1. Who we are

Trading FMCG is committed to ensuring that your privacy is protected. This privacy policy explains how we use the personal data we collect about you through our website www.tradingfmcg.com (the “Website”) and how you can instruct us, if you prefer, to limit the use of that data.

If you have any questions or need any help in relation to our privacy policy, please contact contact@tradingfmcg.com

2. The information we collect and how we use it

INFORMATION FROM YOUR ONLINE INTERACTIONS

We collect the following information from your interactions with the Website:

How you access the Website and the devices that you use to access our Website. This includes collecting unique online identifiers such as IP address and your login data, browser type and version, time zone settings and location data, browser plug-in types and versions, operating system and platform;

Please refer to our Cookie Policy for further details.

INFORMATION THAT YOU SHARE WITH US

When you submit personal data to us, inter alia, through data entry fields on our website, we collect the following personal data from you:

• your first name;
• your last name;
• your email address;
• your phone number;
• your address;
• your date of birth;
• your company details;
• your gender;
• any email communications, including attachments, which you send to us;
• your profile data, including your username and password for registering an account, purchases or orders made by you, your interests and preferences such as your marketing preferences or subscription for our newsletters;

3. How we store and use your personal data

We store and use your personal data for the following reasons:

• it is necessary in order for us to fulfil a contract that we have with you;
• it is required in our legitimate interests;
• it is required in order for us to comply with our legal obligations; or
• it is permitted because you have provided your consent to us.

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you. In this case, you may not be able to use our services.

NECESSARY FOR US TO FULFIL OUR CONTRACT WITH YOU

We collect, store and use your personal data including your name, (e-mail) address, login details and payment information and information about how you use and access the Website because it is necessary in order to provide our services through our website as requested by you and under our Terms and Conditions of use. This includes:

• making the Website and our services available to you;
• providing the Website and any services that you request;
• administering the Website and our services;
• service and account administration requirements such as where we need to contact you for reasons related to the Website and our services, including but not limited to using third party customer service providers to carry out such requirements (for example, where we need to send you a password reminder, to notify you about Website updates or amendments to our Terms and Conditions of use, Cookie Policy or this privacy policy);
• where you are purchasing products through the Website, process your payment (including but not limited to using third party service providers to process such payment); and

OUR LEGITIMATE INTEREST

Sometimes, our use of your personal data is for purposes which are ancillary to the provision of the Website and our services. In those circumstances, we believe we have a legitimate interest in handling your personal data, and believe that the benefits of this storage and use of your personal data outweighs (potential) impact on you and not unduly prejudice your rights or freedoms. The relevant circumstances are:

• detecting and preventing fraud;
• keeping the Website and our services, products and IT systems secure;
• ensuring that our own processes, procedures and systems are as efficient as possible;
• analysing and enhancing the information that we collect;
• determining the effectiveness of our promotional campaigns and advertising;
• using IP addresses and device identifiers to identify the location of users and block any unauthorised users;
• dealing with your enquiries and requests (for example if you were to call customer services to ask for help and assistance then we would need to process your contact details);
• suggesting similar products to you that you may be interested in and to understand which products appeal to our customers; and

If we rely on our (or another person’s) legitimate interests for using your personal data, we will undertake a balancing test to ensure that our (or the other person’s) legitimate interests are not outweighed by your interests or fundamental rights and freedoms which require protection of the personal data.

FOR LEGAL REASONS

We will use your personal data in order to comply with our legal obligations, including if we are asked by regulatory bodies or law enforcement agencies to share your personal data with them.

WHEN YOU HAVE PROVIDED CONSENT TO US

Where you have given us consent, we may contact you by e-mail and/or text message with products and services which we think may be of interest to you.

If we rely on your consent for us to use your personal data in a particular way, but you later change your mind, you may withdraw your consent at any time through your online account or by contacting us at contact@tradingfmcg.com, and we will stop doing so.

4. How we share your personal data who we share it with

We may disclose personal data under the following circumstances:

• Third-party service providers: When we share information with third-party service companies to facilitate or to provide certain services on our behalf. This may include:
  
  • IT infrastructure companies that facilitate our provision of the Website to you such as providers of our platform;
  • Third parties who provide first level customer support on our behalf;
  • IT support service providers;
  • Payment service providers who will process your payments on our behalf; and

These companies are authorised to use your personal data only as necessary to provide these services to us. We require these service providers to respect the security of your data and to treat it in accordance with the law. To the extent necessary, we will enter into a data processing agreement with these service providers.

