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WasteTrade Platform
Privacy Notice and Data Use Clause
Version 1.1 — Effective July 2026 · Applicable to all Contracting Entities of the WasteTrade Group · Published at wastetrade.com/privacy-notice
This Privacy Notice and Data Use Clause forms part of the WasteTrade Platform Terms and Conditions v2.7 by incorporation under clause 16.7. It explains how the WasteTrade Group collects, uses, shares and protects personal data in connection with the WasteTrade Platform, and sets out the Data Use Clause governing commercial use of platform data. Capitalised terms not defined here have the meanings given in the Platform Terms and Conditions v2.7 (the “Terms”).
1. Who we are
The Platform is operated jointly across the WasteTrade Group. Each of the following entities is an independent Contracting Entity and acts as a controller of personal data in respect of the Transactions to which it is party:
| Contracting Entity | Identifiers | Registered office |
|---|---|---|
| Waste Trade Holdings Limited (trading as WasteTrade) | Company No. 13314586, England & Wales | Crown Legal, Dunston Dairy Farm, Dunston, Stafford, Staffordshire, ST18 9AB, United Kingdom |
| WasteTrade.com Romania S.R.L. | Trade Register J2025037071001 · CUI 51846722 · VAT RO 51846722 | Șoseaua Olteniței 181, 077160 Popești-Leordeni, Județul Ilfov, Romania |
| WasteTrade Ghana Holdings Limited | Company Registration No. ET000430425, Ghana | 33 Bolgatanga Close, Accra, Ghana |
Waste Trade Holdings Limited leads the Group privacy function. Where this notice says “WasteTrade”, “we” or “us”, it means the relevant Contracting Entity for the Transaction or interaction in question. Privacy contact for the whole Group: privacy@wastetrade.com.
2. Who and what this notice covers
The Platform is a business-to-business marketplace. Users warrant under clause 4.3 of the Terms that they act in the course of a trade, business, craft or profession and not as consumers. The personal data we process is therefore principally that of individuals acting for businesses: directors, beneficial owners, authorised representatives, account users, drivers and site contacts of Users, Hauliers and counterparties, together with visitors to our websites (wastetrade.com, thinkcarbon.org and successor domains). Personal data of WasteTrade personnel is covered by separate internal notices.
3. Personal data we collect
We collect the following six categories of data, which may include personal data:
| Category | What it includes |
|---|---|
| Registration, identity and KYC | Names, roles and contact details of representatives; company registration and beneficial-ownership information; copies of permits, licences, authorisations and registrations; sanctions and adverse-media screening data; banking details; tax registrations. Collected under clauses 3.7, 4.1 and 12.4 of the Terms. |
| Transactional and commercial | Listings, bids, orders, quotations, contracts, invoices, shipment and customs documentation, weighbridge and quality records, site and access information provided under clause 4.6. |
| Communications | Emails, Platform messages, WhatsApp and telephone communications with our team, call recordings and meeting transcripts made using our telephony and meeting tools, and complaint correspondence. |
| Technical and usage | IP address, device and browser information, log-in records, pages viewed, search and interaction data, and cookies and similar technologies (see our cookie notice on the website). |
| Documents and images | Photographs of materials, sites and loads; scanned certificates and transport documents; and personal data incidentally visible in them. |
| Marketing | Contact preferences, event and campaign interactions, and subscription status. |
4. How we use personal data and our legal bases
| Purpose | Examples | Legal basis |
|---|---|---|
| Operating the Platform and performing Transactions | Account registration, listing management, matching, order processing, logistics coordination, document control, payment processing | Performance of a contract; legitimate interests |
| Verification, compliance and financial crime prevention | Onboarding due diligence (clause 3.7), KYC/KYB, sanctions and AML screening (clause 12), origin and permit verification (clauses 7.8–7.10) | Legal obligation; legitimate interests |
| Regulatory reporting and disclosure | Disclosure to regulators, customs, environmental authorities, law enforcement, banks and insurers where conduct may breach Applicable Law (clause 7.13 of the Terms) | Legal obligation; legitimate interests |
| Platform improvement, market data and analytics | Aggregated trade statistics, indices, pricing analytics, service development under clause 16.2 of the Terms | Legitimate interests |
| AI and automated processing | Classification, search ranking, matching, lead scoring, fraud screening and document extraction, as described in section 5 and the AI Use Policy | Legitimate interests |
| Marketing | Sending relevant commercial communications; event invitations | Legitimate interests or consent, as applicable law requires |
| Establishing and defending legal claims | Debt recovery, dispute resolution, enforcement of the Terms | Legitimate interests |
5. AI and automated processing
The Platform uses automated and semi-automated systems, including artificial intelligence, for classification, categorisation, search ranking, lead scoring, matching, fraud and sanctions screening support, and document extraction. Consistent with clauses 5.2 and 7.16 of the Terms: these outputs are generated from User inputs and publicly available data; they are commercial tools only; they do not constitute certification, endorsement, verification or warranty by WasteTrade; and they are not a match against any Buyer’s regulatory authorisation. Decisions that materially affect a User — such as account suspension, refusal of registration or cancellation of a Transaction — involve human review and are not taken solely by automated means.
