EQUELLO LTD – WHICKR APP PRIVACY POLICY – AUGUST 2026
This privacy policy explains how Equello Ltd, trading as Whickr, collects and uses personal information when you use the Whickr mobile application and services available through it.
It should be read alongside our Terms and Conditions. The separate Website Privacy Policy applies when you use the Whickr website outside the App.
Equello Ltd is the controller responsible for personal information processed through the Whickr App. In this policy, “Whickr”, “we”, “us” and “our” refer to Equello Ltd.
If you have questions about this policy, our use of personal information or your data protection rights, please contact us using these details.
This policy applies when you download, install or use the Whickr mobile application (App) or use services made available through the App.
The App’s account-based services are intended for people aged 16 and over. If you are under 16, you must not create an account or provide personal information through an account-based service. A parent or guardian who believes that a child has provided personal information should contact us.
We may collect and use the following categories of personal information.
This may include your first name, last name, username, Whickr account identifier, whether you are acting privately or as a business, and your business or trading name.
This may include your email address, telephone number, postal or billing address where relevant, general location and communication preferences.
This may include authentication information, profile photograph, biography, account status, saved adverts, favourites, notification settings, marketing choices and other account preferences.
We use authentication providers to manage passwords and access credentials. We do not include passwords in analytics or marketing data.
This may include:
This may include details of services purchased through the App, the amount and currency paid, refunds, payment status, purchase receipts, purchase tokens and transaction identifiers supplied by Apple, Google or another payment provider.
Payments are processed by the relevant app store or payment provider. We do not receive or store complete payment-card or bank-account details through the App.
This may include your internet protocol address, app version, device type, manufacturer and model, operating system, language, locale, time zone, network type, device or app identifiers, push-notification tokens, login and security records, and technical information associated with errors or crashes.
This may include information about how you use the App, such as screens viewed, searches, filters, listing interactions, favourites, message events, purchases, session activity, referral or campaign information, errors, crashes and performance information.
Message events may record that a conversation was created, viewed or used, together with relevant account, conversation and listing identifiers. We do not use the text or private media contained in messages for product analytics, advertising or marketing.
This may include a location, postcode or area you enter when searching, creating an advert or updating your profile. If you choose to use a current-location feature, the App may collect precise GPS location after requesting the relevant device permission.
This may include your choices about receiving marketing, alerts and other communications, records of communications sent to you and your interactions with those communications.
This may include the marketplace, media or co-branded partner through which you reached Whickr, referral and campaign information, and information needed to provide a partner-branded experience.
We may create aggregated or anonymous information for reporting, analytics and service improvement. Information that cannot identify you is not personal information. If we combine it with information that can identify you, we treat the combined information as personal information.
We do not normally ask for or intentionally collect special category personal information, such as information about health, ethnicity, religion, political opinions, sexual orientation or biometric data, or information about criminal convictions and offences.
Please do not include this type of information about yourself or another person in listings, messages or other content unless it is genuinely necessary and lawful to do so.
Where we need information to enter into or perform a contract with you, comply with the law, verify an account or protect users, we may be unable to provide the relevant service if you do not provide it.
For example, we may be unable to create an account, publish an advert, process a purchase, respond to a request or complete a security check.
We collect personal information in the following ways.
You may provide information when you:
When you use the App, we may collect Technical and Device Data and Usage and Analytics Data through server logs, app storage, security systems, analytics tools, crash-reporting tools, push-notification services and similar technologies.
The App may ask for permission to access:
You can refuse or withdraw these permissions through your device settings. Some requested features may then be unavailable, but you can enter a location manually and use other available alternatives where offered.
Another user may provide information about you when they send a message, report an issue, act on your behalf or include you in authorised content.
We may receive information from:
On 10 August 2026, Equello Ltd became the operator of Whickr and the controller responsible for personal information relating to existing Whickr users. Equello received that information from Whickr Group Limited.
