Privacy Notice

Who We Are

Mom Trading Group Ltd (‘our’ ‘we’ or ‘us’) gather and process your personal information in accordance with this privacy notice and in compliance with the GDPR and DPA (18). This notice provides you with the relevant information regarding your rights and explains how we manage your data.

Mom Trading Group Ltd.’s registered office is at 6 Queens Street, Leeds LS1 2TW and we are a company registered in England and Wales under company number 11282448. We are registered on the Information Commissioner's Office Register of Data Controllers under registration number ZA623420 and act as the data controller. Our designated Data Protection Officer/Appointed Person for the organisation is our Compliance Manager, and we can be contacted at [email protected]

Information That We Collect

Mom Trading Group Ltd processes your personal information in line with our obligations and to provide you with the services associated with our mobile application. We are committed to and have processes in place to avoid ever collecting any unnecessary personal data from you and do not process your information in a way that differs from the purposes specified herein.

We only collect data when you register with our mobile application or as part of our support services (which include an in-app messaging service). We do not collect data from any public sources.

The personal data that we collect from is: -

• Name
• Date of Birth
• Email address
• Number of children
• Your photo
• Your child’s date of birth or due date
• When you registered as a user
• Each time you use the application (app)
• The categories you search for and how long you spend within each category
• The items you search for and how long you spend on each item
• A record of your purchases/sales
• Items that you list
• The volume and frequency of your direct messages
• Which accounts you follow
• When we send you push notifications
• Repeat purchases
• The age of your account
• Number of search enquiries
• Frequency of your use
• When you view ads
• How your personalise your account

NB – Please note we do not collect any data described within the GDPR as “special category” (formerly known as sensitive data). All financial transactions are completed outside of our systems (see below under “your rights”)

We collect information in the below ways: -

• When you register as a user
• By monitoring your use of the application

How We Use Your Personal Data

Your privacy is taken very seriously Mom Trading Group Ltd and will commit to never disclose, share or sell your data without your consent, unless required to do so by law. Where you have consented to us providing you with promotional offers and marketing, you are free to withdraw consent at any time. The purposes and reasons for processing your personal data are detailed below: -

• We collect your identity data to enable you to use our mobile application – this is done based on performance of a contract.
• We collect the data about how you use the mobile application to enable us to personalise ads. This is done based on our legitimate interests to sell targeted advertising. In order for us to use this legal basis we have conducted a balance test to establish that our legitimate interests do not outweigh your rights and freedoms. You have the right to object to this processing and if you would like to opt-out please email: [email protected]
• We also process your data based on legal obligation so that we can comply with UK tax law
• For our newsletter we use consent as the legal basis, which you can opt out of at any stage

Your Rights

You have the right of access to any personal information that Mom Trading Group Ltd processes about you and to request what information we hold

If you believe that the data we hold is incomplete or inaccurate, you have the right to ask us to correct that information. We will provide corrections in as shorter period of time as is reasonable.

You have the right to withdraw consent for our newsletter, by emailing [email protected] or by clicking on the unsubscribe option in all newsletters sent by email.

Under certain circumstances (depending on our legal basis) you also have the right to restrict processing or request erasure of your personal data in accordance with data protection laws, as well as to object to any direct marketing from us. We do not undertake any automated decision making that would implicate any risk to your rights and freedoms.

You have the right to object to us using profiling (which we do to make advertising more relevant to you). Please email [email protected] to opt out.

If you would like to us to undertake any actions based on your rights, we may ask you to confirm your identity. We have strict policy and procedures for actioning subject rights and access requests.

Sharing and Disclosing Your Personal Information

We do not share or disclose any of your personal information, other than for the purposes specified in this notice or where there is a legal requirement. Mom Trading Group Ltd uses the companies we partner with to provide the below services and business functions, however all these companies (processors) are acting in accordance with our instructions and in line with the details described in this privacy notice, each processor has provided us with assurances with regard to the security of your data.

Propaganda Agency Limited – they help us with our marketing
https://www.propaganda.co.uk/privacy-policy/

Razor Ltd – they help with the development and management of the mobile application
https://www.razor.co.uk/privacy

Microsoft Azure – they manage our servers and databases
https://privacy.microsoft.com/en-gb/privacystatement

Google Firebase – they provide our application analytical information
https://firebase.google.com/support/privacy

Facebook – they provide further analytics and statistical information about you
https://www.facebook.com/legal/FB_Work_Privacy

Sendgrid – they provide an application to allow us to send our newsletters to you
https://www.twilio.com/legal/privacy

We may share your data with a 3rd party as part of the due diligence afforded to any company wishing to invest in or buy our company.

International Transfer

While all the servers used in providing you this mobile application are UK based some of our partners are based and use services hosted in the US. All our US based partners are Privacy Shield certificated, and as such provide you with the assurances associated with that certification.

Safeguarding Measures

Mom Trading Group Ltd employs several layers of security measures, including: -

• Encryption (TDE) for storage
• TLS for transportation
• Access is restricted to authorised personnel only

Consequences of Not Providing Your Data

You are not obligated to provide your personal information to Mom Trading Group Ltd, however, as this information is required as part of our registration process, you will not be able to use our service without providing this.

How Long We Keep Your Data

Mom Trading Group Ltd have strict review and retention policies in place to meet our obligations and we only retain personal data for as long as is for the purposes we have specified. UK tax law requires us to keep your personal data for a 7-year period after which time it will be destroyed.

Where we have your consent for direct marketing, we will keep such data until you notify us otherwise and/or withdraw your consent.

Special Categories Data

Mom Trading Group Ltd never knowingly processes your special category (or sensitive) personal data from you to. We have put in place specific measures to avoid you sharing any data of this type with us.

Children’s Data

Mom Trading Group Ltd only process the age or age group of children, and we have both conducted impact assessments and implemented additional controls to safeguard that data. We have also put in place specific measures to avoid you sharing any data of this type. Our terms specifically prohibit you to use any pictures that can identify a child, and we may alter pictures to ensure these terms are abided by.

Lodging A Complaint

Please tell us if you're not happy with how we've handled your personal information. You are also entitled to make a complaint to the Information Commissioner's Office.

Mom Trading Group Ltd
Compliance/General Manager
[email protected]

Information Commissioner’s Office

Helpline number: 0303 123 1113
https://ico.org.uk/concerns/