Website Privacy Policy

We are Tupras Trading Ltd. We’re a company registered in England and Wales with company number 12413758, whose registered address is at 50 Pall Mall, St. James’s, London SW1Y 5JH . In this privacy notice we will refer to ourselves as ‘we’, ‘us’ or ‘our’.

You can get hold of us in any of the following ways:

(a) by phoning us on 44 207 004 2399  ;
(b) by e-mailing us at info@tupras.com  ; or
(c) by writing to us at 50 Pall Mall, London SW1Y 5JH, London.

We take the privacy, including the security, of personal information we hold about you seriously. This privacy notice is designed to inform you about how we collect personal information about you and how we use that personal information. You should read this privacy notice carefully so that you know and can understand why and how we use the personal information we collect and hold about you.

We do not have a Data Protection Officer, but if you have any questions about this privacy notice or issues arising from it then you should contact Ali Sarper, who is responsible for matters relating to data protection at our organisation, including any matters in this privacy notice. You can contact them using the details set out above.

We may issue you with other privacy notices from time to time, including when we collect personal information from you. This privacy notice is intended to supplement these and does not override them.

We may update this privacy notice from time to time. This version was last updated on [19 August 2022].

  1. Key Definitions

The key terms that we use throughout this privacy notice are defined below, for ease:

Data Controller: under UK data protection law, this is the organisation or person responsible for deciding how personal information is collected and stored and how it is used.

Personal Information: in this privacy notice we refer to your personal data as ‘personal information’. ‘Personal information’ means any information from which a living individual can be identified. It does not apply to information which has been anonymised.

  1. Details of personal information which we collect and hold about you

2.1 Set out below are the general categories and in each case the types of personal information which we collect, use and hold about you:

Identity Information: This is information relating to your identity such as your name (including any previous names and any titles which you use), gender and date of birth

Contact Information: This is information relating to your contact details such as e-mail address, addresses, telephone numbers

Payment Information: This is information relating to the methods by which you provide payment to us such as bank account details, credit or debit card details and details of any payments (including amounts and dates) which are made between us.

Transaction Information: This is information relating to transactions between us such as details of the goods, services and/or digital content provided to you and any returns details.

Survey Information: This is information which we have collected from you or which you have provided to us in respect of surveys and feedback.

Website, Device and Technical Information: This is information about your use of our website and technical data which we collect (including your IP address, the type of browser you are using and the version, the operating system you are using, details about the time zone and location settings on the device and other information we receive about your device)]

2.2 The types of personal data we collect about you may differ from person to person, depending on who you are and the relationship between us.

  1. Details of how and why we use personal information

3.1 We are only able to use your personal information for certain legal reasons set out in data protection law. There are legal reasons under data protection law other than those listed below, but in most cases, we will use your personal information for the following legal reasons:

(a) Contract Reason: this is in order to perform our obligations to you under a contract we have entered into with you;

(b) Legitimate Interests Reason: this is where the use of your personal information is necessary for our (or a third party’s) legitimate interests, so long as that legitimate interest does not override your fundamental rights, freedoms or interests.

(c) Legal Obligation Reason: this is where we have to use your personal information in order to perform a legal obligation by which we are bound; and

(d) Consent Reason: this is where you have given us your consent to use your personal information for a specific reason or specific reasons.

3.2 So that we are able to provide you with goods and services, we will need your personal information. If you do not provide us with the required personal information, we may be prevented from supplying the goods and services to you.

3.3 It is important that you keep your personal information up to date. If any of your personal information changes, please contact us as soon as possible to let us know. If you do not do this then we may be prevented from supplying the goods and services to you [for example, if you move address and do not tell us, then your goods may be delivered to the wrong address].

3.4 Where we rely on consent for a specific purpose as the legal reason for processing your personal information, you have the right under data protection law to withdraw your consent at any time. If you do wish to withdraw your consent, please contact us using the details set out at the beginning of this notice. If we receive a request from you withdrawing your consent to a specific purpose, we will stop processing your personal information for that purpose, unless we have another legal reason for processing your personal information, in which case, we will confirm that reason to you.

3.5 We have explained below the different purposes for which we use your personal information and, in each case, the legal reason(s) allowing us to use your personal information. Please also note the following:

(a) if we use the Legitimate Interests Reason as the legal reason for which we can use your personal information, we have also explained what that legitimate interest is; and

(b) for some of the purposes we may have listed more than one legal reason on which we can use your personal information, because the legal reason may be different in different circumstances. If you need confirmation of the specific legal reason that we are relying on to use your personal data for that purpose, please contact us using the contact details set out at the start of this privacy notice.

Purpose Legal Reason(s) for using the personal information

  1. To enrol you as a customer [Contract Reason.]
  2. Legitimate Interests Reason in order to [offer you other goods, services)
  • To process your order, which includes taking payment from you, advising you of any updates in relation to your order or any enforcement action against you to recover payment. [Contract Reason.], [Legitimate Interests Reason in order to [recover money which you owe us]
  1. To manage our contract with you and to notify you of any changes [Contract Reason.],[Legal Obligation Reason.]
  2. To comply with audit and accounting matters [Legal Obligation Reason]
  3. For record keeping, [including in relation to any guarantees or warranties provided as part of the sale of goods, services and/or digital content] [Contract Reason.], [Legal Obligation Reason.]
  • To improve the goods, services, and/or digital content which we supply [Legitimate Interests Reason (in order to improve the goods, services, and/or digital content for future customers and to grow our business)]
  • To ensure the smooth running and correct operation of our website [Legitimate Interests Reason (to ensure our website runs correctly)]

To understand how customers and visitors to our website use the website and interact with it via data analysis [Legitimate Interests Reason (to improve and grow our business, including our website, and to understand our customer’s needs, desires and requirements)]

3.6 Sometimes we may anonymise personal information so that you can no longer be identified from it and use this for our own purposes. In addition, sometimes we may use some of your personal information together with other people’s personal information to give us statistical information for our own purposes. Because this is grouped together wither other personal information and you are not identifiable from that combined data we are able to use this.

3.7 Under data protection laws we can only use your personal information for the purposes we have told you about, unless we consider that the new purpose is compatible with the purpose(s) which we told you about. If we want to use your personal information for a different purpose which we do not think is compatible with the purpose(s) which we told you about then we will contact you to explain this and what legal reason is in place to allow us to do this.

  1. Details of how we collect personal information and special information

4.1 We usually collect [Identity Information], [Contact Information,], [Payment Informationormation], [Transaction Information] directly from you when you fill out a form, purchase goods and/or services contact us by e-mail, telephone, in writing or otherwise. This includes the personal information which you provide to us when you subscribe to our customer list.

  1. Details about who personal Information may be shared with

5.1 We may need to share your personal information with other organisations or people. These organisations include:

(a) Other companies in our group (who may might act as joint data controllers or as data processors on our behalf) and who suplies or purchase product.

(b) Third parties who are not part of our group. These may include:

(i) Suppliers: such as IT support services, payment providers, administration providers,

(ii) Government bodies and regulatory bodies: such as HMRC, fraud prevention agencies,

(iii) Our advisors: such as lawyers, accountants, auditors, insurance companies,

(iv) Our bankers;

(c) any organisations which propose to purchase our business and assets in which case we may disclose your personal information to the potential purchaser.

5.2 Depending on the circumstances, the organisations or people who we share your personal information with will be acting as either Data Processors or Data Controllers. Where we share your personal information with a Data Processor we will ensure that we have in place contracts, which set out the responsibilities and obligations of us and them, including in respect of security of personal information.

5.3 We do not sell or trade any of the personal information which you have provided to us.

  1. Details about transfers to countries outside of the EEA

6.1 If any transfer of personal information by us will mean that your personal information is transferred outside of the EEA then we will ensure that safeguards are in place to ensure that a similar degree of protection is given to your personal information, as is given to it within the EEA and that the transfer is made in compliance with data protection laws (including where relevant any exceptions to the general rules on transferring personal information outside of the EEA which are available to us – these are known as ‘derogations’ under data protection laws). We may need to transfer personal information outside of the EEA [to other organisations within our group or] [to the third parties listed above in section 5 who may be located outside of the EEA.]

6.2 The safeguards set out in data protection laws for transferring personal information outside of the EEA include:

(a) where the transfer is to a country or territory which the EU Commission has approved as ensuring an adequate level of protection;

(b) where personal information is transferred to another organisation within our group, under an agreement covering this situation which is known as “binding corporate rules”;

(c) having in place a standard set of clauses which have been approved by the EU Commission;

(d) compliance with an approved code of conduct by a relevant data protection supervisory authority (in the UK, this is the Information Commissioner’s Office (ICO);

(e) certification with an approved certification mechanism;

(f) where the EU Commission has approved specific arrangements in respect of certain countries, such as the US Privacy Shield, in relation to organisations which have signed up to it in the USA.

