BACK MARKET, Inc. (“Back Market” or “we”) offers a platform whose purpose is to bring together professional sellers with individuals who wish to buy and/or trade in refurbished technological products (the “Platform”).
At the date of publication of this privacy policy (the “Policy”), the Platform is available in the United States via the Back Market website under the domain name ocrhardapple.store and the corresponding mobile application available in the United States.
This privacy policy (the “Policy”) applies to all users of this Platform. It aims to :

• Provide you with information about how we collect and process your Personal Data as a user of the Platform (“you” or “your”),
• Explain your rights in this regard and how to exercise them. 

It is supplemented by our Cookie policy, which is available on the website and mobile application operated by Back Market. 
Back Market restricts access by persons of less than 18 years of age, who cannot make a purchase without parental authorization, and in any cases do not knowingly collect personal information from children under 13.
All capitalised terms are defined in the Glossary (section 8). 
CONTENTS

1. WHO COLLECTS YOUR PERSONAL DATA?
2. WHY DO WE USE YOUR PERSONAL DATA?
3. WHAT PERSONAL DATA DO WE COLLECT?
4. HOW LONG DO WE KEEP YOUR PERSONAL DATA?
5. WHO DO WE SHARE YOUR PERSONAL DATA WITH?
6. WHAT ARE YOUR RIGHTS REGARDING YOUR PERSONAL DATA?
7. POLICY UPDATES
8. PERSONAL DATA GLOSSARY

1. WHO COLLECTS YOUR PERSONAL DATA?
Back Market collects and processes your Personal Data:

• Company name and legal form of Back Market: BACK MARKET, Inc, a Delaware corporation, incorporated under the laws of Delaware
• Registered office: 41 Union Square W, 2nd Floor, New York, NY 10003, United State

At Back Market, protecting your privacy is fundamental and we are committed to continually improving our approach to compliance with applicable Personal Data regulations, including notably the California Consumer Privacy Act, as amended (“CCPA”).
2. WHY DO WE USE YOUR PERSONAL DATA? 
We collect and use your Personal Data for the following primary purposes:
2.1 Use of the services offered on the Platform
* As part of our customer service and customer relationship management, in particular to resolve any issues relating to your customer account, to help Sellers manage their customer service with you or to help you manage a trade-in, we may contact you by e-mail, telephone or SMS, including automated SMS, in accordance with our Terms of Services and Trade-in Terms and Conditions, to the extent permitted by applicable law.
2.2 Marketing and sales activities 
2.3 Improving services 
2.4 Prevention, detection, and fight against fraud and security incidents
2.5 Managing legal and tax obligations 
3. WHAT PERSONAL DATA DO WE COLLECT? 
Personal Data collected via the Platform
We collect and process your Personal Data when: you create or modify your account; you place orders or use the Trade-in Service; you interact with our Customer Service; you participate in a game or contest organized by us; or you write a review or respond to a customer satisfaction survey. 
Your Personal Data may also be collected automatically as a result of your navigation on the Platform, in particular through the use of Cookies.
Personal Data we collect are: 

• Your last name, first name, e-mail address, phone number, delivery address and billing address,
• Your bank and payment details; however, only the payment service provider will have access to your full payment card details,
• Your order information and history,
• Device unique identifiers (such as IMEI or serial number) of devices you purchase or trade-in from our platform),
• The data relating to your connection and browsing activity on the Platform (in particular IP address, pages and products viewed)
• Data relating to the ads you have viewed,
• Information you provide when participating in promotional operations, polls and surveys, contests, or events,
• Your reviews and comments,
• Messages and claims relating to products purchased or sold via the Platform,
• Recording of your calls to our Customer Service, unless you object to it,
• Data from fraud risk detection and analysis results.

If you use our Trade-in Service, we will also collect your name and the last four digits of your Social Security Number (“SSN”) to enable you to sell on the marketplace. In addition, you also agree to provide your address and your full nine-digit SSN or your Individual Tax Identification Number (“ITIN”), once your transactions using the Trade-in Service amount to the legal appreciable threshold. We may suspend payouts to individuals who fail to provide a correct SSN/ ITIN once they reach the legal applicable threshold. You acknowledge that we are entitled to retain funds from your payments in case you fail to provide your full valid and matching SSN, or in case you submit incorrect, incomplete, inaccurate or obsolete information about your account.
If, within the year, you exceed the legal applicable threshold using the Trade-in Service, we may also collect certain additional information on behalf of the tax authorities (in particular: your tax number and country of issue, your bank details (IBAN or equivalent), and the name of the bank account holder). 
In the event of a dispute relating to a transaction that has been blocked by our anti-fraud tools, we may collect a copy of your ID and any other supporting documents necessary to assess the situation. In the event of a dispute regarding the delivery or receipt of a product, we may need to verify your identity and, where applicable, collect through a secure mechanism a copy of your identity document, a video selfie and/or other information necessary to verify your identity. In addition to a copy of your identity document, we may also collect other documents, such as a proof of address, a complaint filed, a signed declaration of non-receipt, a proof of deposit and/or any other additional evidence necessary for Back Market and its shipping partner to assess the situation.
To speed up the identity verification process, we may invite you to prove your identity using your valid ID and the "Live Identity Check" system handled by our trusted service provider Onfido on our behalf. This facial biometric verification system verifies automatically the authenticity of your ID and confirms it belongs to you by comparing the face on the ID with a selfie video you provide in the same flow. We need your consent to process your biometric data. If you do not consent to the Live Identity check, we will contact you for an alternative way to verify your identity. 
To improve the handling of your Product returns to the Seller, we might ask a third-party service provider to check the device’s unique identifier (such as the IMEI number) to see if the returned Product is connected to a personal account (such as an iCloud account). If the device is still connected, the Seller won’t be able to process your return request. If that's the case, we'll provide you with instructions on how to disconnect the device remotely to keep your personal data safe and help you with your return. 
Personal Data collected via Social Login
If you choose to create your customer account or connect to our Platform using the Social Login functionality offered by Google, or Apple, they will provide us with your email address, and in some cases your full name, which are required to create your customer account or connect to our Platform. 
Personal Data collected from other sources
As part of our fraud prevention efforts, we may access or receive additional information about you from third-party service providers and/or partners, and cross-check it with information we already have about you. For instance, we may receive background check results or fraud alerts from identity or document verification service providers. 
4. HOW LONG DO WE KEEP YOUR PERSONAL DATA? 
Your personal data will be stored in compliance with applicable data protection laws, and only for as long as necessary to fulfill the processing purposes described in this Privacy Policy. After this period, we will delete your personal data in accordance with our retention and deletion policy or anonymize it, unless we are legally required or permitted to retain your personal data for a longer period (for example, to comply with legal, tax, accounting obligations).
5. WHO DO WE SHARE YOUR PERSONAL DATA WITH?
Please note that in the event of any data transfers, all necessary measures will be taken to ensure the security and confidentiality of your personal information, in accordance with applicable data protection laws.

• Sellers and professional refurbishers

The Personal Data required to manage your order or your trade-in offer will be shared with the refurbishers. In the event of a dispute regarding the delivery of a package, we may also need to share some additional documents (complaint, copy of ID, etc.) that you are asked to provide. The refurbishers are the Controllers of the Personal Data transmitted to them. 

• Carriers and logistics partners

The Personal Data that are necessary for the shipment of the product ordered or traded in will be shared with the carriers and logistics partners in charge of this shipment.

• Brokers and insurers

If you take out an insurance policy, some of your Personal Data necessary for the subscription or management of your insurance policy will be shared or collected directly by our brokers and insurance partners.

• Payment service providers

Some Personal Data will be transferred or directly collected by our payment service providers (PCI DSS certified), the credit institution if you pay by instalments, or banks.

• Sub-contractors and service providers

Your Personal Data will also be shared with our external service providers, acting on our behalf, such as those involved in customer service management, fraud prevention and detection, analytics and marketing services (including our services providers in charge of carrying out analyses and segmentations, marketing and sales studies) or IT services, e.g., for data storage purposes. We make sure that they offer the necessary safeguards to ensure the security and confidentiality of your Personal Data and that they only have access to the Personal Data necessary to perform their services; they are not authorized to process your Personal Data for any other purpose.

• Authorities

Your Personal Data may be disclosed to the authorities pursuant to a legal or regulatory requirement or a decision by a regulatory or judicial authority.

• Social networks and other advertising partners

For advertising purposes, we may share some of your Personal Data with our ad partners to assess the performance of our advertising campaigns. We may also use some of your Personal Data to create personalized audiences or similar for potential customers through the social network advertising platforms of Facebook and Google.
When applicable, you can opt-out to this Processing of Personal Data at any time by changing your Cookies settings through the “Cookies” section available at the bottom of every page on our website, and in the “Privacy” section of our app.
More information about the Processing carried out by Meta here and by Google here and here.
Residents of certain states of the United States may also have the right to opt-out of the sale of personal information and the sharing of personal information for targeted advertising. Please be reassured that we do not sell your information to third parties. However we may share your personal information to our advertising partners, for cross-context behavioral advertising based on your activity across our Platform’s services and third parties websites and applications. You can also choose to object at any time that we share your personal information to third parties for targeted advertising using the methods described below.
6. WHAT ARE YOUR RIGHTS REGARDING YOUR PERSONAL DATA? 

• Your rights

You may request access to and rectification or, where appropriate, erasure of your Personal Data. You may also, in certain cases, object to the Processing of your Personal Data or request that the Processing be restricted, subject to the conditions set out in the applicable regulations. You also have the right to data portability. 

• How to exercise your rights

You can directly and at any time : 

• delete your Back Market customer account via the “My profile” section of your personal account. To start the deletion procedure, click on “Delete my account”. For further information, please consult the help page accessible via this link.
• object to the Processing of your Personal Data for direct marketing purposes by clicking on the “unsubscribe” link in any of our promotional communications, or if you have a customer account, by changing your marketing preferences in the “My Profile” section of your customer account. 
• when applicable, opt-out to the Processing of your Personal Data carried out by our services for the purposes of personalising your user experience on our Platform, analysing your browsing activities, and measuring the audience of our Platform and/or for the purposes of personalising our advertising content, by setting your Cookies preferences in the sections available at the bottom of our Platform’s website, and in the “Privacy” section of our app.
• if you have a customer account, access and rectify your customer account profile (login, contact details, billing, and delivery addresses, etc.) from the “My Profile” section of your account.
• when you call us, object to the recording of the call with our after sale service.
• if one of your transactions has been blocked by our anti-fraud tools, you may send your comments to our Customer Service using your customer account. Our Anti-Fraud Service will then carry out an analysis of the matter.

You may also exercise your rights or ask us questions you may have on the Processing of your Personal Data by writing to us:
Via the following e-mail or the following postal address: Back Market, Legal Team, 41 Union Square W, 2nd Floor, New York, NY 10003.
By writing us, you should specify your full name and the email address used to create your customer account (if you have one)
If we have any reasonable doubt as to your identity, we may ask you to enclose a copy of an official identification document, such as an ID card or passport, in support of your request.
7. POLICY UPDATES
This Privacy Policy may be amended from time to time, in particular to reflect any changes in legislation, regulations, case law or technology.
8. PERSONAL DATA GLOSSARY