Table of Contents
- Privacy Policy
- Cookie Policy
- Acceptable Use Policy
- Counterfeit Report Process Policy
- Electronic Policy
- Firearms and Knives Policy
- Restricted items Policy
01. Privacy Policy
Introduction
Your privacy is important to us.
This privacy policy has been created to explain how and why we collect and use information about our users, and how we manage your privacy protection. We recommend that you read this statement in full, so that you understand how we will use your personal data. You can also read about specific issues by clicking on one of the topics below.
1.What personal data do we collect?
KITT collects personal data to operate our business and to provide you with the product and services that we offer. You provide some of this data to us directly, for example when you open an account with us, contact a seller on the site, or send a query to us through contact us form. Other data is collected when you interact with our products, by using cookies and other technologies.
When using our site, you have choices about what data we collect, and when you are asked to provide personal data you may decline. If you decline to provide data that is necessary to provide you with a particular product or feature, you may not be able to use this product or feature.
We collect personal data in the following ways:
- Through information you provide to us.
When you register with us as a user, you provide us with some personal data such as your name and email address, which we will store in order to create your account. We will also store information relating to any further use of our service, when you contact another user of the site through our platform, the contents of the messages you send to them and any other information that you may upload to the site. Finally, we may also collect information from any correspondence that you have with us.
- Through your use of our services.
When you use our services, we collect information about what types of services you use and how you use them. For example, which parts of our websites you visit, and what listings you view.
The information that we collect while you use our services can be grouped into the following categories:
- Information about your device and internet connection.
Using technical logs and other tools, we register information about the device you use, such as the device manufacturer, operating systems and browser version. We also collect information about the connection to our services, such as IP address, network ID, cookies and unique ID files. This information can help us to adapt the way content is displayed to you, based on your device and user profile.
- Information about how our services are used.
We also register information about how you use our services. For example, which pages of the site you visit, the searches that you have performed, the times and dates that you visited our site, how long a page is displayed on your screen, how you navigate around the page, which websites you have visited before visiting our site, what functions you have carried out on a page, and if you have completed a transaction.
- Cookies and other locally stored content.
When you use our services, cookies and other data are stored locally on your device. These cookies provide us with information that we can then read. You can find more information about cookies, how and why we use them, and how to manage them in our Cookie policy below.
- Information about user location.
We register your geographical location based on your IP address and mobile network code.
- Messages.
We collect information about when you send or receive messages from other users of our site.
- Cashless Payments.
When a seller / trader opts-in to receive cashless payments on KITT they are required to create / sign in to an account with Paypal and authorize a connection to KITT. While Paypal is the data controller for everything that happens within their service during and after sign up / sign in (2 factor authentication, 3D Secure payments, payins, payouts etc.), for the convenience of availing sellers KITT does pre populate the sign-up form using profile information, listed below, which can be edited, amended and/or removed as a user sees fit.
- Business address
- Legal name (your name)
- Statement descriptor (business name)
- Support phone number (phone)
- Email
For buyers availing of the cashless payments service, the same is true in regards to PayPal acting as data controller for the information captured during and in support of payment processing, attained via checkout. If a buyer is logged in to their KITT account, for their convenience we will pre populate their email address on the applicable checkout form field.
2. Legal Basis for Processing
We process your Personal Data in order to ensure the necessary performance of your contract with us. In certain circumstances, we may also process your Personal Data for the purposes of our legitimate interests, such as to inform you of changes to our services, to provide you with information about other services we offer or in order to comply with any legal obligations to which we are subject.
We may also rely upon your consent as a relevant legal basis for processing your Personal Data. In the event you wish to withdraw your consent to the collection and processing of your Personal Data in this manner, please let us know at hello@kitt.ie
3. How We Use Your Personal Data
3.1 We use the data that we collect to provide you with the products and services that we offer. This allows us to improve the products that we offer you and to personalise your experience on our site. We may also use the data to communicate with you, to inform you about your account and to provide you with security updates. Where you have consented for us to do so, we may also use your data to contact you in relation to updates about our own products, products provided by third parties, and to help to show you more relevant adverts on the site. Your data will be used by us to authenticate your account and to enable you to interact with other users of our site.
- Contacting sellers.
When you contact a seller though our site, we will use the personal data that you have provided as part of this contact to connect you to the seller. The seller will receive a copy of any data that you have entered as part of your message to them.
3.2 Legal basis under data protection law: Legitimate interests
- Communications.
We will contact you via email and messages posted on our website. These messages will communicate about service related issues and security updates. Where you have consented for us to do you, we will also contact you with promotional marketing materials from us and from our partners. You can update your marketing preferences at any time within your account. Please note that it will not be possible to opt out of receiving service messages from us. This includes messages relating to security and legal notices. We may issue marketing materials to sellers that are listed on our platform for the purposes of our services.
- Advertising and retargeting.
Banner advertising on our site may be targeted to visitors of the site through a variety of ad networks and exchanges. We also may use this data to measure the performance of these adverts. We may use the data that you provide to us, through your cookie preferences, either separately or combined to deliver advertisements that are more relevant to you and your interests on KITT and offsite, as you browse the internet. Please see our Cookie Policy for more details.
- Research and Developing Our Services.
We use data that we collect through your use of our site and through public feedback, to conduct research and develop our services based on our findings. This allows us to provide you with a better experience when using our site.
- User Research Participation.
We use the data that you provide us in order to contact and schedule your participation in our research. The purpose of this research is to continuously improve the products and services we offer. The data we collect from you will only be accessible by a small number of our internal research team and will be destroyed 6 months after collection. If selected, none of your personal details will be linked to any of your responses in the research.
- Customer Support.
We use the data that you provide to us, including your communications, to investigate and respond to service issues and complaints.
- Insights
We use your data to generate statistics about our site that do not identify you using third-party assets such as cookies. Please see our Cookie Policy for more details. These statistics provide us information about how our site is used, the number of listing impressions served or clicked on, and the demographic distribution of visitors to our site. On various pages of our website, we record visitor behaviour and serve polls/surveys via HotJar. Visitor behaviour is recorded anonymously through click heat maps for each page HotJar is implemented and also through recordings of visitors interacting with the site. For visitor recordings, all personally identifiable information is whitelisted including searches. HotJar also enables us to serve surveys and polls. These surveys are optional and in most cases, we don’t ask for or receive any personally identifiable information. Where we ask for an email address/phone number, the users needs to consent before the survey is submitted.
- Security Monitoring and Investigations.
We will use your data when necessary to investigate and identify possible fraudulent behaviour on the site and possible attempts to harm other members or visitors to the site. We will also use your data to investigate violations of our Terms of Use or this Privacy Policy.
- Cashless Payments.
When a seller opts-in to receive cashless payments on KITT they are required to create / sign in to an account with Paypal (our cashless payments partner) and authorize a connection to Paypal. While Paypal is the data controller for everything that happens within their service during and after sign up / sign in (2 factor authentication, KYC checks, 3D Secure payments, payins, payouts etc.). For buyers availing of the cashless payments service, the same is true in regards to Paypal acting as data controller for the information captured during and in support of payment processing, attained via checkout. If a buyer is logged in to their KITT account, for their convenience we will pre populate their email address on the applicable checkout form field.
4. How we Share Your Information
We retain access to all personal information that we have collected from you. If you have consented on signup, we may provide any of the information we collect to carefully screened third parties to contact you regarding products or services that we think may be of interest to you. If KITT enters into a joint venture with or is sold to or merged with another business entity, your information may be disclosed to our new business partners or owners.
- Our Services.
Our service allows you to engage with other members of our site. If you send a message to another member of our site, your message will be shared with that site member.
- Service Providers.
We engage other service providers to help us to provide our service to you. For example, to process payments, site maintenance and fraud detection. These service providers will have access to your information as much as is reasonably necessary for them to perform these tasks on our behalf. They are obligated not to disclose or use your data for any other purpose.
- Legal Disclosures. When required to by law, we may disclose information about you. This may be as a result of a subpoena or other legal process. Your personal information will also be shared if we believe that the disclosure is necessary to:
- Be used by government enforcement agencies investigate, prevent or take action against any suspected or actual illegal activities.
- To enforce the agreements that we have with you.
- To investigate and defend KITT against any allegations made by third parties.
- To protect the integrity and security of our services.
- To exercise the rights and safety of KITT, our employees and other users of our service.
- Change of Ownership.
If KITT enters into a joint venture with or is sold to or merged with another business entity, your information may be disclosed to our new business partners or owners in preparation for, or as a result of, any of these events. Any other entity which buys KITT or any part of our business, will have the right to continue to use your data in the way described by this privacy policy, unless you consent otherwise.
5. Your Rights and Choices
The General Data Protection Regulations offer you a number of rights in relation to your data. This includes the right to access a copy of your data, a right to receive a copy of your data that can be transferred to another organisation, a right to data deletion, a right to withdraw your consent to data processing, a right to restrict the processing of your data, and information on any automated decision-making processes.
- Data Retention.
The amount of time that we retain data for, depends on the type of data being retained, and how that is used. In some cases, there will be a legal requirement for us to hold data for a specified amount of time. In other cases, we will not retain the data for any longer than necessary for the purpose that it was collected and processed. When you register an account with us, we will retain the information that you provide to us for as long as you hold this account. Once an account has been closed, we will continue to retain this data for a period of seven years. This timeframe is in line with the Irish statutory limitation periods. If you don’t actively close your account with us, it automatically becomes inactive after 3 months of you not accessing it. After this, the data you have provided us will be retained for seven years. All other data provided, which is not personally identifiable, will be retained for possible future use. If you have provided data to us without registering an account, this data will be retained for 7 years after your last date of activity with us.
- Right to Access Your Personal Data.
Registered users of KITT can request we provide them with a copy of the personally identifiable information we hold by using our data request feature.
- Right to Control Your Personal Data. Registered users of our site can update their information by editing their profile. You can also edit and make changes to the personal information by logging into your account and editing it directly from there. You can change your marketing and contact preferences at any time in your account settings by opting out receiving of these communications. You may ask us to make any necessary changes to ensure that such information is accurate and kept up-to-date.
- Right to Data Deletion.
Non- registered and registered users of our sites can request we delete any personally identifiable information we hold by using our data request feature. In some instances we may be unable to delete your data if we are required to retain it to comply with our legal obligations (including requests from law enforcement agencies).
- Right to Data Portability.
Registered users of our site have the right to data portability. This means that you can request that a copy of your data is made available in a structured, commonly used and machine-readable form that can be transferred to you or to another organisation. You may request a portable copy of your data by using our data request feature.
6. Other Important Information
- Special Category Personal Data.
KITT does not collect any special categories of personal data. However, if you enter this information into any free text section of our site, such as the listing description, this information will be held and processed in the same manner as all other data that you have provided to us.
- Security.
The security of your data is important to us. We perform regular monitoring of our systems to identify possible vulnerabilities and attacks. However, we cannot warrant the security of any information that you send to us. No guarantee is given that the data will not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards.
- Direct marketing.
We will only send you marketing information where you have opted in to receive these communications. You can change your marketing preferences at any time, by logging into your account and changing this on your account dashboard. You can also opt out of receiving marketing at any time using the unsubscribe link that can be found at the end of each email that we send.
- Changes to this Statement.
This statement will be updated when necessary to reflect product or other changes. When this statement is updated, the “last updated” date will be revised at the top of this statement. We encourage you to review our Privacy Policy regularly so that you can stay informed about our use of your data.
Contact information
If you have any questions in relation to this Policy, please email us at hello@kitt.ie. If this does not resolve your complaint/question, you have the right to contact your local Data Protection Commissioner. In Ireland, they can be contacted via their website here.
02. Cookie Policy
What are cookies and how are they used?
A cookie is a small amount of data that is sent to your device’s web browser by a website and is stored on your *device’s hard drive. Cookies may allow a website to “remember” your actions or preferences over a period of time, or they may contain data related to the function or delivery of the website. Each website can send its own cookies to your web browser. Your browser will have the option to prevent websites using cookies (your browser’s help screen will tell you how to do this), but please note that this may reduce the functionality of our website and other websites.
KITT(the website) uses cookies to keep our platform working as you expect it to, to analyse traffic, to prevent non-genuine users and/or malicious software from engaging in abusive activities on our platform, to enable performance and product improvements, to tailor your experience through personalised content and advertising, and to offer features for social media.
Device: PCs, laptops, tablets, mobile phones and any other internet accessible hardware.
Types of Cookies:
- First-Party Cookies.
First-party cookies are directly stored by the website (or domain) you visit. These cookies allow website owners to collect analytics data, remember language settings, and perform other useful functions that provide a good user experience.
- Third-Party Cookies.
Third-party cookies are created by domains that are not the website (or domain) that you are visiting, hence the name third-party. They are typically used for cross-site tracking, retargeting and personalised advertising.
Cookie Categories:
- Strictly Necessary Cookies.
These cookies are essential in order to enable you to navigate the website and use its features, such as accessing secure areas of the platform. Without these cookies, services you have asked for, like shopping baskets or checkout features, cannot be provided. To prevent non-genuine users and/or malicious software from engaging in abusive activities on our platform, we are manually watching the site and the cookies it requires to function are classified as strictly necessary to ensure the overall safety of our marketplace. For the privacy of our users, we only use Google Analytics to process obscured and/or non-personally identifiable data to track and understand aggregated usage metrics on our platform, such as number of visitors and unique visits. With these privacy safeguards, Google Analytics and the cookies it requires to function are classified as strictly necessary.
- Analytics Cookies.
These cookies collect information about how visitors use our website, for instance; which pages users visit most often, which links they click on, if they get error messages from certain pages. etc. These cookies do not collect information that can personally identify a user. Any information these cookies collect is aggregated and therefore anonymous. Their sole purpose is to help improve website functions.
- Functional Cookies.
These cookies allow us to remember some of the choices you make and provide an enhanced, more personalised experience (e.g. remembering your username and password for login, your search view preferences between sessions etc). These cookies can also be used to remember changes you have made to text size, fonts and other parts of web pages that you can customise. They may also be used to provide services you have asked for such as posting a comment. The information these cookies collect may be anonymised and cannot track your browsing activity on other websites. From time to time, there may be changes to these third-party cookies such as name changes, etc. We will endeavor to keep the table updated and encourage you to review the Privacy Policies of each of the third parties listed above. This Cookie Policy forms part of our overall Privacy Policy.
03. Acceptable Use Policy
KITT is an online secondhand marketplace that provides the tools and technology for sellers to set up an online shop and sell products on our marketplaces. While we believe the free and open exchange of products is a key area of commerce, there are some activities that are incompatible with KITT’s vision to make conscious shopping easier and more affordable for everyone and to promote sustainable choices.
This Acceptable Use Policy (“AUP”) describes activities that are prohibited in connection with your use of our services.
The following activities are prohibited:
- Child exploitation: You may not offer goods or services, or post or upload materials that exploit or abuse children, including but not limited to images or depictions of child abuse or sexual abuse, or that present children in a sexual manner.
- Harassment, bullying, defamation and threats: You may not offer goods or services, or post or upload materials that harass, bully, defame or threaten a specific individual.
- Hateful content: You may not use our services to promote or condone hate or violence against people based on race, ethnicity, color, national origin, religion, age, gender, sexual orientation, disability, medical condition, veteran status or other forms of discriminatory intolerance. You may not use our services to promote or support organizations, platforms or people that: (i) promote or condone such hate; or (ii) threaten or condone violence to further a cause.
- Illegal activities: You may not offer goods or services, or post or upload Materials, that contravene or that facilitate or promote activities that contravene, the laws of the jurisdictions in which you operate or do business.
- Intellectual property: You may not offer goods or services, or post or upload Materials that infringe on the copyright or trademarks of others.