Listings and public profiles are intended to be publicly available. Information you choose to publish may be:
This may include your name, business name, general location, photographs, videos and any telephone number or other contact details you choose to display publicly.
Do not publish information that you do not want to be publicly available. After content is removed from Whickr, copies may remain temporarily in search-engine caches, social-media posts, emails, backups or third-party systems outside our immediate control.
Messages and enquiries sent through Whickr are intended for the sender and recipient rather than the general public. Whickr may store, access, review, retain or disclose messages and message attachments only where reasonably necessary to:
We do not access private messages for general product-improvement research, advertising or marketing.
Current-location access is used only when you choose a location-enabled feature. Photographs, videos and audio are accessed only when you choose to capture, select, upload or save the relevant content. Device permissions do not make content public by themselves; content becomes public only where you choose to add it to a public listing or profile.
We use personal information only where we have a lawful basis. The lawful basis may differ depending on the purpose and circumstances.
| Purpose | Types of information | Lawful basis |
|---|---|---|
| To provide marketplace browsing, search and core App functionality | Technical and Device, Usage and Analytics, Location Data | Our legitimate interests in operating an accessible and reliable marketplace; performance of a contract where the feature forms part of an account service |
| To create, authenticate and manage your account | Identity, Contact, Account and Profile, Technical and Device Data | Performance of a contract with you; our legitimate interests in protecting account security |
| To create, publish, manage and distribute listings | Identity, Contact, Account and Profile, Listing and Content, Location, Partner and Referral Data | Performance of a contract with you; our legitimate interests in operating and promoting the marketplace |
| To enable messages, enquiries, favourites and alerts | Identity, Contact, Account and Profile, Listing and Content, Usage and Analytics Data | Performance of a contract with you; our legitimate interests in operating useful marketplace features |
| To process purchases, refunds and paid services | Identity, Contact, Transaction and Payment, Account and Profile Data | Performance of a contract with you; compliance with legal obligations; our legitimate interests in managing payments, preventing abuse and recovering money owed |
| To send service and transactional push notifications, emails or other messages | Identity, Contact, Account and Profile, Transaction and Payment, Listing and Content, Technical and Device Data | Performance of a contract with you; our legitimate interests in administering the service and protecting users |
| To provide customer support and manage our relationship with you | Identity, Contact, Account and Profile, Listing and Content, Transaction and Payment, Marketing and Communications Data | Performance of a contract with you; compliance with legal obligations; our legitimate interests in providing support and maintaining accurate records |
| To prevent fraud, scams, security incidents and misuse | Identity, Contact, Account and Profile, Listing and Content, Transaction and Payment, Technical and Device, Usage and Analytics Data | Our legitimate interests in protecting Whickr, its users and the public; compliance with legal obligations where applicable |
| To moderate content, investigate reports or disputes and enforce our Terms and Conditions | Identity, Contact, Account and Profile, Listing and Content, Technical and Device, Usage and Analytics Data | Our legitimate interests in maintaining a safe and trustworthy marketplace; compliance with legal obligations where applicable |
| To secure, troubleshoot and maintain the App | Identity, Contact, Account and Profile, Technical and Device, Usage and Analytics Data | Our legitimate interests in running our business, maintaining security and ensuring service continuity; compliance with legal obligations where applicable |
| To analyse and improve the App and measure performance | Technical and Device, Usage and Analytics, Account and Profile, public Listing and Content, Partner and Referral Data, excluding private message contents and attachments | Consent where required for app storage or access technologies; the statistical-purposes exception where its conditions are met; otherwise our legitimate interests in improving our services and understanding performance |
| To measure campaigns and advertising that leads users to the App | Technical and Device, Usage and Analytics, Partner and Referral Data | Consent where required; otherwise our legitimate interests where permitted by law |
| To send direct marketing about Whickr | Identity, Contact, Account and Profile, Usage and Analytics, Marketing and Communications Data | Consent where required; otherwise our legitimate interests where electronic-marketing law permits |
| To distribute public listings through marketplace, media and co-branded partners | Identity, Contact, Account and Profile, public Listing and Content, Location, Partner and Referral Data | Performance of a contract with you; our legitimate interests in operating and promoting the marketplace |
| To establish, exercise or defend legal claims, respond to authorities and comply with law | Any information relevant to the matter | Compliance with legal obligations; our legitimate interests in protecting our legal rights and those of others |
Where we rely on legitimate interests, we consider whether the use is necessary and balance our interests against your rights, interests and reasonable expectations.
Where we rely on consent, you may withdraw it at any time. Withdrawal does not affect processing carried out before consent was withdrawn.
We do not make decisions about you based solely on automated processing, including profiling, that produce legal effects or similarly significantly affect you.
The App uses third-party technologies to understand usage, diagnose problems, maintain security and, where applicable, measure campaigns.
We use Google Analytics for Firebase to record App interactions and performance information. We use Firebase Crashlytics to receive crash reports and Firebase Cloud Messaging to provide push notifications. Depending on the service and your choices, Google may receive app and device identifiers, Whickr account identifiers, interaction events, transaction or listing metadata, crash and diagnostic information, IP address and push-notification tokens.
Where enabled with the required consent, Meta App Events may receive a Whickr account identifier and information about App interactions, purchases, referrals and campaigns for analytics and advertising measurement. Meta may act as our processor, a joint controller or an independent controller depending on the processing it performs. Meta’s own privacy information applies to processing for which it acts as a controller.
We use Bugsnag to diagnose App errors and crashes. Reports may include an account identifier, name, email address, device and app information, diagnostic information and relevant actions or technical context leading up to an error.
We do not intentionally send private message text, private message attachments, passwords or complete payment-card details to analytics or error-reporting providers. Diagnostic reports can include information present when an error occurs, so access is restricted and reports are used only for appropriate diagnostic, security and support purposes.
Non-essential analytics and advertising-measurement technologies will remain disabled unless you consent, or unless a specific legal exception applies. Where we rely on the statistical-purposes exception, processing is limited to statistics used to improve the App, individual-level information is not retained for longer than needed to aggregate it, and you will be given a simple, free means of objecting.
You can change your analytics and advertising-measurement choices through the App’s privacy settings. You may also contact us at tackroom@whickr.com. Withdrawing consent does not affect processing carried out before withdrawal and does not disable processing that is strictly necessary to provide or secure a service you request.
If you enable push notifications, we use a device token supplied through Apple or Google to send notifications to your Device. Notifications may include service updates, message alerts, listing activity, safety information and other communications you have requested.
You can disable push notifications through the App or your Device settings. Disabling push notifications does not stop essential service communications sent by another appropriate method where they are necessary to provide the service or comply with law.
We will obtain consent before sending marketing where consent is required. You can opt out of marketing at any time by:
Opting out of marketing will not stop service messages needed to operate your account, fulfil a purchase, respond to you, provide safety information or meet legal obligations.
We may share personal information with the following recipients where necessary and lawful.
Public Listing and Profile Data is shared as described in section 6. Private messages and enquiries are shared with their intended recipients and may be accessed by Whickr only for the limited purposes described in section 6.
We may share or display public listing information through authorised partners that distribute or display Whickr listings. We may also share limited referral, support or operational information where necessary to provide a partner-branded service.
Where a partner separately collects or uses personal information for its own purposes, its own privacy policy will apply.
Apple, Google and other payment providers process purchases and may act as independent controllers for parts of their payment, fraud-prevention, account and compliance activity. Their own privacy information applies to that processing.
Google, Meta and other approved providers may process Technical and Device, Usage and Analytics, Partner and Referral Data as described in section 8, subject to your choices and applicable consent requirements.
We use providers of:
Where a provider acts as our processor, it may process personal information only for the agreed purposes and in accordance with our instructions and contractual safeguards. Where a provider acts as an independent or joint controller, its own privacy information also applies.
We require third parties with whom we share user data to provide the same or equivalent protection described in this policy and required by applicable law and Apple’s requirements.
We may share information with accountants, auditors, lawyers, insurers, banks, courts, regulators, tax authorities, law-enforcement bodies, safeguarding organisations and other parties where required or permitted by law or reasonably necessary to protect rights, safety or property.
We may share information in connection with a proposed or completed sale, purchase, financing, restructuring, insolvency, merger or transfer of a business or assets. A recipient may use the information in accordance with this policy or provide replacement privacy information where required.
Some recipients or service providers may be located outside the United Kingdom, or may access personal information from outside the United Kingdom.
Where a restricted transfer takes place, we use a lawful transfer mechanism. Depending on the circumstances, this may include:
Where required, we also assess whether additional protections are needed. You can contact us for more information about safeguards relevant to a particular transfer.
We use appropriate technical and organisational measures designed to protect personal information against accidental or unlawful loss, alteration, disclosure, access or destruction.
These measures may include access controls, authentication, encryption in transit, encryption of stored message content, logging, monitoring, backups, supplier controls and procedures for responding to security incidents.
No internet service is completely secure. You are responsible for keeping your login details confidential and for using a secure, unique password. Contact us promptly if you believe your account has been compromised.
If a personal data breach occurs, we will assess it and notify affected people and the relevant regulator where required by law.
The App stores some information on your Device, including account sessions, preferences, cached content and locally persisted App data. You can remove this information by signing out where the feature is available, clearing the App’s data through your Device or uninstalling the App. Some information will remain in Whickr or provider systems until it is deleted in accordance with this policy.
We keep personal information only for as long as reasonably necessary for the purposes described in this policy, including to provide Whickr, maintain safety and security, resolve disputes, enforce agreements, comply with legal obligations and establish or defend legal claims.
The retention period depends on factors including:
In particular:
You can request account deletion from within the App or by contacting tackroom@whickr.com. When an account is deleted, we delete or anonymise personal information associated with it and remove public listings, except where information must be retained for a legal obligation or is reasonably necessary for fraud prevention, safety, disputes, enforcement or legal claims.
Messages already sent to another user may remain in that user’s conversation record, subject to the safeguards and limited access purposes in this policy. We will remove or anonymise your account and profile information from those records where reasonably possible unless retention is necessary for one of the reasons above.
When you opt out of marketing, we may retain limited information on a suppression list so that we can respect your choice. Backups may retain information for a limited period until they are overwritten in accordance with our backup schedule.
Depending on the circumstances and lawful basis, you may have the right to:
These rights are not absolute and exemptions may apply.
To exercise a right, email tackroom@whickr.com. Please describe your request clearly. We may ask for information reasonably necessary to confirm your identity and protect information from unauthorised disclosure.
You will not usually have to pay a fee. We may charge a reasonable fee or refuse to act where a request is manifestly unfounded or excessive, where permitted by law.
We normally respond without undue delay and within one month. The period may be extended where the request is particularly complex or numerous, in which case we will tell you where required.
You have the right to make a complaint directly to us about how we use your personal information. To make a complaint, email tackroom@whickr.com.
We will acknowledge your complaint within 30 days, take appropriate steps to investigate it without undue delay, keep you informed about its progress and tell you the outcome without undue delay.
You also have the right to complain to the Information Commissioner’s Office. More information is available at https://ico.org.uk/make-a-complaint/.
We keep this policy under regular review. This version was published and last updated on 14 August 2026 and applies from 10 August 2026.
We may update this policy when our services, providers or legal obligations change. We will publish the updated policy on this page and bring material changes to your attention where required, for example through the App, email or another appropriate notice.
Where a new use of personal information requires consent, we will ask for that consent separately before starting that use.