Snoofa Limited is a private limited company whose registered office is at Elm House Llancayo Court, Usk, Monmouthshire, United Kingdom, NP15 1HY with the company number 11994411 (“we”/”us”). By accessing the online auction marketplace The Snoofa Marketplace, available on www.snoofa.com (the “Online Marketplace”), you acknowledge and consent to the information collection and use practices by us in our capacity as data controller as described below. Please read this Privacy Notice carefully and contact us if you have questions or concerns at info@snoofa.com or write to us at our above registered address.

Personal data means data relating to natural persons who can be identified or who are identifiable, directly from the data in question or who can be indirectly identified from that data in combination with other data (“Personal Data”).

We set out below the categories of Personal Data that we may process:

• “Contact Data” includes data such as your delivery address, billing address, email address and telephone numbers;
• “Identity Data” includes first name, last name, maiden name, username or similar identifier;
• “Financial Data” means data relating to your bidding activity, payment (such as credit or debit card number, bank account information, purchase amount, date of purchase, payment method and in some cases, information about your lots, auctions, aftersales, bids, offers and purchases); and
• “Technical Data” includes internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you are using.

Most of the Personal Data we process is provided directly by you or made available when you access or use the Online Marketplace. We set out below some examples of how you may provide Personal Data to us:

• registering on the Online Marketplace as a bidder, buyer or seller;
• publishing lots, auctions or aftersales on the Online Marketplace as a seller;
• placing bids or offers on lots as a bidder or buyer through the Online Marketplace;
• communicating over the Online Marketplace;
• favouriting, sharing or following lots, auctions, aftersales or sellers on the Online Marketplace;
• submitting information to the Online Marketplace by filling in forms and sending enquiries (for example if you are enquiring about registration, publishing a lot, auction or aftersale, or bidding or placing an offer on a lot);
• contacting us by phone, e-mail, social media or otherwise; or
• in the form of information provided by your web browser, when you search and browse the Online Marketplace for content (through the use of cookies or similar software).

For certain transactions, we may be required to fulfil some AML obligations for regulatory purposes and we may collect Personal Data about you through direct interaction, such as requesting copies of passports, proof of address and other information or through third parties/ publicly available sources, for example when we need to conduct background checks. These obligations may also require us to process more sensitive categories of Personal Data which requires additional protection because it is more sensitive (“Sensitive Personal Data”). Sensitive Personal Data may include identifiers from the following categories of data:

• “Criminal Offence Data” is Personal Data relating to criminal convictions and offences or related security measures and may include a wide range of information about criminal activity, allegations, investigations and proceedings; and
• “Special Category Data” includes details about race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data.

We may ask you for further information to comply with our AML obligations, for example to conduct enhanced due diligence on you in the event that we consider that you present a higher risk of money laundering or where you are in a category such as a politically exposed person, where we are required to conduct enhanced due diligence. These enhanced due diligence measures (which in particular may require us to process your Financial Data and Sensitive Personal Data) may include (but is not limited to):

• Examining the background and purpose of a transaction;
• Increase the degree and nature of monitoring of your customer activity;
• Obtaining, and where appropriate verifying, additional information on the customer and any beneficial owner; and/or
• Obtaining information on the source of funds or source of wealth of the customer.

We will process any Sensitive Personal Data in accordance with the lawful basis set out below and the additional conditions and safeguards set out in the Data Protection Act 2018.

We may use your Personal Data for the following purposes and reasons:

Contract:

We may process your Identity Data, Contact Data and Financial Data that you provide when you enquire about an auction, bid or place and offer on a lot, or purchase a lot via the Online Marketplace or publish an auction, aftersale or list a lot on the Online Marketplace. We process this Personal Data to enable us to carry out the pre-contract and contractual relationship between you and us.

Where you become a buyer of the lot:

As a buyer, you may be provided (directly or indirectly) with the Personal Data of the seller, such as the Contact Data, Identity Data and Financial Data, for the purposes of arranging payment for and collection/delivery of the lot. You shall not disclose this Personal Data to a third party unless otherwise required by law, or where permitted under the Buyer Terms.
If you are the buyer, your Personal Data, namely, your Contact Data, Identity Data and Financial Data will be supplied to the seller, and this disclosure is necessary for the performance of the contract (namely in order for the seller to determine which bid/offer to accept, and for you and the seller to arrange payment for and the collection/delivery of the lot).

