Privacy Policy

PRIVACY POLICY 
Introduction 
Cash4mobiles Ltd. respects your privacy and is committed to protecting your 
personal data. This privacy notice will inform you as to how we look after your 
personal data and tell you about your privacy rights and how the law protects you. It 
applies to information we collect in relation to: 
 Users of our website; 
 People who use our services; 
 Employees or representatives of organisations who use our services or supply us 
with goods or services; 
 People who contact us via any medium (e.g through our website, by post, email, 
telephone or social media). 
It is important that you read this notice, together with any other privacy notice we 
may provide on specific occasions when we are collecting or processing personal 
information about you, so that you are aware of how and why we are using such 
information. This privacy notice supplements the other notices and is not intended to 
override them. 
This privacy notice is provided in a layered format so you can click through to the 
specific areas set out below. Please also use the Glossary to understand the 
meaning of some of the terms used in this privacy notice. 
1. IMPORTANT INFORMATION 
AND WHO WE ARE 
Controller and contact information 
Cash4mobiles Ltd. is the controller and responsible for your personal data 
(collectively referred to as “Cash4mobiles”, “we”, “us” or “our” in this privacy notice). 
We have appointed a data privacy manager who is responsible for overseeing 
questions in relation to this privacy notice. If you have any questions about this 
privacy notice, including any requests to exercise your legal rights, please contact 
the data privacy manager using the details set out below: 
Email address: info@cash4mobiles.co.uk 
Postal address: FAO: Amir Dedic, Cash4mobiles Ltd., 2a Silver Street, Kings Heath, 
Birmingham B14 7QU. 

Telephone number: +44 (0)121 4443338 
Complaints 
You have the right to make a complaint at any time to the Information 
Commissioner’s Office (ICO), the UK supervisory authority for data protection issues 
(www.ico.org.uk). We would, however, appreciate the chance to deal with your 
concerns before you approach the ICO so please contact us in the first instance. 
Changes to the privacy notice and your duty to 
inform us of changes 
We reserve the right to update this privacy notice at any time. 
It is important that the personal data we hold about you is accurate and current. 
Please keep us informed if your personal data changes during your relationship with 
us. 
Third-party links 
Our website may include links to third-party websites, plug-ins and applications. 
Clicking on those links or enabling those connections may allow third parties to 
collect or share data about you. We do not control these third-party websites and are 
not responsible for their privacy statements. When you leave our website, we 
encourage you to read the privacy notice of every website you visit. 
2. THE DATA WE COLLECT 
ABOUT YOU 
Personal data, or personal information, means any information about an individual 
from which that person can be identified. It does not include data where the identity 
has been removed (anonymous data). 
We may collect, use, store and transfer different kinds of personal data about you 
which we have grouped together follows: 
 Identity Data includes [first name, maiden name, last name, username or similar 
identifier, marital status, title, company name, date of birth and gender]. 
 Contact Data includes [billing address, delivery address, email address and 
telephone numbers]. 
Financial Data includes [bank account and payment card details]. 
 Transaction Data includes [details about payments to and from you and other 
details of products and services (such as serial number and IMEI you have 
purchased from us, or sold to us]. 

 Technical Data includes [internet protocol (IP) address, your login data, browser 
type and version, time zone setting and location, browser plug-in types and 
versions, operating system and platform and other technology on the devices you 
use to access this website]. 
 Profile Data includes [your username and password, purchases or orders made by 
you, your interests, preferences, feedback and survey responses]. 
 Usage Data includes [information about how you use our website, products and 
services]. 
 Marketing and Communications Data includes [your preferences in receiving 
marketing from us and our third parties and your communication preferences]. 
 Unknown Data includes data on devices received for erasure and destruction 
services, where we do not access or record the data and simply erasure/destroy 
in accordance with the service agreement 
We also collect, use and share Aggregated Data such as statistical or demographic 
data for any purpose. Aggregated Data may be derived from your personal data but 
is not considered personal data in law as this data does not directly or indirectly 
reveal your identity. For example, we may aggregate your Usage Data to calculate the 
percentage of users accessing a specific website feature. However, if we combine or 
connect Aggregated Data with your personal data so that it can directly or indirectly 
identify you, we treat the combined data as personal data which will be used in 
accordance with this privacy notice. 
We do not collect any Special Categories of Personal Data about you (this includes 
details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual 
orientation, political opinions, trade union membership, information about your 
health and genetic and biometric data). Nor do we collect any information about 
criminal convictions and offences. 
If you fail to provide personal data 
Where we need to collect personal data by law, or under the terms of a contract we 
have with you and you fail to provide that data when requested, we may not be able 
to perform the contract we have or are trying to enter into with you (for example, to 
provide you with goods or services). In this case, we may have to cancel a product or 
service you have with us but we will notify you if this is the case at the time. 
3. HOW IS YOUR PERSONAL 
DATA COLLECTED? 
We use different methods to collect data from and about you including through: 
 Direct interactions. You may give us your Identity, Contact and Financial Data by 
filling in forms or by corresponding with us by post, phone, email or otherwise. 
This includes personal data you provide when you 