AI training opt-out. Under clause 16.3 of the Terms, an identifiable natural person whose personal data forms part of User Content may request, by written notice to privacy@wastetrade.com, that their personal data be excluded from the training, testing and validation of artificial intelligence and machine learning models. We will give effect to such a request within a reasonable period. The opt-out applies to personal data only, and not to commercial, transactional, technical, photographic, classification or specification data; it does not affect the other licensed purposes in clause 16.2; and it does not require the recall, deletion or re-training of models trained before the request.
Our approach to AI, including the systems in use and the principles governing them, is set out in the WasteTrade AI Use Policy, which should be read together with this notice.
6. Data Use Clause
In addition to personal-data processing, WasteTrade compiles, aggregates, anonymises and licenses commercial data derived from the Platform — including market data, price indices, trade statistics and material-flow analytics — under the licence granted in clause 16.2 of the Terms. Data used for these purposes is aggregated or anonymised so that it does not identify any natural person and, in the case of published or licensed outputs, does not identify any individual User’s confidential commercial terms. WasteTrade does not sell personal data.
7. Who we share personal data with
We share personal data, where necessary and proportionate, with: other Group Contracting Entities for the operation of the Platform and entity routing under clause 2.3a of the Terms; transaction counterparties, Hauliers, carriers, ports, customs agents and surveyors to perform Transactions; service providers acting as processors, in the categories of cloud hosting and infrastructure, CRM and sales systems, communications and telephony (including call-recording and meeting-transcription tools), email and marketing platforms, document management and e-signature, payment and banking services, screening and compliance databases, and AI service providers; professional advisers, insurers and auditors; and regulators, customs and environmental authorities, law enforcement and banks in accordance with clause 7.13 of the Terms and applicable law. Where a data-sharing or processing relationship requires a separate agreement, we put one in place before relevant personal data is shared.
8. International transfers
Personal data is stored principally in the United Kingdom and the European Union. Transfers between the UK, the EU and Ghana within the Group, and transfers to processors or counterparties outside the UK/EEA, are made under appropriate safeguards, including UK adequacy regulations, the UK International Data Transfer Agreement or Addendum, EU Standard Contractual Clauses, and supplementary measures where required. Transaction-related transfers to counterparties in a destination country are made as necessary for the performance of the contract.
9. Retention
We keep personal data for as long as necessary for the purposes above, then delete or anonymise it. Baseline periods are:
| Data | Retention |
|---|---|
| Transaction records, Documents, correspondence, evidence of recovery and weighbridge data | Minimum seven (7) years, aligned with clause 7.7 of the Terms and record-keeping law |
| KYC, verification, screening and beneficial-ownership records | Duration of the relationship plus seven (7) years |
| Call recordings and meeting transcripts | Twenty-four (24) months, unless transaction-related or required for a dispute or investigation |
| Technical logs | Twelve (12) months |
| Marketing data | Until opt-out, or twenty-four (24) months of inactivity |
10. Your rights
Subject to applicable law, individuals have the right to: access their personal data; rectify inaccurate data; erasure; restriction of processing; data portability; object to processing based on legitimate interests, including profiling; object to direct marketing at any time; withdraw consent where processing is based on consent; and not be subject to solely automated decisions with legal or similarly significant effect. To exercise any right, contact privacy@wastetrade.com. We respond within the timescales required by applicable law.
Complaints may be raised with us at privacy@wastetrade.com or info@wastetrade.com (acknowledged within ten (10) business days with a substantive response within thirty (30) business days, consistent with clause 18.4 of the Terms), and with the relevant supervisory authority: the Information Commissioner’s Office (UK); the Autoritatea Națională de Supraveghere a Prelucrării Datelor cu Caracter Personal (Romania); or the Data Protection Commission (Ghana).
11. Security
We apply appropriate technical and organisational measures to protect personal data, including access controls, encryption in transit, credential discipline, staff confidentiality obligations, and vendor due diligence. No system is completely secure; suspected incidents should be reported to privacy@wastetrade.com immediately.
12. Changes to this notice
We may update this notice from time to time. Material amendments affecting EU-established Users take effect no earlier than fifteen (15) days after notice, consistent with clause 18.4 of the Terms, save where a shorter period is required by law. The current version is always the version published at wastetrade.com/privacy-notice.
13. Language
This notice is issued in English. Any translation is provided for convenience only; in the event of inconsistency, the English version prevails, consistent with clause 19.4 of the Terms.
WasteTrade Privacy Notice and Data Use Clause — Version 1.1 — Effective July 2026
