Likewize Devices Trade-In
Data protection notice

If you use a trade-in service (purchase of devices) from Likewize Services UK Limited or Likewize Europe GmbH, the respective Likewize company may process your personal data. The controller of the personal data is in each case and exclusively that of the two named Likewize companies whose trade-in service you use (hereinafter “Likewize”).

What information do we use?

In order to facilitate the equipment trade-in, we may use the personal data listed below. We may collect/use other types of information about you from time to time as necessary to fulfil the purposes set out below. If we do not collect these other types of information directly from you anyway, we will inform you accordingly. In some cases, we may not collect all of the elements listed below.

The source of the data varies, with some elements being collected directly from you and other elements being provided by the party through which you conducted your trade-in (e.g. network operator, retailer, device manufacturer, bank, etc.) or generated by Likewize.

• Contact details (name, home/collection address, billing address, e-mail address, user name, telephone number).
• Device data (brand, model, colour, IMEI/serial number, information about your device*, class and condition of the device)
• Payment details (Bacs account and sort code, IBAN and BIC, Paypal ID, contract or credit account number).
• Transaction data (details of payments to and from you).
• Technical data (when visiting our website: IP address, login data, browser, time zone, location, operating system, session ID, etc.)
• Customer service data (communication with/about you, call records, customer satisfaction/reviews, etc.).

*When you send a device to us, we ask you to ensure that your device does not contain any personal data (including SIM and memory cards). If this is not possible, we will delete your personal data or recycle your device. If your device is in a condition that makes it impossible for us to digitally erase it, we may send the device to a third party that specialises in the recovery/recycling of devices that are beyond repair. In this case, we will take contractual and governance measures to ensure that this third party protects your data and acts responsibly.

Why do we need your personal data?

The table below sets out the purposes for which we use your personal data, including the types of data we may use for each purpose, the legal basis we rely on for each purpose and the retention period.

In cases where we need your personal data for contractual purposes, failure to provide this personal data may mean that we are unable to conclude a contract with you or fulfil a concluded contract.

To whom can your personal data be passed on?

Your personal data may be disclosed to third parties within the categories listed below if and to the extent necessary to fulfil the purposes listed above.

• Your partner through whom you use our trade-in service (i.e. the party through whom you have organised your inclusive services, e.g. insurer, telephone network, device manufacturer, retailer, etc.)
• Your device manufacturer,
• Other legal entities within the Likewize Group,
• Third party business partners who provide services to us (e.g. legal and financial advisors),
• Digital platform providers and technical support, e.g. software providers, telephony management systems, inventory management systems, payment providers, etc,
• Logistics and delivery/collection partners,
• Other service/product providers in the Likewize supply chain,
• Law enforcement agencies and other statutory bodies, including the courts,
• Industry databases such as fraud databases, mobile property registers, etc,
• Third parties to whom we may sell, transfer or merge parts of our business or assets

Some of these recipients may be based outside the UK or EU/EEA, which could mean transferring your data outside the UK or EU/EEA. If we transfer personal data outside the UK/EU/EEA, we will only do so if:

• the UK Government or the EU Commission has decided that the destination country or organisation provides an adequate level of protection for personal data (“adequacy decision”), or;
•  the transfer has been authorised by the competent data protection authority, or;
• other suitable and appropriate data protection guarantees are in place, such as the conclusion of standard data protection clauses.

A current list of recipients can be provided on request. Our contact details can be found at the end of this privacy policy.
For recipients located outside the UK or the EU/EEA, you may also request information on (i) whether an adequacy decision exists for the destination country and (ii) if not, what other appropriate and adequate data protection safeguards are in place and how you can obtain a copy of them or where they are available

What rights do I have?

Under data protection law, you have the right

• to request information about your personal data (commonly known as a request for information). This enables you to obtain a copy of the personal data we hold about you.
• request the restriction of the processing of your personal data. This enables you to ask us to suspend the processing of your personal data.
• Request the erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it.
• request the correction of the personal data that we have stored about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
• request the transfer of your personal data to another party (commonly known as the right to data portability).
• to object to the processing of your personal data if we rely on a legitimate interest (or the legitimate interests of a third party).

The above rights apply under the provisions and conditions of the General Data Protection Regulation (GDPR).
To exercise the above rights, please contact us. You will find our contact details at the end of this privacy policy.

How can I lodge a complaint?

If you are not satisfied with the way Likewize collects or uses your personal data, you can contact us. Our contact details can be found at the end of this privacy notice.
You also have the right to lodge a complaint with the competent supervisory authority. In the United Kingdom, this is the Information Commissioner’s Office (ICO). In the European Union, our lead supervisory authority is the State Commissioner for Data Protection and Freedom of Information of North Rhine-Westphalia (LDI NRW).

How can I contact Likewize?

Likewize Services UK Limited :
Postal: Likewize Services UK Limited. Data Protection Unit 2, Crewe Logistics Park, Jack Mills Way, Crewe, UK, CW2 5XF.
E-mail: privacy@likewize.com

Likewize Europe GmbH:
By post: Likewize Europe GmbH. Data Protection, Höseler Platz 2, Ratinger Str. 10, 42579 Heiligenhaus, Germany.
E-mail: privacy@likewize.com
Data protection officer: privacy@likewize.com