signed our BCRs, as described in this privacy notice.

We may process and retain your personal information on our servers in the U.S. and elsewhere in the world where our data centres are located.

Where we have a legal obligation to do so, we have appointed data protection officers (DPOs) to be responsible for the privacy programme at each of the respective data controllers. You can contact any of our DPOs via the Contact Us information detailed below in this privacy notice.

Other important privacy information

To help protect your privacy, we allow only limited access to other users’ contact, postage and financial information as necessary to facilitate your transactions and collect payments.

Unwanted or threatening email

We do not tolerate abuse of our Services. You do not have permission to add other users to your mailing list (email or postal), call, or send him/her text messages for commercial purposes, even if
this user purchased something from you, unless the user has given his/her explicit consent. Sending unwanted or threatening email and text messages is against our User Agreement.

Communication tools

We may scan messages automatically and check for spam, viruses, phishing and other malicious activity, illegal or prohibited content or violations of our User Agreement, this privacy notice or our
other policies.

Children’s Privacy

Our websites are general audience websites and not intended for children. We do not knowingly collect personal information from users deemed to be children under their respective national laws.

Third Party Privacy Practices

This privacy notice addresses only our use and handling of personal information we collect from you in connection with providing you our Services. If you disclose your information to a third party, or visit a third party website via a link from our Services, their privacy notices and practices will apply to any personal information you provide to them or they collect from you.

We cannot guarantee the privacy or security of your personal information once you provide it to a third party and we encourage you to evaluate the privacy and security policies of your trading partner before entering into a transaction and choosing to share your personal information. This is true even where the third parties to whom you disclose personal information are bidders, buyers or sellers on our site.

Contact Customer Service

If you’re looking for more help or have a question to ask, contact us.