Privacy Policy
Last updated: January 2025
1. Important information and who we are
This privacy policy gives you information about how Propell collects and uses your personal data through your use of this website, including any data you may provide when you purchase a product or service.
This website is not intended for children and we do not knowingly collect data relating to children.
Controller
Propell Trading Ltd is the controller and responsible for your personal data (collectively referred to as Propell, “we”, “us” or “our” in this privacy policy).
If you have any questions about this privacy policy, including any requests to exercise your legal rights (paragraph 9), please contact us using the information set out in the contact details section (paragraph 10).
2. The types of personal data we collect about you
Personal data means any information about an individual from which that person can be identified.
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
Identity Data includes first name, last name, any previous names, username or similar identifier, marital status, title, date of birth and gender.
Contact Data includes billing address, delivery address, email address and telephone numbers.
Financial Data includes bank account and payment card details.
Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, device ID and other technology on the devices you use to access this website.
Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
Usage Data includes information about how you interact with and use our website, products and services.
Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We also collect, use and share aggregated data such as statistical or demographic data which is not personal data as it does not directly (or indirectly) reveal your identity. For example, we may aggregate individuals' Usage Data to calculate the percentage of users accessing a specific website feature in order to analyse general trends in how users are interacting with our website to help improve the website and our service offering.
3. How is your personal data collected?
We use different methods to collect data from and about you including through:
Your interactions with us
You may give us your personal data by filling in online forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- apply for our products or services;
- create an account on our website;
- subscribe to our service or publications;
- request marketing to be sent to you;
- complete a survey; or
- give us feedback or contact us.
Automated technologies or interactions
As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our Cookie Policy for further details.
Third parties or publicly available sources
We will receive personal data about you from various third parties and public sources. Identity and Contact Data is collected from publicly available sources such as Companies House and the Electoral Register based inside the UK.
4. How we use your personal data
Legal basis
The law requires us to have a legal basis for collecting and using your personal data. We rely on one or more of the following legal bases:
Performance of a contract: Where we need to perform the contract we are about to enter into or have entered into with you.
Legitimate interests: We may use your personal data where it is necessary to conduct our business and pursue our legitimate interests, for example to prevent fraud and enable us to give you the best and most secure customer experience. We make sure we consider and balance any potential impact on you and your rights before we process your personal data for our legitimate interests.
Legal obligation: We may use your personal data where it is necessary for compliance with a legal obligation that we are subject to.
Consent: We rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose, for example if you subscribe to an email newsletter.
Purposes for which we will use your personal data
| Purpose | Type of data | Legal basis |
|---|---|---|
| To register you as a new customer | Identity, Contact | Performance of a contract with you |
| To process and deliver your order, manage payments, fees and charges, and collect and recover money owed to us | Identity, Contact, Financial, Transaction, Marketing and Communications | Performance of a contract; Necessary for our legitimate interests (to recover debts due to us) |
| To manage our relationship with you, including notifying you about changes to our terms or privacy policy | Identity, Contact, Profile, Marketing and Communications | Performance of a contract; Legal obligation; Legitimate interests |
| To administer and protect our business and this website | Identity, Contact, Technical | Legitimate interests (running our business, IT services, network security, fraud prevention); Legal obligation |
| To use data analytics to improve our website, products/services, customer relationships and experiences | Technical, Usage | Legitimate interests (to keep our website updated and relevant, develop our business and inform our marketing strategy) |
| To send you relevant marketing communications and personalised recommendations | Identity, Contact, Technical, Usage, Profile, Marketing and Communications | Legitimate interests (to develop our products/services and grow our business) |
| To carry out market research through your voluntary participation in surveys | Identity, Contact, Profile, Usage | Legitimate interests (to study how customers use our products/services and help us improve them) |
Direct marketing
You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving the marketing.
Third-party marketing
We will get your express consent before we share your personal data with any third party for their own direct marketing purposes.
Opting out of marketing
You can ask to stop sending you marketing communications at any time by following the opt-out links within any marketing communication sent to you or by contacting us at [email protected].
If you opt out of receiving marketing communications, you will still receive service-related communications that are essential for administrative or customer service purposes.
5. Disclosures of your personal data
We may share your personal data where necessary with third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
6. International transfers
We do not transfer your personal data outside the UK.
7. 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.
8. Data retention
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.
In some circumstances we will 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 legal rights
You have a number of rights under data protection laws in relation to your personal data. You have the right to:
Request access to your personal data (commonly known as a “subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected.
Request erasure of your personal data in certain circumstances. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it.
Object to processing of your personal data where we are relying on a legitimate interest as the legal basis for that particular use of your data. You also have the absolute right to object any time to the processing of your personal data for direct marketing purposes.
Request the transfer of your personal data to you or to a third party in a structured, commonly used, machine-readable format.
Withdraw consent at any time where we are relying on consent to process your personal data. This will not affect the lawfulness of any processing carried out before you withdraw your consent.
Request restriction of processing of your personal data, enabling you to ask us to suspend the processing of your personal data in certain scenarios.
No fee usually required
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.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
10. Contact details
If you have any questions about this privacy policy or about the use of your personal data or you want to exercise your privacy rights, please contact us:
Email: [email protected]
11. Complaints
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.
12. Changes to the privacy policy
We keep our privacy policy under regular review. This version was last updated on 01/01/2025. Historic versions can be obtained by contacting us.
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, for example a new address or email address.
13. 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.