 apply for our products or services; 
 create an account on our website; 
 subscribe to our service or publications; 
 request marketing to be sent to you; 
 enter a competition, promotion or survey; or 
 give us some feedback. 
 Automated technologies or interactions. As you interact with our website, we 
may automatically collect Technical Data about your equipment, browsing actions 
and patterns. We collect this personal data by using cookies and other similar 
technologies. We may also receive Technical Data about you if you visit other 
websites employing our cookies. 
o Please see our Cookie Policy for further details. 
 Third parties or publicly available sources. We may receive personal data about 
you from various third parties and public sources as set out below: 
 Technical Data from the following parties: 
1. analytics providers such as Google based outside the EU; 
2. search information providers Linked In based inside the EU. 
 Identity and Contact Data from publicly availably sources such as Companies 
House and the Electoral Register based inside the EU. 
4. HOW WE USE YOUR 
PERSONAL DATA 
We will only use your personal data when the law allows us to. Most commonly, we 
will use your personal data in the following circumstances: 
 Where we need to perform the contract we are about to enter into or have entered 
into with you. 
 Where it is necessary for our legitimate interests (or those of a third party), by 
which we mean in the interest of our business in conducting and managing our 
business to enable us to give you the best service/product and the best and most 
secure experience. We make sure we consider and balance any potential impact 
on you (both positive and negative) and your rights before we process your 
personal data for our legitimate interests. We do not use your personal data for 
activities where our interests are overridden by the impact on you (unless we have 
your consent or are otherwise required or permitted to by law). You can obtain 
further information about how we assess our legitimate interests against any 
potential impact on you in respect of specific activities by contacting us. 
 Where we need to comply with a legal or regulatory obligation. 

Generally we do not rely on consent as a legal basis for processing your personal 
data other than in relation to sending third party direct marketing communications to 
you via email or text message. You have the right to withdraw consent to marketing 
at any time by: 
 making use of the “unsubscribe” link in emails and/or 
 contacting us via any of the methods referred to in paragraph 1 above. 
Purposes for which we will use your personal data 
We have set out below, in a table format, a description of all the ways we plan to use 
your personal data, and which of the legal bases we rely on to do so. We have also 
identified what our legitimate interests are where appropriate. 
Note that we may process your personal data for more than one lawful ground 
depending on the specific purpose for which we are using your data. Please contact 
us if you need details about the specific legal ground we are relying on to process 
your personal data where more than one ground has been set out in the table below. 

Purpose/Activity Type of data Lawful basis for processing including basis of 

legitimate interest 

To provide a mobile phone and device 
reuse and trade-in service. 

(a) Identify 
(b) Contact 
(c) Financial 
(d) Transaction 
(e) Profile 
(f) Usage 
(g) Technical 
(h) Marketing and 
Communications 

(a) Performance of a contract with you 
(b) Necessary for our legitimate interests (to provide 
services to client) 

To register you as a new customer (a) Identity  
(b) Contact 

Performance of a contract with you 

To process and deliver your order 
including: 
(a) Manage payments, fees and charges 
(b) Collect and recover money owed to us 

(a) Identity  
(b) Contact  
(c) Financial  
(d) Transaction  
(e) Marketing and 

(a) Performance of a contract with you  
(b) Necessary for our legitimate interests (to recover 
debts due to us) 

Communications 

To manage our relationship with you or 
your organisation which will include: 
(a) Notifying you about changes to our 
terms or privacy policy 
(b) Asking you to leave a review or take a 
survey 

(a) Identity  
(b) Contact  
(c) Profile  
(d) Marketing and 
Communications 

(a) Performance of a contract with you  
(b) Necessary to comply legitimate with a legal 
obligation 
(c) Necessary for our interests (to keep our records 
updated and to study how customers use our 
products/services) 

To enable you to partake in a prize draw, 
competition or complete a survey 

(a) Identity  
(b) Contact  
(c) Profile  
(d) Usage  
(e) Marketing and 
Communications 

