Legal

Privacy Policy

Last updated: 28 August 2026

Review required before publication. This policy was drafted as a starting point and has not been reviewed by a solicitor. Every highlighted placeholder must be replaced, and the whole document should be checked against your actual data handling before you rely on it.

1. Who we are

iTradeCircle is an independent business-to-business trade network for UK mobile-device retailers, wholesalers, distributors, refurbishers and export traders. For the purposes of UK data protection law, the data controller is [REGISTERED COMPANY NAME], company number [COMPANY NUMBER], registered at [REGISTERED ADDRESS].

You can contact us about anything in this policy at [CONTACT EMAIL] or on WhatsApp at +44 7958 044717.

2. What information we collect

We only collect information you choose to send us. We do not require an account and we do not ask for payment details.

Business identity: trading name, company registration number, and the UK city or region you trade from.
Contact details: your name, the WhatsApp number you message us from, and any email address or phone number you give us.
Trade interest: whether you are buying or supplying, approximate volumes, model categories, and the timing you are working to.
Message content: the WhatsApp conversation you have with us.
Technical data: when you visit this site, your browser makes requests to third-party services that host our fonts and stylesheets. Those services may log your IP address. See section 7.

3. How we collect it

Almost everything reaches us through WhatsApp, because that is how this network operates. This website does not contain a registration form and does not itself collect or store personal data.

WhatsApp is provided by Meta Platforms Ireland Limited. Your messages to us are also processed by Meta under their own terms and privacy policy, which we do not control. If you would prefer not to use WhatsApp, contact us by email instead.

4. Why we use it, and our lawful basis

To operate the network (matching buying and supply interest, and making introductions) — our legitimate interests in running a B2B trade service you have asked to take part in.
To verify your business against the public company register — our legitimate interests in reducing fraud and giving members confidence in who they are dealing with.
To contact you about the network — your consent, given when you message us to register interest. You can withdraw it at any time.
To meet legal obligations — where we are required to retain or disclose information by law.

5. Who we share it with

We do not sell your data. We share it in only two circumstances:

With a counterparty, only after you agree. Your registered interest is described to others in anonymised terms — region, position, approximate volume and timing. Your trading name and contact details are only passed on when you accept an introduction.
With service providers who help us operate, such as the messaging platform we use and our hosting provider. They act on our instructions.

We may also disclose information where required by law, or to establish or defend legal claims.

6. How long we keep it

We keep registration and trade-interest information for as long as you remain part of the network, and for [RETENTION PERIOD, e.g. 24 months] after your last contact with us, after which it is deleted. You can ask us to delete it sooner at any time.

7. Cookies and tracking

This website sets no cookies of its own and runs no analytics. It does load fonts and stylesheets from Google Fonts and jsDelivr, which means your browser contacts those services and they may log your IP address as part of delivering those files.

If advertising or analytics tracking is added to this site in future, this section must be updated and a cookie consent banner will be required.

8. Where your data is held

Our website is hosted in [HOSTING LOCATION]. Where a provider transfers personal data outside the UK, we rely on the safeguards that provider has in place, such as UK adequacy regulations or standard contractual clauses.

9. Your rights

Under UK data protection law you have the right to:

ask for a copy of the personal data we hold about you;
have inaccurate data corrected;
ask us to delete your data;
ask us to restrict how we use it;
object to processing based on our legitimate interests;
ask us to transfer your data to another provider;
withdraw consent at any time, without affecting anything done before you withdrew it.

To exercise any of these, message us on WhatsApp or email [CONTACT EMAIL]. We will respond within one month.

10. Complaints

If you are unhappy with how we have handled your data, please tell us first so we can put it right. You also have the right to complain to the Information Commissioner's Office at ico.org.uk, or on 0303 123 1113.

11. Security

We take reasonable technical and organisational measures to protect the information you share with us, including encrypted connections to this website and restricted access to our records. No method of transmission is completely secure, and we cannot guarantee absolute security.

12. Changes to this policy

We may update this policy from time to time. The date at the top shows when it last changed. If we make a significant change, we will tell registered members directly.