Legal document
Which contact details Tradello holds
What kind of contact detail a package may contain, what it never contains, what is not yet distinguished, and what a buyer becomes responsible for.
This page has not been through legal review
Every category on this page is read out of the disclosure policy in the code, and the rows that decide it are named beside it. None of the wording has been written or approved by a solicitor.
The responsibility split below describes how we understand the position. It is not drafted as an operative term and a solicitor has not settled whether a buyer is an independent controller or a joint controller with us.
Your statutory rights are unaffected by anything on this page. The version you accepted is recorded against your purchase, so which wording applied to your order stays answerable. If you would rather wait for the reviewed wording before buying, nothing here expires.
The short version
A Tradello package contains professional contact details as published by the source. Tradello may provide professional names, roles, work email addresses and professional telephone numbers where an identified official or professional source has published them in connection with a project, procurement or business role.
Availability does not constitute consent to marketing. Nobody in a Tradello package has agreed to hear from you. The details are available because a named publisher published them; what you may lawfully send to them is your decision and your responsibility, and this page sets out where that line falls.
Some of what a package contains reaches a function — a planning or procurement inbox that identifies nobody. Some of it reaches a named person, acting in a professional role, and this page says so rather than implying otherwise. What is never in a package is a mobile number, a mailbox at a consumer provider, a private individual’s details, a named contact whose professional role we could not establish and anything the classification could not place.
It also sets out, in the third list, the things this product does not yet tell apart. That list is there because a page that claimed a protection we have not built would be worse than no page.
What is deciding this today: the classified model
Disclosure in this deployment is decided by the classified contact model. Each route is graded on three separate questions — what kind of body published it, what role it reaches, and what kind of mailbox or line it is — and the answer is looked up in a table of 29 ordered rows, first match winning. The two lists below are that table, read out of it.
A route kind on its own no longer decides anything. A suppression, an objection or a rights request is asked about before the table is consulted at all, and it beats every row in it.
What a package may contain
Each of these is read out of the disclosure table rather than described from memory: the rows that decide a category are named beside it, and what happens to that category is generated from those rows. If a row changes its mind, this list changes with it.
- Role and department inboxes at a public authority
- A function mailbox published by a council, an NHS body, a university or another authority so that the public can use it — planning@, procurement@, tenders@ at an authority’s own domain. It reaches whoever holds that role today and it identifies nobody. A customer who has bought this package sees the value, and may take it away in an export. Enforced by: a rule written for this category in the disclosure table, which grades every route before it can go into a package.
- Published corporate, head-office and department inboxes
- A company’s, LLP’s, Scottish partnership’s or corporate charity’s own function mailbox, published by the organisation or in a public notice: estimating@, headoffice@, supplychain@. A function rather than a person. A customer who has bought this package sees the value, and may take it away in an export. Enforced by: a rule written for this category in the disclosure table, which grades every route before it can go into a package.
- Function inboxes at an establishment named in a public register
- A generic mailbox — info@, hello@, enquiries@, office@ — belonging to a school, college, care home, hospital or food business that appears in a statutory public register, reached from the website that register publishes for it. Neither register publishes an email address of its own; what they publish is a website, and a function mailbox on it is read from that page. It reaches a school office or a reception rather than a person. A customer who has bought this package sees the value, and may take it away in an export. Enforced by: 2 rules written for this category in the disclosure table, which grades every route before it can go into a package.
- Main telephone numbers published in a public register
- The telephone number a statutory public register publishes for the establishment it registers, in a named column of a file anybody may download — a school office, a care home’s reception. It reaches a function and not one person’s desk, and no person is published beside it: the columns naming a head teacher, a registered manager or a nominated individual are never read at all. A number in one of these columns that turns out to be a MOBILE is refused on its digits before this category is reached. A customer who has bought this package sees the value, and may take it away in an export. Enforced by: 2 rules written for this category in the disclosure table, which grades every route before it can go into a package.
- A named professional’s published work email address
- The work mailbox of a named officer, estimator, agent, architect or contract manager, at a public authority or at a corporate body, where an identified source published it against this project in that professional capacity. Professional capacity is the whole basis: a person’s mailbox with nothing establishing what they do at the organisation is a separate category below and is treated differently. A customer who has bought this package sees the value on that project’s record, and it is never included in a bulk export — the same detail in a spreadsheet column is a marketing list however it was assembled. Enforced by: 2 rules written for this category in the disclosure table, which grades every route before it can go into a package.
- Switchboards and published department telephone lines
- A main number or a published duty line — a planning duty desk, a tender helpline, a company switchboard. It reaches a function rather than one person’s desk. A customer who has bought this package sees the value, and may take it away in an export. Enforced by: 2 rules written for this category in the disclosure table, which grades every route before it can go into a package.
- A named professional’s published direct telephone line
- A landline that reaches one named professional’s desk, published by an identified source against this project in that professional capacity. A mobile number is NOT this category and never becomes it, whatever label the publisher put beside it. A customer who has bought this package sees the value on that project’s record, and it is never included in a bulk export — the same detail in a spreadsheet column is a marketing list however it was assembled. Enforced by: 2 rules written for this category in the disclosure table, which grades every route before it can go into a package.
- The source and the dates, on every route
- Every route carries which publisher published it, when the source published it, when we collected it, and when somebody last went back to the source and found it still there. The last of those is empty until a verification has actually happened, and it is never filled in with a neighbouring date. A route that reaches one named person and carries no source a human could open is refused outright. Enforced by: a route that does not name the publisher it came from is rejected before it counts as usable, and refused a second time at the point of release for incomplete provenance.
What a package never contains
Excluded means the value is not in a package and cannot be put into one by changing a setting or paying more. Some of these are held and shown to exist without their value; some are refused before the disclosure table is read at all. Nothing on this list is deleted from our records, because being unable to answer for what we hold would be a worse outcome than holding it.
- Mobile numbers, including professionally published ones
- A mobile is somebody’s pocket whoever published it and whatever it was published as. The disclosure table gives a professionally published mobile a paying-customer row and the product declines to use it. This is refused before the disclosure table is consulted, so no row in that table can release it and no future row can be written that does. The record is retained so that a request from the person it is about can be answered, and it reaches no customer. Enforced by: the route is turned away when it is first offered to us, before the disclosure rules are consulted at all; a second, independent reading of the digits themselves, folded into the structural check every route has to pass, so that nothing we decide about a number afterwards can let one through.
- Mailboxes at a consumer provider
- An address at a free web-mail or an internet provider’s domain is a personal mailbox whoever is using it and whatever they are using it for. A tradesperson running a business from one is an individual subscriber with a business, not a company with an unusual domain. This is refused before the disclosure table is consulted, so no row in that table can release it and no future row can be written that does. The record is retained so that a request from the person it is about can be answered, and it reaches no customer. Enforced by: the route is turned away when it is first offered to us, before the disclosure rules are consulted at all; a rule written for this category in the disclosure table, which grades every route before it can go into a package; the address is checked against the list of consumer web-mail and internet provider domains and rejected there, before it is ever a route at all.
- Private homeowners, private applicants and people acting as people
- A member of the public who applied for an extension, or wrote to a council about somebody else’s application. The organisation axis may resolve to a real registered company — a householder’s application names their builder and their architect — and it does not matter, because the context says the contact is the householder and that is the stricter fact. This is refused before the disclosure table is consulted, so no row in that table can release it and no future row can be written that does. The record is retained so that a request from the person it is about can be answered, and it reaches no customer. Enforced by: the route is turned away when it is first offered to us, before the disclosure rules are consulted at all; 4 rules written for this category in the disclosure table, which grades every route before it can go into a package; a blocking check at publication, which stops the whole release rather than one record if any lead offered for sale qualifies on a non-business route.
- Sole traders, ordinary partnerships and unresolved organisations
- The rules on unsolicited marketing by electronic mail turn on whether the subscriber is an individual or a corporate body, and a sole trader or an ordinary partnership is an individual subscriber however commercial the address looks — the firm’s info@ is the same subscriber as the sole trader. An organisation we could not resolve is treated the same way, because "we could not tell" and "we checked, and it is a limited company" are different facts and only one of them is evidence. The route is shown to EXIST, with its source and its dates, and the value itself reaches no customer at any tier. It is held back rather than deleted, so we can still answer for it. Enforced by: 5 rules written for this category in the disclosure table, which grades every route before it can go into a package.
- A named mailbox or direct line with no established professional role
- A person’s mailbox or desk line at an organisation, with nothing establishing what they do there. Professional capacity is never assumed from an employer’s domain — that is the mistake the old classifier made in the other direction, when it read the department name beside an address instead of reading the address. This is not in a package at all, at any tier, for any customer. It is retained so that a request from the person it is about can be answered, and it is disclosed to nobody. Enforced by: 2 rules written for this category in the disclosure table, which grades every route before it can go into a package.
- Anything the classification could not place
- An address or a number that did not classify, and an authority mailbox hanging off an organisation that did not resolve to an authority. Two axes disagreeing is a resolution defect to be fixed, not averaged, and "I could not tell" is the case this policy exists for. This is not in a package at all, at any tier, for any customer. It is retained so that a request from the person it is about can be answered, and it is disclosed to nobody. Enforced by: 5 rules written for this category in the disclosure table, which grades every route before it can go into a package.
- Guessed, constructed or pattern-matched addresses
- No address is ever built from a pattern, from a domain, from a colleague’s address, by inference or by a language model. Where no qualifying email exists in the record, the package says the source did not publish one rather than being completed with an invention. Enforced by: there are only four ways a route is allowed to have been found — published on the source record, published on the organisation’s own website, published inside a document, or on the public companies register — and a test that fails our build if any part of the product could assemble an address instead.
- Social media accounts
- There is no social account in a Tradello record because there is no route kind that could hold one. It is not filtered out; it has nowhere to go. Enforced by: the list of kinds of route a record can hold has no entry for one, so there is nowhere in the product for a social account to be stored.
