Effective Date: 29/09/24
This is our Privacy Policy. Please read it to find out more about who we are and what we do with your data. Let us know if you need help in understanding what it means for you. We are KANTECH LIMITED (Sefer Swap, SeferSwap, we, our or us) and we operate Sefer Swap website. Our address is Anglo Dal House, 5 Spring Villa Park, Edgware, Middlesex, United Kingdom, HA8 7EB We want to explain here how we use personal information about you (your data). Sefer Swap can be accesed by our website (the Service). When you use our Service, we will collect and use data about you. We have written this Privacy Policy to explain what data we collect, how we use it and what choices you have in relation to your data. We also use cookies, which are files that are stored on your device and access information. You can find out more about how and why we use cookies in our Cookies and Similar Technologies Policy.
We collect your data when you register to Sefer Swap and when you are using our Service. We use your data so that you can use the Service and, from time to time, we may use your data to comply with our legal obligations or for other legitimate reasons. There may also be times when we ask for your consent to use your data.
We collect data from you when you use our Service or when you provide it to us, for example when you:
We need a legal reason to collect and use your data. The main reason we use your data is to perform our contract (the Terms of Service) with you, so that you can use our Service.
We may also collect and use your data if we:
When you open your account, you will provide us with contact information like your name, email address, telephone number, Shull name, Rabbi name, and postcode. We use this contact information so we can get in touch with you:
If you deal with a Sefer Swap receiver (Buyer) or giver (Seller), we will share your contact details with them. This is a necessary part of giving and receiving and using our Service.
We also collect your date of birth when you create an account, which we use for our legitimate interests in verifying your details, understanding the age range of our users, and providing age-appropriate service and support to our users.
Where we cannot confirm your identity using other information that we hold about you or that you have provided to us, we may need you to send us copies of identification documents, which we will use together with your contact information. We use this data for our legitimate interest of verifying your details and helping prevent fraudulent access to the Service or use of your account.
If you contact us, for example by email, phone, post or complete an online form, we will collect the comments and opinions you communicate to us.
We also collect data you provide to us, which includes comments and opinions, when you:
We use comments and opinions where we have a legitimate interest to address any issues, concerns, or questions, as well as to make our Service better for you and other users.
If you complete forms or surveys, participate in research interviews or focus groups, enter competitions or promotions, or post on community boards or other message areas, we use your data, including any comments and opinions, to help determine which products or services you might be interested in and to help send you marketing messages about them.
We collect data you provide to us when you enter a competition or participate in a promotion. We use this data for the purposes of running the competition or promotion you have entered.
This data may include your contact details, such as your name and any other information you provide as part of the competition entry or promotion, as well as any comments or opinions you provide.
If you win a competition or promotion, we have a legitimate interest in using your data in publicity relating to the competition or promotion. This may include your name, username, photographs, likeness, voice, opinions and biographical information.
We collect your content, which may feature images containing your personal data, when you voluntarily submit it to us when using the Service. We may use your content and/or images in our online and offline marketing campaigns, which may be conducted via third parties on our behalf, subject to the licence you give us to use such images and content as set out in our Terms of Service.
We process your personal data for these purposes either on the basis of our legitimate interests in order to promote Sefer Swap in our publicity and marketing campaigns or with your consent.
“In-app”: Refers to actions or interactions performed within our mobile application or website.
If you send in-app messages or comments, or provide item descriptions, we may access, store and review these:
When you create an account and log in, we collect your username, password and information about your device. It is in our legitimate interest to use this data to keep your account secure. You should keep your username and password safe and not share them with anyone else. You are responsible for actions that are taken using your username and password. If you think someone has access to your password or account, you should tell us immediately and change your password.
We will collect information about the device you are using to use the Service. This includes a computer, smartphone or any other electronic device that you can access the Service from. This can include the type of device, unique device identifying number (such as Android ID, Apple ID or browser fingerprint), what operating system is used on the device, what browsers and applications are used to connect to our Service by your device, your internet service provider or mobile network, your IP address and your device telephone number (if it has one).
If you are logged into a registered account, this information may be associated with you.
We use this device information so that the way the Service is presented and works is suitable for your device. We also use this device information for our legitimate interest of ensuring any users that have been banned are not able to access the Service by creating a new account, as well as detecting and analysing potentially suspicious user activity in order to protect our Service and other users of our Service.
Sometimes other users of our Service may provide data about you, such as, feedback and messages they send to you. Other users can also share information about an item they have received from you on other social networks that link to Sefer Swap. However, this is only information that is already public.
If users want to invite you to use our Service or share information about our Service, we will use data they provide to us about you to help them to do this. We will only do this if they have told us that you have agreed they can communicate with you in this way.
