1. WHO WE ARE
1.1 Partios UK Ltd (“we”, “us”, “the Company”), a company incorporated in England and Wales (Company No. 14641531) with registered office at 3 Stadium Court, Plantation Road, Bromborough, Wirral, CH62 3QG, is the data controller for personal data processed as described in this Policy.
1.2 We have not appointed a statutory Data Protection Officer, as we are not required to. Data protection matters are handled by our compliance function, contactable at [email protected].
2. SCOPE
2.1 This Policy applies to personal data of: representatives and staff of business customers and prospective customers; suppliers and their representatives; website users; and individuals who contact us. As a business-to-business wholesaler, most of the personal data we handle relates to individuals in their professional or business capacity.
2.2 This Policy does not cover third-party websites we may link to, which have their own privacy policies.
3. PERSONAL DATA WE COLLECT
We may collect and process the following categories of personal data:
- Identity and contact data: name, job title, business name, business email address, business telephone number, and business address.
- Account and verification data: login credentials, and identity, ownership or compliance documentation provided for KYC, anti-money-laundering (AML), sanctions and due-diligence checks.
- Transaction data: orders, quotes, pro-forma invoices, delivery details and records of correspondence relating to purchases. We do not store full payment card numbers — card payments are processed by our payment provider (see Clause 6).
- Communications data: the content of emails, live-chat conversations, support tickets and other correspondence with us.
- Technical and usage data: IP address, browser type and version, device information, operating system, and information about how you use the Site, collected via cookies and similar technologies (see Clause 9).
- Marketing data: your preferences in receiving marketing from us and your communication preferences.
3.1 We do not intentionally collect special category data (such as health, biometric or racial/ethnic data). Please do not provide such data to us unless specifically requested for a lawful purpose.
4. HOW WE COLLECT PERSONAL DATA
We collect personal data: directly from you (for example, on registration, when placing an order, or when you contact us); automatically as you use the Site (via cookies and similar technologies); and from third parties, such as credit-reference, sanctions-screening and business-verification providers used for compliance checks.
5. HOW WE USE PERSONAL DATA AND OUR LAWFUL BASES
We process personal data for the purposes set out below. In each case we rely on one or more lawful bases under Article 6 UK GDPR:
Purpose | Data used | Lawful basis
Registering and managing wholesale accounts | Identity, contact, account, verification | Contract (steps to enter into / perform a contract); Legitimate interests (account administration)
Processing quotes, orders, payments and fulfilment | Identity, contact, transaction | Contract
Compliance checks: KYC, AML, sanctions, fraud, export control | Identity, verification, transaction | Legal obligation; Legitimate interests (fraud prevention, protecting the business)
Customer support and communications (including live chat) | Contact, communications | Contract; Legitimate interests (responding to enquiries)
Direct marketing to business contacts | Contact, marketing | Legitimate interests (B2B marketing), or Consent where required
Website analytics and improving the Site | Technical, usage | Consent (for non-essential cookies); legitimate interests (site security and core function)
Security, prevention and detection of misuse | Technical, usage, account | Legitimate interests (protecting our systems and business)
Establishing, exercising or defending legal claims | Any relevant data | Legitimate interests; Legal obligation
5.1 Where we rely on legitimate interests, we have carried out a balancing assessment to ensure our interests are not overridden by your rights. You may request further information about this assessment via [email protected].
5.2 Where we rely on consent (for example, certain marketing or non-essential cookies), you may withdraw consent at any time without affecting the lawfulness of prior processing.
6. PAYMENTS
6.1 Card payments made through the Site are processed by a third-party payment provider (for example, Stripe). Your card details are provided directly to that provider and are handled under its own privacy policy and PCI-DSS obligations. We do not store full card numbers on our own systems.
6.2 We receive transaction confirmation and limited data (such as the outcome of a payment and a masked card reference) to administer your order and for fraud prevention.
7. WHO WE SHARE PERSONAL DATA WITH
We share personal data with the following categories of recipient, in each case subject to appropriate safeguards:
- Our approved supply, distribution and logistics network, to source and fulfil orders (identities of which are confidential commercial information).
- Carriers and freight/customs partners, to arrange delivery and, where applicable, customs clearance.
- Payment providers, to process card payments and prevent fraud.
- Technology and communications providers who host our Site and systems and support customer messaging and live chat.
- Analytics and marketing providers, to measure and improve the Site and to send business communications.
- Compliance, credit-reference, sanctions-screening and verification providers.
- Professional advisers (lawyers, accountants, insurers) and, where necessary, regulators, law-enforcement or courts.
