Privacy Statement

This Privacy statement applies directly to new users and for existing users as of 24 February 2023. This Privacy statement supersedes all previous versions.

Contents

• Scope and consent
• Data controller
• Collection of personal data
• Use of personal data
• Legal ground for processing of personal data
• Use of personal data for marketing purposes
• Termination of use of personal data for marketing purposes
• Disclosure of personal data
• Tradera User-ID
• Personal data shared with other users
• Cookies, web-beacons and similar techniques
• Prohibition of spam, spyware and identity theft
• Access, review and changes of personal data
• Transfer of personal data
• Security and storage of personal data
• Termination of account and data retention
• Your rights
• Contact us

Scope and Consent

This Privacy statement describes how we collect, use, store, share and protect your personal data. This Privacy statement applies to Tradera´s website and all related websites, applications, services and tools where reference to this Privacy statement is made, regardless of how you access or use them.

Throughout this Privacy statement we use the term “personal data” to describe any information that directly or indirectly can identify a natural person. We do not consider personal data to include information that has been anonymised or aggregated in a way that it cannot be used, whether in combination with other information or otherwise, to identify a natural person.

We may update this Privacy statement from time to time. The latest version is always available via our website. In the event of substantial changes, due to, for example, new legislative requirements, we may notify you via e-mail.

Third party websites: Some pages on the Tradera website include links to third-party websites. These sites are governed by their own privacy statements, and Tradera is not responsible for their operations, including but not limited to their information practices. Users submitting information to or through these third-party websites should review the privacy statements of these sites before providing them with personal data.

Data Controller

Tradera Marketplace AB, Solnavägen 3H, 113 63 Stockholm, Sweden (hereinafter “Tradera”) is the data controller for the processing described in this Privacy statement. Tradera is responsible for the processing of your personal data and to provide the services stated in User agreement and according to the principles as laid down in this Privacy statement.

Collection of Personal Data

When registering an account with us, you also provide personal data. We need to process certain personal data relating to you in order to verify and identify you as a user, to comply with certain requirements according to the User agreement or as required by law, and to improve our services and provide you with the best possible user experience. We need to process your personal data in order to offer you access to our websites, applications, services and tools so that we can provide you with a customized and improved experience, and in some cases for marketing purposes.

We collect the following personal data about you:

Information we collect automatically

When you visit our websites, use our applications, services and tools, or interact with our advertising or content, we automatically collect information that is sent to us by your computer, mobile device, or other unit used for access. This information is only related to you personally if you sign in as a registered user, and includes for example: device ID or unique identifier, geo-location, device type, data and connection information, statistics on page views, traffic to and from the sites, referral URL, ad data, IP-address and standard web log information. You can read more about cookies further down in this Privacy statement and here.

Information provided by you

We collect information directly from you that you provide on our websites, or that you provide us with when you register an account, use our websites, applications, services or tools. Such information include:

• information you provide to us when registering an account, such as name, e-mail address, telephone number, cell phone number, personal identification number, contact information;
• if you sell goods or services via our websites, applications, services or tools, we also collect financial information related to you, such as bank account numbers, tax identification number and VAT registration number. If you do not have a tax identification number, we collect information about your place of birth;
• additional information you provide us with via social media;
• transactional information based on your activities on the websites (such as bidding, buying, selling, advertising information and content you generate or that relates to your account);
• shipping, billing, payment and other information you provide in order to purchase or ship an item, as well as, where shipping services are provided through one of our integrated systems, additional relevant shipping information (tracking updates) stored by the chosen shipping partner;
• information provided in the context of discussions in forums, chats, dispute resolution, correspondence through our websites, or correspondence that has otherwise been submitted to us;
• additional documents we may ask you to submit to verify your identity or if we believe you are violating site policies. For example, we may ask you to send us a government issued identity document or other documentation in order to verify your identity or address, or to answer additional questions to help verify your identity or ownership of an item you list for sale); and
• information provided in connection with the verification process through e-identification, such as BankID and MitID.