We use data about fraudulent or criminal activity which is related to your use of our Service. We use this for our legitimate interests in detecting and preventing fraud and crime, and to comply with our legal obligations.
So that we can provide the Service to you on the basis of our Terms of Service, we may monitor the data you provide when using the Service to detect and respond to potential fraud, abuse or breaches of our Terms of Service, including listings (description, images), messages, user profile information, phone number, location, linked account information and/or device ID. This can lead to various enforcement actions, from issuing an account warning and content removal to permanently banning an account from the platform.
We will use data we collect to:
We also use your data to resolve disputes between users, provide support to users, to troubleshoot and help solve problems, and to enforce our Terms of Service.
We may collect sensitive data, such as information about your religious beliefs, racial or ethnic origin, physical and mental health details, or sexual orientation.
We collect and use such data when we have your express consent, for example when you complete a survey. With your permission, we may feature you or your profile in publicity and marketing campaigns. Providing your sensitive data for these purposes is entirely voluntary.
We may also collect and use such data to comply with government regulations and guidance. If you put your own sensitive data on the Service (including where you upload or add information to your profile or communications you send to other users), you consent to us processing this sensitive data as described in our Terms of Service.
We may send you emails about listings and services we think you will like, but you can always tell us if you don’t want to receive these anymore.
If you give us your permission, we will send you push notifications and share your email address with third parties you have told us you are happy to hear from about their products and services. When you give us your permission, you can always tell us later if you have changed your mind.
Email: We may contact you by email about our listings and services. If you don’t want us to contact you by email with marketing messages, you can unsubscribe from our marketing emails by replying to the email we send you.
We may use your data to show you advertisements, both on the Service and on other websites, for products we think you will be interested in. This usually involves using Cookies, which are small files stored on your device when you visit a website, or similar technologies. You can find out more in our Cookies and Similar Technologies Policy.
We, and advertising partners we work with, may show you advertising on the Service or other websites by using your data to show you adverts for products we think you will like. These adverts may be on the Service, or on other websites or apps (where our partner has advertising space there).
This works by collecting data about how you use the Service and other web pages, as well as content and ads that you, or others using your device, interact with, visit or view. This information may also include location and the IP address of the device you are using to access the Service.
We may share this type of data with our advertising partners to help measure how successful our advertising has been.
We may share certain information with third party advertising platforms such as Facebook, TikTok, Snapchat, and Google to enable us to better target our advertising on those third party platforms to users of our Service who are also users on those platforms, or to individuals on those platforms that may be similar to users of our Service.
In addition, we may also use information we collect via the Sefer Swap website to create “audience groups” for the purposes of our advertising on third party platforms. In those circumstances, we may share certain information with third party platform providers which allows us to better target our advertising to users on those third party platforms. Any third party platforms will also have their own privacy policies which you should read.
Cookies and similar technologies are usually used to provide this type of advertising. You can find out more about what Cookies we use and why, and how to manage your Cookies settings in our Cookies and Similar Technologies Policy.
When you use our Service, some of your data is public and can be seen by others. This includes your profile information, such as your full name, first 3 digits of your postcode, country, information about items you list to giveaway, and some things you do on our Service such as giving or receiving items. This information is public to allow receivers and givers to use our Service, including to allow receivers and givers to make informed decisions.
In general, we don’t give user email addresses to other users. However, we may pass your email address (as well as other details) to a giver where you have received an item to the extent necessary to fulfil your order.
Please ensure you take all appropriate precautions when chatting with others on SeferSwap before divulging any personal details. SeferSwap is not responsible for any negative occurrences or outcomes from users sharing personal details.
We may need to share your data, for example with other companies that are in our group of companies, to third parties that provide us with services or for legal reasons.
We may share your data with:
Information that cannot identify you: We don’t disclose data that could be used to identify you to anyone else, except as mentioned in this Privacy Policy. We may provide third parties with aggregated statistical information and analytics information about users of our Service, but if we do we make sure no one can be identified from this information before we disclose it.
We will only keep your data for as long as we need it. If you have an account, this means we keep your data when your account is active. If your account is deactivated, we also keep your data for a reasonable period of time afterwards. We may also keep your data for legal or technical reasons.
We only keep your data for as long as we need it and for the purpose it was collected for. This includes when we need to keep your data to comply with any legal, compliance, accounting or reporting requirements, or for the purposes of fraud prevention.
When we decide how long we need to keep your data for, we take into account the amount, nature, and sensitivity of the data, the potential risk of harm from unauthorised use or disclosure of your data, the purposes we use your data for and whether we can achieve those purposes another way, and applicable legal requirements.
