For users residing outside of the UK and the European Economic Area, the following applies to
you: If you access our Sites or Services, or otherwise interact with Neesun, you agree to be bound
by the terms of this Privacy Policy, including our Cookies & Similar Technologies Policy and
Cookies & Similar Technologies Disclosures, which describe our use of cookies, web beacons,
and other similar technologies and your choices with respect to our use of these technologies for
interest-based advertising. This Privacy Policy applies retroactively to your interactions with Neesun
before becoming a Member or agreeing to this Policy. If you do not agree to this Privacy Policy,
you may not use the Sites and Services.
For users located in the United States, including California Residents, you may be entitled
to additional rights or disclosures, please see the United States Regional Privacy Policy
for information about your privacy rights under certain US state laws, which is
incorporated into this policy.
Privacy Policy
1. What Information We Collect and Receive
2. How We Use Your Information and Our Legal Basis
3. How We Share Your Information
4. How We Transfer Your Information
5. How We Protect Your Information
6. How Long We Store Your Information
7. Your Rights & Choices
8. Your Responsibilities
9. Privacy Policy Changes
10. Additional Disclosures for United States Residents
11. Our Relationship With You
12. Contact Us
At Neesun, we care deeply about privacy. We strive to be transparent about what information we
collect, and how we use, share, and retain it.
This Privacy Policy explains our privacy practices for Neesun.com (which we’ll refer to as the "Site"),
Neesun’s mobile applications, including the Neesun App and the Neesun Seller App (together, the "Apps"),
Neesun Payments, Pattern by Neesun, Neesun’s public Application Programming Interface (the “API”), and
other services provided by the Neesun companies (the “Services”) set out at Section 11 (which we’ll
refer to as "Neesun," or as "we," "us," and "our"). We’ll use the term “Services” to refer collectively
to the Site, the Apps, Neesun Payments, Pattern by Neesun, and the API.as well as our Cookies & Similar Technologies Policy and Cookies
This policy applies to our registered buyers (“Buyers”) and sellers (“Sellers”) (together, our
“Members”), those who purchase items on Neesun without an account (“Guests”), and anyone else
who visits our Sites or uses our Services (together with our Members and Guests, “you” and
“your”). This Privacy Policy, & Similar Technologies Disclosures apply to all of your interactions with our Sites and our
Services. If you are not a registered Member or if you are a Guest, please see our Non-Member
Privacy Policy for further information about how we may collect and use your information,
available here.
This policy does not apply to the practices of Neesun Sellers. It also does not apply to any third
parties that you may choose to share information with when you use the Services. Please note
that the collection and use of your information by these third parties is subject to their own privacy
policies and terms. You should understand the privacy and security practices of any third party
before you share information with them.
It is important for you to understand how we use your information. You should read this policy in
full, but some key points to help you navigate the policy are:
● Neesun’s mission is to Keep Commerce Human. We are the marketplace for unique items
from real people. We stay true to this by connecting buyers with items made, designed,
handpicked, or sourced by creative sellers around the world.
● By accepting our Terms of Use and this Privacy Policy, or by using any of our Services,
you confirm that you have read and understand, and in countries outside the United
Kingdom (“UK”) or European Economic Area (“EEA”) agree to this policy.
● We collect and use your information to provide and improve our Services, to protect the
security and integrity of our Services, and to comply with our legal obligations. To learn
more about the information we collect and how we use it, see Section 1 and Section 2
below.
● We share your information with other Neesun group companies, trusted partners, and service
providers to provide our Services, for security purposes, to understand how you use and
interact with our Services, and to meet our legal obligations. To learn more, see Section
3.
● You have certain rights over our use of your data, including the right to object to certain
types of processing that we carry out. For more information, see Section 7.
● Depending on your location, different Neesun entities may provide different parts of the
Services to you. For more information on your relevant service provider(s) and data
controller(s), along with details of how to contact them, see Section 12.
● If you have any questions about this Privacy Policy, or wish to exercise your rights, see
Section 11 for further information about how to contact us. You can learn more about
Neesun’s policies by visiting our House Rules and Help Center.
What Information We Collect and Receive
In the course of providing our Services, we collect and receive information that directly or indirectly
relates to you in different ways and from different sources, which we have set out below. The
1. capitalised terms in this Section 1 are definitions that we use throughout this Policy, so please
refer back to this table as necessary.
Information Category Description of Information Collected
Information You Provide to Us
You provide certain information to Neesun directly when you sign up for an Neesun account or
otherwise use the Services.
Buyer Account Information
We collect certain information from you when
you set up an Neesun Buyer account and use
the Services.
● Buyer Details: Your name, email
address, and phone number
● Buyer Payment Information: Your
billing address and payment
information (e.g., credit or debit card
details or other payment credentials,
like PayPal)
● Delivery Information: Your delivery
address, contact name, and phone
number
● Regional Information: Your country,
preferred language, and currency
Seller Account Information
We collect certain information from you when
you set up an Neesun Seller account, and use
the Services.
● Seller Details: Your name, email
address, country of residence, phone
number, date of birth, taxpayer
address, and Neesun shop name. For
sellers established as incorporated or
other form of legal entities, the name,
address and date of birth of all
individuals who own or control 25% or
more of the entity (“beneficial owners”)
● Seller Payment Information: Your
bank country, bank account details,
billing address and other payment
information (e.g., credit or debit card
details or PayPal credentials)
● Shop Preferences: Your preferred
language, country, and currency
● Business/Tax Information: Your tax
and government-issued identification
numbersBuyer Public Profile Information
As a Buyer on Neesun, you can choose to
provide your name and other information in
connection with your account and activity.
Other people will be able to see your profile
information. Your saved product listings that
are grouped by you (“Favourites and
Collections”) may also be visible publicly,
depending on your settings. You can edit,
remove, or limit this information through your
account settings.
Seller Public Profile Information
As a Seller on Neesun, you must provide certain
information for your shop. You can also
choose to share other information (such as
birthday, gender or location) in connection
with your account and activity. Other people
will be able to see your profile information.
