Treehouse :: Legal

Privacy Policy

Treehouse Markets Ltd (Treehouse) Privacy Policy, including Data Subject Rights and Cookies and Tracking Guidelines

This Data Protection Policy (hereinafter, “Policy”) applies to all activities of Treehouse Markets Limited of 167-169 Great Portland Street, 5th Floor, London, W1W 5PF, United Kingdom (Treehouse), with respect to the protection of personal data that we collect, process and store in the course of our business activities, including through our websites and applications (or “apps”), as well as other electronic interfaces with data subjects that we operate. For any questions regarding the collection, processing or use of your personal data (as explained below) please contact our Data Protection Officer at dpo@treehousemarkets.com.

General Principles

Treehouse is committed to ensuring that your personal data and its privacy are protected in accordance with the best practices available, as well as according to our relevant legal obligations. This Policy explains your rights regarding the personal data we collect, process and use, including via the websites and apps, as well as our use of safeguards to protect these rights. The Policy also explains Treehouse's use of cookies and tracking on the website and application interfaces, as specified in the Cookies and Tracking Guidelines below.

Your personal data is collected and stored lawfully, fairly and transparently by Treehouse. In processing your data, we act in good faith, in a proportionate manner, and with the appropriate technical and organisational measures in line with the state-of-the-art best practices and in accordance with the risks represented by the processing and the nature of the data protected. The collection, processing and use of personal data may also be carried out by external data processors on our behalf, in the course of Treehouse's business and supply of services. We require them to comply with relevant legal data protection rules and legislation applicable to the services they provide us, within the framework of our contracts with such external processors. Treehouse may revise this Policy from time to time, and such changes shall come into effect from the moment we notify you of such changes and/or updates, either on the websites, apps or in some other reasonable and transparent manner. Important note: please refrain from logging in and making use of the websites and apps, or otherwise providing Treehouse with your personal data, if you do not consent to the collection, use, processing and disclosure of this data as set forth below.

Data Subject Rights

1. Your Rights as a Data Subject

‍1.1. Consent – We will only process personal data if you have consented to such processing, unless we are otherwise legally authorised or obliged to collect and further process personal data relating to you. If we process data solely based on your informed consent, it will be used only for the purposes stated in the consent procedure and as explained below.

‍1.2. Withdrawal of consent – You may revoke or withdraw your consent at any time by notifying our Data Protection Officer at dpo@treehousemarkets.com. Upon receipt of your Form, we will delete your data unless we are legally obliged or authorised to retain it, including for ongoing legitimate business interests of Treehouse.

‍1.3. Minimisation of data processing – Treehouse processes and stores a minimum of your personal data, as needed for providing our services to you.

‍1.4. The “right to be forgotten” and data correction – You may also request the deletion or correction of all or part of your personal data held by Treehouse. Upon receiving your request to our Data Protection Officer at dpo@treehousemarkets.com, we will correct or delete your personal data from all of our records, as soon as reasonably possible and when technically feasible, unless there is an overriding legal interest or other legal basis for the continuation of the data processing. Please understand that in the event of deletion or correction of personal data upon your request, Treehouse may not be able to further provide services via the websites, apps and other interfaces in whole or in part. In requesting data deletion or correction, you irrevocably agree and waive any claim against Treehouse's inability to provide said services,or any interruption or malfunction resulting therefrom. Note that your request for deletion or correction may also be rejected by Treehouse for lack of relevant or accurate information provided by you, or because of inadequate verification of your identity.

‍1.5. Transparency and portability of personal data – You are entitled to receive from Treehouse, upon request, information about the type of personal data about you that we have collected. You are also entitled to obtain it in a commonly-used and machine-readable form, subject to technical feasibility and lawfulness considerations. Please forward your request to our Data Protection Officer at dpo@treehousemarkets.com.

‍1.6. Automated decision-making on the basis of your personal data – Treehouse does not intentionally take any potentially-damaging decision concerning you based on automated processing operations without human intervention; and commits to giving you the opportunity to obtain human intervention in such a decision, express your point of view, and obtain an explanation of the decision. Please send your request regarding automated decision-making to our Data Protection Officer at dpo@treehousemarkets.com.

‍1.7. Personal data relating to children and minors – Treehouse does not knowingly collect or process personal data relating to children and minors under the age of 16 years, unless we are legally obliged to do so. If we become aware that personal data was transferred to us or collected by us relating to children and minors under the age of 16 years without the informed consent of a parent or legal guardian, we will delete such personal data without undue delay. Please forward your request to our Data Protection Officer at dpo@treehousemarkets.com. In the implementation of these data protection rights, Treehouse is committed to providing a timely, transparent and appropriate response to your requests.

2. Why Treehouseuses your private data

2.1. We use your personal data to provide the business services requested by you and to process your requests and inquiries, including those that include payment-related data, where applicable.

‍2.2. Your personal data is also used for the cookies and tracking utilized in the websites and apps to distinguish you from other users, to improve your use of these interfaces, and to ensure that content in the websites, apps and other relevant interfaces is presented in the most effective manner for you.

‍2.3. Additional information about our use of cookies and tracking may be found in our Cookies and Tracking Guidelines below.

3. The types of personal data we collect and how we use it

3.1. The personal data collected and used by Treehouse is limited strictly to the data necessary for us to provide you with services we supply in the course of our ongoing business, while operating under the relevant data protection and other regulatory obligations.

3.2. The data collected and processed is both general in nature, (for example, for technical purposes) and may include, depending on the services you select and utilise, personal data such as your name, identifying numbers, your IP address and internet service provider, browser type, software identification, as well as the websites you have visited before being transferred to Treehouse websites and apps, including keywords used for searches and the sites from which you have been transferred (e.g., search engine or linked content)

3.3. Some automatic processing of your personal data may occur. As is true of most organisations operating websites and apps, Treehouse gathers certain information automatically and stores it in log files. This information includes but is not limited to IP addresses, browser type, internet service provider, referral pages, operating systems, a date/time stamp and clickstream data. We may use this information to analyse trends, to administer the website and apps, to track users’ movements through them and to gather information about our user base as a whole. Treehouse may link this automatically-collected data to personal information for legitimate business purposes, such as to detect and prevent fraudulent activity; and for other legally-authorised purposes.

3.4. When you receive services from Treehouse through the websites, apps and other electronic interfaces, you may also be directed to third-party processors such as payment service providers, including credit card or online payment providers. When we use such third-party payment processors, we do not store credit card details, but instead rely on the third-party service provider to process personal data in order to provide these services. We contractually require such third-party payment processors to comply with the data protection and other laws and regulations applicable to their payment processing services. Please check the respective service provider’s relevant data protection terms and compliance with applicable laws prior to usage of any such processor’s services. The same applies to any links to and from websites of third-party networks, advertisers and affiliates. Such third-party websites are governed solely by such third parties’ data protection policies and you are advised to be careful and check any such third party’s privacy policies and compliance with laws, prior to supplying them with any of your personal data to them.

3.5. Please note that Treehouse may also disclose your data to a third party if we are required to do so by applicable law, court order or governmental regulation; or if such disclosure is otherwise authorised and necessary in support of any criminal or legal investigation or proceeding in accordance with applicable laws and regulations.

3.6. Treehouse may need to transfer the data submitted by you for the purposes described above to third parties in locations outside the country in which you are physically located, potentially including countries which may not require an adequate level of protection for your personal data compared with that provided in your country. By accepting this Policy, you consent to such data transfer as described in this section

4. Treehouse Protection of your personal data

4.1. We have taken all reasonable, industry-standard technical and organizational measures to protect your personal data against loss, alteration, theft or access by unauthorized third parties.

4.2. We will not sell, share, transfer or use the data we collect from you for purposes other than those purposes stated expressly herein above.

4.3. We will delete your personal data where the business purpose for which the data was being collected or processed ceases to apply, or if applicable data protection rules require us to delete such personal data.

4.4. The above notwithstanding, Treehouse will not be liable or responsible for any damage or loss resulting from the improper use or any breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, your personal data.

Treehouse Cookies and Tracking Guidelines

This Cookies and Tracking Policy applies to all activities of Treehouse with respect to the cookies that we collect and store in the course of our business activities, including through the websites, apps, and other electronic interfaces with data subjects that we operate. Important note: You may indicate your consent to this Cookies Policy by clicking “I agree” on the button that appears in the banner at the top of the website.

