Intelligent Listing Optimisation

Maximising visibility and conversion for your retail product listings

ListSmart Privacy policy

Updated 7th July 2016 (Coolgarif Technologies Ltd trading as AltViz)

This privacy policy applies between you, the User of this Website and Coolgarif Limited (ListSmart), the owner and provider of this Website. We take the privacy of your information very seriously. This privacy policy applies to our use of any and all Data collected by us or provided by you in relation to your use of the Website. This privacy policy forms part of the terms and conditions of use of the Website (Terms), and should be read in conjunction with the Terms.

Please read this privacy policy carefully.

1. Definitions and interpretation

In this privacy policy, the following definitions are used in addition to those set out in the Terms:


collectively all information collected by us in relation to you, in accordance with the "Data collected" section of this policy;


a small text file placed on your computer by this Website when you visit certain parts of the Website and/or when you use certain features of the Website. Details of the cookies used by this Website are set out in the clause below (Cookies);

Coolgarif Limited, ListSmart, we, our or us

Coolgarif Limited which is a company incorporated in England and Wales with registered number 08026895 whose registered address is 25/29 Harper Road, London, United Kingdom, SE1 6AW;

UK and EU Cookie Law

the Privacy and Electronic Communications (EC Directive) Regulations 2003 as amended by the Privacy and Electronic Communications (EC Directive) (Amendment) Regulations 2011;

User, you or your

A registered user with an account with the Website; and


the website that you are currently using, the ListSmart marketplace listing recommendations website (including any sub-domains, unless expressly excluded by their own terms and conditions.

In this privacy policy, unless the context requires a different interpretation: (a) the singular includes the plural and vice versa; (b) "including" is understood to mean "including without limitation"; and (c) reference to any statutory provision includes any modification or amendment of it.

2. Scope of this privacy policy

This privacy policy applies only to the actions of ListSmart and Users with respect to this Website. It does not extend to any websites that can be accessed from this Website including, but not limited to, any links we may provide to social media websites.

3. Data collected

  1. When you sign up to the Website, we will collect information we ask you for, like your username, password, e-mail address, profession. We will also collect information you voluntarily add to your profile. If you connect to the Website using an authentication service such as your Facebook of Google credentials, you authorise us to collect your authentication information, such as your username, encrypted access credentials, and other information that may be available on or through your account, including your name, profile picture, country, hometown, e-mail address, date of birth, and gender. We may store this information so that it can be used for the purposes explained in this privacy policy.
  2. We will also collect data which relates to you and which you permit us to access from third party websites on your behalf by providing us with the relevant authorisation or credentials. For the avoidance of doubt, where you provide such permission, we will continue to retrieve such data on an on-going basis as we provide the Service. We may change the types and volume of data which we from such third party websites retrieve (using the authorisation or credentials you have provided), as we develop and improve our Service.
  3. When you use the Service, we automatically collect certain information, including: (i) information about your interactions with the Service; (ii) details of your use of the Website; (iii) technical data, which may include the URL you are coming from or head to, your IP address, unique device ID, network and computer performance, browser type, language and identifying information; and (iv) location information. We may store this information so that it can be used for the purposes explained in this privacy policy.
  4. When you sign up for a paid subscription, your credit card information and other financial data that we need to process your payment are collected and stored by third party payment processors, and we store some details of your transaction history. These third parties generally provide us with some limited information related to you, such as a unique token that enables you to make additional purchases using the information they have stored, and your credit card type, expiration date, and last four digits. We may store this information so that it can be used for the purposes explained in this privacy policy.

4. Our use of Data

  1. For purposes of the Data Protection Act 1998, ListSmart is the "data controller".
  2. We will display Data submitted by you on the Website in the form of a profile and store the profile Data for all Users.
  3. All personal data (as defined in the Data Protection Act 1998) is stored securely in accordance with the principles of the Data Protection Act 1998. For more details on security see the Security section set out below.
  4. We process information about our Users on servers which can be located in a number of countries. Information collected within the European Economic Area (EEA) and Switzerland may therefore be transferred to, and stored in, a country outside of the EEA and Switzerland, and we may subcontract processing or share your information to a third party located in such a country, solely in accordance with this privacy policy and applicable law. You expressly consent to this.
  5. Any or all of the above Data may be required by us from time to time in order to provide you with the best possible service and experience when using our Website. Specifically, Data may be used by us for the following reasons:
    1. internal record keeping;
    2. improvement and personalisation of our products / services;
    3. transmission (including by email) of advertising and promotional materials that may be of interest to you,
    4. sharing your Data with our affiliates so that they can, where permitted or you have consented, send advertising and promotional materials to you;
    5. contact for market research purposes which may be done using email, telephone or mail. Such information may be used to customise or update the Website;

    in each case, in accordance with this privacy policy.

