Privacy & Cookie Policy

1. Who we are

1.1 Our identity
Our website is operated by:

Interactive Network Ltd

Company number: 07616055

Registered in England and Wales.

Registered office:

Clemency Business Centre
354a Hollinwood Avenue
Manchester
M40 0JB
United Kingdom

VAT registration number: GB 235 3496 02

For the purposes of applicable data protection law, Interactive Network Ltd is generally the controller of personal data that we process in connection with our website and marketplace.
1.2 Our marketplace
Rubbish.com operates an online marketplace through which Customers can request quotes for waste-removal services from independent Members.

We are not normally the provider of the waste-removal services themselves.

The contract for waste-removal services is between the Customer and the relevant Member, as explained in our Customer Terms & Conditions.

Members are independent businesses and may have their own legal responsibilities for personal data that they receive and process in connection with providing their services.

2. The personal data we collect

Depending on how you use our website and services, we may collect the following categories of personal data.

2.1 Customer information
If you request a quote, we may collect:
- your name;
- email address;
- telephone number;
- collection address;
- billing or payment information where applicable;
- details of the waste you want removed;
- information about the quantity and type of waste;
- access arrangements and other information relevant to the collection;
- photographs or other information you provide about the waste;
- communications between you and us; and
You should not provide unnecessary sensitive personal data when submitting a waste-removal request.
2.2 Member information
If you register or operate as a Member, we may collect:
- your name;
- business or trading name;
- business address;
- email address;
- telephone number;
- website and social-media information where relevant;
- waste-carrier or other relevant licence information;
- insurance information;
- company or business registration information;
- payment and invoicing information;
- information contained in your Member profile;
- photographs, descriptions and other content you provide;
- communications between you and us;
- information concerning your use of our website; and
- information relating to quotes, complaints or other activity carried out through the marketplace.
2.3 Technical and usage information
When you use our website, we may collect technical information such as:
- IP address;
- device type;
- browser type and version;
- operating system;
- approximate geographical information derived from technical data;
- referral information;
- pages visited;
- time spent on pages;
- navigation information;
- information about interactions with our website; and
- information concerning cookies and similar technologies.
The precise information collected will depend on the technology used on our website and your cookie preferences.
2.4 Communications
If you contact us, we may retain the contents of your communications and information associated with those communications.

3. How we use personal data

We use personal data only where we have a lawful basis for doing so.

The purposes for which we may process personal data include the following.

3.1 Providing the marketplace
We may process Customer information in order to:
- receive and administer quote requests;
- identify relevant Members;
- provide Customer requests to relevant Members;
- enable Members to assess requests and provide quotes;
- communicate with Customers and Members;
- assist communications between Customers and Members; and
- operate and administer our marketplace.
The relevant lawful basis will generally be performance of a contract or taking steps at your request before entering into a contract, or our legitimate interests in operating our marketplace, depending on the circumstances.
3.2 Providing the quote-request service
Where you request a quote or arrange services through our marketplace, we may process your personal data to:
- process and administer your quote request;
- issue confirmations;
- provide information about your quote request or arranged services;
- share relevant information with Members who may be able to provide a quote;
- communicate with you concerning your quote request or arranged services;
- administer cancellations, rearrangements and refunds; and
- provide customer support.
The relevant lawful basis will generally be performance of a contract or taking steps at your request before entering into a contract.
3.3 Payments
We may process payment and transaction information when you make a payment to us.

Payment information may be processed directly by third-party payment providers acting on our behalf.

We may retain transaction information necessary for accounting, legal, tax, fraud-prevention and record-keeping purposes.
3.4 Member services
If you are a Member, we may process your personal data to:
- assess and administer your membership application;
- create and administer your Member account;
- publish your business information and profile;
- provide you with Customer quote requests;
- facilitate communications with Customers regarding quote requests;
- administer your relationship with us;
- verify relevant business, licence or insurance information where appropriate;
- administer payments or charges where applicable;
- maintain records; and
- communicate with you about your membership and our services.
The relevant lawful basis will generally be performance of a contract, taking steps at your request before entering into a contract, legal obligation, or legitimate interests, depending on the particular processing.
3.5 Website operation and security
We may process personal data where necessary to:
- operate our website;
- maintain website security;
- prevent fraud and misuse;
- investigate suspected unlawful activity;
- troubleshoot technical problems;
- maintain backups;
- maintain system logs;
- protect our business and users; and
- improve the reliability and security of our services.
The lawful basis will generally be our legitimate interests in operating a secure and reliable website, and/or compliance with a legal obligation.
3.6 Legal and regulatory purposes
We may process personal data where necessary to:
- comply with legal or regulatory obligations;
- respond to lawful requests from public authorities;
- establish, exercise or defend legal claims;
- obtain legal or professional advice;
- manage insurance and risk; and
- enforce our contractual rights.
The lawful basis may be legal obligation or legitimate interests, depending on the circumstances.