1. What’s a cookie?
A cookie is a small file sent from a website, which is then stored by your web browser. The information in the cookie can be used to recognise your last session with Treehouse. Cookies cannot install malicious software such as viruses on your device, and they do not store any of your personal data or account information.

2. Why do we use cookies?
We use cookies to save and maintain Treehouse users’ settings and selected preferences during browsing sessions, for saving repeating users’ preferences for future use (e.g. geographic allocation, accessibility and language selections and preferences), and for statistical analysis of the performance of websites and apps, trend analysis, and monitoring and identifying errors.

3. Where do cookies come from?
Cookies originate from two types of sources: 1st-party and 3rd-party. This classification refers to the internet domain that is placing the cookie. 1st-party cookies are those set by a website that is being visited by the user at the time. 3rd-party cookies are cookies that are set by a domain other than that of the site being visited by the user. If a user visits a website and another entity sets a cookie through that site this would be a 3rd-party cookie.

4. Opting out
When you first visit the websites and apps, you may acceptor decline the use of cookies. You can also control the use of cookies at the individual browser level, and instructions for managing cookie usage can be found for the following browsers at:
‍
- Google Chrome
- Internet Explorer
- Firefox
- Safari
- Safari Mobile
- Opera

If you opt out of cookies, you may still use the websites and apps, but your ability to use some features may be limited. Many browsers allow a private mode to be activated through which the cookies are always erased after the visit, and you hereby irrevocably and unconditionally waive any claim or demand in this regard.

5. Do Not Track/Privacy Mode
“Do not track” or “privacy mode” is a function that allows users to opt out from being tracked by websites for any purpose including the use of analytics services, advertising networks and social platforms. Do not track options are available in a few browsers including:

- Firefox
- Internet Explorer
- Chrome
- Safari
- Opera

If you have enabled the “do not track” function in your browser, you will not be tracked. This is in addition to you opting-out of the aggregation and analysis of data for the Website and App statistics.

6. Categories of cookies we use
Treehouse places a high priority on the security and confidentiality of the information stored in the persistent cookies we use. For example, we do not store any of your personal information, payment information or passwords in persistent cookies.

7. Any questions?
For any questions about the use of cookies by Treehouse, please be in touch with our Data Protection Officer at dpo@treehousemarkets.com.

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Website Terms of Use

This website is operated by, or on behalf of Treehouse Markets Limited of 167-169 Great Portland Street, 5th Floor, London, W1W 5PF, United Kingdom.

By using our Websites, you agree to comply with and be bound by the following terms and conditions (the "Terms of Use") together with our privacy policy and any other documents referred to therein. If you do not agree to these Terms of Use, you must not use our site.

We reserve the right to amend these Terms of Use from time to time. Any changes will be posted on our Websites. Your continued use of our Websites after posting will constitute your acceptance of, and agreement to, any changes. Specific services that we offer, or make available to you, may also be governed by additional or alternative terms and conditions with us, or other third parties.

Registering on our websites

You must be 18 years old or over to create an account on our Websites and to contact our partners through our Websites, and warrant that the details you provide on registration are true, accurate, complete and current. You must promptly update us with any changes to your account details. You must create a password when you register and you are responsible for maintaining the confidentiality of that password. You agree that any person to whom your username or password is disclosed is authorised to act as your agent for the purpose of transacting for any services via this Website, and you will be responsible for any and all activity conducted using your password. You shall take reasonable steps to prevent unauthorised access to your account via any computer or other device that you use to access your account. If you believe someone has, without authorisation, accessed an account that you created on this Website, please contact us immediately.

When you create an account you may be given the opportunity to opt-in to receive marketing emails from us or third parties. You can manage your email subscription preferences via our Websites or unsubscribe from emails at any time. From time to time, we may need to send you service emails relating to your accounts, and we reserve the right to do so.

Your responsibilities

The content on our site is provided for general information only. It is not intended to amount to advice on which you should rely. You must obtain professional or specialist advice before taking, or refraining from, any action on the basis of the content on our site. The project owners that post details of their projects are solely responsible for their accuracy and for fielding enquiries relating to those properties. We do not participate in any communications between you and project owners nor in any part of a subsequent transactions. We host the project details in good faith but we have not verified them and we make no representations, warranties or guarantees, whether express or implied about the details. We are also not giving you any advice (investment, financial or otherwise) in respect of any content on our Website or recommending or endorsing any properties, products or content on our Website.

Materials you provide

By submitting content on our Website or otherwise providing content to us ("Content"), you grant us a worldwide, royalty-free, perpetual, irrevocable, non-exclusive, sub-licensable and fully transferable licence to use, reproduce, display, sell, modify and edit the Content. You waive any moral rights you may have in the Content. We will not pay you any fees for the Content and reserve the right in our sole discretion to remove or edit it at any time. You warrant and represent that you have all rights necessary to grant us these rights. We will permit you to post Content on our Website in accordance with our procedures and provided that the content is not illegal, obscene, abusive, threatening, defamatory or otherwise objectionable to us. Any personal data that you provide via, or in connection with, the Website will be governed by our privacy policy.

Disclaimer and liability

The Website (including all content on it) is provided by us on an "as is" and "as available" basis and we make no representations, guarantees or warranties of any kind, either express or implied, including without limitation, warranties as to quality, suitability for any purpose, compatibility, reliability, accuracy, completeness, timeliness, access or use. It is your responsibility to evaluate the quality, suitability, accuracy, completeness and reliability of our Website and any information or content contained therein. We accept no responsibility and make no representations, guarantees, or warranties that the Website will operate continuously, without interruptions or be fault-free. We may need to make the Website unavailable with or without notice to carry out maintenance or upgrade work. We accept no liability for any interruption or loss of service.

Any value estimates provided on our Website are intended for general interest and information purposes only and should not be relied upon for any commercial transaction or similar use. These estimates are based on publicly available information which may be inaccurate or incomplete, and typical factors in certain locations. They will not take account of any factors which are unknown to us and should only be used as a general estimate. None of the information available on our Website is intended to be a substitute for independent professional advice and users are recommended to seek advice from suitably qualified professionals. We shall not be liable for any losses suffered as a result of relying on our value estimates.

Project descriptions and other information provided on our website are intended for information and marketing purposes and, whilst displayed in good faith, we will not in any circumstances accept responsibility for their accuracy. It is the responsibility of prospective buyers to satisfy themselves as to the accuracy of any project descriptions displayed and the responsibility of project owners to ensure the accuracy and integrity of project descriptions provided on our website.

Nothing in these Terms of Use excludes or limits our liability for death or personal injury arising from our negligence, or our fraud or fraudulent misrepresentation, or any other liability that cannot be excluded or limited by English law.

To the extent permitted by law, we exclude all conditions, warranties, representations or other terms which may apply to our site or any content on it, whether express or implied.

We will not be liable to any user for any loss or damage, whether in contract, tort (including negligence), breach of statutory duty, or otherwise, even if foreseeable, arising under or in connection with:

use of, or inability to use, our site; or
use of or reliance on any content displayed on our site.

If you are a business user, please note that in particular, we will not be liable for:

loss of profits, sales, business, or revenue;
business interruption;
loss of anticipated savings;
loss of business opportunity, goodwill or reputation; or
any indirect or consequential loss or damage.

If you are a consumer user, please note that we only provide our site for domestic and private use. You agree not to use our site for any commercial or business purposes, and we have no liability to you for any loss of profit, loss of business, business interruption, or loss of business opportunity.

We assume no responsibility for the content of websites linked to on our site. Such links should not be interpreted as endorsement by us of those linked websites. We will not be liable for any loss or damage that may arise from your use of them.

Indemnification

You agree to indemnify, defend and hold us and our shareholders, officers, directors, employees, agents or suppliers harmless from any and all claims or demands, made by any third party due to or arising out of your use of this Website or through your password or otherwise, the violation of these Terms of Use by you, or the infringement by you of any intellectual property or other right of any other person or entity.

