Version number: 1
Effective date: 1 January 2021
Who are we?
1.1 We are Exchange Technology Solutions Ltd trading as
“Branbee”. For privacy queries, you can
contact us at firstname.lastname@example.org. Other contact details are on our website.
What’s the point of this policy?
2.1 It tells you what to expect when we collect your personal information
via our website
Please only use our service if you are completely happy with this policy.
2.2 Generally, the policy covers only information provided to us. If you
give personal information to other people, such as payment providers or
other websites, please check their privacy policies.
Might the policy change?
3.1 Yes. Please check it whenever you visit our website.
We will assume you agree to the new version of the policy if you use the
site after its effective date. We may also notify you of any changes by
email or in-service message.
What do we collect?
4.1 Information which you upload to our service or otherwise give us such
your name and contact details;
other information provided when you register with us such as a profile
details about your transactions on our service;
information included in your profile or in posts or which you otherwise
provide for display on our service;
contact or other information which you give or allow us to use for
newsletters or other marketing; and
your communications with us.
4.2 Automated information about your use of our service such as: the
internet protocol (IP) address used to connect your device to the internet,
connection information such as browser type and version, information about
your device including device-type and device identifier, operating system
and platform, mobile network data, a unique reference number linked to the
data you enter on our system, login details,
the site from which you arrived at our service,
details of your activity with date / time stamps including pages you
visited and your searches / transactions.
4.3 The following information about you may be provided to us by other
If you log in via Facebook or Google: your user ID, full name and email
What’s our reason / legal basis for collecting the information?
5.1 Because it’s necessary to take steps at your request to enter
into a contract with you and/or to perform such a contract
. This applies to initial enquiries and to contact and transaction
details as well as to information which you provide for public display
on our service].
5.2 Because it’s in our “legitimate interests”, e.g., to
manage and improve our service including tracking usage patterns and
preventing or detecting fraud or abuse. This applies to automated usage
5.3 Because you’ve agreed. This applies to contact or other
information which you give or allow us to use for newsletters or other
marketing. You can withdraw permission at any time as explained on our
service or by emailing us at the above email address.
How long do we keep personal information?
6.1 Until your account is closed or our contract with you has ended (or
earlier if your account has been inactive for a certain amount of time
provided we say so in our terms and conditions). You can close your account
by emailing us at the above email address.
6.2 We may hold on to some of your information for longer (typically up to
six years) if reasonably needed for legal, regulatory or tax reasons, deal
with disputes, prevent fraud or abuse and/or enforce our terms and
6.3 We will keep your information which we use only for newsletters or
other marketing until you tell us to stop sending you such messages.
To whom do we send or make available your personal information?
7.1 To other people who supply us with a service, e.g.
website hosts, payment providers, , and businesses which help us send
communications or monitor our website and which provide us with analytics
and other IT services.
7.2 To other users of our service, including personal information into your
profile or otherwise include it in a post, comment or other public action
on our service.
7.3 To the relevant decision taker to whom any petition which you sign is
addressed or to any other people to whom the promoter of the petition
decides to send it.
7.4 To credit reference agencies, regulators and the police and other law
enforcement authorities to help deal with fraud and abuse and/or comply
with legal requirements.
7.5 To insurers and professional advisers in connection with our insurance
cover or to deal with legal claims.
7.6 To potential buyers so far as reasonably necessary, in the case of an
actual or proposed (including negotiations for a) sale or merger or
business combination involving all or the relevant part of our business.
Do we send your information outside the European Union?
8.1 Your personal information which we collect is stored within the EU and
is not transferred to any third countries except as follows.
8.2 Your personal information may be transferred to the US by the following
companies certified under the
EU-US Privacy Shield Framework
, which provides certain safeguards for your personal information: Google
(analytics), Facebook (social media) and Twitter (social media).
What rights do you have?
9.1 If the legal requirements are met: To ask us for access to your
personal information, to rectify it if there are mistakes, to delete or
restrict its use in certain circumstances or to “data
portability” or to withdraw any consent you’ve given (e.g.
9.2 You may also have the right to object to use of your personal
information in certain circumstances.
9.3 If you have a complaint about how we are dealing with your personal
information, please contact us via the email address above. If you are not
happy with our response or think we are not handling your personal
information in accordance with the law, you have the right to complain to
the Information Commissioner’s Office (ICO).
9.4 For more information about your rights, visit the ICO’s website: www.ico.org.uk.
What about cookies?
on our website. A cookie is an identifier (a small file of letters and
numbers) that is sent to your web browser. Cookies are widely used to make
websites work, or work more efficiently, as well as to provide information
to the website owner or others. Some are session temporary
“session” cookies that remain in the cookie file of your
browser only until your browser is closed. Whereas persistent cookies stay
for longer (depending on the lifetime of the specific cookie). For further
information on cookies, including how to use your browser to block them and
how to delete existing cookies, visit: www.allaboutcookies.org. Our
site’s functionality will be limited if you configure your browser to
10.2 We ourselves place the following types of cookies:
Type of cookies
Assess whether you are logged in to our site
Remember you and speed up your login when you return to our
Identify and authenticate you to help you move easily
through the site
Store information about the preferences you’ve
selected (eg favourites, currency, wishlists) and
personalise the site
Store your response to our cookie notice
10.3 Companies which provide us with a service also place cookies. Some of
these cookies (e.g. from Google) may involve certain information, such as
your IP address and web address of the page you’re visiting, being
sent to the company concerned. Below is a summary of the kinds of cookies
used together with details about who places them and where you can go to
get more information and to opt out (where possible):
These kinds of cookies recognise and count the number of website
visitors as well as providing other information about the visit such as
duration, route through the website and where the visitor came from.
This information helps us to improve the way our website works, for
example by making sure users find what they need easily. These cookies
are provided by:
Google Analytics (“GA”).
- general information about the
types of cookies
placed by Google including analytics
of GA cookies
use of its partners’ data
including how to control information collected by Google
- how to specifically
opt out from GA cookies
· Social media cookies: These kinds of cookies
are placed by social media companies when you use their features on
another site, for example if you play, click a Facebook
“like” or send a tweet. These features may involve the
relevant companies using cookies to collect information relating to
your visit to our website or your interaction with their services or
otherwise. Click the following links for further information including
how to opt out where this is possible:
Payment provider cookies:
Our payment provider may place cookies if you use their payment
services on our site:
Third party log-in cookies:
If you log in through a third party website, that website will place
its own cookies on your computer: