Privacy Policy
Version 1.0 | Effective date: 19 October 2026
This Privacy Policy explains how Raw Trade Cosmetics Ltd, a company registered in England and Wales under company number 08631262, whose registered office is at Wiston House, 1 Wiston Avenue, Worthing, West Sussex BN14 7QL ("Raw Trade", "we", "us" or "our"), collects and uses personal information.
For the purposes of UK data protection law, Raw Trade is generally the controller of the personal information described in this policy.
Privacy contact: hello@rawtrade.co.uk
1. Who This Policy Applies To
1.1 This policy applies to personal information relating to website visitors, prospective and actual sellers and buyers, people who submit enquiries, representatives and employees of businesses using Raw Trade, suppliers, professional advisers and other business contacts.
1.2 Raw Trade is a business-to-business service. We do not intentionally offer our commercial services to consumers.
2. Personal Information We Collect
2.1 Depending on how you interact with us, we may collect:
a. identity information, such as your name and job title;
b. business contact information, such as your work email address, telephone number, company and business address;
c. account, enquiry and correspondence information, including messages and records of communications with us;
d. seller and buyer information supplied when submitting listings, enquiries or using our introduction service;
e. transaction-related information where necessary to administer our services, although Raw Trade does not ordinarily act as buyer or seller of listed materials;
f. technical information about use of our website, such as IP address, browser or device information, logs and security information;
g. cookie or similar technology information where used; and
h. records showing acceptance of applicable service terms, including the version accepted and date and time of acceptance.
3. Where We Obtain Information
3.1 We collect personal information directly from you when you use our website, submit a form, correspond with us, submit or enquire about a listing, accept terms or otherwise deal with Raw Trade.
3.2 We may also receive business contact information from the organisation you work for, another participant in an introduction, professional or industry contacts, publicly available business sources, or other legitimate business sources.
3.3 Where data protection law requires us to provide privacy information after obtaining personal data from another source, we will do so within the applicable period unless an exemption applies.
4. How and Why We Use Personal Information
4.1 We may use personal information to:
a. respond to enquiries and communicate with you;
b. provide listing, enquiry and introduction services;
c. administer our contractual relationship with sellers, buyers and other customers;
d. facilitate agreed introductions between businesses;
e. maintain records of listings, enquiries, introductions and acceptance of terms;
f. invoice for and administer paid services;
g. operate, maintain, secure and improve our website and services;
h. prevent fraud, misuse and security incidents;
i. establish, exercise or defend legal claims and comply with legal obligations; and
j. send business marketing communications where permitted by law.
5. Lawful Bases
5.1 We use personal information only where we have an appropriate lawful basis.
5.2 Depending on the circumstances, these bases may include:
a. contract - where processing is necessary to enter into or perform a contract with you as an individual;
b. legitimate interests - including operating and developing Raw Trade, communicating with business contacts, facilitating B2B introductions, maintaining appropriate business records, protecting our systems and establishing or defending legal rights;
c. legal obligation - where processing is necessary for us to comply with applicable law; and
d. consent - where we specifically ask for consent and consent is the appropriate lawful basis.
5.3 Where we rely on legitimate interests, we consider whether those interests are outweighed by the rights and interests of the individuals concerned.
6. Sharing Personal Information
6.1 We may share personal information where reasonably necessary with:
a. prospective or actual buyers and sellers where an introduction has been agreed or disclosure is otherwise necessary to provide the service;
b. providers that host, maintain or support our website, communications, data storage, payment, accounting or other business systems;
c. professional advisers such as lawyers, accountants and insurers;
d. regulators, courts, law enforcement agencies or other authorities where required or permitted by law; and
e. a purchaser, investor or adviser in connection with a proposed sale, investment, restructuring or transfer of all or part of our business.
6.2 Service providers processing personal information on our behalf are required to handle it appropriately and only for authorised purposes.
6.3 Our website uses hosting and database service providers to operate the service and store its records, Resend to send service emails, and Google Analytics to measure website use where you have consented. We also use Google Fonts to display website typefaces; your browser sends Google technical information, such as your IP address and browser details, when requesting those fonts.
7. International Transfers
7.1 Some service providers may process personal information outside the United Kingdom.
7.2 Where personal information is transferred internationally, we will use an appropriate lawful transfer mechanism where required, such as UK adequacy regulations or approved contractual safeguards.
