Privacy Policy

 

Privacy policy

1.       Introduction

1.1    We are committed to safeguarding the privacy of our customers, website users and persons we communicate with

1.2    This policy applies where we are acting as a data controller with respect to the personal data of customers, website users and persons we communicate with; in other words, where we determine the purposes and means of the processing of that personal data.

1.3    In this policy, "we", "us" and "our" refer to Trade Base Direct Limited.

2.       How we use your personal data

2.1    In this Section 2 we have set out:

(a)    the general categories of personal data that we may process;

(b)    in the case of personal data that we did not obtain directly from you, the source and specific categories of that data;

(c)    the purposes for which we may process personal data; and

(d)    the legal bases of the processing.

2.2    We may process data about your use of our website and services ("usage data"). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system. This usage data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is consent or our legitimate interests, namely monitoring and improving our website and services.

2.3    We may process your account data ("account data"). The account data may include your name and email address. The source of the account data is you or your employer. The account data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is consent OR our legitimate interests, namely the proper administration of our website and business or the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

2.4    We may process information relating to our customer relationships, including customer contact information ("customer relationship data"). The customer relationship data may include your name, your employer, your job title or role, your contact details, your address, and information contained in communications between us and you or your employer. The source of the customer relationship data is you or your employer. The customer relationship data may be processed for the purposes of managing our relationships with customers, communicating with customers, keeping records of those communications and promoting our products and services to customers. The legal basis for this processing is consent or our legitimate interests, namely the proper management of our customer relationships.

2.5    We may process information relating to transactions, including purchases of goods and services, that you enter into with us and/or through our website ("transaction data"). The transaction data may include your contact details, your card details and the transaction details. The transaction data may be processed for the purpose of supplying the purchased goods and services and keeping proper records of those transactions. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract and our legitimate interests, namely the proper administration of our website and business.

2.6    We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters ("notification data"). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is consent or the performance of a contract between you and us and/or taking steps, at your request, to enter into such a.

2.7    In addition to the specific purposes for which we may process your personal data set out in this Section 2, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

2.8    Please do not supply any other person's personal data to us, unless we prompt you to do so.

3.       Providing your personal data to others

3.1    We may disclose your personal data to any member of our group of companies (this means our ultimate holding company Rutherford Ide Limited) insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy.

3.2    We may disclose your personal data to our insurers and/or professional advisers]insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

3.3    We may disclose address and contact details to our suppliers or subcontractors insofar as reasonably necessary for the supply of goods or services.

3.4    Financial transactions relating to our website and services are handled by our payment services providers, Sage Pay Europe Limited and PayPal. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds.

3.5    In addition to the specific disclosures of personal data set out in this Section 3, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

 

4.       Retaining and deleting personal data

4.1    This Section 5 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.

4.2    Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.

4.3    We will retain your personal data as follows:

(a)    Your name, address, employer, job title or role, contact details, your address and information contained in communications between us and you or your employer will be retained for a minimum period of 5 years following the date of your last contact and for a maximum period of 10 following the date of your last contact.

4.4    Notwithstanding the other provisions of this Section 5, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

5.       Amendments

5.1    We may update this policy from time to time by publishing a new version on our website.

5.2    You should check this page occasionally to ensure you are happy with any changes to this policy.

5.3    We may notify you of significant changes to this policy by email.

6.       Your rights

6.1    You may instruct us to provide you with any personal information we hold about you; provision of such information will be subject to:

(a)    the supply of appropriate evidence of your identity (for this purpose, we will usually accept a photocopy of your passport certified by a solicitor or bank plus an original copy of a utility bill showing your current address).

6.2    We may withhold personal information that you request to the extent permitted by law.

6.3    You may instruct us at any time not to process your personal information for marketing purposes. You can do this by emailing info@tradebase.com

6.4    In practice, you will usually either expressly agree in advance to our use of your personal information for marketing purposes, or we will provide you with an opportunity to opt out of the use of your personal information for marketing purposes.

7.       Our details

7.1    This website is owned and operated by Trade Base Direct Limited.

7.2    We are registered in England and Wales under registration number 8932308, and our registered office is at Brendenwood, Winchester Road, Chilworth, Hampshire, SO16 7LJ.

7.3    Our principal place of business is at Unit 4 Telford Gate, Whittle Road, West Portway Industrial Estate, Andover, Hampshire, SP10 3SF

7.4    You can contact us:

(a)    by post, to the postal address given above;

(b)    by telephone, on the contact number published on our website from time to time; or

(c)    by email, using the email address published on our website from time to time.

8.       Data protection officer

8.1    Our data protection officer's contact details are: Harvey Ghinn, info@tradebase.com

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