You can edit, remove, or limit this information
through your account settings.
● Regional Information: Your country,
preferred language, and currency
● Your name
● Birthday
● Gender
● Location
● Profile photo
● Your bio
● Favourites and Collections
● Who you follow and your followers
● Linked third-party accounts (e.g.,
social media, “sign-in with”)
● Product reviews
● Registry information (e.g., name,
partner name, wedding or special
event date, delivery information, items
on your registry)
● Shop name
● Your name
● Birthday
● Gender
● Location and/or business address (if
applicable)
● Profile photo
● Your bio, shop photos, and shop links
● Holiday mode announcements
● Linked third-party accounts (e.g.,
social, “sign-in with”)Seller Verification Information
As a Seller on Neesun, you must provide certain
information where applicable to help us verify
your identity and prevent fraud.
Biometric Data
Where applicable, we use certain information
about your physical characteristics to perform
seller verification checks.
Guest Checkout Information
You can purchase items on Neesun without an
account through our ‘Guest Checkout’
feature. We need certain information about
you to facilitate your purchase and complete
the transaction.
Transaction Information
When you buy or sell items on Neesun, we
collect information about the order as part of
your transaction history.
Photographs and Videos
You may enable the Apps to access your
mobile device’s camera to upload
photographs and videos to Neesun, or you can
upload photos and videos directly through our
Site.
Forums/Community Information
We offer several features that allow users to
connect and communicate in public or semi-
public spaces, such as Forums and Teams,
which are a part of the Neesun Community
space.
Messages Information ● Shop policies (e.g., returns)
● Selfie: The live photo(s) of your face
you take when onboarding
● Government ID: A copy of your
government-issued photo ID
● A biometric scan of your facial
geometry extracted from your
Government ID and from your Selfie
● Your name
● Email address
● Phone number
● Billing name and address
● Credit or debit card information or
other payment method
● Delivery name and address
● Information about your transactions on
our Services, such as the shop name,
items purchased, Buyer’s name,
purchase price, and date of the
transaction
● Photos and videos you upload to your
profile, our forums, as part of product
reviews or through Neesun’s other
products and features (e.g., search,
gifting)
● Content you post in our community
spaces
● Any additional information you choose
to provide
● Messages Content: Content (including
text and photos) you share with, orYou can contact another Member using Neesun
Messages for a variety of reasons, such as
customer support, personalising products, or
product and order questions.
receive from, other Members through
our Messages function
● Messages Metadata: Metadata about
content (such as the location where a
photo was taken) and Messages
(such as the date and time of the
message)
Promotion Information
From time to time, Neesun runs promotional
offers, contests and sweepstakes.
● In general, we collect the following
information about entrants:
○ Email address
○ Social handle (if social
promotion)
● We’ll tell you about any other data we
collect in the terms of the relevant
promotion, available on Our House
Rules page
Customer Support Information
We collect certain information when you
engage with our customer support teams.
● Your communications with and
through our support team and tools,
including the automated and live chat
features on our Site
● Any additional information you
provide, including transaction
information (e.g., order number and
transaction ID), and/or device and
technical information (e.g., IP address
for troubleshooting)
Survey Responses and Market Research
You may choose to provide certain
information in connection with surveys,
research, and other feedback mechanisms.
● Demographic information, including
your age, gender, work status, region,
and neighbourhood type (e.g., rural,
suburban, or urban), and if you are
located in the US, your income,
education, and race/ethnicity
● Business and selling information, such
as the size of your business, any other
selling channels you use, and your
business income breakdown (by
percentage) for each selling channel
● Any additional information you may
provide
Information We Collect AutomaticallyNeesun automatically receives and records information from your browser and/or your mobile
device when you visit the Site, use the Apps, or use certain features of the Services (even if
you do not have an Neesun account).
Browser and Device Information
Neesun automatically receives and records
information from your browser and/or your
mobile device when you visit the Site, use the
Apps, or otherwise instal, access, or use
certain features of the Services.
● Browser and device information,
including your IP address, device
type, hardware model, operating
system information, unique device
identifier, and your detected language
● App information, including app
version, app usage and debugging
information, and app ID
Service Usage Information
We collect certain information about your use
of the Services, such as how often you use
the Apps, how you interact with the Services,
and actions you take when interacting with
the Site and Apps, in order to help us ensure
the Services are functioning correctly, tailor
your experience, and improve our offerings.
We may collect this information from a subset
of users when testing new products or
features.
● Usage Information: Information about
your interaction with our Sites and
Apps, including how often you use the
Sites and/or Apps, what happens
within the Sites and/or Apps, what
listings you view and interact with,
how you navigate the Site (including
your mouse movements, searches
you make, and pages you visit) or
other actions you take (such as
clicking on particular parts of the Site
or Apps or entering text into form
fields)
● Diagnostic and Troubleshooting
Information: Information about how
our Services are performing when you
use them, like service-related
diagnostic and performance
information, including timestamps,
crash data, website performance logs
and error messages or reports
General Location Information
We collect your general location information
for things like tailoring our Services to your
location, to estimate postage costs, and for
security, sanctions and fraud prevention
purposes. See Section 2 for further details on
● IP addresses and other information
like your zip or pincode, to estimate
your general location (e.g., country,
state, or city)
● The general location you set in your
regional preferences on the Site orhow we use this information. Apps
Precise Location Information
We collect your precise geo-location where
you have given us permission to do so
through your device-based settings. See
Section 2 for further detail.
● Your precise geo-location collected
from your device
Cookie Information ● For more information about these
online tools and how we use them,
see our Cookies & Similar
Technologies Policy
Information We Receive from Third Parties
We receive certain information about you from third parties.
Information from our Payment Processors
and Other Entities
We receive certain information about Buyers
from third parties such as payment
processors or fraud prevention partners, who
help us to process transactions, provide our
Services and prevent fraudulent or illegal
activity.