(a) Performance of a contract with you  
(b) Necessary for our legitimate interests (to study 
how customers use our products/services, to 
develop them and grow our business) 

To administer and protect our business 
and this website (including 
troubleshooting, data analysis, testing, 
system maintenance, support, reporting 
and hosting of data) 

(a) Identity 
(b) Contact 
(c) Technical 
(d) Usage 

(a) Necessary for our legitimate interests (for 
running our business, provision of administration 
and IT services, network security, to prevent fraud 
and in the context of a business reorganisation or 
group restructuring exercise) 
(b) Necessary to comply with a legal obligation 

To deliver relevant website content and 
advertisements to you and measure or 
understand the effectiveness of the 
advertising we serve to you 

(a) Identity  
(b) Contact  
(c) Profile  
(d) Usage  
(e) Marketing and 
Communications  
(f) Technical 

Necessary for our legitimate interests (to study how 
customers use our products/services, to develop 
them, to grow our business and to inform our 
marketing strategy) 

To use data analytics to improve our 
website, products/services, marketing, 
customer relationships and experiences 

(a) Technical  
(b) Usage 

Necessary for our legitimate interests (to define 
types of customers for our products and services, to 
keep our website updated and relevant, to develop 
our business and to inform our marketing strategy) 

To make suggestions and 
recommendations to you about goods or 
services that may be of interest to you 

(a) Identity  
(b) Contact  
(c) Technical  
(d) Usage  
(e) Profile 

Necessary for our legitimate interests (to develop 
our products/services and grow our business) 

Marketing 
We strive to provide you with choices regarding certain personal data uses, 
particularly around marketing and advertising. Please see Opting Out below. 
Promotional offers from us 
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view 
on what we think you may want or need, or what may be of interest to you. This is 
how we decide which products, services and offers may be relevant for you (we call 
this marketing). 
You will receive marketing communications from us if you have requested 
information from us or purchased services from us and, in each case, you have not 
opted out of receiving that marketing. 
Third-party marketing 
We will get your express opt-in consent before we share your personal data with any 
company outside the Cash4mobiles Ltd. for marketing purposes. 
Opting out 
You can ask us or third parties to stop sending you marketing messages at any time 
by following the opt-out links on any marketing message or emails sent to you at any 
time. 
Where you opt out of receiving these marketing messages, this will not apply to 
personal data provided to us as a result of a service purchase, product/service 
experience or other transactions. 
Cookies 
You can set your browser to refuse all or some browser cookies, or to alert you when 
websites set or access cookies. If you disable or refuse cookies, please note that 
some parts of this website may become inaccessible or not function properly. For 
more information about the cookies we use, please see our Cookie Policy. 
Change of purpose 

We will only use your personal data for the purposes for which we collected it, unless 
we reasonably consider that we need to use it for another reason and that reason is 
compatible with the original purpose. If you wish to get an explanation as to how the 
processing for the new purpose is compatible with the original purpose, please 
Contact Us. 
If we need to use your personal data for an unrelated purpose, we will notify you and 
we will explain the legal basis which allows us to do so. 
Please note that we may process your personal data without your knowledge or 
consent, in compliance with the above rules, where this is required or permitted by 
law. 
5. DISCLOSURES OF YOUR 
PERSONAL DATA 
We may have to share your personal data with the parties set out below for the 
purposes set out in the table in paragraph 4 above. 
 Service providers acting as processors based in England and Wales who provide 
IT and system administration services, Logistics Services and downstream 
processing. 
 Professional advisers acting as processors or joint controllers including lawyers, 
bankers, auditors and insurers based England and Wales who provide 
consultancy, banking, legal, insurance and accounting services, including the 
following: 
1. Legal 
2. Accounting Services 
3. HR advice 
4. Insurance 
 HM Revenue & Customs, regulators and other authorities acting as processors or 
joint controllers based in the United Kingdom who require reporting of processing 
activities in certain circumstances. 
 Third parties to whom we may choose to sell, transfer, or merge parts of our 
business or our assets. Alternatively, we may seek to acquire other businesses or 
merge with them. If a change happens to our business, then the new owners may 
use your personal data in the same way as set out in this privacy notice. 
We require all third parties to respect the security of your personal data and to treat 
it in accordance with the law. We do not allow our third-party service providers to use 
your personal data for their own purposes and only permit them to process your 
personal data for specified purposes and in accordance with our instructions. 

6. INTERNATIONAL TRANSFERS 
We do not transfer your personal data outside the European Economic Area (EEA). 
7. DATA SECURITY 
We have put in place appropriate security measures to prevent your personal data 
from being accidentally lost, used or accessed in an unauthorised way, altered or 
disclosed. In addition, we limit access to your personal data to those employees, 
agents, contractors and other third parties who have a business need to know. They 
will only process your personal data on our instructions and they are subject to a 
duty of confidentiality. 
We have put in place procedures to deal with any suspected personal data breach 
and will notify you and any applicable regulator of a breach where we are legally 
required to do so. 
8. DATA RETENTION 
How long will you use my personal data for? 
We will only retain your personal data for as long as necessary to fulfil the purposes 
we collected it for, including for the purposes of satisfying any legal, accounting, or 
reporting requirements. 
To determine the appropriate retention period for personal data, we consider the 
amount, nature, and sensitivity of the personal data, the potential risk of harm from 
unauthorised use or disclosure of your personal data, the purposes for which we 
process your personal data and whether we can achieve those purposes through 
other means, and the applicable legal requirements. 
By law we have to keep basic information about our customers (including Contact, 
Identity, Financial and Transaction Data) for six years after they cease being 
customers for tax purposes. 
In some circumstances you can ask us to delete your data: see Request 
erasure below for further information. 
In some circumstances we may anonymise your personal data (so that it can no 
longer be associated with you) for research or statistical purposes in which case we 
may use this information indefinitely without further notice to you. 
9. YOUR LEGAL RIGHTS 

Under certain circumstances, you have rights under data protection laws in relation 
to your personal data. Please click on the links below to find out more about these 
rights: 
You have the right to: 
 Request access to your personal data (commonly known as a “data subject 
access request”). This enables you to receive a copy of the personal data we hold 
about you and to check that we are lawfully processing it. 
 Request correction of the personal data that we hold about you. This enables you 
to have any incomplete or inaccurate data we hold about you corrected, though 
we may need to verify the accuracy of the new data you provide to us. 
 Request 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. You also have the right to ask us to delete or remove your personal data where 
you have successfully exercised your right to object to processing (see below), 
where we may have processed your information unlawfully or where we are 
required to erase your personal data to comply with local law. Note, however, that 
we may not always be able to comply with your request of erasure for specific 
legal reasons which will be notified to you, if applicable, at the time of your 
request. 
 Object to processing of your personal data where we are relying on a legitimate 
interest (or those of a third party) and there is something about your particular 
situation which makes you want to object to processing on this ground as you 
feel it impacts on your fundamental rights and freedoms. You also have the right 
to object where we are processing your personal data for direct marketing 
purposes. In some cases, we may demonstrate that we have compelling 
legitimate grounds to process your information which override your rights and 
freedoms. 
 Request restriction of processing of your personal data. This enables you to ask 
us to suspend the processing of your personal data in the following scenarios: (a) 
if you want us to establish the data’s accuracy; (b) where our use of the data is 
unlawful but you do not want us to erase it; (c) where you need us to hold the data 
even if we no longer require it as you need it to establish, exercise or defend legal 
claims; or (d) you have objected to our use of your data but we need to verify 
whether we have overriding legitimate grounds to use it. 
 Request the transfer of your personal data to you or to a third party. We will 
provide to you, or a third party you have chosen, your personal data in a 
structured, commonly used, machine-readable format. Note that this right only 
applies to automated information which you initially provided consent for us to 
use or where we used the information to perform a contract with you. 
 Withdraw consent at any time where we are relying on consent to process your 
personal data. However, this will not affect the lawfulness of any processing 
carried out before you withdraw your consent. If you withdraw your consent, we 
may not be able to provide certain products or services to you. We will advise you 
if this is the case at the time you withdraw your consent. 

If you wish to exercise any of the rights set out above, please Contact Us. 
No fee usually required 
You will not have to pay a fee to access your personal data (or to exercise any of the 
other rights). However, we may charge a reasonable fee if your request is clearly 
unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your 
request in these circumstances. 
What we may need from you 
We may need to request specific information from you to help us confirm your 
identity and ensure your right to access your personal data (or to exercise any of 
your other rights). This is a security measure to ensure that personal data is not 
disclosed to any person who has no right to receive it. We may also contact you to 
ask you for further information in relation to your request to speed up our response. 
Time limit to respond 
We try to respond to all legitimate requests within one month. Occasionally it may 
take us longer than a month if your request is particularly complex or you have made 
a number of requests. In this case, we will notify you and keep you updated.PRIVACY POLICY 
Introduction 
Cash4mobiles Ltd. respects your privacy and is committed to protecting your 
personal data. This privacy notice will inform you as to how we look after your 
personal data and tell you about your privacy rights and how the law protects you. It 
applies to information we collect in relation to: 
 Users of our website; 
 People who use our services; 
 Employees or representatives of organisations who use our services or supply us 
with goods or services; 
 People who contact us via any medium (e.g through our website, by post, email, 
telephone or social media). 
It is important that you read this notice, together with any other privacy notice we 
may provide on specific occasions when we are collecting or processing personal 
information about you, so that you are aware of how and why we are using such 
information. This privacy notice supplements the other notices and is not intended to 
override them. 
This privacy notice is provided in a layered format so you can click through to the 
specific areas set out below. Please also use the Glossary to understand the 
meaning of some of the terms used in this privacy notice. 
1. IMPORTANT INFORMATION 
AND WHO WE ARE 
Controller and contact information 
Cash4mobiles Ltd. is the controller and responsible for your personal data 
(collectively referred to as “Cash4mobiles”, “we”, “us” or “our” in this privacy notice). 
We have appointed a data privacy manager who is responsible for overseeing 
questions in relation to this privacy notice. If you have any questions about this 
privacy notice, including any requests to exercise your legal rights, please contact 
the data privacy manager using the details set out below: 
Email address: info@cash4mobiles.co.uk 
Postal address: FAO: Amir Dedic, Cash4mobiles Ltd., 2a Silver Street, Kings Heath, 
Birmingham B14 7QU. 

Telephone number: +44 (0)121 4443338 
Complaints 
You have the right to make a complaint at any time to the Information 
Commissioner’s Office (ICO), the UK supervisory authority for data protection issues 
(www.ico.org.uk). We would, however, appreciate the chance to deal with your 
concerns before you approach the ICO so please contact us in the first instance. 
Changes to the privacy notice and your duty to 
inform us of changes 
We reserve the right to update this privacy notice at any time. 
It is important that the personal data we hold about you is accurate and current. 
Please keep us informed if your personal data changes during your relationship with 
us. 
Third-party links 
Our website may include links to third-party websites, plug-ins and applications. 
Clicking on those links or enabling those connections may allow third parties to 
collect or share data about you. We do not control these third-party websites and are 
not responsible for their privacy statements. When you leave our website, we 
encourage you to read the privacy notice of every website you visit. 
2. THE DATA WE COLLECT 
ABOUT YOU 
Personal data, or personal information, means any information about an individual 
from which that person can be identified. It does not include data where the identity 
has been removed (anonymous data). 
We may collect, use, store and transfer different kinds of personal data about you 
which we have grouped together follows: 
 Identity Data includes [first name, maiden name, last name, username or similar 
identifier, marital status, title, company name, date of birth and gender]. 
 Contact Data includes [billing address, delivery address, email address and 
telephone numbers]. 
Financial Data includes [bank account and payment card details]. 
 Transaction Data includes [details about payments to and from you and other 
details of products and services (such as serial number and IMEI you have 
purchased from us, or sold to us]. 

 Technical Data includes [internet protocol (IP) address, your login data, browser 
type and version, time zone setting and location, browser plug-in types and 
versions, operating system and platform and other technology on the devices you 
use to access this website]. 
 Profile Data includes [your username and password, purchases or orders made by 
you, your interests, preferences, feedback and survey responses]. 
 Usage Data includes [information about how you use our website, products and 
services]. 
 Marketing and Communications Data includes [your preferences in receiving 
marketing from us and our third parties and your communication preferences]. 
 Unknown Data includes data on devices received for erasure and destruction 
services, where we do not access or record the data and simply erasure/destroy 
in accordance with the service agreement 
We also collect, use and share Aggregated Data such as statistical or demographic 
data for any purpose. Aggregated Data may be derived from your personal data but 
is not considered personal data in law as this data does not directly or indirectly 
reveal your identity. For example, we may aggregate your Usage Data to calculate the 
percentage of users accessing a specific website feature. However, if we combine or 
connect Aggregated Data with your personal data so that it can directly or indirectly 
identify you, we treat the combined data as personal data which will be used in 
accordance with this privacy notice. 
We do not collect any Special Categories of Personal Data about you (this includes 
details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual 
orientation, political opinions, trade union membership, information about your 
health and genetic and biometric data). Nor do we collect any information about 
criminal convictions and offences. 
If you fail to provide personal data 
Where we need to collect personal data by law, or under the terms of a contract we 
have with you and you fail to provide that data when requested, we may not be able 
to perform the contract we have or are trying to enter into with you (for example, to 
provide you with goods or services). In this case, we may have to cancel a product or 
service you have with us but we will notify you if this is the case at the time. 
3. HOW IS YOUR PERSONAL 
DATA COLLECTED? 
We use different methods to collect data from and about you including through: 
 Direct interactions. You may give us your Identity, Contact and Financial Data by 
filling in forms or by corresponding with us by post, phone, email or otherwise. 
This includes personal data you provide when you 