- A buyer or successor in the event of a sale, reorganisation or transfer of our business or assets.
7.1 We require processors acting on our behalf to process personal data only on our documented instructions and under a written contract meeting Article 28 UK GDPR.
8. INTERNATIONAL TRANSFERS
8.1 Some of our service providers (for example, certain hosting, communications, live-chat, analytics and logistics providers) are located outside the United Kingdom, including in the United States and the European Economic Area. This means your personal data may be transferred to, stored in, or accessed from, countries outside the UK.
8.2 Where we transfer personal data outside the UK, we ensure a similar degree of protection by relying on one or more of the following safeguards: (a) transfers to countries the UK Government has determined provide an adequate level of protection; (b) the UK International Data Transfer Agreement (IDTA) or the UK Addendum to the EU Standard Contractual Clauses; or (c) for transfers to the United States, provider certification under the UK Extension to the EU–US Data Privacy Framework where available.
8.3 You may request a copy of the safeguards we use for a particular transfer by contacting [email protected].
9. COOKIES AND SIMILAR TECHNOLOGIES
9.1 We use cookies and similar technologies on the Site. These include: strictly necessary cookies (required for the Site to function, including login and security); analytics cookies (to understand how the Site is used, for example via Google Analytics); functionality cookies (to remember your preferences); and, where relevant, cookies used by our live-chat and marketing tools.
9.2 Non-essential cookies are set only where you have given consent through our cookie banner. You can change or withdraw your preferences at any time via the cookie settings on the Site, and you can control cookies through your browser settings.
9.3 Strictly necessary cookies do not require consent and cannot be disabled through the banner without affecting Site functionality.
10. MARKETING AND YOUR CHOICES
10.1 We may send business-to-business marketing communications about our products and services to relevant business contacts, relying on legitimate interests or, where required by the Privacy and Electronic Communications Regulations (PECR), on consent.
10.2 You can opt out of marketing at any time by using the unsubscribe link in any marketing email or by contacting [email protected]. Opting out of marketing does not stop service-related communications necessary to administer your account or orders.
11. HOW LONG WE KEEP PERSONAL DATA
11.1 We keep personal data only for as long as necessary for the purposes for which it was collected, including to satisfy legal, accounting, tax or reporting requirements.
As a general guide:
- Account and transaction records: for the duration of the relationship and then for at least 6 years, to meet contractual, tax and accounting obligations.
- Compliance and due-diligence records (KYC/AML/sanctions): typically 5 years after the end of the business relationship, or longer where required by law.
- Marketing data: until you opt out or withdraw consent, and for a short period thereafter to record your preference.
- Website analytics data: in line with the retention settings of the relevant analytics tools.
11.2 When personal data is no longer required, we securely delete or anonymise it.
12. SECURITY
We implement appropriate technical and organisational measures to protect personal data against unauthorised or unlawful processing, accidental loss, destruction or damage, including access controls, encryption in transit, and limiting access to those who need it. We have procedures to deal with any suspected personal data breach and will notify you and any applicable regulator where legally required.
13. YOUR RIGHTS
Subject to the conditions and exemptions in data protection law, you have the right to:
- request access to the personal data we hold about you;
- request correction of inaccurate or incomplete personal data;
- request erasure of your personal data in certain circumstances;
- object to processing based on legitimate interests, and to object to direct marketing at any time;
- request restriction of processing in certain circumstances;
- request the transfer of your personal data (data portability) where processing is based on consent or contract and carried out by automated means; and
- withdraw consent at any time where we rely on consent.
13.1 To exercise any of these rights, contact [email protected]. We will respond within one month, which may be extended by two further months for complex requests. We may need to verify your identity before acting.
13.2 There is normally no charge, although we may charge a reasonable fee or refuse to act on requests that are manifestly unfounded or excessive.
14. COMPLAINTS
If you have concerns about how we handle your personal data, please contact us first at [email protected] so we can try to resolve them. You also have the right to lodge a complaint with the Information Commissioner’s Office (ICO), the UK supervisory authority, at ico.org.uk or on 0303 123 1113.
15. CHANGES TO THIS POLICY
We may update this Policy from time to time. The current version is always available on the Site, and the Version and Effective Date at the top show when it was last updated. Material changes will be notified by appropriate means.
16. CONTACT US
Partios UK Ltd
3 Stadium Court, Plantation Road, Bromborough, Wirral, United Kingdom CH62 3QG
Data protection / privacy: [email protected]
General: [email protected]