• Vendors who offer their products on the Website: We may provide your personal data to the vendors from whom you purchase products on the Website. These vendors need your personal data in order to process and deliver your product.
• Group companies: We may provide your personal data to our subsidiaries or affiliated companies for the purpose of processing personal data on our behalf to provide the Website and our services to you. These parties are required to process such information based on our instructions and in accordance with this privacy policy. They do not have any independent right to share this personal data.
• Compliance with laws and legal proceedings: When we respond to court orders, legal process or to establish or exercise our legal rights or defend against legal claims, or as otherwise required by law.
• Merger or acquisition: When we need to transfer personal data about you if we are acquired by or merged with another company. If we are involved in a merger, acquisition, or sale of all or a portion of its our assets, you will be notified afterwards via e-mail and/or a prominent notice on our Website of any change in ownership or uses of your personal data, as well as any choices you may have regarding your personal data.

5. International transfers

If you are located in the EU then we may transfer personal data that we collect from you to third party data processors located in countries that are outside of the European Economic Area (“EEA”) or to members of our group of companies in connection with the above purposes. Please be aware that countries which are outside the EEA may not offer the same level of data protection as the EEA, although our collection, storage and use of your personal data will continue to be governed by this privacy policy.

When transferring personal data outside the EEA, we will:

• include the standard contractual data protection clauses approved by the European Commission for transferring personal data outside the EEA into our contracts with those third parties (these are the clauses approved under Article 46.2 of the General Data Protection Regulation (“GDPR”);
• ensure that the country in which your personal data will be handled has been deemed “adequate” by the European Commission under Article 45 of the GDPR; or
• (where appropriate when we are transferring your personal data to a recipient in the US) ensure that the recipient is part of the Privacy Shield which requires them to provide similar protection to any personal data shared between Europe and the US.

You can find out further information about the rules on data transfers outside the EEA, including the mechanisms that we rely upon, on the European Commission website here. You may request a copy of the mechanisms that we rely upon via contact@tradingfmcg.com.

6. Cookies and similar technologies

Technologies such as cookies, beacons, tags and scripts are used by us and our partners, affiliates, or analytics or service providers. These technologies are used in analysing trends, administering the services, tracking users’ movements around the Website and to gather demographic information about our user base as a whole. We receive reports based on the use of these technologies by these companies on an individual as well as aggregated basis.

We use cookies, for example, to remember users’ settings (e.g. language preference) and for authentication. Users can control the use of cookies at the individual browser level. If you reject cookies, you may still use our services, but your ability to use some features or areas of our services may be limited.

Please read more about how we use cookies and what information is collected using cookies in our Cookie Policy.

7. Security

Whilst we take appropriate technical and organisational measures to safeguard the personal data that you provide to us, no transmission over the Internet can ever be guaranteed secure. Consequently, please note that we cannot guarantee the security of any personal data that you transfer over the Internet to us.

We are committed to protecting your personal data using appropriate technical and operational measures such as access controls that restrict and manage the ways in which your personal data is stored and handled.

8. Data Retention

We will retain information (including personal data ) for as long as we need to use it for the reasons set out in the privacy policy and will delete it 10 years after your last activity on the Website except where we need to keep any personal data to comply with our legal obligations, resolve disputes, or enforce our agreements.

We may delete your personal data (including any account that you set up to use on the Website) if you do not use the Website and our services in 10 years.

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.

9. Your rights

You have certain rights in relation to your personal data. If you would like further information in relation to these or would like to exercise any of them, please contact contact@tradingfmcg.com at any time. You have the right to request that we:

• provide access to any personal data we hold about you;
• update any of your personal data which is out of date or incorrect;
• delete any personal data which we are holding about you;
• restrict the way that we process your personal data;
• prevent the processing of your personal data for direct-marketing purposes;
• provide your personal data to a third party provider of services;
• provide you with a copy of any personal data which we hold about you; or
• consider any valid objections which you have to our use of your personal data.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive.

We will consider all such requests and provide our response within a reasonable period (and in any event within any time period required by applicable law). Please note, however, that certain personal data may be exempt from such requests in certain circumstances.

If an exception applies, we will tell you this when responding to your request. We may request you provide us with information necessary to confirm your identity before responding to any request you make.

10. Marketing

We may collect and use your personal data for undertaking marketing by e-mail. We will send you certain marketing communications (including electronic marketing communications) if it is in our legitimate interests to do so for marketing and business development purposes.

However, we will always obtain your consent to direct marketing communications where we are required to do so by law and if we intend to disclose your personal data to any third party for such marketing.

If you wish to stop receiving marketing communications, you can click unsubscribe in any marketing e-mail from us, change your preferences through your online account or by contacting us at contact@tradingfmcg.com.

11. Third party sites

The Website may contain links and pages to other websites operated by third parties. Please note that this privacy policy applies only to the personal data that we collect through the Website and we cannot be responsible for personal data that third parties, including vendors may collect, store and use through their website. You should always read the privacy policy of each website you visit carefully.

12. Changes to this privacy policy

This privacy policy was last updated on January 1st 2022.

Please check back regularly to keep informed of updates to this privacy policy. Where we make significant changes to this privacy policy, and we have your e-mail address, we will send you notification of the changes.