- Malicious and deceptive practices: You may not use our services to transmit malware or host phishing pages. You may not perform activities or upload or distribute materials that harm or disrupt the operation of the Services or other infrastructure, including KITT third party providers. You may not use our Services for deceptive commercial practices or any other illegal or deceptive activities.
- Personal, confidential, and protected health information: You may not post or upload any materials that contain personally identifiable information, sensitive personal information, or confidential information, such as credit card numbers, confidential passport numbers, or account passwords unless you have consent from the person to whom the information belongs or who is otherwise authorized to provide such consent. You may not use our Services to collect, store, or process any protected health information, any applicable health privacy regulation or any other applicable law governing the processing, use, or disclosure of protected health information.
- Restricted Items: You may not offer goods or services that are, or appear to be, Restricted Items.
- Self-harm: You may not offer goods or services, or post or upload Materials that promote self-harm.
- Spam: You may not use our Services to transmit unsolicited commercial electronic messages.
- Terrorist organizations: You may not offer goods or services, or post or upload Materials that imply or promote support or funding of, or membership in, a terrorist organization.
We may, at any time and without notice, remove any materials, and suspend or terminate your account or your access to our Services if you engage in activities that violate the letter or spirit of this AUP, including activities outside of your use of the Services.
KITT has the right, but not the obligation, to monitor or investigate any materials and your use of the Services at any time for compliance with this AUP and KITT’s Terms of Service, or any other agreement between you and KITT governing your use of the Services (collectively, the “Terms”). Our determination of whether a violation of this AUP has occurred will be final and binding, and any action taken with respect to enforcing this AUP, including taking no action at all, will be at our sole discretion.
KITT may modify this AUP, including the list of Restricted Items, at any time by posting a revised version on our site. By continuing to use our Services or access your Account after a revised version of the AUP has been posted, you agree to comply with the latest version of the AUP. In the event of a conflict between the AUP and the Terms, this AUP will take precedence, but only to the extent required to resolve such conflict. Capitalized terms used but not defined in this AUP shall have the meanings set forth in the Terms.
If you feel that a user of our Services has violated this AUP, please contact us at hello@kitt.ie
04. Counterfeit Report Process Policy
KITT takes fraud management very seriously. We have a counterfeit report process in place to help fight against potential crime via listings on our site.
There are a number of circumstances you may find yourself in:
- a crime for the Gardaí to investigate
- a civil matter between you and the seller
- a misunderstanding that potentially can be resolved amicably
If you are in doubt about what you should do, please contact us through our contact us form on the KITT site: www.kitt.ie/contact-us
When to go to the Gardaí
We strongly encourage you to contact your local Gardaí to report the incident or the seller if you:
- feel you have been defrauded by a seller on KITT through the sale of counterfeit items
- have reason to believe you have discovered stolen goods or
- someone who is listing or selling something that may have legal implications
Before you go to the Gardaí
Rather than dealing with counterfeit or stolen goods, it might be the case that you are dealing with a seller who is slow at sending an item or keeping in contact. In these cases, we encourage you to try resolving the issue with the seller directly. You should always exhaust all options before going to the Gardaí.
05. Electronics Policy
Status of this Policy:
This Policy forms part of our Agreement with you concerning the use of our Website. For other policies applicable to this Agreement please go to our Terms and Conditions and all of which you should read carefully before you start to use this Website.
By accessing and using this Website, you indicate that you have read, understand and accept that Agreement, and that you agree to abide by its terms and conditions every time you access and use this Website. If you do not agree to all of the terms and conditions of the Agreement you should not use this Website.
General rules on all items described in this policy:
This policy is intended to help to protect users of the Website in general from intellectual property infringement. The items described in this policy are considered by KITT to be items which either infringe certain third-party intellectual property rights or proprietary rights or that encourage illegal activity.
KITT prohibits the listing of items that encourage, promote, facilitate or instruct others to engage in illegal activities. You may not upload or create content listings or referring to electronics equipment that fall into this category, including equipment deemed unlawful by the Commission for Communication Regulation (ComReg) in Ireland on the KITT Website.
