Give, Sell, Hire (address) (hereinafter referred to as “GSH”) operates website(s) (including givesellhire.com and other country specific top level domains like e.g. .co.uk, .de, .at) (hereinafter collectively “GiveSellHire “/ “GiveSellHire services”), under the name “GiveSellHire “. GSH is the controller of personal data within the General Data Protection Regulation (GDPR). GSH decides on the purposes and means of processing personal data and is ultimately responsible for ensuring that the processing takes place in compliance with the governing personal data legislation.
GSH takes data privacy very seriously and wants to be open and transparent on how this topic is dealt with when GSH is provided with a set of personal data. Personal data means information which can directly or indirectly be linked to a living natural person. Examples of personal data include name, address, telephone number and email address; however, information about IP numbers and user behaviour when using the services may also constitute personal data. Below, GSH explains to users of GSH (hereinafter referred to as “user” or “users”) how data, what kind of data and for what purpose data is collected and to whom this data may be shared with. Finally, GSH informs users about their rights as well as internal rules for data storage.
- Data collection and processing
GSH collects data in connection with the registration of an account and also in connection with successive use of the GSH services. In order to give a good overview of how the processing of personal data is carried out, the personal data has been divided into categories based on how it is collected:
1. Data that is given to us by the user
When an account is created or activities are carried out through the framework of the account, personal information about the individual user is needed. Personal data in this category is pigeonholed by the fact that the user actively provides the data to us by, completing a web form, reporting incidents to support, or providing us with feedback through functions created for such purposes.
To ease the registration for users and to reduce the threat of scammers and spammers the user will have three ways of registering an account (but for now can only sign up using E-Mail conformation):
Registration with E-Mail confirmation:
GSH hereby accesses the data of the user, which he has specified during the registration process, i.e. name, e-mail address and telephone number. The profile data given by the user must be correct, complete and must continuously be kept up-to-date. In order to preserve a certain amount of anonymity towards other users, only the profile picture of the user, the first name and the last name abbreviated to the first letter (John D.) instead of the full name (John Doe) is shown to other users.
2. Data collected when you use the GSH services
By using GSH services and carrying out activities, the user provides data which is stored by GSH in its database. This process takes place for user recognition and to ensure the delivery of the service that the user has requested. GSH will also store information when the user contacts them, for example when the user e-mails our customer support, so that GSH can assist the user and answer open questions. GSH may use anonymous and aggregated data about such inquiries to improve its services.
By using the GSH services, information is gathered about individual user’s activity, e.g. which services and screens are visited within GSH and how they are used. The collected data can be divided into the following types:
a. Technical information about the user’s device and internet connection
Through server logs and other tools GSH records information about the user’s device and internet connection, including operating system, browser version, IP addresses, cookies and other unique identifiers. The technical information is processed as combined data in order to analyse how GSH services are used. GSH may, however, link such data to the user’s account, for instance so that the Operator can customize the GSH-services to the User’s device.
b. Information about the use of the GSH services
GSH registers the user’s account activities such as logging in or out of the user account, and any purchase of products or services through the GSH services. GSH also stores information about a user’s visit on the site. GSH uses this information, amongst other things, to prevent abuse and fraudulent activities, to improve the GSH services and to provide users with personalised services, recommendations and information.
c. Information about users’ location
When GSH is used, the individual user’s location may be estimated through the IP or Geo-location detected on the individual’s device. This information is, for instance, used to show content or provide offers relevant to the user’s location. This is done to improve the GSH services and to identify and display the location of the classified ads listed by the user. In order to avoid the identification of a user’s actual exact location, a displaced location of the seller is shown in the published classified ads.
d. Cookies and locally stored content
3. Information from other sources
GSH may from time to time receive information from other sources such as partners, ad networks and other third parties that help GSH understand user activity and preferences. This is essentially collected to improve the GSH services. Examples of this include, when the user creates an account by connecting with their Facebook profile, and GSH may add basic profile information. An advertising partner may also share information about what happened after the user had clicked on an ad on the GSH website, so that we, GSH can measure the impact of an ad and provide more relevant content or advertisements. The analysis is usually carried out at an aggregated and anonymised level.
To improve the GSH services and to analyse errors, the Operator uses certain tracking-tools. Therefore, GSH traces user behaviour independently as well as via third-party suppliers (e.g. Google Analytics, Firebase, Crashlytics).
GSH may inform the user about changes to or improvements of the GSH services by using their e-mail address or – if the user uses mobile devices – through push notifications.