Viruses

We do not guarantee that the Website will be secure or free from bugs or viruses. You are responsible for configuring your information technology, computer programme and platform in order to access the Website. You should use your own virus protection software. You must not misuse the Website by knowingly introducing viruses, trojans, worms, logic bombs or other material which is malicious or technologically harmful. You must not attempt to gain unauthorised access to the Website, the server on which the Website are stored or any server, computer or database connected to the Website.

We will not be liable for any loss or damage caused by a virus, distributed denial-of-service attack, or other technologically harmful material that may infect your computer equipment, computer programs, data or other proprietary material due to your use of our site or to your downloading of any content on it, or on any website linked to it.

Intellectual Property

We are the owner or licensee of intellectual property rights in the Website, information and content available on the Website, any database operated by us, any proprietary software utilised by us to enable you to use this Website ("Software") and the underlying source code. Much of this information and content is protected by copyright, trade mark, database rights, design rights (including in the "look and feel" and other visual or non-literal elements), and/or other intellectual property rights (whether registered or unregistered). Our logos, together with our trade marks and/or service marks, may not be copied or reproduced without our prior written consent. All rights are reserved.

We grant you a non-exclusive, non-transferable licence to use the Software solely in executable form and only to the extent necessary for use of the Website, and for no other purpose.

You must not use an automated program (including, without limitation, any web-crawling or screen-scraping software or any equivalent technology or techniques), to access the Website for the purpose of collecting, obtaining and/or accumulating (or other similar activity) data or content in this Website. Any such use of an automated program is prohibited and shall be a breach of these Terms of Use.

You may not reproduce, republish, transmit or distribute any material, information or content on this Website, or that form part of our services, without our prior written consent. However, you are granted a limited right to access and use the Website and our services, and retrieve, display and print content pages, for your own personal, non-commercial use and to the extent necessary for use of the Website and our services only. We reserve the right, in our sole discretion and without notice to you, to terminate your licence and to prevent future access by you to this Website.

Third Parties

This Website may contain links to third party products, services and/or websites that are not affiliated with us. We have no control over the products, services or websites of these third parties and we do not guarantee or take responsibility for them. This Website may also contain advertising from third parties and we are not responsible for any misleading or inaccurate advertisements which are the sole responsibility of the advertiser. Any links or advertisements on this Website should not be taken as an endorsement by us of any kind. Furthermore, this Website contains data provided by third parties and we accept no responsibility for any inaccuracies in this material. You agree to release us from claims or disputes of any kind arising from or in any way connected to such disputes with third parties.

Restrictions on Use

You agree not to:

transmit any material designed to interrupt, damage, destroy or limit the functionality of our Website;
use any automated software to view our Website without consent and to only access our Website manually;
use our Website other than for your own personal use;
attempt to copy our data our reverse engineer our processes;
use our Website in any manner that is illegal, immoral or harmful to us (including to commit or facilitate the commitment of any fraud against us);
use our Website in breach of any policy or other notice on our Website;
remove or alter any copyright notices that appear on our Website;
publish any material that may encourage a breach of any relevant laws or regulations;
interfere with any other user’s enjoyment of our Website;
transmit materials protected by copyright without the permission of the owner; or
conduct yourself in an offensive or abusive manner whilst using our Website.

We shall be entitled to suspend the Services and/or terminate these Terms of Use without notice to you if you commit a breach of these Terms of Use, and in particular these restrictions on use, which in our reasonable opinion is serious enough to merit immediate termination.

Governing Law

These Terms of Use are governed by English law and the contract between you and us is made in England. Any disputes will be settled in English courts, although we may take action to enforce our intellectual property rights in any relevant jurisdiction. If any provision of these Terms of Use is found to be unenforceable, it will be replaced with a provision reflecting the intent of the original provision.

General

The headings in these Terms of Use are solely used for convenience only. You may not assign or delegate any or all of your rights or obligations in this Agreement. We may assign this Agreement at any time without notice to you. Our delay or failure to exercise or enforce any right or provision of these Terms of Use shall not constitute or be construed as a waiver of such right to act. We shall not be responsible for any breach of these Terms of Use caused by circumstances beyond our control. Nothing in these Terms of Use shall be construed to create a joint venture, partnership, or agency relationship between you and us, and neither you or we shall have the right or authority to incur any liability, debt, or cost, or enter into any contracts or other arrangements, in the name of or on behalf of the other.

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