Privacy Policy

Trade Engine Limited - Privacy Policy

Last updated: 16/10/2023

1. Definitions and interpretation

In this Policy, the following terms shall have the following meanings:

2. Information about us

Our Site is owned and operated by Trade Engine Limited, a Limited Company registered in England under company number 10278876.

• Registered address: Swan Park Business Centre, Kettlebrook Road, Tamworth, England, B77 1AG
• Main trading address: Swan Park Business Centre, Kettlebrook Road, Tamworth, England, B77 1AG
• VAT number: Please e-mail web@tradeengine.co.uk
• Data Protection Officer: Andrew Brown
• E-mail address: web@tradeengine.co.uk
• Telephone number: (0330) 223 0606

3. What does this policy cover?

This Privacy Policy applies only to your use of our Site. Our Site may contain links to other websites. Please note that we have no control over how your data is collected, stored, or used by other websites, and we advise you to check the privacy policies of any such websites before providing any data to them.

4. What is personal data?

Personal data is defined by the UK GDPR and the Data Protection Act 2018 (collectively, "the Data Protection Legislation") as 'any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier.'

Personal data is any information about you that enables your identification. It covers obvious information such as your name and contact details, but it also includes less obvious data such as identification numbers, electronic location data, and other online identifiers.

5. What are my rights?

Under the Data Protection Legislation, you have the following rights:

• The right to be informed about our collection and use of your personal data. This Privacy Policy should tell you everything you need to know, but you can always contact us for more information.
• The right to access the personal data we hold about you.
• The right to have your personal data rectified if it's inaccurate or incomplete.
• The right to be forgotten, i.e., the right to ask us to delete or dispose of any of your personal data.
• The right to restrict (prevent) the processing of your personal data.
• The right to object to us using your personal data for a particular purpose or purposes.
• The right to withdraw consent if we rely on your consent as the legal basis for using your personal data.
• The right to data portability.
• Rights relating to automated decision-making and profiling. (We do not use your personal data this way.)

It's essential to keep your personal data accurate and up-to-date. If any of the personal data we hold about you changes, please inform us.

For more information about your rights, you can also contact the Information Commissioner's Office or your local Citizens Advice Bureau.

If you have any complaints about our use of your personal data, please contact us first, using the details in Part 15.

6. What Data Do You Collect and How?

Depending on your use of Our Site, we may collect and hold some or all of the personal and non-personal data set out in the table below, using the methods described in the table. We do not collect any 'special category' or 'sensitive' personal data or personal data relating to children or data relating to criminal convictions and/or offenses.

Data collected	How we collect this data
Identity information, including name and date of birth	Collected via registration/signup forms.
Contact information, including address, email, and phone number	Collected via registration/signup forms.
Business information, including business name, job title, business website, and business address	Collected via registration/signup forms.
Payment information, including card details and billing address	Using payment integration with Stripe and PayPal.
Profile information, including preferences and interests	Collected via registration/signup forms.
Data from third parties, including IP address, browser type, and version, and operating system	Google Analytics

7. How do you use my personal data?

Under the Data Protection Legislation, we must always have a lawful basis for using personal data. The following table describes how we may use your personal data and our lawful bases for doing so:

What we do	What data we use	Our lawful basis
Registering you on Our Site	Name, email, phone, address, business name, business website, and billing address	Legitimate interest in our products or services following an inquiry or form submission.
Supplying our products and services to you	Name, email, phone, address, business name, business website, billing address, and card payment details	Legitimate interest in our products or services following an inquiry, form submission, or purchase.
Managing payments for our products and services	Name, email, phone, address, business name, business website, billing address, and card payment details	Legitimate interest in our products or services following a purchase.
Communicating with you	Name, email address, and interests	Legitimate interest in our products or services following an inquiry, form submission, or purchase.
Supplying you with information by email that you have opted-in to	Name, email address, and interests	Legitimate interest in our products or services following an inquiry, form submission, or purchase.

With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, including contacting you by email, telephone, text message, or post with information, news, and offers on our products and services. You will not receive any unlawful marketing or spam, and you can opt-out at any time.

Third Parties whose content appears on Our Site may use third-party Cookies (see Part 14 for more information). We will only use your personal data for the purpose(s) for which it was originally collected unless we reasonably believe that another purpose is compatible with the original purpose(s) and need to use your personal data for that purpose.

If we use your personal data for a purpose unrelated to the original purpose(s), we will inform you and explain the legal basis for doing so.

In some circumstances, where permitted or required by law, we may process your personal data without your knowledge or consent within the bounds of the Data Protection Legislation and your legal rights.