 apply for our products or services; 
 create an account on our website; 
 subscribe to our service or publications; 
 request marketing to be sent to you; 
 enter a competition, promotion or survey; or 
 give us some feedback. 
 Automated technologies or interactions. As you interact with our website, we 
may automatically collect Technical Data about your equipment, browsing actions 
and patterns. We collect this personal data by using cookies and other similar 
technologies. We may also receive Technical Data about you if you visit other 
websites employing our cookies. 
o Please see our Cookie Policy for further details. 
 Third parties or publicly available sources. We may receive personal data about 
you from various third parties and public sources as set out below: 
 Technical Data from the following parties: 
1. analytics providers such as Google based outside the EU; 
2. search information providers Linked In based inside the EU. 
 Identity and Contact Data from publicly availably sources such as Companies 
House and the Electoral Register based inside the EU. 
4. HOW WE USE YOUR 
PERSONAL DATA 
We will only use your personal data when the law allows us to. Most commonly, we 
will use your personal data in the following circumstances: 
 Where we need to perform the contract we are about to enter into or have entered 
into with you. 
 Where it is necessary for our legitimate interests (or those of a third party), by 
which we mean in the interest of our business in conducting and managing our 
business to enable us to give you the best service/product and the best and most 
secure experience. We make sure we consider and balance any potential impact 
on you (both positive and negative) and your rights before we process your 
personal data for our legitimate interests. We do not use your personal data for 
activities where our interests are overridden by the impact on you (unless we have 
your consent or are otherwise required or permitted to by law). You can obtain 
further information about how we assess our legitimate interests against any 
potential impact on you in respect of specific activities by contacting us. 
 Where we need to comply with a legal or regulatory obligation. 

Generally we do not rely on consent as a legal basis for processing your personal 
data other than in relation to sending third party direct marketing communications to 
you via email or text message. You have the right to withdraw consent to marketing 
at any time by: 
 making use of the “unsubscribe” link in emails and/or 
 contacting us via any of the methods referred to in paragraph 1 above. 
Purposes for which we will use your personal data 
We have set out below, in a table format, a description of all the ways we plan to use 
your personal data, and which of the legal bases we rely on to do so. We have also 
identified what our legitimate interests are where appropriate. 
Note that we may process your personal data for more than one lawful ground 
depending on the specific purpose for which we are using your data. Please contact 
us if you need details about the specific legal ground we are relying on to process 
your personal data where more than one ground has been set out in the table below. 

Purpose/Activity Type of data Lawful basis for processing including basis of 

legitimate interest 

To provide a mobile phone and device 
reuse and trade-in service. 

(a) Identify 
(b) Contact 
(c) Financial 
(d) Transaction 
(e) Profile 
(f) Usage 
(g) Technical 
(h) Marketing and 
Communications 

(a) Performance of a contract with you 
(b) Necessary for our legitimate interests (to provide 
services to client) 

To register you as a new customer (a) Identity  
(b) Contact 

Performance of a contract with you 

To process and deliver your order 
including: 
(a) Manage payments, fees and charges 
(b) Collect and recover money owed to us 

(a) Identity  
(b) Contact  
(c) Financial  
(d) Transaction  
(e) Marketing and 

(a) Performance of a contract with you  
(b) Necessary for our legitimate interests (to recover 
debts due to us) 

Communications 

To manage our relationship with you or 
your organisation which will include: 
(a) Notifying you about changes to our 
terms or privacy policy 
(b) Asking you to leave a review or take a 
survey 

(a) Identity  
(b) Contact  
(c) Profile  
(d) Marketing and 
Communications 

(a) Performance of a contract with you  
(b) Necessary to comply legitimate with a legal 
obligation 
(c) Necessary for our interests (to keep our records 
updated and to study how customers use our 
products/services) 

To enable you to partake in a prize draw, 
competition or complete a survey 

(a) Identity  
(b) Contact  
(c) Profile  
(d) Usage  
(e) Marketing and 
Communications 