● Your name
● Your billing address
● Your email address
● Your phone number
● Fraud prevention data such as risk-
scoring
Information from Advertising and
Marketing Partners
We receive certain information about you
from our advertising and marketing partners,
including in some instances what marketing
content you viewed or clicked, or the actions
you take on our Sites and Apps. This
information helps us determine how our
marketing campaigns and other customer
interactions may contribute to sales,
conversions, or other goals and also allows
us to tailor ads for products and services that
may be of interest to you.
● We may receive from our third-party
partners, for example, attribution
information via cookies and UTM tags
in URLs to help us determine the
source of the traffic to Neesun or track
the performance of a specific
campaign
● We may also receive responses to
marketing emails and advertisements,
responses to offers, and audience
information from partners who you
have given consent to share that
information with us
● Demographic information, like your
age, gender, household composition,
estimated income, interests, and
purchasing habits
Analytics Information ● We use third-party software to recordWe use data analytics software to ensure Site
and App functionality and to improve the
Services. For more information, see Neesun's
Cookies & Similar Technologies Policy and
Cookies & Similar Technologies Disclosures.
information such as how often you use
the Site and/or Apps, what happens
within the Apps or on our Site (e.g.,
how you interact with our Services),
aggregated usage, performance data,
app errors and debugging information,
and, in the case of Apps, where the
Apps were downloaded from
Third-Party Application Information
We receive certain information when you
engage with third-party applications or
platform integrations on other sites and apps.
● When you link our Services with third-
party applications or integrations (e.g.,
linked third-party accounts), we
receive your contact information,
including your name and email
address, and any additional
information you authorise the third
party to share with us (for example,
social media accounts and/or sign-in
functionality)
● Business partners such as delivery
partners may share business
information such as package and
transaction data
Non-Member Information
Neesun receives or obtains information about a
person who is not yet a registered Neesun
Member or who is a Guest, and has not
directly made a purchase (a “Non-Member”)
in connection with certain Neesun features, such
as when a Non-Member subscribes to an
Neesun newsletter, a Member invites a Non-
Member to visit the Site, a Member uploads
Non-Member information to send a gift, or
when a Member sends a gift card code to a
Non-Member. For more information, please
see our Non-Member Privacy Policy,
available here.
● Non-Member email address
● Non-Member IP address
● Non-Member physical postal address
● Non-Member special occasions and
interests
2. How We Use Your Information and Our Legal Basis
When you access or use the Services or interact with our Sites and/or Apps, we collect, use,
share, and otherwise process your information for the purposes described in this policy. To the
extent required by applicable law, we rely on a number of legal bases to use your information in
these ways. If you reside outside the European Economic Area (“EEA”), Switzerland or the United
Kingdom (“UK”) (together referred to as the “European Region”), the legal bases on which we rely
may differ from those listed below.Why and How We Use Your Information Information Categories Used
Where necessary to perform our contract with you
We use certain information that is necessary for us to provide you with the Services and
perform our Terms of Use or other relevant contract(s) with you. We will need to close your
account if we cannot process your information for such purposes.
To create and maintain your Neesun account
and provide our Services
We collect certain information to set up your
Neesun account and to allow you to interact with
the Neesun Community.
● Buyer Account Information
● Seller Account Information
● Buyer Public Profile Information
● Seller Public Profile Information
● Browser and Device Information
● Forums/Community Information
● Third-Party Application Information
(where relevant)
To facilitate buying and selling on Neesun
We use certain information to facilitate buying
and selling on Neesun. This may involve us
sharing some of your information with our
third-party partners, including our delivery
partners and our payment partners, to enable
us and our Sellers to provide the Services to
you pursuant to our Terms of Use. Such
partners will process your information in
accordance with their own privacy policies.
For more information on data sharing, please
see Section 3.
● Buyer Account Information
● Seller Account Information
● Seller Verification Information
● General Location Information
● Information from our Payment
Processors
● Guest Checkout Information
● Transaction Information
● Customer Support Information
To provide our Payments service
As an Neesun Seller, you may use our payment
service, Neesun Payments, depending on your
location, to accept various forms of payments
on the Site, Apps, and other Services. You
● Seller Account Information
● Seller Verification Informationwill need to provide certain information to set
up an account.
For more information, see the Neesun Payments
Policy.
To provide Guest Checkout
We allow Guests to purchase items from Neesun
without an account through Guest Checkout.
To promote the safety, security and integrity
of our Services
We process certain information and apply
automated processing techniques and/or
manual (human) review to verify accounts
and related activity, to find and address
violations of our Terms of Use and applicable
policies, to investigate suspicious activity, to
detect, prevent and combat harmful, unsafe,
or unlawful behaviour, including fraud, to
detect and prevent spam and security issues,
and to maintain the integrity of our Service.
To send Service communications
We may send you administrative or account-
related communications about our Services,
including to verify your email address and
mobile telephone number, welcome you to
the Services, confirm a transaction, or notify
you about an order, service availability,
changes to the Services, or updates to this
Policy, our Terms of Use, or other policies.
You may not opt out of receiving service
communications, such as emails or mobile
notifications sent for legal, security, or other
transactional purposes.
To run promotions and sweepstakes ● Guest Checkout Information
● Browser and Device Information
● Transaction Information
● Payment Information
● Buyer Public Profile Information
● Seller Public Profile Information
● Buyer Account Information
● Seller Account Information
● Seller Verification Information
● Browser and Device Information
● Customer Support Information
● Information from our Payment
Processors
● Messages Information
● Buyer Account Information
● Seller Account Information
● Transaction Information
● Guest Checkout Information
● Promotion InformationWe use certain information about entrants to
our promotions, and sweepstakes, to manage
the relevant promotion and, where applicable,
identify the relevant winner(s), and to
determine eligibility for other incentive
programmes we may offer to Buyers and
Sellers
● Buyer Account Information
● Seller Account Information
● Buyer Public Profile Information
● Seller Public Profile Information
To provide support and resolve order issues
We use your information to respond to
requests for support (via the Apps, Site, or
email) and to respond to customer care and
other inquiries, including via our Customer
Support Chatbot and/or providing telephone-
based customer support.
We may also use your information to resolve
any cases, order issues, or dispute(s)
between you and another Member.