4. Legal bases for processing

Depending on the circumstances, we may rely on one or more of the following lawful bases:

4.1 Contract
Processing is necessary to perform a contract with you or to take steps at your request before entering into a contract.

For example, this may apply when you request a quote or register as a Member.
4.2 Legal obligation
Processing is necessary for us to comply with a legal or regulatory obligation.
4.3 Legitimate interests
Processing is necessary for our legitimate interests, or those of a third party, provided those interests are not overridden by your interests or fundamental rights and freedoms.

Our legitimate interests may include:
- operating and improving our marketplace;
- maintaining website security;
- preventing fraud and misuse;
- administering our business;
- communicating with Customers and Members;
- maintaining appropriate records;
- enforcing our rights; and
- managing business and legal risks.
Where we rely on legitimate interests, we will consider the impact of the processing on individuals and whether our interests are appropriately balanced against their rights.
4.4 Consent
Where applicable law requires consent, we will ask for your consent before carrying out the relevant processing.

Where we rely on consent, you may withdraw it at any time. Withdrawal of consent does not affect the lawfulness of processing carried out before withdrawal.

Consent will not be used as a substitute for another lawful basis where another lawful basis is more appropriate.

5. Sharing personal data with Members

5.1 Customer quote requests
If you submit a request for waste-removal quotes, we may share relevant information from your request with Members so that they can:
- assess your request;
- provide a quote;
- contact you about your request;
- discuss the waste, access arrangements and collection requirements; and
- where applicable, arrange the waste-removal services.
The information shared will depend on what is reasonably necessary for the particular request.
5.2 Quote requests and arranged services
When you submit a quote request, we may provide relevant Members with relevant information, including your contact details and information concerning the waste and collection arrangements, where necessary to arrange and provide the waste-removal services.

We may also provide you with the relevant Member's contact details so that you and the Member can communicate directly.
5.3 Members' own processing
Members are independent businesses.

Where a Member receives your personal data, the Member may become independently responsible for processing that personal data in connection with providing its waste-removal services.

Members must comply with applicable data protection law in relation to their own processing of personal data.

A Member may provide you with its own privacy information where required by law.

Our Privacy & Cookie Policy does not make us responsible for a Member's independent processing of your personal data.

6. Other recipients of personal data

Depending on the circumstances, we may disclose personal data to:

relevant Members;
payment service providers;
website hosting and technology providers;
IT and software service providers;
communications providers;
analytics providers;
security and fraud-prevention providers;
professional advisers, including lawyers, accountants and insurers;
regulators, law-enforcement bodies and government authorities where required or permitted by law;
companies within our corporate group, where applicable; and
a purchaser, investor or prospective purchaser of all or part of our business, where appropriate.

Where third parties process personal data on our behalf, we will take appropriate steps to ensure that they process personal data in accordance with applicable data protection requirements.

7. Direct marketing

We may send you information about our own services where permitted by applicable law.

Where we send direct marketing by email, text message or other electronic mail, we will comply with applicable PECR requirements.

Where consent is required, we will obtain appropriate consent before sending the relevant marketing.

A marketing consent request will be separate from acceptance of our Terms & Conditions and will require a clear affirmative action.

You can unsubscribe from marketing communications at any time by:

using the unsubscribe facility included in the communication;
changing your marketing preferences where such functionality is available; or
contacting us using the details in section 17.

Service and transactional communications, such as service confirmations and important information concerning an arranged service, are not necessarily marketing communications and may still be sent where necessary to provide our services or comply with our legal obligations.

8. Information received from other sources

In some circumstances, we may receive personal data from sources other than you.

For example, we may receive information:

from a Member concerning a Customer's quote or arranged service;
from a Customer concerning a Member;
from service providers;
from publicly available sources;
from fraud-prevention or security providers; or
from government, regulatory or licensing bodies where permitted by law.

Where we obtain personal data from another source, we will handle it in accordance with applicable data protection law.

9. International transfers

We generally seek to process UK users' personal data in the United Kingdom.

However, some of our technology providers, software providers or other service providers may process personal data outside the UK.

Where personal data is transferred outside the UK, we will take appropriate steps to ensure that the transfer is lawful under applicable data protection law.

Depending on the circumstances, this may include relying on:

UK adequacy regulations or other applicable adequacy arrangements;
appropriate contractual safeguards, including the UK International Data Transfer Agreement or UK Addendum where applicable; or
another lawful transfer mechanism recognised under applicable data protection law.

We will not represent that all personal data will always remain in the UK where our service providers or technology infrastructure involve international processing.

10. Security

We take reasonable technical and organisational measures designed to protect personal data against:

unauthorised access;
accidental loss;
destruction;
alteration;
disclosure; and
other unlawful or unauthorised processing.

No internet transmission or electronic storage system can be guaranteed to be completely secure.