Information we collect from other sources

We collect additional information related to you from third parties such as authorities, public actors and third party providers such as Creditsafe and Trapets who provide, for example, information about a company's beneficial owner and so-called PEP lists (Politically Exposed Persons) and sanctions lists. From merchants, data bureaus and data providers we receive, for example, demographic and navigation information, credit check information, additional information about you from a credit bureau, as permitted by law.

Information retrieved from registration and sharing in social media

We may offer sign-in services that allow you to use third party login credentials to access www.tradera.com and related websites. We may also offer services that allow you to share information with third party social media websites.

You may choose to provide us with access to certain personal data stored by third party websites. The personal data we access varies depending on the third party website your privacy settings on that third party website and your consent. By associating an account managed by a third party with your Tradera account and granting Tradera access to this information, you agree that Tradera may collect, use and store information from these websites in accordance with this Privacy statement.

Use of Personal Data

Our purposes for collecting personal data are to provide you with access to our websites and/or use of our services, applications, and tools, provide you with requested customer service and relevant information about your account and our services, as well as to provide you with a safe, efficient, and customised experience. By accepting this Privacy statement, you confirm that we may use your personal data for the following purposes:

• manage your account, for example when you create or terminate an account;
• provide you with access to our websites and the services and customer support you request;
• prevent, detect, and investigate any fraud, security breaches, potentially prohibited or illegal activities, as well as enforce our User agreement;
• customise, measure and improve our services, content and advertising;
• contact you, either via e-mail or telephone, in order to resolve disputes, collect fees, and troubleshoot problems related to your account or our websites, services, applications or tools, or for other purposes authorised by law;
• compare information for accuracy, as well as verify it with third parties; and
• provide you with other services requested by you and as described when collecting the information.

Legal ground for processing of Personal Data

Every processing of personal data must be accompanied by an applicable legal ground. Our processing of personal data is based on the following legal grounds.

Legal obligation

In certain situations, we are required by law to process personal data. The following processing is carried out on the basis of such a legal obligation:

• to implement measures in order to fulfil Tradera's obligation regarding customer awareness, risk assessment and reporting obligations;
• to identify reportable sellers by, among other things, compiling information on sales compensation;
• to determine and verify that the information is reliable by reviewing the provided information against existing information and information from third parties;
• to provide, and enable you to use, payment services;
• to detect and prevent money laundering, fraud, abuse and security incidents; and
• to comply with anti-money laundering legal requirements, as well as payment, accounting and tax legislation.

Fulfilment of contract

We process certain Personal Data in order to fulfil the obligations we have during the time you have an account registered with us, for example:

• to establish your account;
• to fulfil our obligations towards you under the User agreement; and
• to manage your account while you have an active account with us, and for certain periods thereafter.

Consent

We ask for your consent to process certain personal data. If you have given your consent, you can withdraw it at any time by contacting us at privacy@tradera.com. You can read more about consent further down in this Privacy statement, in the section describing your rights.

We carry out the following processing based on your consent:

• to target marketing measures to you by delivering marketing materials about Tradera products and online services and the products and services of other businesses. We may also process your personal data to tailor certain services or user experiences in order to better cater to our understanding of your interests;
• to provide personalized services offered by Tradera on third-party websites and online services. We may use your personal data and additional information collected in accordance with this Privacy statement to provide a targeted display, feature or offer to you on third-party websites. We may use cookies and other tracking technologies to provide these online services and/or work together with other third-parties such as advertising or analytics companies to provide these online services;
• to provide you with location-specific options, functionality or offers if you choose to share your geolocation information through the services. We will use this information to enhance the security of the websites and services and provide you with location-based services, such as advertising, search results, and other personalized content;
• to make it easier for you to find and connect with other users, we may use the information you share with the service to suggest connections between you and people you may know. For example, we may associate information that we learn about you through your and your contacts’ use of the services, and information you and others provide to suggest people you may know or may want to transact with through our services. Social networking services and features designed to simplify your use of the services with others vary depending on the type service; and
• to respond to your requests, for example to contact you about a question you submitted to our customer service team.

Legitimate interest

Lastly, we also process certain personal data based on our legitimate interest. This means that our interest in processing your personal data outweighs your rights and freedoms in relation to the purpose for which we process the data. We process the following personal data based on our legitimate interest:

• to enforce the terms of our User agreement,
• to manage our everyday business needs; and
• for monitoring and analytics purposes.

Use of personal data for marketing purposes

With your consent obtained in a manner consistent with applicable regulations and this Privacy statement, we may use your personal data to;

• tell you about our websites, applications, services and tools;
• deliver targeted marketing and promotional offers based on your communication preferences; and
• personalize our services and measure and improve our advertising, based on your ad customization preferences.

We do not sell or rent your personal data to third parties for their marketing purposes without your explicit consent.

Termination of use of personal data for marketing purposes

If you do not wish to receive marketing and promotional communications from us, you can indicate your communications preference in your My Tradera- page, or within the direct communication received from us.

You can review our Cookie policy to learn more information on how to opt-out of third party cookies for advertising.

If you withdraw your consent for the use or disclosure of your personal data for the other purposes set out in this Privacy statement we may not be able to continue to allow you to have access to our websites, applications, or tools, or to provide you with some or all of the services and customer support offered to our users and authorised under this Privacy statement and our User agreement. You can read more about consent further down in this Privacy statement, in the section describing your rights.

Disclosure of personal data

We disclose personal data in order to fulfil legal requirements, enforce our policies, respond to claims that a listing or other content violates the rights of others, or protect anyone’s rights, property, or safety. Such information will be disclosed only in accordance with applicable laws and regulations.

We may share your personal data with:

• Our service providers who help with our business operations (such as, but not limited to, customer service, fraud investigations, bill collection, affiliate and reward programs and website operations).
• Other Tradera users, whether located in or outside of your country of residence, as authorized by you or your use of our websites, services, applications or tools. For example, where you are involved in a transaction with another user, the other user may view your e-mail address and request and obtain your contact information and postal address to help complete the transaction.
• Other third parties to whom you explicitly request us to send your personal data (or to third parties whom you are otherwise explicitly notified of and consent to when using a specific service).
• Supervisory authorities or other regulatory authorities, law enforcement or authorised third-parties, in response to a verified request relating to a criminal investigation or alleged illegal activity, for example money laundering or any other activity that may expose us, you, or any other Tradera user to legal liability. In such events, we will disclose, as allowed by applicable law, information relevant and necessary to the investigation or inquiry, such as name, personal identification number, city, state or province, postal code, telephone number, e-mail address, User-ID history, IP-address, fraud complaints, bidding and listing history.
• Tax authorities for the purpose of providing tax authorities with information prior to decisions on correct compliance with relevant legal obligations. In such cases, to the extent required or permitted by applicable law, we will disclose such information that is relevant for the tax authority's assessment, such as full name, primary address, social security number, tax identification number, place of birth and VAT registration number. Some of our users are closely held companies or sole traders, for whom data that relates to their business may constitute personal data either directly or indirectly. Under such circumstances we may also disclose information stating company registration number or foreign company registration number.
• Service providers who provide services relating to verification of beneficial ownership, PEP (Politically Exposed Person) and sanctions lists, in this case Trapets.
• Credit bureaus to which we may report information relating to your account, including information on late payments, missed payments, or other violations of your account that may be reflected in your credit report, as allowed by applicable law.
• Participating right holders in the Tradera VeRO- Program who are subject to a confidentiality agreement, as we in our sole discretion believe necessary or appropriate in relation to an investigation of fraud, intellectual property infringement, piracy, or other unlawful activity. In such events, we will disclose, as allowed by applicable laws, name, personal identification number, street address, city, state, provincial postal code, country, phone number, e-mail address and company name.
• Other business entities in the event we become subject to a merger or acquisition by that business entity. In such event, we will require that the new combined entity follow this Privacy statement with respect to your personal data. If your personal data will be used or disclosed for any purposes not set out in this notice, you will receive prior notification and we will ask you for your consent where applicable.

Tradera user-ID

Your user-ID is displayed throughout Tradera (and, as a result, it is available to the public), and is connected to all of your Tradera activity. Other people can see your bids, purchases, items for sale, storefronts, feedback, ratings and associated comments. Other users can also see any information you choose to share in your profile. Notices sent to other community members about suspicious activity and policy violations on our sites refer to user-IDs and specific items. Therefore, if you associate your name with your user-ID, the people to whom you have disclosed your name will be able to identify your Tradera activities.

If you access our websites from a public or shared computer or a computer in an internet café, certain information about you may also be visible to other individuals who use the computer after you.

Personal data shared with other users

Tradera enables you to share personal and financial information to complete transactions and collect payments. We encourage you to disclose your privacy practices and respect the privacy of other users. We are not responsible for information that you choose to share with other users and partners and therefore we encourage you, where appropriate, to evaluate the privacy and security policies of your trading partner before entering into a transaction and choosing to share your information. In order to further protect your privacy, we allow only limited access to other users’ contact, shipping and financial information to facilitate your transactions and collect payments. You must, under all circumstances, provide other users the option to request to be deleted from your database and a chance to review the information you have collected about them.

You agree to use another user’s personal data strictly for:

• Tradera transaction-related purposes, and not for unsolicited marketing messages;
• using services offered through Tradera (such as payment, shipping, delivery and fraud complaints); or
• specific purposes to which the user expressly chooses or consents to.

Cookies, web beacons and similar technologies

When you visit or interact with our websites, services, applications, communicating channels (such as e-mail), and tools, we or our authorised service providers may use cookies, web beacons, and other similar technologies for storing information to help provide you with a better, faster, and safer experience, and for advertising purposes. To read more detailed information on our use of these technologies, see our Cookie policy.

Prohibition of spam, spyware and identity theft

We do not tolerate spam. To report Tradera-related spam or spoof e-mails to us, please forward the e-mail to abuse@tradera.com.

We may automatically scan and manually filter messages to check for spam, viruses, phishing attacks and other malicious activity or illegal or prohibited content, but we do not permanently store messages sent through these tools.

Accessing, reviewing and changing your personal data

Your password is the key to your account. Use unique numbers, letters and special characters, and do not disclose your Tradera-password to anyone. If you do share your password or your personal data with others, remember that you are responsible for all activity on your account. If you lose control of your password, you may also lose control over your personal data and may be subject to obligations due to actions taken on your behalf. Therefore, if your password has been compromised for any reason, you should immediately notify Tradera and change your password.

You can access, review and change most of your personal data by logging in to Tradera. You may edit your personal data in your account profile settings. You must promptly update your personal data in the event of changes or if it is or becomes inaccurate. If you make a public posting on the site, you may not always be able to change or remove it. However, we will honour any statutory right that you may have pursuant to laws to correct or erase your personal data.

Transfer of Personal Data

We store and process your personal data on our servers located in Sweden and elsewhere in the world and are committed to providing appropriate protection for your personal data where such data is transferred outside of the EU/EEA. In the event that we share information with, for example, an IT provider located outside the EU/EEA, we take appropriate security measures such as the European Commission's standard contractual clauses. The European Commission's standard contractual clauses are available on their website.

We use physical, technical and organizational security measures to, in relation to the amount and sensitivity of personal data, prevent unauthorised processing, including but not limited to, unauthorised access to, acquisition and use of, loss, destruction, or damage to any users personal data. To exemplify, we use safeguards such as firewalls and data encryption, physical access controls to our data centers, and information access authorization controls.

Termination of account and data retention

Upon your request, and subject to the provisions in this section, we will close your account and, as soon as reasonably possible, erase your personal data so that it cannot be viewed by other users. Erasure of personal data will be based on your account status and in accordance with applicable law. At our own discretion we may also terminate or deactivate inactive accounts, or accounts that are used in violation with the terms of our User agreement.

We never store personal data for a longer period than is necessary to comply with the purpose for which it was collected. For example, we store certain information for a longer period of time if required by applicable law, such as accounting- and tax regulations. In general, personal data from terminated or inactive accounts will be deleted or anonymised as soon as reasonably possibly after the account is terminated or deactivated. We may retain personal data from terminated or inactive accounts if:

• it is in our legitimate business interests and not prohibited by law such as collection of fees owed, resolution of disputes or to enforce our User agreement;
• we need to be able to defend ourselves against legal claims or otherwise take legal action
• in the event of, for example, a dispute; or
• if we are obliged to retain the personal data to meet legal obligations such as compliance with member state legislation, particularly fraud and money laundering prevention, tax legislation or to otherwise take actions permitted by law.

Provided the above circumstances, personal data will be kept securely and only for as long as necessary.

Your Rights

Subject to limitations set out in privacy regulations applicable in the EU/EEA, you have certain rights in respect of your personal data. Exercising your rights is not accompanied by any costs or fees. We strive to adhere to your rights as soon as possible after you contact us with a request.

Right to information

You have the right to know what information we process about you. The easiest way to find out is to read this Privacy statement.

Right to access

You have the right to request an extract from our register. This is a summary of the personal data we process about you. If you contact us with such a request, we will ask you to identify yourself.

You do not have the right to request access to personal data that does not refer to you.

Right to rectification and completion

If your information changes, for example by changing your name or address, you can rectify these by visiting your My Tradera-page or by contacting us so that we can rectify or complete the information we have about you.

Right to object

You have the right to object to our processing of your personal data. If you wish to do so, please contact us at privacy@tradera.com.

You have the right to object and oppose the processing of your personal data for direct marketing measures. If you object to such processing, we will no longer process your personal data for that purpose and will therefore not be able to offer you all of our services, such as access to certain information.

You may also object to processing carried out by us on the basis of our legitimate interest. In the event of such a request, we will assess whether we have a compelling legitimate interest that nevertheless justifies the continued processing of your personal data and which overrides your interest of non-processing, or whether we need to continue processing the personal data in order to determine, exercise or defend ourselves against legal claims. In the absence of such legitimate interest, we will cease with the objected processing.

Right to transfer and data portability

Upon request for a transfer of your personal data, we will transfer the data in a structured, commonly used and machine-readable format. In some cases, you may also have the right to obtain and transfer your personal data to another controller (data portability). Your right to request transfer or data portability of your personal data is limited to such information that you yourself have provided to us. Our right to process your personal data does not cease after such a transfer.

Consent

If you provided your consent to us for certain processing, you may withdraw it at any time, you can read more about this above in the section where we explain which processing we carry out on the basis of your consent. A withdrawn consent does not affect the lawfulness of the processing we carried out while we had your consent. We may not however, continue to process your personal data on the basis of your consent from the moment you withdraw it.

However, if you withdraw your consent, we will continue to process personal data that is based on another legal ground, such as legal obligation, legitimate interest and fulfilment of contract.

Complaints and comments

If you believe that we have not processed your personal data correctly, please contact us with your comments at privacy@tradera.com.

You may also, if you are not satisfied with the way we address your concerns, lodge a complaint with the applicable supervisory authority which in Sweden is Integritetsskyddsmyndigheten. You can find their contact details at www.imy.se.

Contact Details

Tradera Marketplace AB, org no 556569-4642

Solnavägen 3H

113 63 Stockholm, Sweden

+46771-392 000

privacy@tradera.com