8. How long will you keep my personal data?

We will not keep your personal data for any longer than is necessary for the reason(s) for which it was first collected. Your personal data will be kept for the following periods:

Type of data	How long we keep it
Identity Information, including name and date of birth	As long as there is legitimate interest or until you request the removal of the data.
Contact information, including address, email, phone number	As long as there is legitimate interest or until you request the removal of the data.
Business information, including business name, job title, business website, and business address	As long as there is legitimate interest or until you request the removal of the data.
Payment information, including card details and billing address	As long as there is legitimate interest or until you request the removal of the data.
Profile information, including preferences and interests	As long as there is legitimate interest or until you request the removal of the data.
Data from third parties, including IP address, browser type, and version, and operating system	As long as there is legitimate interest or until you request the removal of the data.

9. How and where do you store or transfer my personal data?

We may store some or all of your personal data in countries outside of the UK (third countries). We will ensure that your personal data is protected under binding corporate rules, which are common rules that all our group companies must follow when processing personal data.

For more information, please refer to the Information Commissioner's Office.

10. Do you share my personal data?

We will not share any of your personal data with third parties, except in the following situations:

• If we sell, transfer, or merge parts of our business or assets, your personal data may be transferred to a third party who will continue to use it as specified in this Privacy Policy.
• In some limited circumstances, we may be legally required to share certain personal data, including yours, if we are involved in legal proceedings, complying with legal obligations, a court order, or the instructions of a government authority.

11. How can I control my personal data?

In addition to your rights under the Data Protection Legislation, when you submit personal data via Our Site, you may have options to restrict our use of your personal data. We aim to give you strong controls on our use of your data for direct marketing purposes, including the ability to opt-out of receiving emails from us.

You may also sign up for preference services in the UK, such as The Telephone Preference Service (TPS), the Corporate Telephone Preference Service (CTPS), and the Mailing Preference Service (MPS). These services may help prevent unsolicited marketing.

Please note that these services will not prevent you from receiving marketing communications that you have consented to receive.

12. Can I withold information?

You may access certain areas of Our Site without providing any personal data. However, to use all features and functions available on Our Site, you may be required to submit or allow for the collection of certain data.

You may also restrict our use of Cookies (see Part 14 for more information).

13. How can I access my personal data?

If you want to know what personal data we have about you, you can ask us for details of that personal data and a copy of it. This is known as a "subject access request."

All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 15.

There is usually no charge for a subject access request, but if your request is 'manifestly unfounded or excessive' (for example, if you make repetitive requests), a fee may be charged to cover administrative costs.

We will respond to your subject access request within 21 days and, in any case, not more than one month from receiving it. In some cases, more time may be required, up to a maximum of three months.

You will be kept informed of our progress.

14. How do you use cookies?

Our Site may place and access certain first-party Cookies on your computer or device. First-party Cookies are placed directly by us and used only by us. We use Cookies to facilitate and improve your experience of Our Site and to provide and improve our products and services.

By using Our Site, you may receive certain third-party Cookies on your computer or device. Third-party Cookies are placed by websites, services, and parties other than us. Third-party Cookies are used for understanding user behaviour, providing a personalized experience, and marketing. Please refer to the table below for more details.

All Cookies used by and on Our Site comply with current Cookie Law. Before Cookies are placed on your computer or device, you will be shown a pop-up requesting your consent to set those Cookies.

Certain features of Our Site depend on Cookies to function. Cookie Law deems these Cookies to be "strictly necessary." Your consent will not be sought to place these Cookies, but it is still important that you are aware of them.

The following first-party Cookies may be placed on your computer or device:

• Google Analytics: Website tracking and measuring user behaviour. (Strictly necessary)

The following third-party Cookies may be placed on your computer or device:

• Google Analytics: Website tracking and measuring user behaviour.

15. How do I contact you?

To contact us about your personal data and data protection, including making a subject access request, please use the following details:

• E-mail address: web@tradeengine.co.uk
• Telephone number: (0330) 223 0606
• Postal address: Swan Park Business Centre, Kettlebrook Road, Tamworth, England, B77 1AG

16. Changes to this Privacy Policy

We may change this Privacy Policy from time to time, for example, if the law changes or if we change our business in a way that affects personal data protection.

Any changes will be immediately posted on Our Site, and you will be deemed to have accepted the terms of the Privacy Policy on your first use of Our Site following the alterations. We recommend checking this page regularly to stay up-to-date. This Privacy Policy was last updated on 16/10/2023.