You are responsible for keeping any passwords or account credentials confidential and should notify us promptly if you believe your account has been compromised.

11. Retention of personal data

We retain personal data only for as long as reasonably necessary for the purposes for which it was collected and processed.

The appropriate retention period depends on factors including:

the nature of the personal data;
the purpose for which it was collected;
whether you continue to have a relationship with us;
our legal and regulatory obligations;
accounting and tax requirements;
the need to establish, exercise or defend legal claims;
fraud and security requirements; and
legitimate business requirements.

We may retain certain information for longer where necessary to comply with legal obligations or to establish, exercise or defend legal claims.

When personal data is no longer required, we will take reasonable steps to delete it or otherwise dispose of it securely, subject to applicable legal and regulatory requirements.

12. Your rights

Subject to applicable law, you may have rights including:

the right to obtain access to your personal data;
the right to have inaccurate personal data corrected;
the right to have personal data erased in certain circumstances;
the right to restrict processing in certain circumstances;
the right to object to certain processing;
the right to data portability where applicable;
the right to withdraw consent where processing is based on consent; and
the right to complain to the Information Commissioner's Office.

These rights are not absolute and may be subject to legal exceptions.

For example, we may need to retain or process certain information to comply with legal obligations or establish, exercise or defend legal claims.

The ICO's current guidance confirms that privacy information should explain these rights and the relevant lawful bases and recipients.

13. How to exercise your rights

You may exercise your data-protection rights by contacting us using the details in section 17.

We may need to request additional information from you to verify your identity before responding to a request.

We will normally respond to a valid request within the period required by applicable data protection law.

If you are dissatisfied with how we handle your personal data, you may complain to the UK's data protection regulator:

Information Commissioner's Office (ICO)

You can find information about making a complaint through the ICO's website.

14. Children

Our website and quote-request service is intended for people aged 18 or over, consistent with our Customer Terms & Conditions.

We do not knowingly seek to collect personal data from children through our quote-request service.

If you believe that a child has provided us with personal data, please contact us.

15. Cookies and similar technologies

Cookies are small text files or similar technologies that may be placed on your device when you visit a website.

We may use cookies and similar technologies for purposes including:

operating and securing our website;
remembering preferences;
maintaining sessions and login functionality;
understanding how our website is used;
measuring website performance;
improving our website and services; and
where applicable, supporting marketing or advertising.

Some cookies are strictly necessary for the website to operate.

Other cookies, including certain analytics and advertising cookies, may require your consent.

We will not set non-essential cookies that require consent before obtaining the required consent.

The ICO's current guidance states that non-essential cookies should not be set before the user has given valid consent, and that consent must involve a clear positive action rather than simply continuing to browse the website.

16. Analytics

We may use analytics technologies, such as Google Analytics or other analytics services, to understand how visitors use our website and to help us improve our services.

The specific analytics services and cookies used may change from time to time.

Where an analytics cookie or similar technology requires consent under applicable law, it will only be used after the relevant consent has been obtained.

Our cookie-management tool will provide information about the categories of optional cookies used on our website and allow you to manage your preferences.

17. Managing cookies

When you first visit our website, where required, we will provide you with a cookie-management mechanism allowing you to:

accept optional cookies;
reject optional cookies; and/or
manage your cookie preferences.

You can change your cookie preferences at any time using the cookie-preference mechanism made available on our website.

You can also control or delete cookies through your browser settings.

Blocking strictly necessary cookies may affect the operation of the website.

We will maintain appropriate records of cookie consent where required. The ICO recommends that organisations identify their cookies, distinguish necessary from non-essential cookies and provide a mechanism allowing users to control non-essential cookies.

18. Third-party websites and services

Our website may contain links to websites, applications or services operated by third parties.

Those third parties have their own privacy policies and terms.

We are not responsible for the privacy practices of third-party websites or services that we do not control.

Where we use third-party services as processors or service providers for our own business, we will take appropriate steps to protect personal data in accordance with applicable law.

19. Changes to this Privacy & Cookie Policy

We may update this Privacy & Cookie Policy from time to time.

Changes may be necessary to reflect:

changes to our website or marketplace;
changes to the services we provide;
changes to how we process personal data;
changes to our service providers;
changes to applicable law or regulatory guidance; or
changes to our use of cookies or similar technologies.

The latest version will be published on our website with its "Last updated" date.

Where required by law, we will provide additional notice of material changes.

20. Contact us

If you have questions about this Privacy & Cookie Policy, our processing of personal data, or wish to exercise your data-protection rights, please contact us.

Interactive Network Ltd

Clemency Business Centre
354a Hollinwood Avenue
Manchester
M40 0JB
United Kingdom

Company number: 07616055

You may contact us:

by post using the address above;
through our Contact Us page;
by telephone using the number published on our website; or
by email at [email protected].