(a) Performance of a contract with you  
(b) Necessary for our legitimate interests (to study 
how customers use our products/services, to 
develop them and grow our business) 

To administer and protect our business 
and this website (including 
troubleshooting, data analysis, testing, 
system maintenance, support, reporting 
and hosting of data) 

(a) Identity 
(b) Contact 
(c) Technical 
(d) Usage 

(a) Necessary for our legitimate interests (for 
running our business, provision of administration 
and IT services, network security, to prevent fraud 
and in the context of a business reorganisation or 
group restructuring exercise) 
(b) Necessary to comply with a legal obligation 

To deliver relevant website content and 
advertisements to you and measure or 
understand the effectiveness of the 
advertising we serve to you 

(a) Identity  
(b) Contact  
(c) Profile  
(d) Usage  
(e) Marketing and 
Communications  
(f) Technical 

Necessary for our legitimate interests (to study how 
customers use our products/services, to develop 
them, to grow our business and to inform our 
marketing strategy) 

To use data analytics to improve our 
website, products/services, marketing, 
customer relationships and experiences 

(a) Technical  
(b) Usage 

Necessary for our legitimate interests (to define 
types of customers for our products and services, to 
keep our website updated and relevant, to develop 
our business and to inform our marketing strategy) 

To make suggestions and 
recommendations to you about goods or 
services that may be of interest to you 

(a) Identity  
(b) Contact  
(c) Technical  
(d) Usage  
(e) Profile 

Necessary for our legitimate interests (to develop 
our products/services and grow our business) 

Marketing 
We strive to provide you with choices regarding certain personal data uses, 
particularly around marketing and advertising. Please see Opting Out below. 
Promotional offers from us 
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view 
on what we think you may want or need, or what may be of interest to you. This is 
how we decide which products, services and offers may be relevant for you (we call 
this marketing). 
You will receive marketing communications from us if you have requested 
information from us or purchased services from us and, in each case, you have not 
opted out of receiving that marketing. 
Third-party marketing 
We will get your express opt-in consent before we share your personal data with any 
company outside the Cash4mobiles Ltd. for marketing purposes. 
Opting out 
You can ask us or third parties to stop sending you marketing messages at any time 
by following the opt-out links on any marketing message or emails sent to you at any 
time. 
Where you opt out of receiving these marketing messages, this will not apply to 
personal data provided to us as a result of a service purchase, product/service 
experience or other transactions. 
Cookies 
You can set your browser to refuse all or some browser cookies, or to alert you when 
websites set or access cookies. If you disable or refuse cookies, please note that 
some parts of this website may become inaccessible or not function properly. For 
more information about the cookies we use, please see our Cookie Policy. 
Change of purpose 

We will only use your personal data for the purposes for which we collected it, unless 
we reasonably consider that we need to use it for another reason and that reason is 
compatible with the original purpose. If you wish to get an explanation as to how the 
processing for the new purpose is compatible with the original purpose, please 
Contact Us. 
If we need to use your personal data for an unrelated purpose, we will notify you and 
we will explain the legal basis which allows us to do so. 
Please note that we may process your personal data without your knowledge or 
consent, in compliance with the above rules, where this is required or permitted by 
law. 
5. DISCLOSURES OF YOUR 
PERSONAL DATA 
We may have to share your personal data with the parties set out below for the 
purposes set out in the table in paragraph 4 above. 
 Service providers acting as processors based in England and Wales who provide 
IT and system administration services, Logistics Services and downstream 
processing. 
 Professional advisers acting as processors or joint controllers including lawyers, 
bankers, auditors and insurers based England and Wales who provide 
consultancy, banking, legal, insurance and accounting services, including the 
following: 
1. Legal 
2. Accounting Services 
3. HR advice 
4. Insurance 
 HM Revenue & Customs, regulators and other authorities acting as processors or 
joint controllers based in the United Kingdom who require reporting of processing 
activities in certain circumstances. 
 Third parties to whom we may choose to sell, transfer, or merge parts of our 
business or our assets. Alternatively, we may seek to acquire other businesses or 
merge with them. If a change happens to our business, then the new owners may 
use your personal data in the same way as set out in this privacy notice. 
We require all third parties to respect the security of your personal data and to treat 
it in accordance with the law. We do not allow our third-party service providers to use 
your personal data for their own purposes and only permit them to process your 
personal data for specified purposes and in accordance with our instructions. 