● Buyer Account Information
● Seller Account Information
● Guest Checkout Information
● Transaction Information
● Service Usage Information
● General Location Information
● Customer Support Information
● Messages Information
To detect and monitor suspicious activity
We process certain information about our
Members to safeguard against fraud, scams,
and security threats, including as part of
onboarding.
This information is collected by us and/or our
fraud vendors who may also share fraud
insights with other companies, including other
online marketplaces.
● Buyer Account Information
● Seller Account Information
● Seller Verification Information
● General Location Information
● Transaction Information
● Browser and Device Information
● Messages Information
Where necessary to comply with our legal obligations
Our Services are subject to laws and regulations that require us to collect, use, and store your
information in certain ways. Where applicable, if you do not provide the information required
by law, we will have to close your account.
Why and How We Use Your Information Information Categories Used
To comply with local laws on selling goods ● Buyer Public Profile InformationIn certain countries we are required to display
certain information about Sellers on Neesun
(e.g., as required under the Digital Services
Act).
To comply with our obligations to verify
Sellers
Certain countries have laws requiring us to
verify the identity of our Sellers and to take
measures to prevent money laundering
and/or terrorist financing on the Services.
These laws include the EU Digital Services
Act, the Irish Criminal Justice (Money
Laundering and Terrorist Financing) Act
2010, the United States Integrity, Notification,
and Fairness in Online Retail Marketplaces
for Consumers Act (“INFORM”) and others.
To comply with these laws, we collect and
store certain information about our Sellers.
To comply with other legal and regulatory
obligations
Neesun may also use, access, preserve, or
release your information in response to legal
requests, like search warrants, court orders,
production orders, regulatory requests, or
subpoenas. We also may do so to comply
with our legal and regulatory obligations,
including in response to lawful requests by
public authorities (including tax authorities)
and to meet legitimate national security or law
enforcement requirements.
Examples of applicable laws that could give
rise to an obligation requiring us to process
and/or disclose your information include:
Civil, commercial, criminal, consumer
protection, and litigation matters: where
we are in receipt of an order to disclose
information or a regulatory inquiry (e.g., under
the Irish Competition and Consumer
Protection Act 2014, the Consumer Rights
Act 2022, or the Liability For Defective
Products Act, 1991) or where we have a legal
obligation to disclose data to a law
● Seller Public Profile Information
● Buyer Account Information
● Seller Account information
● Seller Account Information
● Seller Verification Information
The categories of information depend on the
specific circumstances of each request or
obligation. Only the information necessary to
comply with the relevant legal obligation will
be processed. Depending on the
circumstances, it could include the following:
● Buyer Public Profile Information
● Seller Public Profile Information
● Buyer Account Information
● Seller Account Information
● Seller Verification Information
● Information from our Payment
Processors
● General Location Information
● Browser and Device Information
● Messages Informationenforcement body.
Corporate and taxation matters: to comply
with our corporation and taxation obligations,
such as those under the Irish Companies Act
2014, the Taxes Consolidation Act 1997,
Council Directive (EU) 2021/514 (“DAC7”),
and the Internal Revenue Service code.
Regulatory matters: to comply with our
regulatory obligations, including as an e-
commerce platform arising under the P2B
Regulation, the Digital Services Act, and
similar regulations.
Where necessary for our legitimate interests
We rely on our legitimate interests or those of third parties (like other Buyers and Sellers, and
in some cases, the general public) where they are not outweighed by your rights and
freedoms. In the EEA, UK, and other countries you have the right to object to, and seek the
restriction of, this processing. To learn more, see Section 7.
Why and How We Use Your Information Legitimate Interests
Relied On
Information
Categories Used
To understand how you use our Services and
improve your experience on Neesun
We use certain information to improve our
Services, including to ensure the Services are
functioning correctly, to help Sellers find the
best ways to market and sell their products on
Neesun, and for Buyers to discover such
products. We also use this information to
identify and support high-performing Sellers,
and for general research and aggregate
reporting.
It is in our legitimate
interests to
understand how our
Services are being
used, and to explore
and unlock ways to
develop and grow our
business.
It is in our legitimate
interests to better
understand our
Members by logging
their preferences,
purchases and other
interactions with us,
including identifying
when logged-out
users may already
have an Neesun
account.
It is in our legitimate
interests, and those
● Service
Usage
Information
● Browser and
Device
Information
● Cookie
Information
● Customer
Support
Information
● Survey
Responses
and Market
Research
● Information
from
Advertising
and Marketing
Partners
● Analytics
Information
● General
LocationTo rank your search results
We use certain information to rank your
search results. When a Member or Guest
searches for an item on Neesun, Neesun’s search
engine works to return the most relevant
matches based on the search query and the
Information Categories listed here.
We may also highlight a cross-section of
shops or listings organically, above or
alongside primary search results.
To provide on-platform advertising on our
Sites and Apps
Sellers can purchase paid advertising on Neesun
(“Neesun Ads”). Neesun Ads display a Seller's
listings or shops more prominently on the
Sites and/or Apps (and are marked as “Seller
Ads”). Neesun Ads are displayed in one or more
locations, such as Members’ and Guests’
search results.
To display non-personalised advertising on
third-party platforms and sites
We use your information for non-personalised
ads for our Services on third-party platforms
and sites.
For example, we purchase offsite advertising
of our Members, to
improve the efficiency
of our Services,
troubleshoot errors
with our Services,
increase interest in
our Services, and
obtain insights into
usage patterns of our
Services.
It is in our legitimate
interests, and those
of our Members, to
customise our
Services, including
identifying products
that our Buyers would
be most interested in.
It is in our legitimate
interests, and those
of our Sellers, to help
Sellers reach the
most appropriate
audience for their
goods.
It is in our legitimate
interests to promote
the Services and
listings on third-party
platforms and sites.
Information
● Service
Usage
Information
● Browser and
Device
Information
● Shop
Preferences
● General
Location
Information
● Service
Usage
Information
● Browser and
Device
Information
● General
Location
Information
● Buyer Public
Profile
Information
● Guest
Checkout
Information
● Transaction
Information
● Information
from
Advertising
and Marketing
Partners
● Cookie
Informationfrom a network of participating providers,
such as social networks and search engines.
