Privacy Policy

1. Who we are and what this policy covers

RWTT Ltd ("RWTT", "we", "us") is a tyre wholesaler supplying trade customers. We are the data controller for the personal data described in this policy.

Company details: RWTT Ltd, a private limited company registered in England and Wales, company number 16652063, registered office 70 Rainham Road, Rainham, England, RM13 7RL. Email: sales@rwtt.co.uk.

This policy explains what personal data we collect, why we collect it, who we share it with and what rights you have. It applies to personal data we process under the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018 and the Privacy and Electronic Communications Regulations 2003 (PECR).

Last updated: 16 September 2026.

2. Who this policy applies to

Most of our customers are businesses. Data protection law protects individuals, not companies, so this policy covers the personal data of people we deal with in the course of trade:

• Owners, directors, buyers, accounts staff and other contacts at our trade customers
• Sole traders and partners in partnerships, whose business details are also their personal data
• Contacts at our suppliers, hauliers, manufacturers and other service providers
• Visitors to our website and people who contact us by phone, email or social media
• Prospective customers we approach or who enquire with us

If you give us personal data about someone else at your business (for example a new accounts contact), please make sure they know about this policy.

3. The personal data we collect

We collect only what we need to trade with you. The main categories are:

Category

Examples

Identity and contact

Name, job title, business name, business address, phone, email

Account and trading

Trade account number, credit limit, order history, delivery addresses, pricing agreed with you

Financial

Bank details for invoice payments and refunds, invoices, statements and payment history

Credit and identity checks

Information from credit reference agencies, Companies House, trade references and, for sole traders, proof of identity

Correspondence

Emails, letters, call notes, complaints, warranty and returns claims

Vehicle and fleet

Vehicle registrations, tyre sizes and fitting details where you give them to us for an order or claim

Website and technical

IP address, browser type, pages viewed, cookie identifiers

We do not knowingly collect special category data (such as health or ethnicity data) or data about children. If you send it to us, we will delete it unless we have a legal reason to keep it.

4. How we collect personal data

Most of it comes directly from you: when you open a trade account, place an order by phone or email, use the contact form on our website, ask for a quote, or make a warranty or returns claim. We deal with customers by phone and email; there is no trade counter.

Some comes from third parties: credit reference agencies and Companies House when we assess your account; tyre manufacturers and distributors when they pass on a lead or a warranty claim; hauliers and couriers who confirm deliveries; and publicly available business directories and LinkedIn when we research prospective trade customers.

Some is collected automatically: our website uses cookies and similar technologies (see section 13), and our phone system records call times and numbers.

5. Why we use personal data and our lawful bases

UK GDPR requires us to have a lawful basis for every use of personal data. The table below sets out what we do and why we are allowed to do it.

Purpose

Lawful basis

Opening and managing your trade account, taking orders, delivering tyres, invoicing and collecting payment

Performance of a contract (sole traders and partnerships); legitimate interests in trading with your business (limited companies)

Assessing creditworthiness and setting credit limits

Legitimate interests in managing credit risk

Handling warranty claims, returns, complaints and disputes

Performance of a contract; legitimate interests in resolving issues

Keeping accounting, tax and VAT records

Legal obligation (Companies Act 2006, VAT Act 1994, HMRC record-keeping rules)

Complying with product safety, recall and waste tyre (duty of care) obligations

Legal obligation

Telling you about products, prices, stock and offers relevant to your trade

Legitimate interests in promoting our business (see section 7)

Improving our website, catalogue and service

Legitimate interests in running an efficient business

Preventing fraud, protecting our premises and stock, and pursuing unpaid debts

Legitimate interests in protecting our business; legal obligation where fraud is suspected

Responding to enquiries from prospective customers

Legitimate interests in winning new trade business

Where we rely on legitimate interests, we have balanced our interests against your rights and concluded that the impact on you is minimal because the data is limited to what is needed to trade with your business. You can object to any processing based on legitimate interests (see section 12).

We do not make decisions about you using solely automated processing that has a legal or similarly significant effect. Credit decisions are reviewed by a member of staff.

6. Credit checks and trade references

When you apply for a credit account, we check your business with a credit reference agency and with Companies House. For limited companies this is mostly company data, but it may include the names and addresses of directors and any personal guarantors.

For sole traders and partnerships, the search is against you personally and may leave a footprint on your credit file. We will tell you before we run the search. The agency's own privacy notice explains how it uses the data; we will give you a link on request.

We may contact the trade references you supply and may share your payment record with credit reference agencies and trade credit insurers. This can affect your ability to get credit from other suppliers if you do not pay on time.

7. Marketing communications

We send trade customers and prospects information about tyre ranges, stock arrivals, price changes, promotions and industry news by email only. We do not make marketing calls or send marketing by post.

The rules differ by who you are:

• Limited companies, LLPs and other corporate bodies. Under PECR we may email named contacts at a corporate body without prior consent, relying on our legitimate interests. Every email includes an unsubscribe link and we honour opt-outs promptly.
• Sole traders and partnerships. PECR treats you as an individual subscriber. We will only send you marketing emails if you have opted in, or if you are an existing customer and the message is about similar products (the "soft opt-in") and you were given the chance to refuse when we took your details.