6. INTERNATIONAL TRANSFERS 
We do not transfer your personal data outside the European Economic Area (EEA). 
7. DATA SECURITY 
We have put in place appropriate security measures to prevent your personal data 
from being accidentally lost, used or accessed in an unauthorised way, altered or 
disclosed. In addition, we limit access to your personal data to those employees, 
agents, contractors and other third parties who have a business need to know. They 
will only process your personal data on our instructions and they are subject to a 
duty of confidentiality. 
We have put in place procedures to deal with any suspected personal data breach 
and will notify you and any applicable regulator of a breach where we are legally 
required to do so. 
8. DATA RETENTION 
How long will you use my personal data for? 
We will only retain your personal data for as long as necessary to fulfil the purposes 
we collected it for, including for the purposes of satisfying any legal, accounting, or 
reporting requirements. 
To determine the appropriate retention period for personal data, we consider the 
amount, nature, and sensitivity of the personal data, the potential risk of harm from 
unauthorised use or disclosure of your personal data, the purposes for which we 
process your personal data and whether we can achieve those purposes through 
other means, and the applicable legal requirements. 
By law we have to keep basic information about our customers (including Contact, 
Identity, Financial and Transaction Data) for six years after they cease being 
customers for tax purposes. 
In some circumstances you can ask us to delete your data: see Request 
erasure below for further information. 
In some circumstances we may anonymise your personal data (so that it can no 
longer be associated with you) for research or statistical purposes in which case we 
may use this information indefinitely without further notice to you. 
9. YOUR LEGAL RIGHTS 

Under certain circumstances, you have rights under data protection laws in relation 
to your personal data. Please click on the links below to find out more about these 
rights: 
You have the right to: 
 Request access to your personal data (commonly known as a “data subject 
access request”). This enables you to receive a copy of the personal data we hold 
about you and to check that we are lawfully processing it. 
 Request correction of the personal data that we hold about you. This enables you 
to have any incomplete or inaccurate data we hold about you corrected, though 
we may need to verify the accuracy of the new data you provide to us. 
 Request 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. You also have the right to ask us to delete or remove your personal data where 
you have successfully exercised your right to object to processing (see below), 
where we may have processed your information unlawfully or where we are 
required to erase your personal data to comply with local law. Note, however, that 
we may not always be able to comply with your request of erasure for specific 
legal reasons which will be notified to you, if applicable, at the time of your 
request. 
 Object to processing of your personal data where we are relying on a legitimate 
interest (or those of a third party) and there is something about your particular 
situation which makes you want to object to processing on this ground as you 
feel it impacts on your fundamental rights and freedoms. You also have the right 
to object where we are processing your personal data for direct marketing 
purposes. In some cases, we may demonstrate that we have compelling 
legitimate grounds to process your information which override your rights and 
freedoms. 
 Request restriction of processing of your personal data. This enables you to ask 
us to suspend the processing of your personal data in the following scenarios: (a) 
if you want us to establish the data’s accuracy; (b) where our use of the data is 
unlawful but you do not want us to erase it; (c) where you need us to hold the data 
even if we no longer require it as you need it to establish, exercise or defend legal 
claims; or (d) you have objected to our use of your data but we need to verify 
whether we have overriding legitimate grounds to use it. 
 Request the transfer of your personal data to you or to a third party. We will 
provide to you, or a third party you have chosen, your personal data in a 
structured, commonly used, machine-readable format. Note that this right only 
applies to automated information which you initially provided consent for us to 
use or where we used the information to perform a contract with you. 
 Withdraw consent at any time where we are relying on consent to process your 
personal data. However, this will not affect the lawfulness of any processing 
carried out before you withdraw your consent. If you withdraw your consent, we 
may not be able to provide certain products or services to you. We will advise you 
if this is the case at the time you withdraw your consent. 

If you wish to exercise any of the rights set out above, please Contact Us. 
No fee usually required 
You will not have to pay a fee to access your personal data (or to exercise any of the 
other rights). However, we may charge a reasonable fee if your request is clearly 
unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your 
request in these circumstances. 
What we may need from you 
We may need to request specific information from you to help us confirm your 
identity and ensure your right to access your personal data (or to exercise any of 
your other rights). This is a security measure to ensure that personal data is not 
disclosed to any person who has no right to receive it. We may also contact you to 
ask you for further information in relation to your request to speed up our response. 
Time limit to respond 
We try to respond to all legitimate requests within one month. Occasionally it may 
take us longer than a month if your request is particularly complex or you have made 
a number of requests. In this case, we will notify you and keep you updated.