Your data protection rights

These rights belong to two different groups of people:

• Customers. If you have an account with us we hold your name, your email address, your company name, an optional website, a hash of your password and your purchase history.
• People whose work details we captured from a published record. Case officers, procurement officers, estimators, agents. You never gave us anything and you have probably never heard of us. The page written for you is if your details are in Tradello; this page is the detail on the rights themselves.

The rights below are the same for both, and they apply whether or not you are a customer and whether or not you have paid us anything.

To see what we hold — Article 15

A copy of the personal data we hold about you, what we use it for, who we give it to, how long we keep it, and where we got it. We keep the source and the date on every record specifically so this is answerable.

To have it corrected — Article 16

If something is wrong, tell us and we will fix it. Correcting it at the body that published it is worth doing as well, because we re-read those publishers and so does everybody else.

To have it erased — Article 17

We will delete your name, your job title and your personal contact details. We keep the company-level record, which is about an organisation rather than about you. See the honest note below on what we cannot yet guarantee about this one.

To object — Article 21

You can object at any time, on grounds relating to your particular situation, to processing we do on the basis of our legitimate interests. We then have to stop unless we can demonstrate compelling legitimate grounds that override your interests. We expect objections to succeed against the details we hold and never show anybody, because once disclosure has been given up there is very little left on our side of that balance.

To restrict what we do with it — Article 18

In certain circumstances you can require us to hold a record without using it, for instance while a dispute about its accuracy is resolved.

To take it with you — Article 20

Where processing is based on your consent or on a contract with you and is carried out by automated means, you can ask for it in a machine-readable form. In practice this affects customer accounts, not captured records.

To withdraw consent

The only thing we ever ask consent for is marketing email, and it is separate, optional, never pre-ticked and never a condition of buying anything. You can withdraw it at any time and it changes nothing about what you have bought.

Without undue delay, and within one month of receiving your request. That is Article 12(3) UK GDPR. The month can be extended by up to two further months where a request is complex or there are several of them, and if we extend it we have to tell you within the first month and say why.

Responding is free. We are not going to charge you for a copy of your own data.

Use the request form. There is a route for asking, it needs no account, and it is at /privacy/request. A letter or an email is treated exactly as the form is and on the same deadlines. Where a deployment has no durable case store the form is not shown at all and the page gives the written route instead, rather than accepting a submission it would lose on the next restart.

Write to us about a data protection request at support@tradello.co.uk, or by post to the registered office.

It helps if you say what you want — to see it, to correct it, to have it deleted, or to object — and give us enough to find you: the name and work email address as they would have been published, and the organisation.

We may need to check you are who you say you are before we send a copy of somebody’s data to an address, and we will ask for the least that will do it. We have not yet written down a formal identification procedure, which is on the list below.

There is a route for asking, it needs no account, and it is at /privacy/request. A letter or an email is treated exactly as the form is and on the same deadlines. Where a deployment has no durable case store the form is not shown at all and the page gives the written route instead, rather than accepting a submission it would lose on the next restart.

When somebody tells us to stop, the record of that is kept outside the data we rebuild and is keyed to what the publisher publishes rather than to a row we hold. So the next collection run recognises them and refuses to bring them back — and the refusal happens where data is written rather than where it is shown, which covers screens nobody has built yet.

A complaint is a separate object from a request and carries its own clock: thirty days to acknowledge under section 164A(3) of the Data Protection Act 2018, counted from the day it arrives, held in the case store and alerted on before the deadline rather than when it passes. One message can be both a request and a complaint, and each half keeps its own deadline rather than inheriting the longer one.

A named professional contact stops being visible to customers 12 months after the last time the source was successfully read and the detail was still there. Reading it again restarts the period. It runs from that reading and not from the day we collected the record, because the day a page was read once is not evidence that the page is still right.

That period is performed on the read that would otherwise have disclosed the detail, every time, rather than by a sweep: a sweep that runs nightly leaves a day in which an expired detail is still sold, and a sweep that fails leaves a month. Because nothing yet goes back to a source and re-checks, a window can be closed by time but cannot yet be reopened by a fresh check — so the effect is stricter than the period as stated, never looser.

This section is here because the alternative is a page that describes a process we do not operate. The rights above are real and the machinery below them is real. These are the specific gaps that remain:

• There is no automated erasure sweep. Nothing has yet been deleted under that period. The detail goes out of a customer’s reach on time and is still held by us afterwards, which is less than the period promises, and we would rather say so than print a period we only half keep. Removing somebody on request is done today, and it is done by a person rather than by a job.
• Nothing goes back to a source and re-checks it. So a visibility window can be closed by time but cannot yet be reopened by a fresh check. That is stricter than the rule as stated, never looser.
• No individual inside the business has been publicly named as the owner of these requests, and no internal response timetable has been published. The case store records who took each one; the statutory one-month limit applies to us either way.
• How we confirm it is you is written down, and only that far. Nothing is removed or changed until we know a request came from the person concerned: a single-use link sent to an email address we hold for you, or, for a phone number or a name, a check we make ourselves — both are described on the request page. Beyond those two, we ask for the least that will identify you and decide case by case.

None of these reduces what you are entitled to. They are what we owe you an accurate description of, and they are being worked on.

You can complain to us and you can complain to the Information Commissioner’s Office. You do not have to come to us first, and complaining to us does not use up your right to go to them. Both routes are on complaining about how your data is handled.