EEESafe & LocalitEEE

Last updated: August 2026

About this Privacy Policy

EEESafe and LocalitEEE Ltd ("EEESafe", "we", "us" or "our") is responsible for the personal information described in this Privacy Policy.

This Privacy Policy explains what personal information we collect, why we use it, how we use and share it, how long we keep it, and the rights you have in relation to it. It applies to personal information processed through the EEESafe and LocalitEEE websites, the Appliance Safety Repair Register, LocalitEEE Marketplace and related platform services and communications.

Where a particular service or activity requires additional privacy information, we may provide that information at the point where the personal information is collected.

Information We Collect From You

When you create or use an EEESafe and LocalitEEE account, register a Product Item, participate as a Stakeholder, use the Marketplace or communicate with us, we may collect the personal information needed for the relevant service. This may include:

• Identity and Contact Information: your name, email address, telephone number, postal address, postcode and other information needed to identify you and allocate you to the appropriate LocalitEEE Community.
• Account and Participation Information: account credentials, participant or Stakeholder type, age confirmation, verification status and information relating to the services or participation arrangements associated with your account.
• Verification Information: information and documents provided to establish your identity, qualifying address and eligibility to participate. Verification documents are reviewed for that purpose and are deleted once the verification decision has been made, whether the application is approved or rejected. We retain the outcome of the verification and any information needed to administer your continuing participant status.
• Profile and Directory Information: information associated with a Citizen Profile or, where applicable, a LocalitEEE Business Directory entry. This may include participant status, business information, certification or verification status, documents or information the participant chooses to display, reviews and platform-generated activity or community metrics.
• Product Item and Digital Twin Information: information about registered electrical or electronic products, such as product category, manufacturer, model, serial number, age or purchase information where supplied, ownership linkage, repair or refurbishment history, safety information, Marketplace activity and other records associated with the Product Item.
• Repair and Safety Records: where a Product Item is linked to a repair or refurbishment activity, information may include the repairer involved, reported fault, work undertaken, parts or components recorded, relevant safety or test information, dates and other evidence required under the applicable EEESafe or UEEESafe process.
• Marketplace and Transaction Information: information about products listed, bought, sold, donated or transferred through the Marketplace, together with transaction values, applicable platform charges, payment status and payment-provider transaction references.
• Communications and Support Information: information you provide when you contact us, use forms, submit feedback, raise a complaint or communicate with us about your account or a platform service.

Information We Collect Automatically

When you use our websites, applications or platform services, certain technical information may be generated automatically. This may include:

• Technical and Log Information: IP address, browser and device type, operating system, dates and times of access, pages or platform functions accessed, referring information where available, and technical or security logs generated through use of the service.
• Platform Usage Information: information about how platform functions are used, such as account activity, searches, Marketplace activity and other interactions needed to operate, secure, troubleshoot and improve the service.
• Cookie and Preference Information: information stored or collected through cookies and similar technologies, including login/session information, cookie choices and other preferences. Non-essential cookies and similar technologies are used only in accordance with our Cookie Policy and applicable consent requirements.

We use this information where necessary to operate and secure the platform, prevent and investigate misuse, diagnose technical problems, maintain account sessions and preferences, understand how our services are being used and improve their performance.

Information We Obtain from Other Sources

In some circumstances, we may receive or obtain information from sources other than directly from you where this is necessary to operate the relevant platform service.

This may include:

• Product and Safety Information: product specifications, Product Recall and Safety Alert information and other relevant product information obtained from manufacturers, regulators, government sources or other publicly available safety information. Where appropriate, this information may be matched to a registered Product Item.
• Repair and Product Records: information recorded by a repairer or other authorised participant about a Product Item, including repair, refurbishment, test, safety or related activity carried out through the applicable EEESafe or UEEESafe process.
• Marketplace and Payment Information: transaction status, payment confirmation, refunds, charges and transaction references received from payment-processing providers used by the platform.
• Participant Activity and Feedback: information generated through interactions between platform participants, such as completed repair activity, Marketplace transactions, reviews or feedback associated with an account, Business Directory entry, Citizen Profile or Product Item.

Where information from another source relates to an identifiable individual, we use it only for the purposes for which it was obtained and in accordance with the lawful bases and other safeguards described in this Privacy Policy.

Platform-Generated Metrics and Community Totals

EEESafe and LocalitEEE generate totals and metrics from qualifying activity carried out through the platform. This may include registered Product Items, completed repairs, refurbishment, reuse, gifting or donation, Marketplace activity, contributions associated with LocalitEEE Business Rewards and associated environmental, social or community metrics.

