This privacy policy sets out how IRecycle Tech Ltd as IRecycle Tech.com uses and protects any information that you give IRecycle Tech.com when you use this website.

IRecycle Tech.com is committed to ensuring that your privacy is protected. Should we ask you to provide certain information by which you can be identified when using this website, then you can be assured that it will only be used in accordance with this privacy statement.

IRecycle Tech.com may change this policy from time to time by updating this page. You should check this page from time to time to ensure that you are happy with any changes.

This version was last updated in March 2023.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Who we are

Suggested text: Our website address is: http://irecycletech.com.

Data Controller

IRecycle Tech Ltd is the controller and responsible for your personal data (collectively referred to as ” IRecycle Tech.com “, “we”, “us” or “our” in this privacy policy).

We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.

Contact details

If you have any questions about this privacy policy or our privacy practices, please contact our data privacy manager in the following ways:

-Email: Support@iRecycleTech.com

-Post: Customer Services Department, IRecycle Tech Ltd, Unit B 54 Elm Row, EH7 4AQ, Edinburgh.

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

Your rights

At any point whilst we are in possession of or processing your personal data, you, the data subject, have the following rights:

• Right of access – you have the right to request a copy of the information that we hold about you.
• Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
• Right to restriction of processing – where certain conditions apply to have a right to restrict the processing.
• Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records. Bear in mind, if you ask us to erase your information from our records, we may purchase data in the future that contains your information. We can however mark it as “do not contact” therefore stopping any contact we may make to you.
• Right to object – you have the right to object to certain types of processing such as direct marketing.
• Right of portability – you have the right to have the data we hold about you transferred to another organisation.
• Right to object to automated processing, including profiling – you also have the right to be subject to the legal effects of automated processing or profiling.
• Right to judicial review: in the event that IRecycle Tech refuses your request under rights of access, we will provide you with a reason as to why. You have the right to contact the ICO which can be done here.

Should you wish to exercise any of these rights, please contact us via email to support@iRecycle Tech.com

All of the above requests will be forwarded on should there be a third party involved in the processing of your personal data.

How the law protects you

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Data protection law says that we are allowed to use personal information only if we have a proper reason to do so. This includes sharing it outside of IRecycle Tech. The law says we must have one or more of these reasons:

• To fulfil a contract we have with you, or
• When it is our legal duty, or
• When it is in our legitimate interest

A legitimate interest is when we have a business or commercial reason to use your information. But even then, it must not unfairly go against what is right and best for you. If we rely on our legitimate interest, we will tell you what that is.

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

Below is a list of all the ways that we may use your personal information, and which reasons we rely on to do so. This is also where we tell you what our legitimate interests are:

What we use your personal information for	Our Reasons	Our legitimate interests
Marketing Customer retention Fulfilling payment Fulfilling order Website user analysis Ensuring company property is safe and secure	Our legal duty Our legitimate business interest Fulfilling orders	Quality control and monitoring Security and safety of visitors, staff and assets Protect our commercial interest against bad debt

Groups of personal information

We may use many different kinds of personal information, and then group them together like this:

Type of personal information	Description
Banking	Your bank account details for payment
CCTV	If you enter any of our premises your images may be captured on CCTV
Communications	What we learn about you from letters, emails and verbal conversations between us
Contact	Your address, email and phone number to fulfil orders
Contractual	Details about the products or services we provide you
Open Data and Public Records	Details about you that are in public records, such as information held in Companies House, and information about you that is openly available on the internet
Technical	Details on the devices and technology you use
Transactional	Details about payments to and from your accounts with us
Usage Data	Other data about how your use our services

Where we collect personal information from

We may collect personal information about you from these sources:

Where we collect personal information from

• When you talk to us on the phone
• When you use our website
• In emails and letters
• When you buy products and/or services – this includes banking details for billing and payments

Data from third parties:

• Companies and people who know you that pass us your details
• Affiliate 3rd party sites that are required to pass on your details in order to complete any transaction

Who we share your personal information with

IRecycle Tech will not pass on your personal data to third parties unless: it is a requirement of the service or product you have with us, where this will be detailed within the contract. Or if it is a prerequisite to the service or product you intend to have with us, you will be notified beforehand.

Who we share your personal information with

• Network service providers who provide the service agreed in your contract
• Other service providers if purchased through us. E.g. insurance companies, or other product providers
• Companies we have a joint venture or agreement to co-operate with
• Companies we have contracts with, to provide you with the services agreed in your contract. E.g. device repair centres
• If you use direct debits, we will share your data with the Direct Debit scheme
• Debt collection agencies or other debt recovery organisations
• Law enforcement agencies, regulatory organisations, courts or other public authorities if we have to, or are authorised to do so by law

In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets as part of the process of evaluation and to ensure continuity of service.

Some of the data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). It will also be processed by staff operating outside the EEA who are owned by and solely work for us or for one of our suppliers or business partners. This includes staff engaged in, among other things, the fulfilment of your order, the processing of your payment details and the provision of support services. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy and the UK General Data Protection Regulation (GDPR), and we have the necessary legal contract in place to fulfil these services.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data
• Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK

Data Retention

The length of time we retain your information is dependent on what we are holding and why we are holding it. We will not keep your information for longer that is necessary for our business or legal requirements.

IRecycle Tech may process personal data for up to 7 years if you are a prospective customer and for the length of your contract if you become an active customer. This is in keeping with our legitimate interests and contractual obligations.

We may also store personal data for up to 7 years for any of the following reasons:

• Respond to any questions or complaints
• To show that we treated you fairly
• To maintain records to comply with legal and regulatory rules that apply to us
• In keeping with our legitimate interests and contractual obligations

We may store your personal data in paper or electronic formats, both of which are stored securely and based on the guidelines as specified in ISO/IEC standards 17799, 27001 and 27002. We also have processes in place to securely dispose of data we no longer require.

Data Security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Marketing

We may use your personal information to tell you about relevant products and offers. This is what we mean when we talk about ‘marketing’

The personal information we have for you is made up of what you tell us, and data we collect when you use our services, or from third parties we work with.

We study this to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you.

We can only use your personal information to send you marketing messages if we have either your consent or a ‘legitimate interest’. That is when we have a business or commercial reason to use your information. It must not unfairly go against what is right and best for you.

You can ask us to stop sending you marketing messages by contacting us. Alternatively, you can choose how we contact you in the “My Account” section of your profile. Whatever you choose, you’ll still receive other important information relating to your existing products and services.

How to get a copy of your personal information (Subject Access Request)

In compliance with your rights detailed above, you can request copies of all the personal information we hold on you. This is known as a “Subject Access Request”, “SAR” for short.

There are several ways of applying:

• Email: Support@iRecycleTech.com
• Post: IRecycle Tech Ltd, Unit B, 54 Elm Row, EH7 4AQ
  

To make sure we are only sending the information to someone authorised to have it, we may at our discretion require you to provide two forms of ID from the below list:

• Passport
• Driving licence
• Birth certificate
• Utility bill (from last 3 months)
• Current vehicle registration document
• Bank statement (from last 3 months)
• Rent book (from last 3 months)

To submit a Subject Access Request please contact us in writing to support@iRecycleTech.com

If things go wrong and you wish to make a complaint

If you are not happy with the service you have received you can raise a complaint through any of the following channels:

• Email: info@iRecycle Tech.com
• Post: IRecycle Tech Ltd, Unit B, 54 Elm Row, EH7 4AQ

In the event that you wish to make a complaint about how your personal data is being processed by IRecycle Tech (or third parties as described above), or how your complaint has been handled, you have the right to lodge a complaint directly with the supervisory authority who can be contacted as follows:-

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

casework@ico.org.uk
03031 231113

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