Where you are a seller:

As a seller, you may be provided (directly or indirectly) with the Personal Data of the bidder or buyer, such as the Contact Data, Identity Data and Financial Data, for the purposes of determining which bid or offer to accept, arranging payment for and delivery of the lot. Depending on your access level, you may see Personal Data of the users making the offers and bids: (i) if you have client anonymisation disabled, upon a user submitting a bid or placing an offer, you will be able to view certain Personal Data, including the value of the bid/ offer, the time at which the bid/offer was made, the bidder’s/ potential buyer’s first and last name and the delivery address and phone number; and (ii) if you have client anonymisation enabled, upon the bidder/potential buyer submitting a bid or placing an offer, you will be able to view the value of the bid/ offer, the time at which the bid/offer was made, but you will not be able to view any other information, except where the bidder/potential buyer successfully previously purchased a lot from you via the Online Marketplace in which case you will see Personal Data of that bidder/buyer as if you had anonymisation disabled. You shall not disclose this Personal Data to a third party unless otherwise required by law, or where permitted under the Seller Terms.

This is necessary in order for the seller to accept a bid/offer and for the buyer and seller to be able to arrange the payment and the collection/delivery of the lot pursuant to the Buyer and Seller Terms and to enable us, the seller and you to carry out the contract. If you do not agree to this, you should not register nor place a bid or an offer, nor list lots at auction or aftersales on the Online Marketplace.

Consent:

As a buyer/bidder, we will ask for your express consent (via a tick box when you register on the Online Marketplace) for us to share your Personal Data with the seller. The seller may either have client anonymisation enabled or disabled on their account. You will not be notified which access the seller has. This is a requirement of registration. If you do not agree to this, you should not register on the Online Marketplace. If after registering and prior to bidding or placing an offer on a lot, you change your mind and do not wish to have your details shared with the seller, you should write to us immediately at the email address or registered address listed above, and we will promptly deactivate your profile.

When you subscribe to the newsletter, we may process your Contact Data and Identity Data. You have the right to withdraw consent at any time, simply click the link provided in the newsletter, or write to us either at the email address or registered address listed above.

Legitimate Interests:

We may process the bidders/buyers Contact Data, Identity Data and Financial Data (including their bidding/purchasing activity, and the activity as a seller listing and selling lots at auction and aftersales) in order to report to third parties on the Online Marketplace’s performance.

If we sell the business to a third party or in the event of a change of ownership, sharing of the Personal Data (of both you as a bidder, buyer or seller) to the buyer of the business may be necessary for our legitimate interest in selling the business. In such an event, we will ensure that the buyer agrees that they can only use the Personal Data for the purposes for which it was originally collected and in accordance with the applicable data protection laws and that consent must be sought if the Personal Data is to be used for a different purpose.

We may contact you using your Contact Data and Identity Data where it is necessary to notify you of changes to the entry of lots you have bid or placed an offer on, or to notify you whether or not your bid or offer was successful.

We may also process additional data that you submit to us (for example, requests for customer support and technical assistance) and Technical Data that we automatically collect using cookies, server logs and other similar technologies.

We may process the Personal Data (in particular Contact Data and Identity Data) of a previous client with whom we have worked to personalise emails, send updates about us and the material changes in the Privacy Notice, or for other purposes permitted by law.

We may provide you with information about auctions, aftersales or lots we feel may interest you. If you are an existing client, we will only contact you by electronic means with information about lots that are similar to those which were the subject of a previous sale to you or similar to the lot you published on the Online Marketplace at an auction or aftersale.

Where we rely on our legitimate business interests to process these categories of Personal Data about you, we will balance our legitimate interests against your interests and rights (for example, responding to inquiries, improving the Online Marketplace, and enabling network and information security).

Legal Obligation:

We may process your Personal Data, in particular your Financial Data (such as details of your past transactions and the source of your funds) and your Sensitive Personal Data (which is set out in greater detail above), to comply with our legal obligations or making disclosures to government, regulatory or other public bodies where in our reasonable opinion the disclosure is appropriate and permitted by law. This includes legal obligations with respect to Anti-Money Laundering (“AML”) requirements if applicable as set out under Clause 3 of this Privacy Notice.

We may also collect Personal Data to perform other functions that are not listed above, which will either be described to you when the Personal Data is collected or it may be collected if you have granted your consent for a particular purpose.

We use third-party platforms to support the Online Marketplace and communications. We are not responsible for their privacy practices and you are encouraged to read their privacy notices. The key third-party platforms currently used are set out below, but may change from time to time:

• Stripe Payments UK Ltd (“Stripe”): Stripe is an online payment processing and credit card processing platform for businesses. We use Stripe to facilitate payments for transactions on the Online Marketplace, including payment of the service fee charged to buyers and sellers on the Online Marketplace. Please read Stripe’s privacy notice here to understand how Stripe processes your Financial Data, Identity Data and Contact Data.
• GB Group PLC (“GBG”): GBG is an online platform that assists with identification verification, and fraud prevention for businesses. We use GBG to perform our AML obligations in order to identify and verify the identity and location of buyers and sellers, who place bids/offers, buy and/or sell lots on the Online Marketplace that exceed or are likely to exceed the AML threshold and to perform sanction screening and PEP checks on buyers and sellers on the Online Marketplace. Please read GBG’s privacy notice here to understand how GBG processes your Identity Data, Contact Data and Sensitive Personal Data.
• Heap.io (“Heap”): Heap is a SaaS product analytics platform. We use Heap to collect and analyze Personal Data about how users are interacting with the Online Marketplace to optimize performance of product usage, diagnose problems, and correlate activity with long-term value. Please read Heap’s privacy notice here to understand how Heap processes your Identity Data, Contact Data, and Technical Data.
• Mailchimp: Mailchimp is a marketing automation and email marketing platform. We use Mailchimp to send email marketing materials to you such as newsletters and email correspondence. Please read Mailchimp’s privacy notice here to understand how Mailchimp processes your Contact Data, Identity Data and Technical Data.
• Mailgun Technologies Inc (“Mailgun”): Mailgun is an email delivery service for sending, receiving, and tracking emails. We use Mailgun for transactional emails, which are messages that are sent in response to an action a user takes on the Online Marketplace. Please read Mailgun’s privacy notice here to understand how Mailgun processes your Contact Data, Identity Data and Technical Data.

In addition to the above, you may be able to register and/or log on to the Online Marketplace by logging on via your Meta and/or Google accounts. Please ensure you review their respective privacy notices available online.

We will not share your Personal Data with third parties other than as necessary for the purposes outlined above and only with third party service providers that provide business, professional or technical support functions on our behalf or as required by law.

Your Personal Data may be transferred outside the UK and EU. For example, this may be in relation to an international sale at auction (where the buyer or seller are located outside of the UK/EU), or where we are sharing information with our third party service providers who operate outside the UK or EU.

We are strongly committed to protecting your Personal Data and we take reasonable and appropriate steps to protect your Personal Data from unauthorised access, loss, misuse, alteration or corruption. We have put in place physical, electronic, and organisational procedures to safeguard and secure the Personal Data you provide to us, including industry-standard access controls such as secure passwords and multi factor authentication.

We take reasonable steps to ensure that the Personal Data we hold about you is as accurate and complete as is necessary to carry out the relevant purposes described in this Privacy Notice and we will retain your Personal Data for so long as is reasonably necessary for us to fulfil the relevant purposes described in this Privacy Notice, unless a longer retention period is required or permitted by law (for example for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements or in the event of a complaint or where there is a prospect of litigation).

We will then securely dispose of your Personal Data that we hold by permanently deleting it and any back-up files. Personal Data shared with third party service providers is stored and deleted according to their privacy notices.

Please be aware that no electronic transmission or storage of Personal Data can be guaranteed to be 100% secure. We cannot and do not warrant the security of any Personal Data that you transmit, and all such transmissions are done at your own risk.

We receive and store Technical Data whenever you use the Online Marketplace. We use “cookies” to improve the Online Marketplace. A cookie is a small file of letters and numbers that is stored on your browser or the memory of your computer or device. Cookies mean that a website will remember you and enable online transactions and help us understand how you use the Online Marketplace. For more information on the cookies that we use on the Online Marketplace, please see our Cookie Policy available on the Online Marketplace.

Under the Data Protection Act 2018, you have rights including:

• Right of Access: To ask for copies of your Personal Data.
• Right to Rectification: To ask to rectify inaccurate/incomplete Personal Data.
• Right to Erasure: To ask for your Personal Data to be erased in certain circumstances.
• Right to Restriction of Processing: To ask to restrict the processing of your Personal Data in certain circumstances.
• Your right to Object to Processing: To object to the processing of your Personal Data in certain circumstances.
• Your right to Data Portability: To ask that your Personal Data be transferred to another organisation, or to you, in certain circumstances.

For more information or to exercise your data protection rights regarding our processing, please write to us at the email address or registered address listed above. We will try to respond to all legitimate requests within one month.

If you are unhappy with any aspect of how we handle your Personal Data you can make a complaint to the Information Commissioner’s Office here.

This Privacy Notice may be updated from time to time. All amendments will take effect immediately upon posting of the updated Privacy Notice on the Online Marketplace. If the changes are material, we will post a notice on the Online Marketplace before the changes go into effect. We encourage you to periodically review this Privacy Notice to stay informed about how we are helping to protect your Personal Data.

This version of the Privacy Notice was last updated on 1st March 2025.