If you have an account with us, we will keep your data for as long as your account is active. If you deactivate your account, or we deactivate it because you have been inactive for a long time, your data will be kept for a period of time after your account has been deactivated.
After your account has been deactivated, we may also need to keep your data for legal or technical reasons (including back-up systems), for example to retain proof of transactions, so we can enforce our rights, and enable the other party to a transaction to access records of past purchases or sales. Following this period we will either delete the data or change it to a form that does not identify you, with or without notice to you.
If your account is deactivated, some of your data may persist and appear within the Service, for example where your data has been shared by other users of our Service. If your account has been banned, we will retain certain data about you to prevent you from opening a new account, in order to protect us, our users and the safety of our Service. For details of retention periods for other aspects of your data, please contact us at [email protected].
We may store information, which may include your data, locally on your device using Cookies and other methods. For more information on how long Cookies are stored, please see our Cookies and Similar Technologies Policy.
Your data may be transferred to a country outside of the country where you live. Not all countries have the same standards of data protection. However, where we do transfer your data to another country, we will only do this where we have appropriate measures in place to protect your data.
The data we collect may be transferred to and stored in countries outside of the country where you live, including outside of the UK, European Economic Area (EEA) or Australia. This includes to companies within our group and to third party service providers and moderators. Your data may be processed by staff (who work for us or one of our suppliers) and other users of the Service that are outside of the UK, EEA or Australia. This may happen to fulfil a purchase, process payment details, provide support and verification services and enable us to run the Service.
Not all countries offer the same level of protection of data and may be less protective than the UK or EEA. However, we will only transfer your data to countries that are subject to an adequacy decision issued by the European Commission, or where the entity is bound by an appropriate data transfer agreement as deemed adequate by the European Commission, known as the Standard Contractual Clauses or SCC. You can request a copy of our SCC using the contact details in Get in Touch.
Where we use service providers in the US, we may transfer data to them if they have agreed to the Standard Contractual Clauses, which requires them to provide similar protection to personal data shared between the EEA (and the UK) and the US.
We will take all reasonable steps to ensure that your data is treated securely and in accordance with this Privacy Policy and any relevant privacy laws.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your data, we cannot guarantee the security of your data transmitted through our Service and any transmission is at your own risk. Once we have received your data, we will use strict procedures and security features to try to prevent unauthorised access.
You have certain rights relating to the data we hold about you. If you make a request we may not be required to comply with it, but if that happens we will explain why. If you want to exercise any of your rights you can contact us using the details set out in Get in Touch.
To exercise any of your rights, or if you have any questions about your rights, please contact us by using the details set out in Get in Touch. We may need to request specific information from you when you exercise your rights to confirm your identity and to speed up our response. We may not be able to fulfil your request if we are not able to identify you.
You can exercise these rights free of charge. However, in some circumstances we may be entitled to charge a reasonable fee, or refuse to comply with your request where we are permitted under law, for example if your request is unfounded, repetitive or excessive.
We try to respond to all valid requests within one month (once we have been able to verify your identity, if we need to). Sometimes it may take us longer than this if your request is particularly complex or you have made a number of requests. If this is the case, we will let you know if we need more time to respond.
Our service may contain links to and from third party websites. These may include our partner networks, advertisers, partner merchants, retailers and affiliates. If you click on one of these links and visit these websites, these websites have their own privacy policies which you should read. We are not responsible for these third party’s websites or privacy policies.
Our Service is only available to users aged 13 or over. The Service is not aimed at children under the age of 13. We do not knowingly collect data from anyone under the age of 13. If you are under the age of 13, you are not allowed to use our Service.
If you think a child under 13 has given us their data, please contact us using the details set out in Get in Touch so we can remove this data and terminate the relevant account.
If you have any questions or want to make a request regarding your data, you can contact us at [email protected].
If you have any questions, comments, or requests regarding this Privacy Policy, you can contact us at [email protected] or by contacting us via our Feedback page here.
If you have a complaint about our use of your data, you have the right to complain to your local data protection authority. In the UK, this is the Information Commissioner’s Office (ICO). You can see more details here. Details of how to do this are set out in the “for the public” section of the ICO’s website. In Australia, this is the Office of the Australian Information Commissioner. Contact details are set out here.
However, Sefer Swap welcomes the opportunity to resolve any complaint and we would suggest you first contact our Data Protection Officer via Get in Touch, prior to making a complaint to the ICO or your local data protection authority, so we can first try to resolve any complaints you have.
We may update or make changes to our Privacy Policy from time to time. If we make material changes to this Privacy Policy, we will notify you of any such changes as described below.
If we need to tell you about something, which might be for a legal, marketing or other purposes related to our Service, we will contact you using the method we believe is best to get in touch with you.
We will usually do this by email, or placing a notice on the Service itself.