  1. Details about how long we will hold your personal information

7.1 We will only hold your personal data for as long as is necessary. How long is necessary will depend upon the purposes for which we collected the personal information (see section 3 above) and whether we are under any legal obligation to keep the personal information (such as in relation to accounting or auditing records or for tax reasons). We may also need to keep personal information in case of any legal claims, including in relation to any guarantees or warranties which we have provided with the goods or services.

7.2 You can contact us (using the details at the beginning of this notice) to request a copy of our retention policy which sets out how long different types of personal data will be kept for.

  1. Your Rights Under Data Protection Law

8.1 Under data protection laws you have certain rights in relation to your personal information, as follows:

(a) Right to request access: (this is often called ‘subject access’). This is the right to obtain from us a copy of the personal information which we hold about you. We must also provide you with certain other information in response to these requests to help you understand how your personal information is being used.

(b) Right to correction: this is the right to request that any incorrect personal data is corrected and that any incomplete personal data is completed.

(c) Right to erasure: (this is often called the “right to be forgotten”). This right only applies in certain circumstances. Where it does apply, you have the right to request us to erase all of your personal information.

(d) Right to restrict processing: this right only applies in certain circumstances. Where it does apply, you have the right to request us to restrict the processing of your personal information.

(e) Right to data portability: this right allows you to request us to transfer your personal information to someone else.

(f) Right to object: you have the right to object to us processing your personal information for direct marketing purposes. You also have the right to object to us processing personal information where our legal reason for doing so is the Legitimate Interests Reason (see section 3 above) and there is something about your particular situation which means that you want to object to us processing your personal information.

8.2 In addition to the rights set out in section 8.1, where we rely on consent as the legal reason for using your personal information, you have the right to withdraw your consent. Further details about this are set out in section 3.4.

8.3 If you want to exercise any of the above rights in relation to your personal information, please contact us using the details set out at the beginning of this notice. If you do make a request then please note:

(a) we may need certain information from you so that we can verify your identity;

(b) we do not charge a fee for exercising your rights unless your request is unfounded or excessive; and

(c) if your request is unfounded or excessive then we may refuse to deal with your request.

  1. Complaints

If you are unhappy about the way that we have handled or used your personal information, you have the right to complain to the UK supervisory authority for data protection, which is the Information Commissioner’s Office (ICO). Please do contact us in the first instance if you wish to raise any queries or make a complaint in respect of our handling or use of your personal information, so that we have the opportunity to discuss this with you and to take steps to resolve the position. You can contact us using the details set out at the beginning of this privacy notice.

  1. Third Party Websites

Our website may contain links to third party websites. If you click and follow those links then these will take you to the third party website. Those third party websites may collect personal information from you and you will need to check their privacy notices to understand how your personal information is collected and used by them.]

Cookie Policy 

This is the Cookie Policy for Tupras Trading, accessible from tuprastrading.com

What Are Cookies

As is common practice with almost all professional websites this site uses cookies, which are tiny files that are downloaded to your computer, to improve your experience. This page describes what information they gather, how we use it and why we sometimes need to store these cookies. We will also share how you can prevent these cookies from being stored however this may downgrade or ‘break’ certain elements of the sites functionality.

How We Use Cookies

We use cookies for a variety of reasons detailed below. Unfortunately in most cases there are no industry standard options for disabling cookies without completely disabling the functionality and features they add to this site. It is recommended that you leave on all cookies if you are not sure whether you need them or not in case they are used to provide a service that you use.

Disabling Cookies

You can prevent the setting of cookies by adjusting the settings on your browser (see your browser Help for how to do this). Be aware that disabling cookies will affect the functionality of this and many other websites that you visit. Disabling cookies will usually result in also disabling certain functionality and features of the this site. Therefore it is recommended that you do not disable cookies. 

The Cookies We Set

  • Site preferences cookies

    In order to provide you with a great experience on this site we provide the functionality to set your preferences for how this site runs when you use it. In order to remember your preferences we need to set cookies so that this information can be called whenever you interact with a page is affected by your preferences.

Third Party Cookies

In some special cases we also use cookies provided by trusted third parties. The following section details which third party cookies you might encounter through this site.

  • This site uses Google Analytics which is one of the most widespread and trusted analytics solution on the web for helping us to understand how you use the site and ways that we can improve your experience. These cookies may track things such as how long you spend on the site and the pages that you visit so we can continue to produce engaging content.

    For more information on Google Analytics cookies, see the official Google Analytics page.

More Information

Hopefully that has clarified things for you and as was previously mentioned if there is something that you aren’t sure whether you need or not it’s usually safer to leave cookies enabled in case it does interact with one of the features you use on our site.

However if you are still looking for more information then you can contact us through one of our preferred contact methods: