The Recycled Assets Company Ltd – Privacy Policy;


This privacy policy describes how TRACOUK (also referred to as “we,” “us” or “our” or “The Recycled Assets Company Ltd”) will make use of your information in the context of:


TRACOUK websites such as the TRACO portal.

Mobile apps

TRACOUK’s marketing, sales, and advertising practices.

This policy explains when we process personal information for our legitimate interests. You can ask us to stop processing this information.

We use your personal information to enable you to register with TRACOUK and to provide you with our websites and apps, and other services that you request.

Information we hold


TRACOUK ID number, registration, and customer support

When you register to use our portal or TRACOUK website or app, create a TRACOUK ID, or contact us for support or other offerings, TRACOUK collects information that identifies you. This may include:

  • Name;
  • Company name;
  • Email address;
  • Telephone number;
  • Address;
  • Country;
  • IP address;
  • Payment/billing information
  • Eligibility information
  • Types of products and websites of interest; and
  • Content of customer support communications.

To help keep our databases current and to provide you the most up to date content and information, we may combine information provided by you with information from third party sources, in accordance with applicable law. For example, the size, industry, and other information about the company you work for (where you have provided company name) will be obtained from other sources.

Please note that in order to use our websites you authorise TRACOUK to collect, store and transfer personal data.  We will only transfer your personal information to these countries where permitted to do so by law and we will take steps intended to ensure that your personal information continues to receive appropriate protections.



Emails we send you may include information that tells TRACOUK whether you have received or opened the email, or clicked a link in the email.

TRACOUK online advertising


TRACOUK advertises online in a variety of ways, including displaying TRACOUK ads to you on other companies’ websites and apps and on social media platforms, such as Facebook and LinkedIn and other companies that allow us to gather additional information to measure and improve the effectiveness of our advertising. We may collect information such as:

  • Which ads are displayed;
  • Which ads are clicked on; and
  • Where the ad was displayed.


Buttons, tools, and content from other companies


There are several places within TRACOUK’s websites that allow you to post comments, upload pictures, or submit content which will be publicly available where you choose to participate in these activities. We also share information with third parties we engage to process information on our behalf or when such sharing is required by law.


TRACOUK apps and websites may include buttons, tools, or content that link to other companies’ services (for example, a Facebook “Like” button). We may collect information about your use of these feature, such as content “liked” and address information in Google Maps. In addition, when you see or interact with these buttons, tools, or content, or view an TRACOUK web page or app containing them, some information from your browser may automatically be sent to the other company. Please read that company’s privacy policy for more information.

TRACOUK social networking pages and social sign-on services

You can sign in to some TRACOUK apps or websites using a social networking account, such as a Facebook account. Where you give appropriate permissions, we will receive information about you from your social networking account, such as name, location, basic demographic information.


TRACOUK has its own pages on many social networking sites (for example, @TRACOUK Facebook page). We will collect information which you have made publicly available on your social networking account, such as name and interests in our products and services, when you interact with our social networking pages.


How do we use information about you?


TRACOUK uses the information we collect about you for the following purposes:

  • To fulfill a contract, or take steps linked to a contract: this is relevant where you register to use an TRACOUK app or website This includes:
    • Providing you with the TRACOUK websites and apps for which you have registered, and any other services or products that you have requested;
    • Verifying your identity;
    • Taking payments;
    • Sending you necessary communications (for example, related to payments)
    • Providing customer support.


  • As required by TRACOUK to conduct our business and pursue our legitimate interests, in particular:
    • Providing you with the TRACOUK websites and apps for which you have registered and any other services you have requested;
    • Analysing your use and measuring effectiveness of our websites and apps to better understand how they are being used so we can improve them and engage and retain users;
    • Sending you information about TRACOUK products and services, special offers and similar information;
    • Analysing use of our websites and apps, and interaction with our communications, to tailor and customise the website or app, and marketing communications;
    • Diagnosing problems in our apps and websites;
    • Conducting surveys and market research about our customers, their interests, the effectiveness of our marketing campaigns, and customer satisfaction (unless we need consent to undertake such surveys, in which case we will only do this with your permission);
    • Investigating and responding to any comments or complaints that you may send us;
    • Checking the validity of the sort code, account number and card number you submit if you use a credit or debit card for payment, in order to prevent fraud (we use third parties for this – see “Does TRACOUK share my personal information?” below); and
    • Regarding legal claims, compliance, regulatory and investigative purposes as necessary (including disclosure of information in connection with legal process or litigation).


  • Where you give TRACOUK your consent or otherwise consistent with your choices:


    • Sending you information about TRACOUK products and services, special offers and similar information, and sharing your information with third parties for their own marketing purposes (where your consent is required);

On other occasions where we ask you for consent, we will use the information for the purposes which we explain at that time.

  • For legal reasons:
    • Responding to requests by government or law enforcement authorities investigating.
    • To detect, prevent, or otherwise address fraud, security or technical issues.


Information sharing


Sharing with other Data Controllers

We will share personal information with companies, organisations or individuals outside of TRACOUK if we have a good-faith belief that access, use, preservation or disclosure of the information is reasonably necessary to detect, prevent, or otherwise address fraud, security or technical issues, or the public as required or permitted by law.