3. Personalised contents, offerings and recommendations
GSH uses information to personalise and tailor services, and to also provide users with content that may be relevant to them. From time to time GSH serves content based on the user’s explicit wishes, such as if the user opts in to receive search alerts. GSH may also serve content and recommendations based on user activities; for example, when GSH recommends products based on popularity among other users.
GSH can advertise via the GSH services and may collaborate with third party providers in order to optimise the impact of the advertisement.
In order to display personalised advertisements in the Services, data such as birthdays (if shared by the user), gender (if shared by the user), approximate geographic location, language, internet service provider (ISP), categories of interest, can be shared with advertising network operators such as Google, Facebook and other similar providers.
If explicit user consent for such data transfer is required, consent will be collected. In this case the user consent can be withdrawn at any time in the user settings.
4. Identification of market trends
GSH analyses data to understand market trends in order to advance, develop and customise the GSH services. Such analysis can be made both by GSH directly or by so called data processors, which analyse the data on behalf of GSH (subject to strict data processing agreements that maintain data confidentiality and integrity).
5. Preventing, limiting and investigating abuse of the GSH services
We use information to restrict various forms of abuse of the GSH services, such as fraudulent activities, denial of service attacks, spamming, unauthorized logins and other actions that violate our Terms & Conditions, or are prohibited by law.
IV. Legal Basis for data processing
If the operator processes personal user data such processing is necessary for the performance of the contractual services or for the purposes of the legitimate interests pursued by the operator.
Any further data processing not necessary for the previously mentioned purposes will be only carried out if the user has given consent to the processing or if necessary for compliance with a legal obligation to which the operator is subject.
V. Usage of data by third parties
Users may prevent such data collection by logging out of social media networks before logging in to the services.
VI. Transfer of data
However, GSH may collaborate with service providers who process data based on corresponding data processing agreements. Service providers processing user data on behalf of GSH will only do so for the purposes as prescribed in the data processing agreement and as explicitly instructed by GSH.
Personal data may be transferred due to the following reasons:
2. Disclosure of personal data to a third party
If there is suspicion of illegal activities in connection with the use of our services, information may be disclosed to the police and other public or local authorities subject to a court or administrative order. GSH may share information with other third parties if they can prove an overriding interest in the identity verification of a user as well as in the determination of certain unlawful facts. Further third parties have to verify that the knowledge of this information is essential evidence for a prosecution act.
3. Data processors
GSH collaborates with service providers (data processors within the meaning of the GDPR) especially for displaying adverts, to analyse user behaviour and to integrate third party services.
4. Transfer of personal data to a country outside the EU or the EEA
GSH will only transfer personal data only to a third country, i.e. a country outside the EU or the EEA where there is either a decision of the European Commission on sufficient data protection standards, or there is an agreement on the EU Standard Contractual Clauses (http://ec.europa.eu/justice/data-protection/international-transfers/transfer/index_en.htm; andhttps://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en) or they are certified under the privacy shield (https://www.privacyshield.gov/welcome).
5. Payment via PayPal
In case the user is using the PayPal payment function within the Give, Sell, Hire website or App, the following personal data will be stored and/or shared with PayPal:
GSH will save the seller’s billing details in the check-in form for the duration of the seller’s contractual relationship with GSH, to make the payment process easier for the seller or hirer. The billing address will be automatically deleted 5 years after the seller’s last use of GSH. Invoices will be saved for up to 10 years, because it is a legal requirement in Austria.
GSH will save the buyer’s shipping address for the duration of your contractual relationship with the operator, to make the payment process easier for the buyer. The shipping address will be automatically deleted 5 years after the buyer’s last use of GSH.
VII. Cookies and other technologies
The GSH website uses “cookies” in order to enable all functionalities of the GSH website and to enable the use of the page. “Cookies” are small text files that allow GSH to store specific information on the user’s PC while they visit the GSH website. The User may disable cookies in general, restrict them from certain websites or adjust their browser to notify them about cookies. Cookies can be removed from a PCs hard disk at any time. Please note that in this case the display of the website may be restricted and the user guidance might be limited.
VIII. User Rights
1. Right to Information
The user has the right to be informed on if and what personal data of the user GSH processes and to request a copy of such data.
2. Right of rectification and restriction
The user has the right to rectification, restriction, addition or deletion of personal data concerning him where the data is inaccurate or the processing unlawful.
3. Right to object
The user is in certain cases entitled to object certain personal data processing concerning themselves and to withdraw consent where consent has been given.