Version 2.0 · Last updated: 25 February 2026
This policy applies to all users of the Utilitarian platform, including end-customers and business users.
This Privacy Policy explains how Utilitarian collects, uses, stores, and protects personal data when you use our platform — whether you are an end-customer participating in a take-back or recycling programme, or a business user managing programmes on the platform.
We are committed to protecting your personal information and complying with applicable data protection laws, including the EU General Data Protection Regulation (GDPR), the UK GDPR, and the Australian Privacy Act 1988 (Cth). This policy should be read alongside our Terms of Service and Data Processing Agreement.
Utilitarian is a product lifecycle and take-back technology platform. We provide tools for product recognition, customer engagement, reporting, and programme management for take-back, recycling, and brand activation programmes operated by retailers and brands.
Depending on your location, the Utilitarian entity responsible for your data is:
Utilitarian B.V., registered in the Netherlands (KVK 97343927), Schiedamse Vest 154, 3011 BH Rotterdam — for users in the European Economic Area, the United Kingdom, and Switzerland.
Utilitarian Pty Ltd (ABN 89 655 178 402) — for users in Australia and New Zealand.
For all other locations, Utilitarian B.V. is the responsible entity unless otherwise specified.
— Email address — if the programme includes email capture (used to send your discount or confirmation).
— Photo submissions — images you upload (typically of products such as shoes). These are screened automatically; see Section 5.
— Product and brand information — data identified or confirmed from your upload.
— Technical data — IP address, browser type, device information, and approximate location derived from normal web use. This is not used for profiling.
— Account data — name, business email address, role, and permissions.
— Store and programme details — information linked to your organisation's programmes.
— Technical and usage data — login activity, actions taken on the platform, and technical signals.
— We do not collect biometric data, financial or payment details, or government-issued identity numbers.
— We do not intentionally collect special category data (as defined in GDPR Article 9). If such data is included in a photo upload, it is handled through our screening and quarantine workflow (see Section 5).
— Directly from you — when you participate in a programme (uploading a photo, entering your email) or when you create a business account.
— From retailers — our clients provide programme and store details that may include information about their staff.
— Automatically — through cookies and similar technologies when you access the platform or open emails sent through it. See Section 8 for details.
— Operating the platform — enabling retailers to run take-back, recycling, and brand activation programmes, and enabling you to participate in them.
— Image screening — automatically screening photo uploads to detect prohibited content and ensure only product images enter the operational workflow. See Section 5.
— Communications — sending confirmation emails, discount codes, or follow-up messages on behalf of the retailer operating the programme.
— Reporting and analytics — generating programme reports for retailers (using aggregated or de-identified data where possible).
— Service improvement — maintaining, securing, and improving the platform.
— Legal compliance — meeting our regulatory, contractual, or legal obligations.
We do not sell personal data to third parties. We do not use personal data for profiling or automated decision-making that produces legal or similarly significant effects, other than the image screening described in Section 5.
When you upload a photo through the platform, it is automatically screened using AI-based tools for two purposes:
(a) Product recognition — identifying the product type, brand, and category.
(b) Prohibited content detection — checking for the presence of people, faces, identity documents, or other personal or sensitive content that should not be in a product photo.
If the screening identifies your upload as a product-only image, it is classified as an Approved Image and enters the programme workflow.
If the screening detects potentially prohibited content, your upload is classified as a Quarantined Image and held for review by Utilitarian staff. Quarantined images are not visible to the retailer or any programme partner. After review, the image is either approved, deleted (with a prompt to re-upload), or escalated for further review.
This screening is automated but is not used to make decisions that produce legal or similarly significant effects on you. You may request human review of any screening decision by contacting privacy@utilitarian.world.
— Performance of contract — processing personal data as necessary to operate the platform on instruction from the retailer (our client), who is the data controller.
— Legitimate interests — maintaining and improving our platform, ensuring security, preventing misuse, and generating aggregated insights.
