About Snoofa Limited

1.1 We are Snoofa Limited, (“We/Us (our) ”) English Registered Company No 11994411 whose registered office is at Elm House, Llancayo Court, Usk, Monmouthshire, NP15 1HY. You can also contact us at info@snoofa.com for general inquiries or at gdpr@snoofa.com for inquiries specifically concerning our processing of your personal information. We can also be contacted by telephoning +44 (0)20 8191 9981 and asking for our data protection officer. Our data protection officer is Sarah Buchanan.

1.2 We are committed to protecting your privacy and making it clear how we use your information. This privacy policy (“Privacy Policy“) describes for you, as a user of the website www.snoofa.com (the “Website“) and services available through the Website: the kinds of information that we may collect about you, when and how we use that information; how we protect it; who we disclose it to and why; and your rights to access and control our use of your information.

1.3 Our legal status under UK data protection law is that of both a data controller and a data processor. “Data controller” is the legal term which identifies the person who controls what to do with any given personal information. “Data processor” is the legal term which identifies the person who processes any given personal information. As both data controller and data processor we have registered with the Information Commissioner’s Office and our registration number is ZA524291.

1.4 This Privacy Policy was last updated on 27th February 2022.

2. We currently operate this website to promote business to business transactions focused on the business of selling and purchasing of goods and services by online auctions. We do not yet transact business with consumers. Nevertheless whether you simply visit this site out of curiosity or you visit it in your capacity as a commercial trader or the representative of a business interested in doing business with us, you may provide us with personal information which may enable us or our systems to identify you through processing of data, so this Privacy Policy applies to you. As our business develops so will our Privacy Policy evolve to meet the entitlements of those who visit our website and whose personal information we process to operate this website efficiently.

3. The types of information we currently collect and why:-

When you access the Website we will collect both “personal information” and “browsing information” about you.

For these purposes “personal information” means any information that enables us to determine your actual identity (such as your name or contact details). We use the term, “browsing information” to mean certain anonymous information that we collect about your use of the Website. On its own, this browsing information does not enable us to determine your actual identity.

There are differences in how we treat each type of information, as further explained in this Privacy Policy.

3.1.1 Visitors to our Website

If you are a visitor to our website, and you have clicked on our Cookies button to enter the Website, we use a cookie to identify your IP address to improve your access to our Website the next time you visit us. If you interact with our website you may share your name and email address with us. Please see Section 4 below for information about the cookies we use, and how you can manage them from your own computer.

3.1.2 Prospective Snoofa™ Customers

If you are interested in our Product and Services as a prospective Buyer we collect personal information from you if and when you (whether on your own behalf of on behalf of a business) you register to use our services, such as your name, email address, username and a dedicated password and telephone contact number and when you contact us to place an Order. We collect and process this personal information to register your interest, for account setup, to respond to your requests (and those you are making on behalf of your business) and for administration purposes. This helps us to provide you with an efficient and responsive experience.

We may also collect your name and email address when you sign up to receive information about our business activities and developments in our field of business or for promotional emails so that we or third parties can send you information about offers and promotions we or they think may interest you. However, we will contact you only in accordance with your expressed marketing preferences when you complete your registration form. Please see section 7.1 below for information on how to contact us to change your marketing preferences.

3.1.3 Snoofa™ Customers

If you contact us to discuss or place an Order for our products and services to become, or represent a Customer we may collect personal information from you, such as your contact details, your business role, details of the business you represent and the services provided by you (or it) and when you contact us (for example, when you complete an online Order form). We need these details to evaluate your Order with a view to establishing and administering your (or your business’) account with us and to fulfill any Order which we accept.

3.2 Browsing information

3.2.1 When you visit the Website, we collect limited browsing information about your visit. This may include information about the pages of the Website that you access, how many clicks it takes you to reach specific information, and the kinds of instruments and Suppliers you search for and the search terms you enter.

3.2.2 As stated above it may also include information about your computer’s Internet Protocol (“IP“) address, as well as details about cookies served to your computer through the Website.

3.3 IP addresses

An IP address is the unique number automatically assigned to your computer whenever you access the Internet. It is automatically transmitted to us by your computer whenever you access the Website. We use this information so that our server can recognize your computer when you next access our website, to diagnose problems with our server and to administer the Website; however, this number on its own does not enable us to determine your actual identity.

Cookies

4.1 Cookies are small text files that websites often send and store on computer hard drives of visitors to their websites. They are widely used to improve access to websites and visitors’ navigation of a website to identify the number of visits to and where a visitor goes when visiting a website.

4.2 A cookie contains a unique number, which is used to recognise your computer when a user of your computer returns to a website that it visited previously. We use cookies to enhance the online experience of our visitors and to better understand how the Website is used. Cookies may tell us, for example, whether you have visited the Website before or whether you are a new visitor.

4.3 There are two broad categories of cookies – ‘first party cookies’ and ‘third party cookies’. First party cookies are cookies that are served directly by the website operator to your computer, and are used only by the website operator to recognise your computer when it revisits that website. Third party cookies are served by a service provider on behalf of the website operator, and can be used by the service provider to recognise your computer when it visits other websites. Third party cookies are most commonly used for website analytics or advertising purposes.

4.4 This Website sends the following cookies to your computer:

4.4.1 Essential website cookie served by snoofa.com (first party cookie)PHPSESSION, WEBID_ONLINE This cookie is strictly necessary to provide the website and is used to allow you to move around the website. This cookie is deleted when you close your browser. Please see below for information about how you configure your browser to notify you when you receive a new cookie, and how to disable cookies altogether.

4.4.2 Google Analytics (third party cookie)Utma; _utmb; _utmc; _utmz; _ga; _gid; _gt These cookies are set by Google, Inc. and are used to collect information about how visitors use the Website. We use this information to compile reports and to help us improve the Website. The cookies collect information in an anonymous form, including the number of visitors to the Website, where visitors have come to the Website from and the pages they visited. To see an overview of privacy at Google and how this applies to Google Analytics visithttp://www.google.co.uk/intl/en/analytics/privacyoverview.htmlTo opt out of being tracked by Google Analytics across all websites visit http://tools.google.com/dlpage/gaoptout.

4.4.3 Facebook Pixel

The Facebook pixel is an analytics tool that allows us to measure the effectiveness of your advertising by understanding the actions people take on your website. To see an overview of privacy and Terms and Conditions at Facebook visit https://www.facebook.com/policies

You can choose whether or not to accept cookies by amending or setting the controls on your browser to reflect your cookie preferences.

The “help” portion of the toolbar on most Internet browsers will tell you how to change your browser cookie settings, including how to have the browser notify you when you receive a new cookie, and how to disable cookies altogether. For further information about cookies and how to control their use, please visit the following third party educational resources: www.youronlinechoice.eu, Cookies | ICO and www.allaboutcookies.org.

However, please note that if you choose to refuse or to remove cookies you may experience difficulty in accessing and or be unable to use the full functionality of this Website.

We may process your personal information

1. for negotiation, setting up and performance of a contract with you or a business you represent;
2. whilst you continue to consent to use cookies to enable us and our service providers to analyse traffic on our website;
3. to understand how the Website is used to help us plan develop and improve its functionality;
4. on an anonymised basis to predict demand for and review the use of our product and services to optimise return on and to increase the services we provide;
5. to improve your awareness and experience of our Website our product and our services
6. for so long as you consent to receive it to send third party marketing and or to promote other selected businesses’ services where you are likely to be interested in purchasing and/or using such products and services;
7. to detect and understand market trends to produce anonymised market analysis reports and data for use in our business sector
8. To check prospective customers’ financial status and credit ratings with credit reference agencies banks and financial institutions
9. to facilitate connections between customers or groups of customers and third party service providers;
10. to produce aggregated and anonymised data to share with third party providers and
11. where necessary to enable contractors we use to support our business (such as our Website hosting providers)
12. to seek help from our professional advisers to comply with our statutory obligations as an English registered company or to obtain legal advice
13. if we are permitted or required to do so by law or the order of a duly constituted court or tribunal
14. to comply with anti-money laundering procedures or for the prevention and detection of crime
15. to transfer information in confidence to a prospective buyer of our business and in the event we sell or transfer all or a portion of our business in which case we shall stipulate that the transferee will thereafter only use personal information you provided to us consistent with this Privacy Policy and any consent you have given to us at that time.

Personal information we collect from you during the course of providing our service may be transferred to our service providers which are located outside of the European Economic Area (“EEA”) by Google LLC, MailChimp, Apple Inc., Rackspace Inc., XERO, Slack Technologies. While territories outside the EEA may not have the same standards of data protection as those within the EEA, we will take such measures as are necessary to ensure that any personal information we transfer outside the EEA is adequately protected and processed only in accordance with this Privacy Policy, including via standard contractual clauses and the EU-US Privacy Shield.4.2. for your protection and ours.

We implement current appropriate commercial technical cyber-security measures and internal organisational measures from time to time to protect your personal information we hold from unauthorised or unlawful access or processing and against accidental loss corruption or destruction

How to access and control your information

7.1 You have the following rights under the Data Protection Act 2018 in relation to your personal information:

• to contact us by emailing gdpr@snoofa.com to tell us about any changes you may wish to make concerning your preferences for receiving communications including any changes to the marketing information you are already receiving
• upon giving us satisfactory proof of your identity to be given a copy of the personal information we hold about you;
• to access your personal information in machine-readable format and to ask that we transfer this to a third party data controller;
• to tell us not to contact you further for marketing purposes even if you have previously consented to receive this.
• to object to processing your personal information which causes or will cause damage or distress;
• upon satisfying the statutory requirements to have inaccurate personal information rectified on taken down from or deleted from our systems;
• to object to decisions about you being taken by automated means;
• to seek compensation for damage caused to you by our breach of data protection legislation; and
• (if we do not address your concerns to your satisfaction) to complain to the Information Commissioner’s Office in respect of our use of your personal information.

If you have any concerns about your entitlements please notify us by emailing our data protection officer at dpo@snoofa.com. We shall do our best to accommodate your request or objection. Please note that not all your rights are absolute. Sometimes other legal obligations or third party rights will take precedence.

We shall retain your personal information only for the recommended period necessary to fulfil the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law. Accordingly, your personal information shall routinely be stored for up to seven years following the end of the services we provide to you / your last contact with us. This retention period can be extended if any applicable statutory or regulatory obligation requires us to hold information for a longer period.

The Website may contain links or references to other websites to which this Privacy Policy does not apply. You must read the privacy policy of every website you visit as, once you leave the Website to visit another website, the way in which your personal information is then handled will be subject to a different privacy policy.

We shall regularly review and may update this policy in the future. We shall take reasonable steps to make you aware through our Website of any changes to it. We recommend that you revisit this page regularly to keep informed of our updated privacy policy from time to time.

If you have questions about our Privacy Policy or the privacy and security of your information, you can contact us

• on dpo@snoofa.com
• by calling our data protection officer on +44 20 8191 9981
• by writing to DPO, Snoofa Limited, Elm House, Llancayo Court, Usk, Monmouthshire, NP15 1HY