Privacy Policy

At Retrails, we're committed to protecting your privacy. This policy explains how we collect, use, store and protect your personal data, and your rights in relation to it.

Retrails is the trading name of Sportive Hub Ltd, a company registered in England and Wales. Company registration number: 14521044. Registered address: 71–75 Shelton Street, Covent Garden, London, WC2H 9JQ. ICO Registration Number: [ADD ICO NUMBER]. Our contact email is hello@retrails.com.

1. Who This Policy Applies To

This policy applies to:

• Visitors to our website

• Brands and business contacts who enquire about or sign up to our services

• Sellers who list items through a Retrails powered marketplace

• Buyers who purchase items through a Retrails powered marketplace

• Anyone who communicates with us directly

2. Definitions

Personal data: Any information that identifies or can reasonably identify a natural person.

Processing: Any action performed on personal data including collection, storage, use and disclosure.

Controller: The entity that determines the purposes and means of processing personal data. For the purposes of this policy, Retrails is the controller.

Anonymous data: Information that cannot reasonably be used to identify you. We may use anonymous and aggregated data for analytics and business improvement purposes without restriction.

Sensitive personal information: We do not intentionally collect sensitive personal data such as government IDs, biometric data, health data or precise geolocation unless specifically required for a transaction or legal compliance.

3. What Data We Collect

From website visitors:

• Name and email address if you subscribe to our mailing list or fill in a contact form

• Usage data including pages visited, time spent on site and browser type collected via cookies

• Approximate location data derived from your IP address

• Device identifiers, browser type and operating system

From brands and business contacts:

• Name, job title, company name, email address and phone number

• Information you provide during onboarding including brand guidelines, pricing rules and business preferences

• Communication records including emails and call notes

From sellers:

• Name, email address and contact details

• Order history where connected via Shopify integration

• Item listings including photographs, descriptions and condition details

• Payment details processed securely via Stripe

From buyers:

• Name, email address and delivery address

• Purchase history and transaction data

• Payment details processed securely via Stripe

4. How We Use Your Data

We use your data to:

• Respond to enquiries and communicate with you about our services

• Onboard and support brand partners through the pilot program and beyond

• Operate the resale marketplace including processing listings, transactions and payouts

• Send marketing emails and product updates where you have opted in

• Process payments securely via Stripe

• Authenticate items and manage quality control

• Personalise and improve your experience on our platform

• Detect and prevent fraud and ensure platform security

• Analyse trends and improve our website and services

• Comply with our legal obligations

We do not sell your data to third parties. We do not share your data with third parties for their own marketing purposes.

5. Our Legal Basis for Processing Your Data

Under UK GDPR we process your data on the following legal bases:

• Contract: To fulfil our obligations to brands, sellers and buyers using our platform

• Legitimate interests: To operate and improve our business, communicate with potential partners and prevent fraud

• Consent: To send marketing emails where you have opted in

• Legal obligation: Where we are required to process data to comply with the law

6. Cookies and Tracking Technologies

Our website uses cookies to improve functionality and understand how visitors use the site.

Types of cookies we use:

Strictly necessary cookies: Required for the website to function. These cannot be disabled.

Analytics cookies: Help us understand how visitors use our site including pages visited, time spent and links clicked.

Marketing cookies: Used to support relevant advertising and track the effectiveness of our marketing. These are only set with your consent.

You can accept or decline non-essential cookies via our cookie consent banner when you first visit our website. You can also manage your cookie preferences at any time through your browser settings.

7. How Long We Keep Your Data

• Enquiry and contact data: Up to 2 years from last contact

• Brand and business data: For the duration of the relationship and up to 5 years after it ends

• Seller and buyer transaction data: Up to 7 years to comply with financial and legal obligations

• Marketing data: Until you unsubscribe or withdraw consent

• Analytics data: Retained per each provider's policy

When we no longer have a legitimate reason to hold your data we will either delete it or anonymise it securely.

8. How We Store and Protect Your Data

Your data is stored securely through trusted third party platforms including Shopify and Stripe. We take appropriate technical and organisational measures to protect your data from loss, misuse, unauthorised access, disclosure or alteration. These measures include encryption, access controls and regular security reviews.

All payment data is processed by Stripe and is never stored directly by Retrails. Stripe is PCI DSS compliant.

Please be aware that no transmission of data over the internet can be guaranteed to be 100% secure. While we take all reasonable steps to protect your data, use of our website and services is at your own risk.

9. Data Breach Notification

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, Retrails will notify the Information Commissioner's Office within 72 hours of becoming aware of the breach as required by UK GDPR. Where the breach is likely to result in a high risk to your rights and freedoms we will notify affected users directly via email without undue delay.

10. International Data Transfers

Some of our third party service providers may process your personal data outside the UK. Where this happens we ensure appropriate safeguards are in place in accordance with UK GDPR, including adequacy decisions and Standard Contractual Clauses as approved by the Information Commissioner's Office.

If you would like more information about how we protect your data during international transfers please contact us at hello@retrails.com.

11. Third Parties We Work With

We share data only where necessary to operate our services. Our current third party processors include:

• Shopify — e-commerce and marketplace infrastructure

• Stripe — payment processing

• Email marketing platform — for sending communications where you have opted in

• Analytics providers — to help us understand how our website and services are used

All third parties are required to handle your data in accordance with UK GDPR and are bound by confidentiality obligations.

12. Seller Policy and Counterfeit Items

All items listed through a Retrails powered marketplace are subject to authentication and quality control checks. By listing an item you confirm that:

• The item is genuine and not counterfeit

• You have the right to sell the item

• The item matches the description and condition you have provided

If we identify a counterfeit or misrepresented item we will contact you directly. You will have the option to have the item returned to you at your own cost within 14 days. If no response is received we reserve the right to dispose of the item responsibly and sustainably. Retrails accepts no liability for counterfeit items submitted by sellers.

13. Your Rights

Under UK GDPR you have the right to:

• Access the personal data we hold about you

• Correct inaccurate or incomplete data

• Request deletion of your data where we no longer have a legal basis to hold it

• Restrict or object to how we process your data

• Request a copy of your data in a portable format

• Withdraw consent for marketing at any time

To exercise any of these rights please contact us at hello@retrails.com. We will respond within 30 days.

14. Marketing Opt Out

You can unsubscribe from marketing emails at any time by clicking the unsubscribe link in any email we send you or by emailing hello@retrails.com. Opting out of marketing emails will not affect service related communications such as order confirmations or account updates.

15. Children's Privacy

Our services are not directed at children under the age of 16. We do not knowingly collect personal data from children. If you believe a child has provided us with personal data please contact us at hello@retrails.com and we will delete it promptly.

16. Accessibility

If you have a disability and need this policy in an alternative format please contact us at hello@retrails.com and we will do our best to accommodate your needs.

17. Changes to This Policy

We may update this policy from time to time. When we do we will update the date at the top of this page. Where we make significant changes we will notify you via email or prominent notice on our website. We encourage you to review this policy periodically.

18. Contact Us and Complaints

If you have any questions about this policy or how we handle your data please contact us at:

Email: hello@retrails.com Company: Retrails, trading as Sportive Hub Ltd Company number: 14521044 Registered address: 71–75 Shelton Street, Covent Garden, London, WC2H 9JQ ICO Registration Number: [ADD ICO NUMBER]

If you are unhappy with how we have handled your data you have the right to lodge a complaint with the Information Commissioner's Office at ico.org.uk or by calling 0303 123 1113.