Privacy Policy

This Privacy Policy explains how PassOn LTD (“PassOn”, “we”, “us”, “our”) collects, uses, shares and protects your personal data when you use the PassOn marketplace mobile app and the website at passonmarket.co.uk (together, the “Service”). PassOn is a marketplace for buying and selling pre-loved and secondhand items.

We are the “data controller” for the personal data described here, for the purposes of UK data protection law, including the UK GDPR and the Data Protection Act 2018. If you have any questions or want to exercise your rights, contact us at Pr@PassOnMarket.co.uk or via our contact page.

1. Information we collect

Information you give us

• Account details — your name, email address, username, password, and (where you choose to add them) a profile photo, bio, display-name colour and social links.
• Listings and content — the photos, descriptions, prices, categories and other details of items you list, plus messages, offers, reviews and reports you send through the Service.
• Addresses — the delivery and return addresses used to buy, sell and ship items.
• Seller and payout details — for sellers, the information needed to pay you, which is collected and verified by our payment provider (Stripe). This can include your name, address, date of birth and bank/payout account details, as required for identity verification and anti-money-laundering checks.
• Business/trader information — if you sell as a business, additional details such as your business name, and (where applicable) company or VAT registration information.
• Tax information — information we are legally required to collect and report about sellers on digital platforms (see “Tax reporting (HMRC)” below).
• Proof-of-authenticity information — where you provide it, photos of tags, receipts or other proof to support a listing.
• Support and correspondence — the content of messages you send us and information you provide when contacting support.

Information we collect automatically

• Device and technical data — device model and operating system, app version, IP address, and identifiers such as a push-notification token.
• Approximate location — derived from your IP address or device settings, for example to show relevant results and help prevent fraud. Precise location is only used if you grant permission.
• Usage data — how you interact with the Service, pages and listings viewed, and actions taken, collected through logs, cookies and similar technologies.

Information from third parties

• Sign-in providers — if you choose “Continue with Google” or “Continue with Facebook”, we receive basic profile information (such as your name and email) from that provider to create or sign you in to your account.
• Payment provider — Stripe shares limited information with us to process payments and payouts and to confirm verification status (we do not receive or store your full card number).
• Couriers — delivery and tracking status from our shipping partners and carriers.
• eBay import (optional) — if you use our eBay import feature, we access your active eBay listings via eBay’s authorised connection so you can import them as drafts. We only do this when you connect your eBay account.

2. How we use your information, and our legal bases

We use your personal data for the following purposes. Where we rely on “legitimate interests”, we have balanced those interests against your rights.

• Provide the Service — create and manage your account, host your listings, and enable buying and selling. Legal basis: performance of a contract.
• Process payments and payouts — take payment from buyers, hold funds where appropriate, and pay sellers, via Stripe. Legal basis: performance of a contract; legal obligation.
• Arrange shipping — generate prepaid shipping labels and provide tracking through our courier partners. Legal basis: performance of a contract.
• Enable marketplace features — messaging, offers, bundles, reviews and notifications (including push and email). Legal basis: performance of a contract; legitimate interests.
• Keep the Service safe — prevent fraud, detect counterfeit or prohibited listings, moderate content and enforce our Terms. Legal basis: legitimate interests; legal obligation.
• Customer support — respond to your questions, reports and disputes. Legal basis: performance of a contract; legitimate interests.
• Legal and tax compliance — meet our obligations, including reporting seller information to HM Revenue & Customs. Legal basis: legal obligation.
• Improve the Service — understand usage and improve features, performance and safety. Legal basis: legitimate interests.
• Marketing — send you updates and offers where you have opted in. Legal basis: consent, which you can withdraw at any time.

3. Moderation and automated processing

To keep the marketplace safe, we use automated systems to flag potentially fraudulent, counterfeit or prohibited activity — for example, risk scoring that can hide a listing pending review. These systems support, but do not replace, human judgement: they refer matters to our moderation team rather than automatically banning accounts, and our moderation is fair and human-run. We do not make decisions that produce legal or similarly significant effects about you based solely on automated processing without human involvement.