You may see ads for Neesun on these channels
even if you have opted out of personalised
advertisements.
If you are a Seller, we may use information
about you in order to feature you in marketing
and advocacy materials, and to feature you
and your shop on and off the platform, as
provided for in Neesun’s Terms of Use.
To measure the performance of advertising
on our Sites and Apps and on third-party
platforms and apps
We use your information to measure the
effectiveness of advertising both on our own
Sites and Apps and on third-party platforms
and apps. This includes sharing information
with advertising partners for these purposes.
Your information may be used even where
you optout of personalised advertising (for
example, we may use your information to
measure the performance of non-
personalised advertising).
To facilitate campaigns, surveys, and
petitions
Members have the ability to sign onto
campaigns, surveys, or petitions for causes
they care about on our advocacy website or
to donate to causes during checkout. To
facilitate this, we need to collect and use
certain information about our Members.
To keep our Services safe and secure
We process your information and, in some
cases, apply automated processing and
manual (i.e., human) review to maintain the
security and integrity of our Services and
prevent security risks and other harms. This
involves taking steps to detect, investigate
and otherwise protect our community against
abuse, harassment, intellectual property
It is in our legitimate
interests to promote
the Services and
understand how our
advertising is
performing both on
our Sites and Apps
and on third-party
platforms and apps.
It is in our legitimate
interests and our
Members’ interests to
provide these
services and to
conduct surveys to
help us in improving
our Services.
It is in our legitimate
interests, and those
of our Members, to
ensure the security of
our Services, to verify
accounts and activity
and to combat
harmful or
inappropriate conduct
or content.
● Information
from
Advertising
and Marketing
Partners
● Cookie
Information
● Seller Public
Profile
Information
● Seller Account
Information
● Neesun
Payments
Information
(for charitable
donations)
● Buyer Public
Profile
Information
● Seller Public
Profile
Information
● Buyer
Account
Information
● Seller Accountinfringement, crime, illegal activity, suspected
fraud, harm, suspected violations of Neesun’s
Terms of Use and other policies, including
resolving disputes between Members related
to the foregoing.
It is in our legitimate
interests, and those
of our Members and
the general public to
enforce our House
Rules, Terms of Use
and associated
policies, including to
prevent or address
fraud, offsite
transactions and
illegal activities and
to resolve disputes
between Members.
To protect our legal rights
We may also retain, preserve, disclose, or
review your information to protect, establish,
or exercise our legal rights or defend against
impending or asserted legal claims, including
to collect a debt or address a violation of our
Terms of Use and policies.
It is in our legitimate
interests to seek legal
advice and protect
ourselves (including
our rights, personnel,
intellectual property
or platform), our
Members or others,
including as part of
resolution process, or
in respect of
regulatory inquiries,
litigation or any other
dispute.
To share information with law enforcement
and respond to legal requests
We may share your information with a third
party, including law enforcement authorities,
even where not compelled by law when we
believe in good faith that such use and/or
disclosure is reasonably necessary to detect,
prevent or prosecute illegal activity or to
prevent imminent death or imminent bodily
harm.
It is in our legitimate
interests, and those
interests of the
general public, to
share information
with third parties,
including as part of
investigations or
regulatory inquiries,
to detect, investigate
and prosecute illegal
activity or to prevent
Information
● Seller
Verification
Information
● Transaction
Information
● Messages
Information
● Service
Usage
Information
● Buyer Public
Profile
Information
● Seller Public
Profile
Information
● Buyer
Account
Information
● Seller Account
Information
● Seller
Verification
Information
● Transaction
Information
● Service
Usage
Information
● Messages
Information
● Buyer Public
Profile
Information
● Seller Public
Profile
Information
● Buyer
Account
Information
● Seller Account
Information
● SellerThe categories of information that we access,
preserve, use and share for these purposes
will depend on the specific circumstances.
To learn more about how and why Neesun
shares information in these circumstances,
see Section 3 and review our Requests for
Information Policy.
In the event of a business reorganisation
In some cases, Neesun may choose to
reorganise its business. In these types of
transactions (such as a sale, merger,
liquidation, receivership, reorganisation, or
transfer of all or substantially all of Neesun’s
assets), Member information is typically one
of the business assets that is transferred.
To share when Sellers were last active and
average response rate
We may display when Sellers were last active
on the Site or App by visiting their profile. This
status indicator reflects when a Seller last
completed a certain Seller activity.
We also display the average time it takes
Sellers to respond to messages.
To share information with our service
providers and business partners
We share certain information with our service
providers and business partners, as detailed
in Section 3.
death or imminent
bodily harm.
Such transactions
may be necessary
and in our legitimate
interests, particularly
our interest in making
decisions that enable
our business to
develop over the long
term.
It is in our legitimate
interests and those of
our Members, to
improve our Services
and assist in
connecting our
Members.
It is in our legitimate
interests, and those
of our Members, to
engage service
providers and
partners to assist in
the provision of the
Services
Verification
Information
● Transaction
Information
● Messages
Information
● Service
Usage
Information
● Buyer Public
Profile
Information
● Seller Public
Profile
Information
● Buyer
Account
Information
● Seller Account
Information
● Seller Activity
Status and
Average
Response
Rate
● Buyer
Account
Information
● Seller Account
Information
● Buyer Public
Profile
Information
● Seller Public
Profile
Information
● Seller
Verification
Information
● Informationfrom our
Payment
Processors
● Transaction
Information
● Customer
Support
Information
● Messages
Information
Where you provide your consent
When we use your information based on your consent, you have the right to withdraw your
consent at any time on a go-forward basis (meaning our prior use of your data will not be
affected). You may change your device-based or in-app settings anytime.
To send you email marketing
In certain countries (such as those in the
European Region), we may need your
consent to send you email marketing
messages. You will be given the opportunity
to opt out of each marketing communication
that we send.