You must ensure that any listing or Content does not infringe the copyrights, trademarks or other intellectual property rights of third parties; examples of items which are prohibited from being listed on this Website include blocker devices, etc.
If you are responding to a listing on this Website for any item mentioned in this policy then:
as a prospective buyer, it is your responsibility to satisfy yourself:
- list the item for sale on the Website in the manner set out in your listing; and
- sell the item in Ireland and the United Kingdom.
You may report any listing that offends this policy to us using the “Contact Us” mechanism.
In addition to other rights and remedies available to us under this Agreement, if in our view you breach this KITT policy, it may result in the removal of the offending Content from this Website without any notice to you or any refund to you of any fee paid to us.
Policy on CDs and DVDs
You may only list items or material on recordable media (which includes items such as VHS tapes, compact discs, audio tapes, CD-Rs, DVDs and DVD-Rs) on this Website where:
- you are a legitimate rights holder in the item or material, or if you are authorised to do so by the legitimate rights holder, its agent or the law; and
- you are authorised to sell the item or material; and
- the item or material is NOT A COPY.
We reserve the right to remove any listing that you post on this Website that does not contain this wording from this Website without notice and without any refund of any fees paid.
06. Firearms & Knives Policy
We do not allow listings for any type of firearms, knives, swords, weapons, fireworks or other related goods (including replicas) on KITT. This rule extends to accessories and components. If listings are posted on kitt.ie in breach of this policy we reserve the right to remove them from the website without giving notice to the seller or refunding any fee paid.
The prohibition above includes any firearm or weapon referred to in the Firearms and Offensive Weapons Act 1990 including, but not limited to, the following goods: flick-knives, knuckledusters, swordsticks, sword umbrellas, hand and foot claws, belt buckle knives, pushdaggers, hollow kubotans, shurikens, butterfly knives, telescopic truncheons, blowpipes, kusari gama, kyoketsu shoge, manrikigusari, sap gloves and machetes. Knives and swords are also restricted on KITT in line with the Firearms and Offensive Weapons Act 1990 (Offensive Weapons) (Amendments) Order 2009. The Act allows for certain types of knives and collectible swords to be legally sold, but this is not within the remit of KITT to allow for this on our site. The prohibition above also includes airsoft guns and similar items.
Status of this Policy
This policy forms part of our Agreement with you concerning use of our Website Terms and conditions all of which you should read carefully before you start to use this Website. By accessing and using this Website, you indicate that you have read, understand and accept that Agreement, and that you agree to abide by its terms and conditions each time you access and use this Website. If you do not agree to all of the terms and conditions of the Agreement you should not use this Website.
07. Restricted Items Policy
The definitions listed below (“AUP Definitions”) apply to KITT’s ‘Acceptable Use Policy’. KITT reserves the right to update and change the AUP definitions at any time.
“Materials” means any photo, image, video, graphic, written content, audio file, code, information, data or other content uploaded, collected, generated, stored, displayed, distributed, transmitted or exhibited on or in connection with your Account.
“Services” has the meaning set out in KITT’s Terms of Service. “Restricted items” You may not offer goods or services that are, or appear to be, Restricted Items.
Restricted items list
- Adults only
- Alcohol
- Animals and wildlife products
- Drugs and drug paraphernalia
- Embargoed goods
- Firearms, weapons and knives
- Government items
- Hazardous, restricted, or regulated materials
- Human parts and remains
- Any items encouraging illegal activity
- Lock-picking devices
- Mailing lists and personal information
- Medicine and healthcare products
- Offensive material
- Police-related items
- Prescription drugs
- Prohibited services
- Stolen property
- Artefacts, antiques, cultural items and grave-related items
- Catalogue sales
- Charity or fundraising listings
- Contracts
- Cosmetics or used cosmetics
- Counterfeit currency and stamps
- Credit cards
- Digitally delivered goods
- Event tickets
- Food
- Football tickets
- Gaming (slot/fruit) machines
- Plants and seeds
- Postage meters
- Property
- Recalled items
- Stocks and other securities
- Tobacco
- Travel
- Unlocking software
- Vouchers
