Where The Trade Buys

Privacy Policy

Last updated: 01 December 2023

WTTB Ltd, a company registered in England and Wales, company number (15097004), with its registered address at Unit 15 Thames Gateway Park, Chequers Lane, Dagenham, England, RM9 6FB (“us”, “our”, “we”, “WTTB”) is the controller of your personal data collected through the Website. WTTB is committed to protecting and respecting your privacy.

1. Introduction

This privacy policy (the “Privacy Policy”) sets out the types of personal data we collect when you access and visit https://wttb.co.uk/ (the “Website”) and our products or services (together the henceforth known as the “WTTB Services”), and how we may manage and use that data.

It is important that you read this Privacy Policy together with any other privacy notice or fair processing notices that we may provide on specific occasions when we are collecting or processing your personal data so that you are fully aware of how and why we are using that data.

This Privacy Policy supplements other terms or notices on our Website and is not intended to override or replace them.

By visiting or otherwise using our Website or the WTTB Services, you accept that you have read and understood this Privacy Policy. If, for any reason, you do not agree with the content of this Privacy Policy, please stop using this Website or the WTTB Services.

We reserve the right to revise or amend this Privacy Policy at any time to reflect changes to our business or changes in the law. Where these changes are significant, we will endeavour to let you know. However, it is your responsibility to check this Privacy Policy before each use of the Website or the WTTB Services.

The Website or the WTTB Services are not intended for children and we do not knowingly collect personal data relating to children.

2. What information can we collect?

This Privacy Policy covers the collection and processing of your personal data. Where this Privacy Policy refers to ‘personal data’ it is referring to data about you from which you could be identified – such as your name, your date of birth, your contact details and even your IP address.

The personal data we collect from you may include:

Identity Data: which includes your full name and your job title.

Contact Data: which includes your billing address, delivery address, e-mail address and telephone number.

Financial Data: which includes bank account and payment card details.

Transaction Data: which includes details about payments to and from you and other details or services you have purchased from us.

Technical Data: which includes your IP address, operating system, browser type and browser version.

Usage Data: which includes information about how you use the Website and our products and services.

Marketing and Communications Data: which includes your preferences in receiving marketing from us (including our newsletter) and our third parties.

3. How is your personal information collected?

Information you give to us

When you use the Website or the WTTB Services to complete a form, contact us by email or by post, contact us via our live chat function, report a problem, or offer your information to us in any way, we may collect, store and use the personal data that you disclose to us.

It is important that the personal data we hold about you is accurate and current. If you want to update the information you have previously given to us, please contact us at GDPR@wherethetradebuys.co.uk.

Automated technologies or interactions

Each time you use our Website, we will automatically collect your personal data including Technical Data and Usage Data. We collect this data using technologies such as cookies or other similar tracking technologies.

Please refer to our Cookies Policy for further details.

Third parties or publicly available sources

We may also receive personal data about you from various third parties, and public sources, such as: analytics providers, advertising networks and search information providers.

4. How and why do we use/share your personal data?

Lawful basis for processing your information

We will only use your personal data when the law allows us to. Most commonly we will use your personal data in the following circumstances:

● Where you have asked us to do so, or consented to us doing so;

● Where we need to do so in order to perform a contract, we have entered into with you;

● Where it is necessary for our legitimate interests (or those of a third party) and your fundamental rights do not override those interests; and

● Where we need to comply with a legal or regulatory obligation.

Here are some examples about how we may use the information we collect about you and the lawful basis we rely on to do so.

Activity

To register you as a new user of our Website or the WTTB Services.

Data: Identity and Contact
Basis: Performance of contract with you

To deliver the Website or WTTB Services to you and manage our relationship with you.

Data: Identity, Contact, Financial, Transactional, Technical and Usage
Basis:Performance of contract with you

To deliver any products you have ordered

Data: Identity, Contact, Financial and Transactional
Basis: Performance of contract with you

To process your purchases including managing payments and collecting money owed to us.

Data: Identity, Contact, Financial and Transaction
Basis: Performance of a contract with you.

Necessary for our legitimate interest (to recover debts due to us)

To administer and protect our business and this Website (including troubleshooting, data analysis and system testing)

Data: Identity, Contact and Technical
Basis: Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)

Necessary to comply with a legal obligation.

To use data analytics to improve our Website and customer relationships

Data: Technical Data and Usage Data
Basis: Necessary for our legitimate interests (to keep our website updated and relevant and to develop our business)

To deliver relevant content and advertisements to you

Data: Identity, Contact, Technical, Profile, Usage and Marketing and Communications.
Basis: Your consent

Necessary for our legitimate interests (to develop our products/services and grow our business)

Marketing

We may use your personal data to contact you about our latest news, our products or our services (we call this marketing).

You will receive marketing communications from us if you have:

• provided us with your business e-mail account and we have a legitimate interest in keeping you up to date with our latest news and offers;

• subscribed to receive marketing communications from us; or

• purchased our products or services, and you have not opted out of receiving marketing from us when providing us with your e-mail address or contact number.