5. Sharing Data

  1. We may from time to time engage other companies in our group and third party service providers to perform functions and process Data, consistent with this privacy policy. Third party service providers' processing of user data will always be subject to security and confidentiality obligations consistent with this privacy policy and applicable law.
  2. In addition to the above, we may also share your Data with third parties for these limited purposes:
    1. (1) to respond to legal process (e.g. a court order or subpoena), if we believe in good faith that it is necessary to do so; (2) to comply with requirements of mandatory applicable law; (3) to protect the safety of any person; (4) to protect the rights and property of ListSmart, including to enforce the Terms; (5) and to address fraud, security or technical issues;
    2. to inform business partners about use of the Website and products and services made available through the Service, in the form of aggregated statistics or otherwise de-identified data; and
    3. where a User is under an Alternative Fee Arrangement (as defined in the Terms), we may share your Data with the third party marketplace involved in such arrangement.

6. Third party websites and services

  1. ListSmart may, from time to time, employ the services of other parties for dealing with certain processes necessary for the operation of the Website. The providers of such services have access to certain personal Data provided by Users of this Website.
  2. Any Data used by such parties is used only to the extent required by them to perform the services that we request. Any use for other purposes is strictly prohibited. Furthermore, any Data that is processed by third parties will be processed within the terms of this privacy policy and in accordance with the Data Protection Act 1998.

7. Links to other websites

This Website may, from time to time, provide links to other websites. We have no control over such websites and are not responsible for the content of these websites. This privacy policy does not extend to your use of such websites. You are advised to read the privacy policy or statement of other websites prior to using them.

8. Changes of business ownership and control

  1. ListSmart may, from time to time, expand or reduce our business and this may involve the sale and/or the transfer of control of all or part of ListSmart. Data provided by Users will, where it is relevant to any part of our business so transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this privacy policy, be permitted to use the Data for the purposes for which it was originally supplied to us.
  2. We may also disclose Data to a prospective purchaser of our business or any part of it.
  3. In the above instances, we will take steps with the aim of ensuring your privacy is protected.

9. Accessing your own Data

You have the right to ask for a copy of any of your personal Data held by ListSmart (where such Data is held) free of charge. We will respond within a reasonable period of time upon verification of your identity.

10. Security

  1. Data security is of great importance to ListSmart. To protect your Data we have put in place suitable physical, electronic and managerial procedures to safeguard and secure Data collected via this Website, including registration and management of all user types with secure systems for login and authentication roles and access control levels.
  2. Server side authentication is handled in a secure manner using a standardised protocol.
  3. Passwords are required in order to log in to the Website. You are responsible for keeping your password confidential. Passwords are encrypted and stored securely. The Website includes a reset-password functionality.
  4. We endeavour to do our best to protect your personal Data. However, transmission of information over the internet is not entirely secure and is done at your own risk. We cannot ensure the security of your Data transmitted to the Website.

11. Cookies

  1. This Website may place and access certain Cookies on your computer. ListSmart uses Cookies to improve your experience of using the Website and to improve our range of services. ListSmart has carefully chosen these Cookies and has taken steps to ensure that your privacy is protected and respected at all times.
  2. All Cookies used by this Website are used in accordance with current UK and EU Cookie Law.
  3. Before the Website places Cookies on your computer, you will be presented with a message bar requesting your consent to set those Cookies. By giving your consent to the placing of Cookies, you are enabling ListSmart to provide a better experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of the Website may not function fully or as intended.
  4. This Website may place the following Cookies:
  5. Type of Cookie Purpose
    1. Strictly necessary cookies - These are cookies that are required for the operation of our Website. They include, for example, cookies that enable you to log into secure areas of our Website, use a shopping cart or make use of e-billing services.
    2. Analytical/performance cookies - They allow us to recognise and count the number of visitors and to see how visitors move around our Website when they are using it. This helps us to improve the way our Website works, for example, by ensuring that users are finding what they are looking for easily.
    3. Functionality cookies - These are used to recognise you when you return to our Website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
  6. You can choose to enable or disable Cookies in your internet browser. By default, most internet browsers accept Cookies but this can be changed. For further details, please consult the help menu in your internet browser.
  7. You can choose to delete Cookies at any time; however, you may lose any information that enables you to access the Website more quickly and efficiently including, but not limited to, personalisation settings.
  8. It is recommended that you ensure that your internet browser is up-to-date and that you consult the help and guidance provided by the developer of your internet browser if you are unsure about adjusting your privacy settings.

12. General

  1. You may not transfer any of your rights under this privacy policy to any other person. We may transfer our rights under this privacy policy where we reasonably believe your rights will not be affected.
  2. If any court or competent authority finds that any provision of this privacy policy (or part of any provision) is invalid, illegal or unenforceable, that provision or part-provision will, to the extent required, be deemed to be deleted, and the validity and enforceability of the other provisions of this privacy policy will not be affected.
  3. Unless otherwise agreed, no delay, act or omission by a party in exercising any right or remedy will be deemed a waiver of that, or any other, right or remedy.
  4. This privacy policy is governed by and interpreted according to English law. All disputes arising under this privacy policy are subject to the exclusive jurisdiction of the English courts.

13. Changes to this privacy policy

ListSmart reserves the right to change this privacy policy as we may deem necessary from time to time or as may be required by law. Any changes will be posted on the Website and your continued use of the Website thereafter constitutes acceptance of the changes.

You can contact ListSmart by email on