Privacy Policy

1. Who we are

ECOMSTRADING LTD (“we”, “us”), which trades as Sphere, is a company registered in England and Wales under company number 16906997, with its registered office at 124 City Road, London, EC1V 2NX, United Kingdom.

For data collected through this website we are the data controller. You can reach us about anything in this policy at info@ecoms-trading.com.

2. What this policy covers

This policy covers personal data we collect when you visit this website, use the enquiry or route-plan forms, or email us. It does not cover the handling of end-customer data within fulfilment operations carried out for a commercial partner — that is governed by the contract and data processing terms agreed with that partner.

3. Personal data we collect

Data you give us

Route plan and enquiry forms: your name, email address, telephone number, and optionally your primary market and monthly order volume.
Email: anything you choose to include when you write to us.

Where a form on this site is configured to open a draft in your own email application rather than send to a server, the details you typed are handed to your email client and are only received by us if you then send that message.

Data collected automatically

Consent choice: your cookie choice is stored in your own browser, in local storage, under the key ecoms.consent.v1. It never leaves your device.
Server logs: the hosting provider serving this site records standard request data, which can include your IP address, the pages requested, timestamps and your browser user agent. These logs are held by the hosting provider for a limited period and used only to keep the service secure and available.
Web fonts: this site loads typefaces from Google Fonts. Your browser therefore makes a request to fonts.googleapis.com and fonts.gstatic.com, and Google receives your IP address as part of that request. See section 6.

We do not run advertising or analytics tracking on this site at the date of this policy. If that changes, this policy and the cookie policy will be updated before the tracking is switched on, and non-essential tracking will only run where you have accepted it.

4. Why we use it, and our lawful basis

To answer your enquiry and prepare a route plan. Lawful basis: legitimate interests — responding to a business enquiry you initiated, and where relevant steps prior to entering a contract.
To contact you about the request you made. Lawful basis: legitimate interests, supported by the confirmation you give on the form.
To keep the site secure and available. Lawful basis: legitimate interests in operating a secure service.
To remember your cookie choice. Stored locally on your device because you need it to be; no lawful basis for processing by us arises, as we never receive it.

We do not use your details for marketing unrelated to your enquiry, and we do not add you to a newsletter because you asked for a route plan.

5. Who we share it with

We do not sell personal data, and we do not share it with third parties for their own marketing.

Your data may be handled by service providers acting on our instructions, which may include our hosting provider, our email provider and, where used, a customer relationship management system. Each of them acts only on our instructions and under a written agreement.

We may also disclose data where we are required to by law, or to establish, exercise or defend legal claims.

6. International transfers

We operate across three continents, and some of our service providers are based outside the United Kingdom. Where personal data is transferred outside the UK, we rely on an adequacy decision where one exists, or on the UK International Data Transfer Agreement or Addendum to the EU Standard Contractual Clauses.

The Google Fonts request described in section 3 involves a transfer of your IP address to Google. If you would rather the site made no third-party requests at all, write to us and we will tell you the current position.

7. How long we keep it

Enquiries that do not become a commercial relationship: 24 months from last contact, then deletion.
Enquiries that become a commercial relationship: retained for the life of the relationship and then for the period required by UK company and tax law — ordinarily six years.
Server logs: a limited period set by our hosting provider.
Consent choice: held in your browser until you clear your site data.

8. Your rights

Under UK GDPR you have the right to: be informed about how your data is used; access a copy of it; have inaccurate data corrected; have data erased in certain circumstances; restrict or object to processing; and receive your data in a portable form. Where processing rests on consent, you may withdraw it at any time without affecting processing already carried out.

To exercise any of these, write to info@ecoms-trading.com. We will respond within one month. We will not charge you, and we will not make you justify the request.

If you are not satisfied with our response, you can complain to the Information Commissioner’s Office at ico.org.uk, or by calling their helpline. You are entitled to complain to them without contacting us first.

9. Cookies

Cookie handling is set out separately in our Cookie Policy. You can reopen the choice at any time using the cookie settings link, which also appears in the footer of every page.

10. Security

This site is served over HTTPS. Access to enquiry correspondence is limited to the people who need it to answer you. No transmission over the internet is completely secure, and we cannot guarantee the security of data sent to us before it reaches us.

11. Changes and how to contact us

If this policy changes materially we will update the version and date at the top of this page, and where the change affects how we use data you have already given us, we will tell you directly.

ECOMSTRADING LTD, 124 City Road, London, EC1V 2NX, United Kingdom · info@ecoms-trading.com · Company No. 16906997.