PRIVACY POLICY

Kelp Technologies Limited trading as TRUSS

Last Updated: November 2025

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1. INTRODUCTION

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This Privacy Policy explains how Kelp Technologies Limited, trading as TRUSS ("we", "us", or "our"), collects, uses, discloses, and protects your personal information when you use our resale pricing intelligence platform (the "Service").

We are committed to protecting your privacy and handling your personal data in accordance with the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018, and other applicable UK data protection laws.

By using our Service, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with our practices, please do not use our Service.

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2. DATA CONTROLLER

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Kelp Technologies Limited is the data controller responsible for your personal data. Our contact details are:

Kelp Technologies Limited

T/A TRUSS

Market, 133a Rye Lane

London, England, SE15 4BQ

Company Registration Number: 12723561

Email: info@truss.fashion

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3. INFORMATION WE COLLECT

3.1 Information You Provide to Us

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When you create an account, subscribe to our Service, or contact us, we may collect:

Name and contact details (email address, mailing address, phone number)
Account credentials (username and password)
Payment and billing information (processed securely through our payment partners)
Business information (company name, role, if applicable)
Communications you send to us (support enquiries, feedback)

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3.2 Images You Upload

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When you use our image search functionality, we collect and process the images you upload. We retain these images only as necessary to provide our Service. You retain all ownership rights to images you upload.

Important: We automatically filter and omit images containing identifiable people to protect privacy.

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3.3 Information Collected Automatically

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When you use our Service, we automatically collect:

Usage data (features accessed, searches performed, valuations requested)
Device information (browser type, operating system, device identifiers)
Log data (IP address, access times, pages viewed, referring URLs)
Cookies and similar tracking technologies (see Section 8)

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3.4 Third-Party Data

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Our Service aggregates pricing and product data from various third-party sources, including online marketplaces, auction sites, and retail platforms. This data is used solely to provide pricing intelligence and does not include personal information about you.

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4. HOW WE USE YOUR INFORMATION

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We use your personal information for the following purposes:

To provide and maintain the Service, including processing your image searches and delivering pricing recommendations
To manage your account and subscription
To process payments and billing
To communicate with you about your account, including service updates, security alerts, and support messages
To respond to your enquiries and provide customer support
To improve and develop our Service through analysis of usage patterns
To detect, prevent, and address technical issues, fraud, or security concerns
To comply with legal obligations
To enforce our Terms and Conditions

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5. LEGAL BASES FOR PROCESSING

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Under UK GDPR, we process your personal data based on the following legal grounds:

Contract Performance: Processing necessary to provide the Service you have subscribed to
Legitimate Interests: Processing for our legitimate business interests, such as improving our Service, preventing fraud, and ensuring security
Legal Compliance: Processing necessary to comply with legal obligations
Consent: Where you have given explicit consent for specific processing activities

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6. DATA SHARING AND DISCLOSURE

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6.1 No Sale of Personal Data

We do not sell, rent, or trade your personal information to third parties for their marketing purposes.

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6.2 Service Providers

We may share your information with trusted service providers who assist us in operating the Service, including:

Payment processors for handling transactions
Cloud hosting and infrastructure providers
Analytics providers to help us understand Service usage
Customer support tools

These providers are bound by strict confidentiality obligations and may only process your data as instructed by us and for the purposes outlined in this Privacy Policy.

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6.3 Legal Requirements

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We may disclose your information if required to do so by law or in response to valid requests by public authorities, including to:

Comply with legal processes or government requests
Enforce our Terms and Conditions
Protect our rights, privacy, safety, or property
Protect against legal liability

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6.4 Business Transfers

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In the event of a merger, acquisition, reorganisation, or sale of assets, your personal information may be transferred as part of that transaction. We will notify you of any such change and any choices you may have regarding your information.

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7. DATA RETENTION

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We retain your personal information only for as long as necessary to fulfil the purposes for which it was collected, including to satisfy legal, accounting, or reporting requirements.

Account Information: Retained for the duration of your account and for a reasonable period thereafter for legal and operational purposes
Uploaded Images: Retained only as necessary to provide the Service and deleted in accordance with our retention schedules
Payment Records: Retained as required by tax and accounting laws
Usage Data: Retained in aggregated or anonymised form for analytics purposes

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8. COOKIES AND TRACKING TECHNOLOGIES

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We use cookies and similar tracking technologies to collect and store information about your interactions with our Service.

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8.1 Types of Cookies We Use

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Essential Cookies: Required for the Service to function properly, including authentication and security
Performance Cookies: Help us understand how visitors interact with our Service to improve user experience
Functional Cookies: Remember your preferences and settings

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8.2 Managing Cookies

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You can control and manage cookies through your browser settings. Please note that disabling certain cookies may affect the functionality of our Service.

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9. YOUR DATA PROTECTION RIGHTS

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Under UK data protection law, you have the following rights:

Right of Access: You have the right to request a copy of the personal data we hold about you
Right to Rectification: You have the right to request correction of inaccurate or incomplete personal data
Right to Erasure: You have the right to request deletion of your personal data in certain circumstances
Right to Restrict Processing: You have the right to request restriction of processing in certain circumstances
Right to Object: You have the right to object to processing based on legitimate interests or for direct marketing
Right to Data Portability: You have the right to receive your personal data in a structured, commonly used format
Right to Withdraw Consent: Where processing is based on consent, you may withdraw consent at any time

To exercise any of these rights, please contact us at info@truss.fashion. We will respond to your request within one month, as required by law.

If you are not satisfied with our response, you have the right to lodge a complaint with the Information Commissioner's Office (ICO), the UK's supervisory authority for data protection: www.ico.org.uk

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10. DATA SECURITY

We implement appropriate technical and organisational measures to protect your personal information against unauthorised access, alteration, disclosure, or destruction. These measures include:

Encryption of data in transit and at rest
Secure authentication and access controls
Regular security assessments and monitoring
Employee training on data protection practices

While we strive to protect your personal information, no method of transmission over the internet or electronic storage is completely secure. We cannot guarantee absolute security.

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11. INTERNATIONAL DATA TRANSFERS

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Your personal data may be transferred to and processed in countries outside the United Kingdom. When we transfer data internationally, we ensure appropriate safeguards are in place, such as:

Standard contractual clauses approved by the UK Information Commissioner
Transfers to countries with adequacy decisions
Other lawful transfer mechanisms under UK GDPR

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12. CHILDREN'S PRIVACY

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Our Service is not intended for individuals under the age of 16. We do not knowingly collect personal information from children under 16. If you are a parent or guardian and believe your child has provided us with personal information, please contact us immediately at info@truss.fashion. If we become aware that we have collected personal data from a child under 16, we will take steps to delete that information.

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13. CHANGES TO THIS PRIVACY POLICY

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We may update this Privacy Policy from time to time to reflect changes in our practices or for other operational, legal, or regulatory reasons. Material changes will be communicated via email or through a prominent notice on our Service at least 30 days before they take effect.

We encourage you to review this Privacy Policy periodically. Your continued use of the Service after any changes indicates your acceptance of the updated Privacy Policy.

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14. CONTACT US

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If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us at:

Kelp Technologies Limited

T/A TRUSS

Market, 133a Rye Lane

London, England, SE15 4BQ

Email: info@truss.fashion

BY USING OUR SERVICE, YOU ACKNOWLEDGE THAT YOU HAVE READ, UNDERSTOOD, AND AGREE TO THIS PRIVACY POLICY.