You can stop marketing at any time by clicking unsubscribe, emailing sales@rwtt.co.uk or telling any member of our team. Stopping marketing does not stop service messages such as order confirmations, delivery updates, invoices, recall notices and account statements.

We do not sell or rent your personal data to third parties for their marketing.

8. Who we share personal data with

We share personal data only where needed to run our business and serve your account:

Recipient

Why

Hauliers, couriers and pallet networks

To deliver your order and confirm receipt

Tyre manufacturers and distributors

To process warranty claims, product recalls and manufacturer-backed promotions

Credit reference agencies and trade credit insurers

To assess credit and report payment performance

Our bank

To receive invoice payments by bank transfer and issue refunds

IT, cloud hosting, email, accounting and CRM providers

To store and process data on our behalf under contract

Accountants, auditors, solicitors and insurers

For professional advice, audit and claims

Debt collection agencies and the courts

To recover overdue accounts

HMRC, the Environment Agency, Trading Standards, police and other regulators

Where the law requires or permits disclosure

A buyer or investor

If we sell or restructure the business, under confidentiality terms

Providers that process data on our behalf are bound by written contracts that meet Article 28 UK GDPR and may only use the data on our instructions.

9. International transfers

We are based in the UK and keep your data here where we can. Some of our software providers (for example email, cloud storage or CRM) may store data in the EEA or the United States.

Where data leaves the UK we make sure it is protected by one of the safeguards recognised under UK GDPR: a UK adequacy regulation (which covers the EEA and, for certified organisations, the US under the UK Extension to the EU-US Data Privacy Framework), or the International Data Transfer Agreement / UK Addendum to the EU Standard Contractual Clauses. You can ask us for details of the safeguard used for any transfer.

10. How long we keep personal data

We keep personal data only as long as we need it for the purpose it was collected, or as long as the law requires.

Data

Retention period

Trade account records, orders, invoices and payment history

6 years after the end of the financial year of the last transaction (HMRC and Limitation Act requirements)

Credit application and credit reference data

Duration of the account plus 6 years; declined applications 12 months

Warranty, returns and complaint files

6 years after the matter is closed

Marketing contact details and preferences

Until you opt out, or 2 years after your last contact with us if you are a prospect

Enquiries that do not lead to an account

12 months

Website analytics data

As set out in our cookie policy (section 13)

When the period ends we delete or anonymise the data securely.

11. How we keep personal data secure

We use appropriate technical and organisational measures to protect personal data against loss, misuse and unauthorised access. These include password-protected and access-controlled systems, encrypted connections to our website, regular backups, staff training, and contracts with the providers who process data for us.

No system is completely secure. If we discover a breach that is likely to put your rights at risk, we will tell you and the Information Commissioner's Office (ICO) as the law requires.

12. Your rights

Under UK GDPR you have the right to:

• Access the personal data we hold about you and receive a copy
• Rectification of data that is inaccurate or incomplete
• Erasure of your data where we no longer need it or have no lawful basis to keep it
• Restriction of processing while a dispute about accuracy or lawfulness is resolved
• Object to processing based on legitimate interests, including direct marketing, which we will always stop
• Data portability of data you gave us under a contract, in a machine-readable format
• Withdraw consent at any time where consent is the basis we rely on

These rights apply to individuals. A company cannot exercise them on its own behalf, but a director, partner or employee can exercise them for their own personal data.

To exercise a right, contact us using the details in section 15. We may ask you to confirm your identity. We will respond within one month, which we can extend by two months for complex requests. There is no fee unless a request is clearly unfounded or excessive.

Some rights are limited. For example, we cannot erase invoice records we must keep for HMRC, and we may keep a minimal record of an opt-out so we do not contact you again.

13. Website and cookies

Our website is hosted by IONOS. Strictly necessary cookies (for example to remember your cookie preferences) are set without consent. Analytics and third-party content are loaded only if you accept them through the cookie banner, and you can change your choice at any time using the "Configure" option in the banner.

Type

Purpose

Set by

Strictly necessary

Security, cookie preferences, contact form

RWTT Ltd / IONOS

Analytics

IONOS SiteAnalytics, which counts visits and pages viewed without identifying you

IONOS

Third-party content

Google Maps (our location) and a website translation service, which may set their own cookies when loaded

Google and the translation provider

Our site may link to other websites, including manufacturers and payment providers. Their privacy policies apply once you leave our site.

14. Changes to this policy

We review this policy at least once a year and update it when our processing changes. The current version is always on our website, with the date it was last updated at the top. If a change materially affects how we use your data, we will tell existing account holders by email.

15. How to contact us and how to complain

For any question about this policy or to exercise your rights, contact us:

• Email: sales@rwtt.co.uk (mark your message "Data protection")
• Post: Data Protection, RWTT Ltd, 70 Rainham Road, Rainham, RM13 7RL
• Phone: 0303 123 1113

We are not required to appoint a Data Protection Officer, but [insert name or role] is responsible for data protection at RWTT Ltd.

If you are unhappy with how we have handled your data, please tell us first so we can put it right. You also have the right to complain to the Information Commissioner's Office at ico.org.uk, by phone on 0303 123 1113.

Sources: Companies House record for RWTT Ltd · rwtt.co.uk