To unsubscribe from marketing emails at any time, please click on the unsubscribe link at the bottom of any marketing email, or you can contact us at GDPR@wherethetradebuys.co.uk.

If you do not have a business e-mail address, we will get your express opt-in consent before we share your personal data to any third party for its own marketing purposes.

Sharing your personal data

Depending on how and why you provide us with your personal data we may share it in the following ways:

• we may share your personal data with any member of our company group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006;

• with selected third parties who we sub-contract to provide various services and/or aspects of the Website’s functionality, such as where third-party plugins provide functionality such as message boards or image hosting services (see “Service Providers” below); and

• with analytics and search engine providers that assist us in the improvement and optimisation of this Website as described above.

We may also disclose your personal data to third parties in the following events:

• if we were to sell or buy any business or assets, in which case we might disclose your personal data to the prospective seller or buyer of such business or assets as part of that sale;

• if WTTB or substantially all of its assets are acquired by a third party, in which case personal data held by us about our customers will be one of the transferred assets;

• if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or if we are asked to provide your details to a lawful authority in order to aid in the investigation of crime or disorder; and/or

• in order to enforce or apply our terms of use or terms and conditions, or to protect the rights, property, or safety of our company, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

Service Providers

We engage with service providers to assist us in the delivery of the Website and the WTTB Services. We will only provide service providers with the minimum amount of personal data they need to fulfil the services we request, and we stipulate that they protect this data and do not use it for any other purpose. We take these relationships seriously and oblige all of our data processors to sign contracts with us that clearly set out their commitment to respecting individual rights, and their commitments to assisting us to help you exercise your rights as a data subject. The following is a list of the type of trusted service providers we use:

• Website Developers;
• Website Hosting and Maintenance Providers;
• Analytics Providers;
• Payment Processors;
• Social Media Marketing Managers;
• Online Marketing Providers;
• Client Relationship Management System Providers; and
• Courier Services.

Links to third party sites

The Website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our Website, we encourage you to read the privacy policy of every website you visit.

5. For how long do we keep your personal data?

We will hold your personal information on our systems only for as long as required to provide you with the services you have requested, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

In some circumstances you can ask us to delete your data: see ‘Your Rights’ below for further information.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

6. Security

WTTB takes the protection of your information very seriously. Where we have given you a password that enables you to access certain parts of our Website or the WTTB Services, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

7. International Data Transfers

Whenever we do transfer your personal data outside of the UK, we ensure that a similar degree of protection is afforded to it by ensuring that in most cases at least one of the following safeguards is implemented:

• we will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data under UK data protection laws; and

• where you we use certain service providers, we will use specific contracts approved by the Information Commissioner which gives personal data the same protection it has in the UK.

By submitting your personal data, you understand the terms on which we may transfer your personal data outside of the UK. If you would like more information about transfers outside of the UK, please contact us at GDPR@wherethetradebuys.co.uk.

8. Your Rights

Right of Access

You may, at any time, request access to the personal data we hold about you (you may have heard of this right being described as a "subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Your Right to Rectification

You may request that we correct personal data that we hold about you which you believe is incorrect or inaccurate, though we may need to verify the accuracy of the new data you provide to us.

Your Right to Erasure

You may ask us to erase personal data if you do not believe that we need to continue retaining it (you may have heard of this right described as the “right to be forgotten”). If for any reason we believe that we have a good legal reason to continue processing personal data that you ask us to erase we will tell you what that reason is at the time we respond to your request.

Your Right to Object to Processing

You may object to processing of your personal data where we rely on legitimate interest for processing that personal data. You also have the right to object where we are processing your personal data for direct marketing purposes. We will comply with your request unless we have a compelling overriding legitimate interest for processing or we need to continue processing your personal data to establish, exercise or defend a legal claim.

Your Right to Restrict Processing

This enables you to ask us to suspend the processing of your personal data in the following scenarios:

• if you want us to establish the data's accuracy;
• where our use of the data is unlawful, but you do not want us to erase it;
• where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
• you have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.

Your Right to Portability

We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Your Right to object to automated decision making and profiling

You have the right to be informed about the existence of any automated decision making and profiling of your personal data, and where appropriate, be provided with meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing that affects you.

Your right to withdraw consent at any time

You may withdraw your consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

Exercising your rights

When you write to us making a request to exercise your rights, we are entitled to ask you to prove that you are who you say you are. We may ask you to provide copies of relevant ID documents to help us to verify your identity.

9. Contact Details

If you have any queries regarding this Privacy Policy, if you wish to exercise any of your rights set out above or if you think that the Privacy Policy has not been followed, please contact us at GDPR@wherethetradebuys.co.uk.

You may also lodge a complaint with our lead supervisory authority, the Information Commissioner, or your local supervisory authority about any aspect of our handling or processing of your personal data. We would, however, appreciate the chance to address your concerns before you approach any supervisory authority, so please contact us in the first instance.