1. Who We Are
TroCymru Ltd (Company No. 16844265) operates the TroCymru platform, a circular economy tracking service for the Welsh construction sector. Our registered address is in North Wales, UK. For data protection enquiries, contact us at [email protected].
2. Information We Collect
We collect the following types of information:
- Contact information — name, email address, phone number, and organisation name when you submit a pilot enquiry or contact form.
- Account information — email address and name when you create an account through our authentication provider.
- Platform usage data — material capture records, QR scan events, GPS coordinates, and photographs uploaded through the tracking platform.
- Technical data — IP address, browser type, device information, and cookies for site functionality and analytics.
3. How We Use Your Information
We use your information to:
- Provide and operate the TroCymru tracking platform
- Process pilot programme enquiries and respond to your requests
- Generate carbon calculations, ESG reports, and chain-of-custody evidence packs
- Improve our platform and develop new features
- Comply with legal obligations, including NRW waste carrier regulations
4. Legal Basis for Processing
We process your data under the following legal bases as defined by the UK GDPR:
- Contract performance — to deliver the services you have engaged us for.
- Legitimate interests — to improve our platform, respond to enquiries, and maintain security.
- Legal obligation — to comply with waste management regulations and environmental reporting requirements.
- Consent — where you have given explicit consent, such as for marketing communications.
5. Data Sharing
We do not sell your personal data. We may share data with:
- Your organisation — project data, reports, and evidence packs are shared with the contracting organisation as part of our service.
- Service providers — hosting, analytics, and authentication providers who process data on our behalf under data processing agreements.
- Regulatory bodies — where required by law, such as Natural Resources Wales for waste compliance reporting.
6. Data Retention
We retain your data for as long as necessary to fulfil the purposes described in this policy. Pilot enquiry data is retained for 24 months. Platform tracking data (material captures, chain-of-custody records) is retained for the duration of your service agreement plus 7 years for regulatory compliance. You may request deletion of your personal data at any time.
7. Your Rights
Under the UK GDPR, you have the right to:
- Access the personal data we hold about you
- Request correction of inaccurate data
- Request deletion of your data
- Object to or restrict processing of your data
- Data portability — receive your data in a structured, machine-readable format
- Withdraw consent at any time where processing is based on consent
To exercise any of these rights, contact us at [email protected]. We will respond within 30 days.
8. Cookies
We use essential cookies to maintain your session and authentication state. We also use analytics cookies to understand how visitors use our site. You can manage your cookie preferences through the cookie consent banner displayed when you first visit our site. For more detail, see our cookie consent settings.
9. Security
We implement appropriate technical and organisational measures to protect your data, including encrypted connections (HTTPS/TLS), secure authentication, and access controls. Platform data is hosted on secure cloud infrastructure with regular backups.
10. Changes to This Policy
We may update this policy from time to time. Material changes will be communicated through our platform or by email. The "Last updated" date at the top of this page indicates when the policy was last revised.
11. Contact
If you have questions about this privacy policy or wish to exercise your data rights, contact:
You also have the right to lodge a complaint with the Information Commissioner's Office (ICO) at ico.org.uk.