7.3 Resend processes email service data in the United States. Google may process analytics and font-request information in the United States and other countries where it operates. Applicable provider data-processing terms include transfer safeguards, such as standard contractual clauses with the UK Addendum, or reliance on the UK Extension to the EU-US Data Privacy Framework where applicable. You can request further information about the safeguards relevant to your information by emailing hello@rawtrade.co.uk.
8. How Long We Keep Information
8.1 We keep personal information only for as long as reasonably necessary for the purposes for which it was collected, including providing our services, maintaining appropriate business and contractual records, resolving disputes and meeting legal, tax and accounting requirements.
8.2 Retention periods vary according to the nature of the information and our relationship with you.
8.3 Our usual retention periods and criteria are:
a. enquiries that do not lead to a service: normally up to two years after our last substantive contact;
b. account, listing, introduction, service and terms-acceptance records, and related business correspondence: for the duration of the relationship and normally up to six years after it ends, where needed for business records or legal claims;
c. invoices, payment and accounting records: six years from the end of the company financial year they relate to, or longer where tax or accounting rules require;
d. technical and security records: for as long as reasonably needed to operate and protect the website or investigate a particular incident; and
e. minimal records of marketing objections: for as long as needed to respect your preference. Cookie and consent-storage durations are set out in the website cookie details below.
8.4 We review retained information periodically and delete or anonymise it when it is no longer needed. Relevant records may be kept for longer where reasonably necessary to meet a legal obligation, resolve an ongoing dispute or establish, exercise or defend legal claims.
9. Security
9.1 We use appropriate organisational and technical measures intended to protect personal information against unauthorised access, loss, misuse, alteration or disclosure.
9.2 No internet or electronic storage system can be guaranteed to be completely secure.
10. Cookies and Similar Technologies
10.1 Our website may use cookies and similar technologies for functions such as security, session management, preferences, analytics or other website features.
10.2 Strictly necessary technologies may be used where required for the website or a service requested by the user.
10.3 Where applicable law requires consent for non-essential cookies or similar technologies, we will request that consent before using them.
10.4 The website cookie details below explain the cookies and browser storage used by the application, their purposes and durations. You can accept or reject optional analytics through the cookie notice and change your choice at any time through Cookie settings in the footer. Rejecting analytics does not prevent you from using the website.
11. Marketing
11.1 We may send relevant business-to-business communications where permitted by applicable law.
11.2 Where consent is required for a particular form of electronic marketing, we will obtain it before sending that marketing.
11.3 You can ask us to stop sending marketing communications at any time by using any unsubscribe facility provided or contacting us.
11.4 A request to stop marketing does not prevent us from sending service or administrative communications where appropriate.
12. Your Data Protection Rights
12.1 Depending on the circumstances and the lawful basis used, you may have rights to:
a. request access to your personal information;
b. have inaccurate personal information corrected;
c. request deletion of personal information;
d. request restriction of processing;
e. object to certain processing;
f. receive certain information in a portable format; and
g. withdraw consent where processing is based on consent.
Your right to object: where we rely on legitimate interests, you may have the right to object to our use of your personal information. You also have the right to object to the use of your personal information for direct marketing.
12.2 These rights are subject to conditions and exemptions under data protection law. To exercise a right, contact us at hello@rawtrade.co.uk.
12.3 We may need to verify your identity before acting on a request.
13. Automated Decision-Making
13.1 Raw Trade does not currently envisage using personal information to make solely automated decisions that produce legal or similarly significant effects on individuals.
13.2 If this changes, we will provide the information required by applicable data protection law.
14. Complaints
14.1 If you have concerns about our use of your personal information, please contact us first at hello@rawtrade.co.uk so that we can investigate.
14.2 You also have the right to complain to the UK Information Commissioner's Office (ICO). Current contact and complaint information is available from the ICO at ico.org.uk.
15. Changes to This Policy
15.1 We may update this Privacy Policy to reflect changes to our services, practices or legal requirements.
15.2 The current version will be published on our website with its effective date. Where appropriate, we will bring material changes to the attention of affected individuals before beginning materially different processing.
16. Contact Us
For questions about this Privacy Policy or our use of personal information, contact:
Raw Trade Cosmetics Ltd Wiston House, 1 Wiston Avenue, Worthing, West Sussex BN14 7QL hello@rawtrade.co.uk