4. Who we share your information with

We share personal data only as needed to run the Service and as described below. We do not sell your personal data.

• Other users — your public profile, listings and reviews are visible to other users. To complete a transaction, the information necessary to fulfil and ship an order (such as a name and delivery address on a shipping label) is shared between buyer and seller as needed.
• Payments — Stripe, which processes payments, payouts and identity/anti-fraud checks.
• Shipping — our shipping platform and carriers (for example Royal Mail, Evri, InPost, DPD and DHL) to generate labels and provide tracking.
• Sign-in, messaging and infrastructure — providers such as Google (including Firebase for push notifications and sign-in) and Facebook (for sign-in), our hosting provider, and our email provider.
• Analytics — providers that help us understand and improve how the Service is used.
• eBay — only where you use the optional import feature, under your authorisation.
• Authorities and advisers — HM Revenue & Customs (see below), and law enforcement, regulators or professional advisers where required by law or to protect our rights, users or the public.
• Business transfers — if PassOn is involved in a merger, acquisition or sale of assets, personal data may be transferred as part of that transaction.

These providers act as our processors or as independent controllers, and are required to protect your data and use it only for the purposes we permit.

5. Tax reporting (HMRC)

As a UK digital platform, we are legally required to collect and report certain information about sellers and their earnings to HM Revenue & Customs under the rules for digital platform reporting. This can include your name, address, date of birth (or business registration details), financial account identifier and the amount you have earned through the Service. Where these rules apply to you, we may ask you to provide and confirm this information, and we will report it to HMRC as required and provide you with a copy of the reported information.

6. International transfers

Some of our service providers are located outside the United Kingdom. Where we transfer personal data outside the UK, we rely on appropriate safeguards required by law — such as an adequacy decision (including for transfers to the EEA), the UK’s International Data Transfer Agreement, or standard contractual clauses.

7. Data retention

We keep personal data for as long as your account is active and as needed to provide the Service. After that, we keep it only for as long as necessary to meet legal, tax, accounting, dispute-resolution and fraud-prevention requirements — for example, transaction and tax records are kept for the periods required by law. If you joined our launch waitlist, we keep your email until launch and until you unsubscribe.

8. Security

We use appropriate technical and organisational measures to protect your personal data, including encryption in transit, access controls and secure handling of credentials. Payment card details are handled by Stripe and are not stored on our systems. No method of transmission or storage is completely secure, but we work to protect your information and, where required, will notify you and the relevant regulator of a serious data breach.

9. Your rights

Subject to UK data protection law, you have the right to:

• access the personal data we hold about you;
• have inaccurate data corrected;
• have your data deleted in certain circumstances;
• restrict or object to certain processing (including direct marketing);
• data portability; and
• withdraw consent at any time where we rely on it.

To exercise any of these rights, contact us using the details above. Some rights are limited where we have an overriding legal obligation (for example, to retain tax records). You also have the right to complain to the Information Commissioner’s Office (ICO) at ico.org.uk.

10. Cookies & similar technologies

Our website and app use cookies and similar technologies for essential functionality (such as keeping you signed in and keeping the Service secure), to remember your preferences, and to understand and improve usage. You can control non-essential cookies through your browser or device settings and through any cookie banner we provide. Blocking essential cookies may affect how the Service works.

11. Children

The Service is intended for adults. You must be at least 18 years old to use it, and we do not knowingly collect personal data from children under 18. If you believe a child has provided us with personal data, please contact us and we will delete it.

12. Third-party links

The Service may link to third-party websites or services (for example a payment or sign-in provider). This policy does not cover those third parties, and we encourage you to read their own privacy notices.

13. Changes to this policy

We may update this policy from time to time. If we make material changes, we will take reasonable steps to let you know. The “Last updated” date at the top shows when this policy was last revised.

14. Contact us

PassOn LTD. Email: Pr@PassOnMarket.co.uk. You can also reach us via our contact page.