Privacy Policy
1. Introduction
1.1 We are committed to safeguarding the privacy of our website visitors and service users.
1.2 This policy applies where we are acting as a data controller with respect to the personal data of our website visitors and service users; in other words, where we determine the purposes and means of the processing of that personal data.
1.3 We will ask you to consent to our use of cookies in accordance with the terms of this policy when you first visit our website.
1.4 Our website incorporates privacy controls which affect how we will process your personal data. By using the privacy controls, you can specify whether you would like to receive direct marketing communications and limit the publication of your information. You can access the privacy controls via our Privacy Centre.
1.5 In this policy, “we”, “us” and “our” refer to TBTECH Ltd. For more information about us, see Section 13.
2. Credit
2.1 This document was created using a template from SEQ Legal (https://seqlegal.com).
3. How we use your personal data
3.1 In this Section 3 we have set out:
- the general categories of personal data that we may process;
- in the case of personal data that we did not obtain directly from you, the source and specific categories of that data;
- the purposes for which we may process personal data; and
- the legal bases of the processing.
3.2 We may process data about your use of our website and services (“usage data“). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is Google Analytics. This usage data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website and services.
3.3 We may process your account data (“account data“). The account data may include your name, email address, phone number and/or physical address. The source of the account data is the information you entered when registering for the Two Blokes Trading website or one of Two Blokes Trading services. The account data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
3.4 We may process your profile data (“profile data“), which may include your name, address, telephone number, email address, profile pictures, gender, date of birth, relationship status, interests and hobbies, educational details and employment details. The profile data may be processed for enabling and monitoring your use of our website and services. The legal basis is our legitimate interests and/or performance of a contract.
3.5 We may process information that you post for publication on our website or through our services (“publication data“). The publication data may be processed for the purposes of enabling such publication and administering our website and services. The legal basis is our legitimate interests and/or performance of a contract.
3.6 We may process any enquiry you submit regarding goods and/or services (“enquiry data“), for the purposes of offering, marketing and selling relevant goods and/or services to you. The legal basis is consent.
3.7 We may process transaction data, including purchases of goods and services made with us (“transaction data“), which may include your contact details, your card details and the transaction details. This is processed to supply purchased goods and services and keep proper records. The legal basis is performance of a contract and our legitimate interests.
3.8 We may process subscription data (“notification data“) for email notifications and/or newsletters. The legal basis is performance of a contract and/or your request to enter into such a contract.
3.9 We may process any communication you send to us (“correspondence data“), including content and metadata. Processed for communication and record-keeping purposes. The legal basis is our legitimate interests.
3.10 We may process any personal data where necessary for the establishment, exercise or defence of legal claims. The legal basis is our legitimate interests.
3.11 We may process any personal data where necessary for obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis is our legitimate interests.
3.12 We may also process personal data to comply with a legal obligation or to protect vital interests of any person.
3.13 Please do not supply any other person’s personal data to us unless we prompt you to do so.
5. International transfers of your personal data
5.1 This section explains transfers of personal data outside the European Economic Area (EEA).
5.2 We and our group have offices in Ireland and the UK, both covered by EU adequacy decisions. Transfers are protected by standard data protection clauses.
5.3 Our website hosting is in Romania, also covered by an EU adequacy decision and protected by standard data protection clauses.
5.4 You acknowledge that data you submit for publication may be publicly available online worldwide, and we cannot prevent its misuse by others.
6. Retaining and deleting personal data
6.1 This section sets out our data retention policies and procedures.
6.2 Personal data is not kept longer than necessary for its purpose.
6.3 We will retain personal data for a minimum of 3 months and a maximum of 3 years following submission.
6.4 Where periods cannot be specified in advance, retention is based on customer wishes and engagement.
6.5 We may retain data longer where required to comply with legal obligations or protect vital interests.
7. Amendments
7.1 We may update this policy by publishing a new version on our website.
7.2 You should check this page occasionally for updates.
7.3 We may notify you of changes by email or private message on our platforms.
8. Your rights
8.1 You may request any personal information we hold, subject to:
- Payment of a fee of EUR 15.00.
- Provision of proof of identity (e.g. certified passport copy plus a utility bill).
8.2 We may withhold information to the extent permitted by law.
8.3 You may opt out of processing your data for marketing purposes at any time.
8.4 We will either get your express agreement for marketing or provide an opt-out opportunity.
13. Our details
13.1 This website is owned and operated by TBTECH Ltd.
13.2 We are registered in Ireland under registration number 705164, and our registered office is Riverwalk, Ashford, Co Wicklow, Ireland.
13.4 You can contact us:
- By post: use the address above.
- Using our website contact form.
- By telephone: see the number on our website.
- By email: support@trevesto.com.
14. Data protection officer
14.1 Our data protection officer’s contact details are: support@trevesto.com.