- Anything bought from a list
- No contact data is purchased from a data broker or a list vendor. Every route came from a published record or from an organisation’s own published website. Enforced by: the same four permitted ways of finding a route, above — a bought address is none of them, so it has no way in.
A private person’s contact details are never restored, never enriched and never sold. That applies whatever the source published, whatever any table says, and whatever company is named beside them on the same form.
How long a named professional contact stays visible
A named professional contact stops being visible to customers twelve months after the last time the source was checked and the detail was still there. Checking it again restarts the twelve months. The period runs from that verification and not from the day we collected the record, because the day a crawler read a page is not evidence that the page is still right.
Enforced by: the twelve months are counted on the read that would otherwise have shown you the detail, every time, and the detail is withheld there rather than by a sweep that runs later.
What this product does not yet tell apart
This is the list a buyer needs most, because these are the places where your own judgement has to do the work our system does not. None of the following is a protection we offer. Each is a distinction a reasonable person might assume we draw, and we do not.
- How sure we are that an organisation is what we resolved it to
- An organisation type is a worked-out fact, not a published one, and the strength of the match that produced it is not carried through to the record: measured across every classified route, none carries a resolution confidence. An unresolved organisation is treated as an individual subscriber and masked, which is the strict direction — but where one DID resolve, this page cannot tell you how firmly. It is the single thing that most bounds what is disclosed here, and it is a gap in the record rather than in the policy.
- Which set of marketing rules applies to a particular address
- The rules on unsolicited marketing by electronic mail turn on whether the recipient is an individual subscriber or a corporate one. We record what kind of body published a route and we withhold the ones we read as individual subscribers; we do not make, and do not hand you, a determination about a particular recipient. That judgement is yours, and it is one of the reasons the responsibility split below matters.
- Which country’s rules a contact sits under
- There is no jurisdiction axis in the classification and nothing in the product varies what it does by the country a publishing body is in. Public-sector status is read from United Kingdom and Ireland registry rules only, because those registries’ own eligibility rules are known and restrictive; guessing that another country’s equivalent works the same way would be the domain-sniffing this model exists to stop. The practical effect today is restrictive rather than permissive — a body outside those registries does not resolve to a public authority, so it falls into the masked rows above — but that is an accident of the resolution rules and not a control, and it is not a statement about which rules you are under when you write.
- Special category data
- No special category data is knowingly processed and none is sought. That has not been audited against the free-text fields read out of council documents, so the accurate statement is that we do not knowingly hold any rather than that we have proved we hold none.
There is no limit on how many customers may buy a package containing the same contact route. We do not cap it today and we do not hold it out as exclusive.
You become a controller of what you do next — and we stay one of what we do
When you buy a package you decide what to do with what is in it, so for that processing you are an independent controller in your own right. You are responsible for your own lawful basis for contacting anyone, for your own compliance with the Privacy and Electronic Communications (EC Directive) Regulations 2003 when you send marketing by electronic mail, for screening against the Telephone Preference Service and the Corporate Telephone Preference Service before you call, and for honouring an objection or an opt-out made to you. None of that is something we can do on your behalf, because we are not the sender and we do not know what you intend to send.
That does not move our own responsibilities onto you, and this page does not pretend it does. We remain responsible for how we collect this material, how we store it, how we classify it, what we decide to disclose and to whom, what we tell the people it is about, how we handle their requests and objections, how we suppress what should not be shown, and how we secure all of it. A term in a contract between us and you cannot make a disclosure lawful that was not lawful when we made it, and nothing you agree to here is treated by us as though it could.
The practical effect is that there are two sets of obligations here, not one set that moves across at the point of sale. Ours do not end when yours begin.
Five things we will not tell you, because we cannot know them
Lead sellers say these things. We are not going to, and it is worth being explicit about why, because the absence is easy to read as an oversight.
- That a route is cleared, approved or compliant. No regulator approves an address, and no certificate exists that could. Whether processing is lawful attaches to a use, not to a record — so the same address can be lawful for one message and unlawful for another.
- That anybody agreed to hear from you. Nobody did. A public body publishing a procurement inbox, or an authority publishing the officer handling an application, has not agreed to anything on anybody’s behalf. Consent in data protection law is given by a person, to a controller, for a stated purpose, and none of those three things happened here.
- That you may lawfully send to it. That depends on who the subscriber is, what you are sending, and what basis you have for sending it. We are not the sender and we do not know any of the three.
- That a number has been screened for you. A live marketing call needs screening against the Telephone Preference Service and the Corporate Telephone Preference Service. We do not hold a licence to screen, we do not screen, and no telephone route in any package carries a record that screening has happened. Every one of them records that the step exists and is yours.
- That a route is still live today. Each route carries the date the source published it and the date somebody last went back and found it still there — and the second of those is empty until that has actually happened. A published inbox can be withdrawn, redirected or abandoned by its owner the day after it was checked, and the record shows you when it was checked rather than claiming it is current.
If you are the person whose details these are
This page is written for buyers. If you have arrived because your own name or work contact details are in our records, the page written for you is if your details are in Tradello — it says what is held, who can see it, and how to object or have it corrected. An objection is asked about before any of the rules on this page are applied, and it beats all of them.