Sharing with Data Processors

We will also share your personal information with companies that help us to run our business by processing personal information on behalf of TRACOUK for the purposes identified above. Such companies include providers of customer support services, payment processing services, fraud monitoring and prevention, email, social media, and other marketing platforms and service providers, and hosting services.

Other Information Sharing
TRACOUK may also share your personal information:

  • When you agree to the sharing;
  • When we are required to provide information in response to a subpoena, court order, or other applicable law or legal process
  • When we have a good faith belief that the disclosure is necessary to prevent or respond to fraud, defend our apps or websites against attacks, our customers and users, or the public;

We may share or publish aggregate information that doesn’t specifically identify you, such as statistical information about visitors to our websites or statistical information.


We do not transfer your personal information outside of the EU. We use European Commission approved contract clauses and Privacy Shield to help protect your personal information.


Is information displayed?

There are several places within TRACOUK’s websites and apps that allow you to post comments, upload pictures, or submit content for others to see. You can limit who can see what you share, but there are some places where what you share can be seen by the general public or other users of the app or website. Please be careful when you share your personal information. Do not share anything you wouldn’t want publicly known unless you are sure you are posting it within an app or website that allows you to control who sees what you post. Please note that when you post messages on certain user forums on our websites and app, your email address or name and/or profile photo may be included and displayed with your message.

To remove content you have shared on our websites and apps, please use the same app or website feature you used to share the content. If another user invites you to participate in shared viewing, editing, or commenting of content, you may be able to delete your contributions, but usually the user who invited you has full control. If you have questions or concerns about this, please contact us.


Is my information secure?

We understand that the security of your personal information is important. We provide reasonable administrative, technical, and physical security controls to protect your personal information. However, despite our efforts, no security controls are 100% effective and TRACOUK cannot ensure or warrant the security of your personal information.

Your personal information and files are stored on TRACOUK’s servers and the servers of companies we hire to provide services to us.


Your rights

Under the law, you may have the right to ask us for a copy of your personal information; to correct, delete or restrict (stop any active) processing of your personal information; and to obtain the personal information you provide to us for a contract or with your consent in a structured, machine readable format, and to ask us to share this information to another controller.

In addition, you can object to the processing of your personal information in some circumstances (where we don’t have to process the information to meet a contractual or other legal requirement, or where we are using the information for direct marketing).

These rights may be limited, for example, if fulfilling your request would reveal personal information about another person, or if you ask us to delete information which we are required by law to keep or have compelling legitimate interests in keeping (such as fraud prevention purposes).

To exercise any of these rights (including deactivating your TRACOUK ID account), you can get in touch with us – or our data protection officer – using the details set out below.


If you have unresolved concerns, you have the right to report them to an EU or other data protection authority where you live, work or where you believe a potential violation may have occurred.

To register with TRACOUK, to create a TRACOUK ID, and to use some TRACOUK websites, apps, products or services, the provision of some information is mandatory: if relevant information is not provided, then we will not be able to administer a TRACOUK account to you, or provide you with the websites, apps, products or services requested. All other provision of your information is optional. Providing optional information will help us offer you a better experience, such as more personalized or tailored content or offerings.


Withdrawing Consent

TRACOUK hires companies to help us market our websites and apps on our behalf, these may use your information to provide you with information and offers related to TRACOUK.

Wherever we rely on your consent, you will always be able to withdraw that consent, although we may have other legal grounds for processing your information for other purposes, such as those set out above. In some cases, we are able to send you direct marketing without your consent, where we rely on our legitimate interests. You have an absolute right to opt-out of direct marketing, at any time by:

  • clicking the unsubscribe link at the bottom of our marketing emails; or
  • contacting us using the details provided at the end of this privacy policy.


Information Retention

When you register for a TRACOUK account, we process and keep most personal information we have about you for as long as you are an active user of our products, services or apps. When you close your account, after 180 days we begin deleting certain personal information that we no longer have a business reason to retain, such as your hashed password and your payment account data. However, we typically retain personal information related to our contract and business transactions with you for seven years after your last interaction with us.


Where we process personal information for marketing purposes or with your consent, we process the information until you ask us to stop and for a short period after this (to allow us to implement your requests). We also keep a permanent record of the fact that you have asked us not to send you direct marketing or to process your information so that we can respect your request in future.

If the content or information that you store with TRACOUK contains personal information of other individuals, you must be legally permitted to share the personal information with TRACOUK. Where your consent is required, we will obtain your permission.


Policy Updates

Occasionally, we may change this privacy policy to allow TRACOUK to use or share your personal information in a different way. If we do, the links to the policy on our websites will indicate that the policy has been changed. For new users, the change will become effective upon posting. For existing users, if the change is significant, it will become effective 30 days after posting. We encourage you to periodically review the policy for the latest information on our privacy practices.


Who to contact

If you have a privacy question, concern, or request, please contact Ian Reedy at or phone 02392 960640.  You will be assisted in progressing you request.

Last Update 24 May 2018