● Buyer Account Information
● Seller Account Information
● Browser and Device Information
● Transaction Information
● Information from Advertising and
Marketing Partners
● Service Usage Information
In the European Region, to personalise your
experience on the Sites and Apps
For users in the EEA and UK, we rely on your
consent to personalise your experience on
the Sites and Apps, including to help you
search for and discover relevant items.
● Service Usage Information
● Browser and Device Information
● General Location Information
● Transaction Information
● Information from Advertising and
Marketing Partners
● Guest Checkout Information
● Analytics Information
To personalise the ads you see on third-party
platforms and sites
● Buyer DetailsWe rely on your consent to personalise the
ads you see on third-party platforms and
sites.
This targeted marketing includes third-party
tools, including those offered by Facebook
Custom Audience and Google Customer
Match, and we may use analytics aggregated
from your Service Usage Information
including, for example, search keywords,
favourites, browsing history, and purchase
history in combination with the Information
Categories listed here.
● Service Usage Information
● Cookie Information
● Information from Advertising and
Marketing Partners
● Guest Checkout Information
● Analytics Information
To collect your information through the
device-based settings that you have enabled
We rely on your consent to collect your
device-based Precise Location Information
for: (a) local content, to personalise and tailor
the Services, including search results and
recommendations; (b) delivery and delivery
services; and (c) access your camera and/or
photo gallery if you choose to share photos or
media on our Services.
● Precise Location Information
● Photographs and Videos
To verify your identity biometrically
Sellers can choose to verify their identity
through biometric means. For EEA Sellers,
Neesun relies on the Seller’s explicit consent to
collect and process their Biometric Data for
identity verification purposes. We rely on
consent in other countries, subject to local
law requirements
● Biometric Data
● Seller Verification Information
Data used for tasks carried out in the public interest
To preserve, review, and share information to
perform a task in the public interest
In limited circumstances, we will access,
preserve, and share your information with
regulators, law enforcement or others where
necessary to perform a task in the public
interest. For example, we might share your
information to help combat unlawful or
● Buyer Account Information
● Seller Account Information
● Buyer Public Profile Information
● Seller Public Profile Information
● Information from our Paymentharmful behaviour where it is in the public
interest to do so and where the public interest
is laid down by applicable law (including EU
or Member State law), where required.
Processors
● Transaction Information
● Messages Information
Data use to protect your or others’ vital interests
To preserve, review and share information
with law enforcement and others
We may preserve, review, and share
information with law enforcement and others
in circumstances where someone’s vital
interests require protection, such as in the
case of emergencies. For example, we may
need to share information to prevent loss of
life or personal injury of an Neesun Buyer or
Seller or other third party or to prevent crime
or fraud.
● Buyer Account Information
● Seller Account Information
● Buyer Public Profile Information
● Seller Public Profile Information
● Information from our Payment
Processors
● Transaction Information
● Messages Information
3. How We Share Your Information
We share your data with third parties where necessary to provide the Services, comply with our
legal obligations, or for purposes set out in this Privacy Policy, including:
Publicly Displayed Information: By using the Services, certain information about you will be
publicly displayed on the Site and Apps, such as Buyer Public Profile Information and Seller Public
Profile Information (as defined in Section 2). Buyers and Sellers can choose to make certain
information and activities private through their account or Public Profile settings. We will also
display other information connected with your use of the Services, including the date you joined,
information relating to items you review (including the content of the reviews), photos or videos of
items you purchased, your Favourites and Collections, followers, those you follow, comments you
post in our community spaces, and information you decide to share via social networks. Your
reviews of shops or items you’ve purchased may also be shared on other platforms and indexed
by search engines, including Google.
For certain Sellers, some additional information may be publicly displayed. For example, your
business name, shop location, or business registration number associated with your account
(which you may modify and update in your account settings) may be publicly displayed.Neesun Group Companies: We may share some of the information that we collect, such as Buyer
Account Information, Seller Account Information, Seller Verification Information, Service Usage
Information, Device and Browser Information, and Cookie Information, with our corporate
affiliates, which include Neesun, Inc., Neesun Ireland UC, Neesun Payments Ireland Limited, Neesun Gifting
LLC, Neesun UK, Ltd., other Neesun entities, and Neesun-owned affiliates (including Depop Ltd. ), that help
us conduct business around the world (together, the “Neesun Group Companies”). The information
shared among the Neesun Group Companies may be used for the purposes described in this Privacy
Policy and generally to operate our business, including for ID verification purposes, transaction
monitoring, fraud prevention, payment processing, marketing, the issuing of, and use of, gift cards
as a payment method, legal and regulatory compliance, customer support, business
development, user account administration, and IT, technical, and engineering support.
Sellers: We may share aggregated information about your use of the Services to Sellers, for
example, if you are a frequent purchaser or a new Buyer, so they can provide you with better
service and so we can improve our Site and Apps. To improve the shopping experience, we may
collect and display certain Seller information, including when and how they interact and use the
Services, in order to, for example, display when Sellers were last active, or to show average Seller
response times.
Linked Third-Party Websites or Services: Some Members may choose to connect to Neesun or
register an Neesun account using an external third-party application, such as Facebook or Google.
Connecting your Neesun account to third-party applications or services is optional. If you choose to
connect your account to a third-party application, the providers of those services or products may
receive information about you that Neesun, you, or others share with them.
You can choose to link your payment processing or bank account to facilitate paying for purchases
(or to receive payment and disbursements, in the case of Sellers in select markets) through a
third-party service available through the Site or Neesun App. When you register with these third-party
partners, we will tell you what information is collected and what information the third party will
share with Neesun.
Please be aware that when you use third-party sites or services, their own terms and privacy
policies will govern your use of those sites or services in addition to our own terms and privacy
policy.
Business Partners: Neesun works closely with a number of business partners, such as our delivery
and payment partners, that assist us with providing the Services in accordance with our Terms of
Use. When one of these companies assists us in facilitating your transaction, we or they may
need to share information related to the transaction in order to complete your order, monitor
activity on the Sites and Apps, such as transaction activity, or to resolve post purchase support
or transaction related issues, such as refunds or disputes.