Some platform metrics represent recorded events or financial amounts, such as the number of qualifying repairs or gifted items and qualifying amounts recorded through the platform. Environmental measures, including carbon, materials, weight or other environmental-impact figures, are estimates produced using EEESafe's methodology and available reference information and should not be interpreted as exact measurements.

Businesses and other eligible Stakeholders: qualifying totals may be displayed publicly as part of their LocalitEEE Business Directory entry so that people browsing the Directory can see and recognise their contribution and activity within the LocalitEEE Community. Public display is enabled by default, but the participant may choose not to have those metrics displayed. Where the information constitutes personal information, the applicable data-protection rights described in this Privacy Policy continue to apply.

Citizens: qualifying totals may be recorded in the Citizen's Profile for the Citizen to view. EEESafe and LocalitEEE does not publish those individual Citizen metrics publicly. A Citizen may choose to share their own metrics themselves.

Qualifying activity also contributes to the combined LocalitEEE Community Table of Metrics. Community figures are published as aggregated totals and do not display the underlying individual participant activity, financial records, assumptions or calculation methodology from which those totals were produced.

EEESafe and LocalitEEE may use aggregated Community totals for monitoring and evaluation, research, reporting, service development and communications about the performance and impact of the LocalitEEE model.

Why We Use Your Personal Information and Our Lawful Bases

We use personal information only where we have a lawful basis for doing so. The lawful basis depends on why the information is being used and the relationship we have with the person concerned.

Providing and administering EEESafe and LocalitEEE services: We use information to create and administer accounts, verify participant eligibility, allocate participants to the appropriate LocalitEEE Community, register Product Items, maintain Digital Twins, operate Citizen Profiles and Business Directory records, provide Marketplace functions and deliver other services requested by participants. Where this processing is necessary to provide a service or fulfil our agreement with you, we rely on performance of a contract or steps taken at your request before entering into that agreement.

Verification, platform integrity and prevention of misuse: We use information where necessary to verify eligibility, protect the integrity of the community model, prevent fraud or misuse, investigate suspected breaches, maintain security and protect users and the platform. Depending on the circumstances, we rely on performance of a contract, legitimate interests or a legal obligation. Our legitimate interests include operating a trusted and secure platform and protecting EEESafe and LocalitEEE, its participants and the LocalitEEE Community from misuse.

Product registration, safety and service communications: We use registered Product Item and account information to operate relevant safety functions, maintain Product Item records and provide service-related notices, including available Product Recall or Safety Alert information where supported by the platform. We rely on performance of a contract and our legitimate interests in operating the Register and supporting product safety.

Repairs, Marketplace transactions and payments: We process information required to record qualifying repairs and related activity, administer Marketplace transactions, calculate and record applicable fees and contributions, receive payment status information and maintain transaction records. We rely on performance of a contract and, where records must be retained for tax, accounting or other statutory purposes, legal obligation.

Platform-generated metrics and Business Directory information: We use qualifying activity to generate participant totals and LocalitEEE Community metrics. Where Business Directory metrics relate to identifiable individuals, such as sole traders or named business participants, we rely on our legitimate interests in recognising and demonstrating participant activity and community contribution. Participants may choose not to have their qualifying Business Directory metrics displayed publicly. Citizen metrics are held within the Citizen Profile and are not published by EEESafe and LocalitEEE as individual public metrics.

Operating, securing and improving the platform: We use technical, usage and support information where reasonably necessary to maintain security, diagnose faults, prevent misuse, provide support and improve the performance and usability of our services. We generally rely on our legitimate interests in operating and improving a secure and effective service, except where consent is required for a particular cookie or similar technology.

Legal, Regulatory and Product-Safety Requirements: We may use, retain or disclose information where this is necessary to comply with applicable law or where a regulator, market-surveillance authority, enforcement authority, court or other competent authority lawfully requires information from us. This may include requirements relating to product safety, Product Recalls and Safety Alerts, Marketplace activity, regulatory investigations, tax, accounting or other statutory obligations. Where information is not legally required but its use or disclosure is reasonably necessary for product safety, prevention of unlawful activity, or establishing, exercising or defending legal rights, we may rely on our legitimate interests where appropriate. Any such processing will remain subject to applicable data-protection law.

Marketing: We may send marketing or promotional communications where permitted by law. Where consent is required, we rely on your consent, which you may withdraw at any time. Where the law permits another lawful basis, such as legitimate interests, we will still respect your right to object to direct marketing.

