This Privacy Policy explains how 110 Traders Limited collects, uses and protects your personal data. It complies with the UK General Data Protection Regulation and the Data Protection Act 2018.
1. Who we are
110 Traders Limited (company number 12752068), whose registered office is at 12 Chantry Road, Harrow, HA3 6NT, trading as Tech110 at tech110.com, is the data controller for the personal data described in this policy.
We are registered with the Information Commissioner's Office (ICO). Our ICO registration number is [TO INSERT].
You may contact our data controller at admin@tech110.com or by writing to the registered office above.
2. What personal data we collect
We collect the following categories of personal data:
- Identity data: name, title, job title (for business customers).
- Contact data: billing address, delivery address, email address, telephone number.
- Account data: username and password (stored in salted, hashed form), preferences.
- Transaction data: details of Products ordered, prices paid, delivery details, Order history.
- Payment data: we do not store full payment card details. Card payments are processed by our payment services provider (Stripe Payments UK Ltd). We store a token identifier and the last four digits of the card only to reference transactions.
- Technical data: IP address, browser type and version, time zone, operating system, device identifiers, referring URL.
- Usage data: pages visited, links clicked, session duration, basket contents.
- Marketing data: your preferences for receiving marketing from us.
- Business data (Trade Account holders): company name, company registration number, VAT number, business address, trade references.
We do not knowingly collect special category personal data (health, racial or ethnic origin, political opinions, religious beliefs, sexual orientation, biometric data, or genetic data).
3. How we collect your personal data
- Directly from you when you create an account, place an Order, apply for a Business Account, contact us or subscribe to our marketing.
- Automatically through cookies and similar technologies as you browse tech110.com (see our Cookie Policy).
- From third parties: our payment services provider (transaction confirmation); Companies House and credit reference agencies (for Business Account applications); analytics providers.
4. Lawful basis for processing
Under UK GDPR we must have a lawful basis for processing your personal data. The bases we rely on are:
- Performance of a Contract: to process your Order, deliver Products, provide customer service, and manage your account.
- Legitimate interests: to run our business, prevent fraud, improve tech110.com, secure our systems, analyse Product performance, and communicate about related Products where you have not opted out.
- Consent: for marketing to prospective customers, for non-essential cookies, and for other processing where the law requires consent. You may withdraw consent at any time without affecting the lawfulness of processing before withdrawal.
- Legal obligation: to comply with our obligations under tax, accounting, consumer protection, and financial-crime prevention law.
5. How we use your personal data
We use personal data for the following purposes:
- Processing Orders, taking payment, arranging delivery, and providing Order updates.
- Managing your customer account and Business Account (where applicable).
- Providing customer service, responding to enquiries, handling returns and warranty issues.
- Preventing and detecting fraud, credit-card misuse, and other crimes.
- Complying with our legal obligations.
- Operating and improving tech110.com, its content, security and performance.
- Marketing our Products to existing customers by email (where you have not opted out) and to prospective customers where they have consented.
- Analysing customer behaviour to improve Product listings, offerings and pricing.
6. Sharing your personal data
We share personal data with the following categories of recipients:
- Our approved trade distributors (Ingram Micro, TD SYNNEX, Westcoast, Exertis, Midwich, JGBM, Beta Distribution and others from time to time) — for the sole purpose of fulfilling your Order (name, delivery address and Product details only).
- Couriers and logistics providers — for delivery of your Order.
- Payment services providers (Stripe Payments UK Ltd) — for taking payment and preventing fraud.
- Email delivery providers (Resend and equivalent) — for sending Order confirmations and service messages.
- IT infrastructure providers (Google Cloud Platform, and equivalent) — for hosting tech110.com and processing data on our behalf.
- Professional advisers — accountants, lawyers, and other advisers, where necessary.
- Public authorities and regulators — where required by law.
- Buyers or investors — in the event of a sale, merger or restructuring of our business.
We do not sell your personal data to third parties.
7. International transfers
Most of our processing takes place in the United Kingdom and the European Economic Area. Where personal data is transferred outside the UK, we ensure a similar degree of protection through the use of countries deemed adequate by the UK Government, Standard Contractual Clauses approved by the UK ICO, or an equivalent lawful transfer mechanism.
8. How long we keep your personal data
We retain personal data only for as long as necessary to fulfil the purposes for which it was collected, including for legal, accounting or reporting requirements. Typical retention periods are:
- Order and transaction data: 7 years from the end of the relevant financial year (to meet UK tax record-keeping requirements).
- Account data (active accounts): for the duration of your account, plus 12 months after closure.
- Marketing consent records: for the duration of consent plus 3 years to evidence lawful basis.
- Website analytics: aggregated only, retained for up to 26 months in identifiable form.
9. Your rights
Under UK GDPR you have the following rights in respect of your personal data:
- Right of access — to request a copy of the personal data we hold about you.
- Right to rectification — to require correction of inaccurate data.
- Right to erasure — to require deletion of your personal data in certain circumstances.
- Right to restrict processing — in certain circumstances.
- Right to data portability — to receive your personal data in a machine-readable form.
- Right to object — including to processing based on legitimate interests and to direct marketing.
- Right to withdraw consent — where consent is the lawful basis for processing.
To exercise any of these rights please contact us at admin@tech110.com. We will respond within one month. We may need to verify your identity before actioning any request.
You have the right to complain to the ICO at ico.org.uk if you consider that our processing of your personal data breaches data protection law. We would appreciate the chance to address your concerns first, so please contact us before you complain.
10. Security
We apply appropriate technical and organisational measures to protect personal data from unauthorised access, loss, alteration or disclosure. These include encryption in transit, access controls, secure hosting, and staff training. We regularly review these measures. However, no online transmission or storage is entirely secure and you use tech110.com at your own risk.
11. Changes to this Privacy Policy
We may update this Privacy Policy from time to time. The latest version is always available on tech110.com. Where a change is material we will notify account holders by email.
12. Contact us
Questions or complaints about this Privacy Policy or our data-handling practices should be directed to: admin@tech110.com, or by post to 110 Traders Limited, 12 Chantry Road, Harrow, HA3 6NT.