Neesun also partners with other businesses to make Sellers’ products available off Neesun. Neesun and
our partners will tell you how we and they collect, use, and share your information.Neesun also offers services or products from affiliated businesses, such as services that assist our
Sellers with accounting or other small business management services. These affiliated
businesses may sell items or services to you through the Services or offer promotions (including
email promotions). In each case, these partners will process your information in accordance with
their own privacy policies. We encourage you to read the privacy policies and ask questions of
third parties before you disclose your information to them.
Professional Advisors, Industry Partners, Authorities, Regulators, and other Entities: We
share your information described in Section 2 with our advisors, consultants, regulators and tax
authorities, law enforcement, government agencies, civil litigants, industry partners (for example,
trade groups), and other entities as reasonably necessary to:
● comply with applicable law or regulations, court orders, subpoenas, legal process, or
government requests;
● detect, investigate, prevent, or address actual or suspected fraud, violations of Neesun’s
Terms of Use, and other illegal activity or security and technical issues; and/or
● protect the rights, property, and safety of our Members, Neesun and the Neesun Group
Companies, or others, including to prevent death or imminent bodily harm.
Advertising and Marketing Services: Neesun works with third-party advertising and marketing
partners for interest-based advertising purposes as described here.
Business Reorganisation: In some cases, Neesun may choose to reorganise its business. In these
types of transactions (such as a sale, merger, liquidation, receivership, or transfer of all or
substantially all of Neesun’s assets), Member information is typically one of the business assets that
is transferred. If Neesun intends to transfer information about you, Neesun will notify you by email or by
putting a notice on the Site and the Apps.
Community Services: We engage third parties to assist in providing Community Services, which
includes the Neesun Forums and Teams, and need to share certain information about you for these
purposes. This may include, for example, Buyer Public Profile Information and Seller Public Profile
Information, the date that you registered on Neesun, as well as your language and regional settings
on the Site. For more information, see our Community Policy.
Service Providers: Neesun also engages third-party companies and individuals (such as research
companies, analytics services, and security providers) to help us operate, provide, and advertise
the Services. These third parties have limited access to your information, may use your
information only to perform these tasks on our behalf, and are prohibited from disclosing or using
your information for other purposes.
In addition, Neesun also engages third-party service providers who facilitate the sharing of data
between similar companies (e.g., retail companies) for purposes such as fraud prevention and
security.
The types of third-party service providers that we work with include:Third-Party Service Providers and Network
What Information We Share
Participants
● Data room facilitators
● Research companies
● Analytics providers
● Security providers
● Software service providers
● Infrastructure and technical service
providers
● Professional service providers
● Customer service or other outsourced
service providers
● Identity verification and fraud
prevention service providers
● Buyer Public Profile Information
● Seller Public Profile Information
● Buyer Account Information
● Seller Account Information
● Seller Verification Information
● Guest Checkout Information
● Transaction Information
● Forum/Community Information
● General Location Information
● Photos and Videos
● Customer Support Information
● Browser and Device Information
● Service Usage Information
● Survey Responses and Market
Research
● Analytics Information
4. How We Transfer Your Information
Neesun operates a global e-commerce platform. By using the Services, you acknowledge that Neesun
will use your information in the United States, Ireland, and any other country where the Neesun Group
Companies operate. Please be aware that the privacy laws and standards in certain countries,
including the rights of authorities to access your information, may differ from those that apply in
the country in which you reside. To the extent that Neesun is deemed to transfer information outside
of the EEA, we rely separately, alternatively, and independently on the following legal bases to
transfer your information:
Adequacy Decisions
Where available, we rely on decisions of the European Commission, known as “adequacy
decisions”, recognising that certain countries offer a level of protection of data that is essentially
equivalent to the EEA. A list of adequacy decisions is available here via the European
Commission website.
Standard Contractual Clauses
Otherwise, we also rely on the European Commission’s Standard Contractual Clauses for the
international and onward transfer of your data outside of the EEA to third countries, including, for
example, to the United States and India. This includes transfers from Neesun Ireland UC to Neesun, Inc.
and other Neesun Group Companies in addition to our service providers. You can request a copy of
our Standard Contractual Clauses by emailing dpo@Neesun.com.
Necessary for the Performance of the Contract Between Neesun and Our UsersYou can choose whether or not to use the Neesun Services. As we operate in countries worldwide
and use technical infrastructure in the US to deliver the Services to you, in accordance with the
contract between us (including our Terms of Use), we transfer your information to the US and to
other jurisdictions as necessary to provide the Services. Simply put, we can’t provide you with the
Services and perform our contract with you without moving your information outside of your home
country, including the UK or EEA.
5. How We Protect Your Information
The security of your information is important to us. We protect your information through technical
and administrative measures designed to mitigate the risk of unlawful or unauthorised access,
destruction, loss, alteration, disclosure, or use of your data. To protect your account, we
encourage you to choose your password carefully and enable two factor authentication (2FA) for
signing in. You can learn more about enhancing your account security in your account settings.
We use Google reCAPTCHA Enterprise and Mastercard’s Ekata (Mastercard’s identity
verification product) in connection with our Services to help prevent spam, fraud, and abuse.
reCAPTCHA Enterprise collects hardware and software information, such as device and
application data, and sends it to Google for purposes of providing, maintaining, and improving
reCAPTCHA Enterprise and for general security purposes. Your use of reCAPTCHA Enterprise
is subject to Google’s Privacy Policy and Terms of Use. Mastercard’s use of your information to
provide us fraud prevention solutions is subject to the Ekata Privacy Policy.
6. How Long We Store Your Information
Neesun will retain your information only for as long as is necessary for the purposes set out in this
Policy, for as long as your account is active, or as needed to comply with our legal obligations,
internal policies, or under applicable law. We decide how long we need information on a case-by-
case basis and depending on the retention laws applicable. The following factors typically affect
the retention period.
Necessity to provide our Services
We keep your information as long as necessary to provide the Services to you. This includes
things like maintaining and improving the performance of our Sites and Apps, keeping our
Services secure, and maintaining appropriate business and financial records. Most of our
retention periods are determined on the basis of this general rule.