Cookies and similar technologies: Strictly necessary technologies are used where required to provide or secure a service requested by the user. Where consent is required for non-essential cookies or similar technologies, we rely on consent obtained through the relevant cookie controls.

Who We Share Personal Information With

EEESafe and LocalitEEE does not sell personal information.

We may share personal information only where this is necessary for the relevant platform service, where another participant needs the information to carry out an agreed platform activity, where a service provider processes information on our behalf, or where disclosure is required or otherwise permitted by law.

This may include:

• Other Platform Participants: where necessary for a repair, Marketplace transaction, Digital Inclusion process, donation, transfer or other activity that the participants have chosen to enter into. We share only the information reasonably required for that activity.
• Service Providers: organisations that provide services to EEESafe and LocalitEEE such as hosting, communications, software, technical support, security, payment processing or other operational services. They may process personal information only for the purposes for which they have been engaged and subject to appropriate data-protection arrangements.
• Payment Providers: payment and transaction information may be exchanged with the payment providers used by the platform, such as Stripe or PayPal, where necessary to process transactions, refunds, charges or related payment activity. Those providers may also process information under their own privacy notices where they act independently.
• Regulators, Enforcement Authorities and Courts: we may disclose information where required by law or where a regulator, market-surveillance authority, enforcement authority, court or other competent authority lawfully requires it. Where disclosure is not legally required, we will only disclose personal information where we have an appropriate lawful basis and the disclosure is necessary and proportionate.
• Professional Advisers and Business Support: where reasonably necessary, information may be shared with professional advisers such as accountants, auditors, insurers or legal advisers who owe appropriate duties of confidentiality.

Information displayed through a Business Directory entry, Marketplace listing or other participant-controlled platform function is not treated as confidential where the participant has chosen, or the applicable platform settings provide, for that information to be displayed. Citizen Profile metrics are not published by EEESafe and LocalitEEE as individual public metrics.

Where possible, we share only the minimum personal information necessary for the relevant purpose.

International Transfers

Some organisations that provide services to EEESafe and LocalitEEE may process personal information, or make it accessible, outside the United Kingdom.

Where we make a restricted international transfer of personal information, we will ensure that an appropriate lawful transfer mechanism is in place. Depending on the country and circumstances, this may include UK adequacy regulations, appropriate contractual or other safeguards approved under UK data-protection law, or another permitted transfer mechanism.

Where appropriate safeguards are required, we will take the steps required by applicable data-protection law to assess and protect the information being transferred.

Further information about the safeguards applying to a particular international transfer may be requested by contacting us through the contact details in this Privacy Policy.

How Long We Keep Personal Information

We keep personal information only for as long as it is reasonably necessary for the purpose for which it was collected, for the operation of the relevant platform service, or where we are required to retain it by law.

Verification evidence: documents supplied solely to verify identity, qualifying address or participation eligibility are reviewed for that purpose and then deleted once the verification decision has been completed, whether the application is approved or rejected. We retain the verification outcome and any information needed to administer continuing participant status.

Account and participant information: information associated with an active Citizen, business or Stakeholder account is normally retained while the account or relevant participation remains active and for an appropriate period afterwards where necessary to administer closure, deal with enquiries or disputes, protect the platform, or meet legal obligations.

Product Item and Digital Twin records: Relevant Product Item history may continue to be retained where necessary to maintain the continuing Digital Twin record, including relevant ownership linkage, repair or refurbishment history, safety information and Marketplace history. A Product Item may leave active circulation within the platform because it has been sold, transferred or disposed of elsewhere. Where that Product Item later re-enters the platform and can reasonably be matched to an existing Digital Twin, EEESafe and LocalitEEE may reconnect the Product Item with its previous record. Matching may be assisted by automated tools or other technologies where appropriate. Closing an individual account does not necessarily require deletion of information forming part of the continuing Product Item history, although personal information will not be retained where it is no longer necessary.

Transaction, payment and accounting records: records required for financial, tax, VAT or accounting purposes are retained for the applicable statutory period. We may therefore retain relevant transaction records after an account or Marketplace transaction has ended.

Complaints, disputes, safety and compliance records: relevant information may be retained for as long as reasonably necessary to deal with the matter, establish what occurred, protect legal rights, respond to regulatory enquiries or comply with applicable law.

Marketing information: marketing preferences and related records are retained for as long as necessary to respect your choices, including a record that you have opted out where this is needed to ensure that marketing is not sent to you again.

Aggregated information: information that has been genuinely anonymised so that individuals can no longer be identified may be retained and used as aggregated LocalitEEE Community information without the same UK GDPR retention restrictions that apply to personal information.

We periodically review the personal information we hold and delete or anonymise information when it is no longer needed for the purpose for which it is retained.

How We Protect Personal Information

EEESafe and LocalitEEE use appropriate technical and organisational measures to protect the personal information that we process through our websites, applications, accounts and platform services against unauthorised or unlawful access, use, alteration, disclosure, loss, destruction or damage.

These measures may include access controls, authentication, encryption or other protective technologies where appropriate, secure hosting and communications, system monitoring, backups, software and security maintenance, and controls over the people and service providers who are authorised to process personal information.

Access to personal information is restricted to those who reasonably need it for an authorised purpose. Service providers that process personal information on our behalf are required to apply appropriate security and data-protection safeguards.

We review our security arrangements and may update them as technology, risks and the services provided by EEESafe and LocalitEEE develop.

No online system can be guaranteed to be completely secure. If we become aware of a personal-data breach, we will investigate it and take the action required by applicable data-protection law, including notifying affected individuals or the Information Commissioner's Office where required.

Your Data Protection Rights

Under UK data-protection law, you may have the following rights in relation to your personal information, depending on the circumstances:

• Access: you may ask for confirmation that we process your personal information and request a copy of it, together with relevant information about how it is used.
• Rectification: you may ask us to correct personal information that is inaccurate or complete information that is incomplete.
• Erasure: you may ask us to delete personal information in circumstances where the right to erasure applies. This right is not absolute, and we may need to retain information where there is a lawful reason to do so, including relevant continuing Product Item history or information required by law.
• Restriction: you may ask us to restrict the use of your personal information in certain circumstances, for example while its accuracy or the lawfulness of its use is being considered.
• Objection: where we rely on legitimate interests, you may object to the processing in certain circumstances. You have an absolute right to object to the use of your personal information for direct marketing.
• Data portability: where the right applies, you may ask to receive personal information you provided to us in a structured, commonly used and machine-readable format, or ask us to transfer it to another organisation where technically feasible.
• Withdrawal of consent: where we rely on your consent, you may withdraw it at any time. This does not affect processing already carried out lawfully before withdrawal or processing based on another lawful basis.
• Automated decision-making: where solely automated processing is used to make a decision about you that has legal or similarly significant effects, you have the rights provided by applicable data-protection law.

You may exercise your rights by contacting EEESafe and LocalitEEE using the details provided in this Privacy Policy. We may ask for information reasonably necessary to confirm your identity before responding to a request.

We will respond within the period required by law. In most cases this is one month, although the law allows that period to be extended in certain circumstances. If we cannot comply with all or part of a request, we will explain why where the law requires us to do so.

You also have the right to complain to the Information Commissioner's Office (ICO) about how your personal information has been handled.

User Controls on the Platform

In addition to your formal data-protection rights, EEESafe and LocalitEEE may provide account controls that allow you to manage information and activity associated with your use of the platform.

Depending on the services available to your account, these controls may allow you to:

• update account, contact or profile information;
• manage links between registered Product Items and participating repairers;
• manage Marketplace listings or other content you have submitted;
• manage the public display of eligible Business Directory metrics where that option applies;
• manage communication and marketing preferences; and
• manage cookie preferences through the applicable cookie controls.

Ending a participant link, removing a Marketplace listing or closing an account does not necessarily delete information that EEESafe and LocalitEEE is entitled or required to retain, including relevant Digital Twin history, transaction records, safety information or other records described in this Privacy Policy.

Where a particular control is not available directly through your account, you may contact EEESafe and LocalitEEE using the contact details in this Privacy Policy.

Information About Other People

In some circumstances, a participant may provide information about a Product Item or limited personal information relating to another person. This may occur, for example, where someone assists a family member, where a landlord or Housing Association registers or manages products for which it is responsible, or where a repairer records relevant information about a Product Item it has previously repaired.

You must only provide another person's personal information where you have a proper reason and authority to do so. You must provide only the information reasonably necessary for the relevant platform purpose and must take reasonable care to ensure that it is accurate.

Registering, creating or updating a Product Item record does not by itself establish ownership of the physical Product Item or give the person making the entry rights that they do not otherwise have.

Repairers or other participants adding historical product, repair or safety information must not provide unnecessary personal information about a customer or other individual.

Where EEESafe and LocalitEEE receives personal information about an individual from another person or organisation, we will process it in accordance with this Privacy Policy and applicable data-protection law. Where required by law, we will provide the individual concerned with appropriate privacy information about the information received, its source and how it is used.

Children's Personal Information

Participating EEESafe and LocalitEEE accounts are available only to people aged 18 or over. We do not knowingly create Citizen or other Stakeholder accounts for anyone under 18.

If we become aware that someone under 18 has created or attempted to create a participating account, we will take appropriate steps to close or prevent that participation and delete personal information that we do not have a lawful reason to retain.

In some circumstances, limited information relating to a person under 18 may be provided by an adult or organisation as part of another legitimate platform activity. Where this occurs, EEESafe and LocalitEEE will process only the information reasonably necessary for that purpose and in accordance with applicable data-protection law.

A parent, guardian or other person with appropriate authority who believes that EEESafe and LocalitEEE holds personal information about a person under 18 may contact us using the details in this Privacy Policy.

Accuracy of Personal Information

EEESafe and LocalitEEE take reasonable steps to keep personal information accurate and up to date where this is necessary for the purposes for which it is used.

You are responsible for providing accurate information and for keeping information that you control, such as your contact or account details, reasonably up to date.

If you believe that personal information held about you is inaccurate or incomplete, please contact us or use the available account controls. We will review the information and correct, complete or update it where appropriate.

Where information forms part of a historical Product Item, repair, transaction, safety or other record, we may preserve the original record where necessary for accuracy, traceability or legal purposes while recording an appropriate correction or update.

Data Stored on Electrical, Electronic and Digital Products

EEESafe and LocalitEEE does not access, inspect, copy, retain or erase personal information stored on a physical Product Item merely because the Product Item is registered, repaired, listed, sold, gifted or otherwise used through the platform.

Consumers and business Stakeholders decide whether to have a Product Item repaired, refurbished, sold, gifted or otherwise dealt with. Where they choose to use a platform process involving a Product Item that may contain stored personal or device data, the relevant work is carried out by an independent active Certified EEESafe or Certified UEEESafe Repairer, according to the product category and applicable process.

Where secure data wiping or sanitisation is relevant, the applicable certification requirements require the Repairer to maintain the appropriate evidence, capability and procedures required under its separate agreement with EEESafe and LocalitEEE.

Participants remain responsible for protecting or backing up any personal information they wish to retain before releasing a Product Item and for using the appropriate Certified Repairer where the chosen platform process requires one.

The Repairer is responsible for any personal information it accesses or processes while the Product Item is in its possession and for carrying out any agreed or required data sanitisation in accordance with the applicable agreement and law. EEESafe and LocalitEEE may record evidence that relevant data-wiping or sanitisation activity has been completed against the Product Item's Digital Twin, but does not itself carry out that work or take possession of the Product Item.

EEESafe and LocalitEEE is not responsible for a data incident caused by the handling, repair, refurbishment, storage or data-wiping activities of an independent participant or Repairer, except to the extent that applicable law makes EEESafe and LocalitEEE responsible for its own acts or omissions.

Third-Party Links

The EEESafe and LocalitEEE websites, applications or platform services may contain links to websites, services or information operated by other organisations, such as manufacturers, product-safety sources or other relevant third parties.

When you follow a link to an external website or service, that organisation is responsible for its own processing of personal information. EEESafe and LocalitEEE does not control how an independent third party collects or uses personal information through its own website or service.

You should review the privacy information provided by the relevant third party where appropriate. This Privacy Policy applies to personal information for which EEESafe and LocalitEEE Ltd is responsible as data controller.

Updates to This Privacy Policy

EEESafe and LocalitEEE may update this Privacy Policy from time to time to reflect changes to our services, technology, data-processing activities, legal or regulatory requirements, or other relevant developments.

Where a change materially affects how we use personal information, we will take reasonable steps to bring the change to the attention of affected participants. Depending on the circumstances, this may include an account notification, email or a prominent notice through our websites or platform services.

Where a proposed change requires consent or another specific action under applicable data-protection law, we will obtain that consent or take the required action before carrying out the relevant processing.

The current version of this Privacy Policy will show the date on which it was last updated.

Contact Us and Data Controller

EEESafe and LocalitEEE Ltd is the data controller responsible for the personal information described in this Privacy Policy.

If you have a question about this Privacy Policy, wish to exercise a data-protection right, or have a concern about how your personal information has been handled, please contact us using the details below:

If you are dissatisfied with how we have handled your personal information, you have the right to make a complaint to the Information Commissioner's Office (ICO). We would appreciate the opportunity to consider your concern first, but you do not have to contact us before approaching the ICO.