— Consent — where required, such as for marketing communications. Consent for marketing is managed by the retailer operating the programme, not by Utilitarian directly. You can withdraw consent at any time.
— Legal obligation — where processing is necessary to comply with applicable law.
Retailers (our clients) are the data controllers for end-customer data collected through their programmes. They decide what data is collected, why, and how it is used.
Utilitarian is the data processor. We process personal data on behalf of retailers, following their instructions and in accordance with our Data Processing Agreement.
For a limited set of data — such as billing contacts, security logs, and aggregated analytics — Utilitarian acts as an independent data controller.
These are required for the platform to function — for example, maintaining your session during a programme flow, or authenticating business users. These cannot be disabled.
We use analytics tools to understand how the platform is used, identify issues, and improve performance. These collect data in aggregated form and do not identify individual users. Where these cookies are non-essential, we obtain consent before setting them.
Emails sent through the platform on behalf of retailers may include tracking pixels to measure open rates and engagement. This tracking is managed by the retailer (as data controller) and is subject to the retailer's own privacy practices.
We do not use advertising cookies or third-party tracking for ad targeting.
— Retailers — end-customer data is shared with the retailer operating the programme you participated in.
— Programme Partners — where a programme involves an operational partner (such as a recycler), that partner may see approved product images in view-only mode. Programme Partners cannot access your email address or any other personal identifier, and cannot download or export images.
— Sub-processors — we use trusted service providers for hosting, email delivery, analytics, and IT security. A current list is maintained at utilitarian.world/legal/sub-processors.
— Utilitarian group companies — our Australian and Dutch entities share data for operational purposes under appropriate safeguards.
— Legal authorities — where required by law, regulation, or binding request from a competent authority.
We do not authorise the onward sale of personal data by retailers or their partners.
Personal data of EU/EEA users is hosted and processed in the European Union (Netherlands), unless otherwise agreed with the retailer.
Personal data of Australian users is hosted and processed in Australia and/or the EU.
Where personal data is transferred outside the EEA, we use appropriate safeguards including the EU Standard Contractual Clauses (Commission Decision 2021/914). For Australian data, we comply with Australian Privacy Principle 8 (cross-border disclosure).
— Approved images and programme data: retained for the term of the programme plus 6 months, then deleted or de-identified.
— Quarantined images: retained for 14 days after the screening decision (standard), or until closure of any related request plus 30 days, then deleted.
— Email addresses and customer data: retained for the term of the programme plus 6 months, unless the retailer instructs earlier deletion or you request erasure.
— Audit and security logs: retained for 24 months, then deleted.
— Business user account data: retained for as long as the account is active, plus a reasonable period after deactivation.
You have the right to: access the personal data we hold about you; request rectification of inaccurate data; request erasure; request restriction of processing; request data portability; object to processing based on legitimate interests; request human review of automated screening decisions (see Section 5); and lodge a complaint with a supervisory authority.
You have the right to: access and correct your personal information; complain to us and, if unresolved, to the Office of the Australian Information Commissioner (OAIC).
Contact us at privacy@utilitarian.world. We will respond within 30 days (or sooner where required by law). We may need to verify your identity before processing your request.
We implement appropriate technical and organisational measures to protect personal data against unauthorised access, alteration, disclosure, or destruction. These include encryption in transit and at rest, role-based access controls, multi-factor authentication, regular vulnerability scanning, and audit logging. A detailed description is included in our Data Processing Agreement (Section 4).
We may update this Privacy Policy from time to time. When we do, we will update the "Last updated" date at the top of the page. If changes are significant, we will notify business users directly and, where possible, inform end-customers through the platform or through the retailer.
Europe: Utilitarian B.V., Schiedamse Vest 154, 3011 BH Rotterdam. privacy@utilitarian.world
Australia: Utilitarian Pty Ltd, ABN 89 655 178 402. privacy@utilitarian.world