Consent-based processing of your data
If we process your data on the basis of consent (including consent to the extended storage), we
store the data for as long as necessary to process it according to your consent or until you
withdraw your consent.Statutory, contractual, or other similar obligations
Neesun will retain and use your information to the extent necessary to comply with our legal
obligations, for example, if we are required to retain your information to comply with applicable
tax/revenue laws, Know Your Customer (“KYC”), and similar obligations. Here's what we consider
when deciding how long to keep your information:
Purpose of Processing Retention Period
Information used to provide you with our
Services
Retained for the lifetime of your account.
Information used for regulatory compliance
and other legal obligations
Neesun will retain and use your information to
the extent necessary to comply with our legal
obligations, for example, if we are required to
retain your information to comply with
applicable tax/revenue laws or our KYC or
similar obligations.
Information used for other legitimate
purposes
We may retain your information for other
legitimate purposes, such as to prevent harm,
investigate possible violations of our House
Rules and policies, promote safety, security
and integrity, or protect Neesun, including our
rights, property, or platform. For example,
information related to orders you place and/or
your experience with our customer support
team, including transcripts of interactions,
may be retained for a period of six years
following account closure.
7. Your Rights & Choices
Certain privacy laws around the world, including the European General Data Protection
Regulation (GDPR), provide users with rights and choices related to their information. Consistent
with those laws, Neesun gives you the choice of accessing, editing, or removing certain information,
as well as choices about how we contact you. In addition, subject to applicable law, you may have
certain rights with respect to your information, such as the following:
● Right to Access: You can access certain information associated with your account by
visiting your account privacy settings. You can request a copy of your information in an
easily accessible format, as well as an explanation of how that information is used. See
this Help Centre article for more information.● Right to Portability: You have the right to receive certain of your information which you
provided in a structured, commonly used and machine-readable format and to transmit
such information to another controller.
● Right to Correction: You have the right to request that we rectify any inaccurate information
about you. You can correct and change certain information through your account settings.
● Right to Restrict Processing: In certain cases, you may also have the right to restrict or
limit the ways in which we use your information.
● Right to Deletion: In certain circumstances, you have the right to request the deletion of
your information, except information we are required to retain by law, regulation, or to
protect the safety, security, rights, and integrity of Neesun. Please note that closing your
account may not free up your email address, username, or shop name (if any) for reuse
on a new account. See this Help Centre article for more information.
● Right to Object: If we process your information based on our legitimate interests as
explained above, or in the public interest, you can object to this processing in certain
circumstances. In such cases, we will stop processing your information unless we have
compelling legitimate grounds to continue processing or where it is needed for legal
reasons.
● Right to Withdraw Consent: Where we rely on consent, you can choose to withdraw your
consent to our processing of your information using, for example, an email unsubscribe
link or your account privacy preferences. If you have consented to share your precise
device location details with us, you can revoke that consent through the settings on your
mobile device. This is without prejudice to your general right to permanently close your
account and delete your information. Please be aware that withdrawing consent will not
affect the lawfulness of processing that happened before you withdraw your consent.
● Automated Decision-Making: You have the right not to be subject to a decision when it is
based solely on automated processing (i.e. an operation that is performed without any
human intervention), if it produces a legal effect or significantly impacts you, except under
certain conditions, for example, where the decision is necessary for our contractual
relationship with you, you have provided your consent, or when Neesun is authorised under
relevant law to conduct such processing. You have the right to request additional
safeguards in these circumstances, such as the right to obtain a human review of the
decision.
● Right to File a Complaint: If you are a resident in the EEA, Switzerland or the UK, you
have the right to lodge a complaint about our data protection practices with the supervisory
authority of your country or state. In the UK, the relevant data protection authority is the
Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire,
SK9 5AF, +44 (0303) 123 1113, casework@ico.org.uk.In Ireland, the relevant data protection authority is the Data Protection Commission, 21
Fitzwilliam Square South, Dublin 2, D02 RD28, +353 017650100 / + 353 1800437737,
email: info@dataprotection.ie or by using this online form.
Please see the United States Regional Privacy Policy for information about your privacy rights
under certain US state laws.
How to Exercise Your Rights and Choices. If you would like to manage, change, limit, correct,
or delete your information, you can do so via your Neesun account settings or profile. Alternatively,
you can exercise any of the rights above, subject to applicable law, through the contact options
set out in Section 11. Once you contact us to exercise any of your rights, we will confirm receipt
of your request. Limiting use of, or deleting, your information may impact features and services
that rely on that information.
Communication Choices. We may send you marketing communications via email, text
messages (SMS), mobile push notifications, and other digital or social media tools, with your
consent where required. You can opt out of receiving marketing text messages by texting STOP.
For marketing emails, you can opt out by using unsubscribe links or visiting your account settings.
Even if you opt out of marketing messages, you may still receive service-related communications
from us.
Certain communications from Neesun are service-related or legally required and you will continue to
receive them even if you opt-out.
8. Your Responsibilities
If you are a Seller on our Services or if you use Neesun’s API, you may receive certain information
and will have legal obligations with respect to certain information. Your privacy responsibilities are
laid out in the Neesun Seller Policy and the Neesun API Terms of Use.
9. Privacy Policy Changes
We may amend or update this policy from time to time. If we believe that the changes are material,
we’ll let you know by posting the changes through the Services and sending you an email or
message about the changes. We encourage you to check back regularly and review any updates.
10. Additional Disclosures for United States Residents
In certain US states, you may be entitled to additional rights or disclosures. Please see our United
States Regional Privacy Policy, where you can learn more about how we use your information
and any additional privacy rights you may have.
11. Contact Us
If you have any questions:
● Contact Neesun’s Support team via our Help Centre
● Chat Support (available on our Site)
● Send an email to Neesun’s Data Protection Officer at help@neesun.co.uk
● Write to us at one of the following addresses:
Neesun Support Team – Privacy Policy
84 Tadros Court Carter House HP137GF UK
