Privacy Policy

1. Who we are

This website is operated by Holborn Trading Limited (“Holborn Trading”, “we”, “us” or “our”), a company registered in England and Wales with its registered office at 4 Artillery Lane, London, E1 7LJ, United Kingdom. For the purposes of the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018, Holborn Trading Limited is the data controller for the personal data collected through this website.

If you have any questions about this policy or how we handle your personal data, you can contact us at holborn@holborntrading.com.

2. Personal data we collect

We collect personal data in the following ways:

• Information you give us: when you contact us through our website, by email or by phone, for example your name, company, email address, phone number and the content of your message.
• Information collected automatically: when you visit our site, our analytics tools may collect information about your device and usage, such as IP address (truncated), browser type, device type, pages viewed, referring URL, and approximate location. This data is collected only where you have given your consent via our cookie banner.

3. How we use your personal data

We use personal data for the following purposes:

• to respond to enquiries and provide the services you request;
• to operate, maintain and secure our website;
• to measure and improve the performance and content of our website using aggregated analytics;
• to comply with our legal, regulatory and tax obligations.

4. Legal bases for processing

• Consent— for setting non-essential cookies and similar technologies, including Google Analytics.
• Legitimate interests — to respond to your enquiries, protect our website from misuse and understand, on an aggregated basis, how our site is used.
• Legal obligation— where we are required to retain or disclose personal data to comply with applicable law.

5. Cookies and similar technologies

Cookies are small text files placed on your device when you visit a website. We use cookies and similar technologies (such as pixels and local storage) to operate the site and, with your consent, to measure how it is used.

When you first visit our site you will see a cookie banner. You can accept all cookies, reject all non-essential cookies, or choose which categories to allow. You can change or withdraw your consent at any time using the “Manage cookies” link in the footer, or by clearing cookies and site data in your browser.

We also use Google Search Console to monitor how our site appears in Google search. Search Console verification does not set cookies or collect personal data from visitors to this site; Google’s data comes from its own index of the web.

6. Google analytics tools and international transfers

Subject to your consent, we use the following tools provided by Google LLC and Google Ireland Limited:

• Google Analytics 4— aggregated statistics on site usage. IP addresses are truncated before being stored and Google Consent Mode v2 is used so that no analytics data is collected until you give consent.
• Google Tag(gtag.js) — loads and configures the analytics tags described above.
• Google Search Console— aggregated statistics on how our pages appear in Google search results.

These services may transfer personal data outside the UK/EEA, including to the United States. Where this happens, Google relies on the UK International Data Transfer Addendum and Standard Contractual Clauses to provide an appropriate level of protection. You can read more in Google’s Privacy Policy.

7. Sharing your personal data

We do not sell your personal data. We share it only with carefully selected service providers who process it on our behalf (for example our hosting, analytics and email providers), with our professional advisers, and where required by law or regulation.

8. How long we keep personal data

We keep personal data only for as long as necessary for the purposes set out above, to meet our legal and regulatory obligations, and to resolve disputes. Enquiry correspondence is typically kept for up to 24 months after our last interaction, unless a longer period is required.

9. Your rights

Under UK data protection law you have the right to:

• access the personal data we hold about you;
• ask us to correct inaccurate or incomplete data;
• ask us to erase your data in certain circumstances;
• restrict or object to our processing of your data;
• receive your data in a portable format;
• withdraw consent where we rely on it, at any time.

To exercise any of these rights, contact holborn@holborntrading.com. You also have the right to complain to the UK Information Commissioner’s Office (ICO) at ico.org.uk.

10. Changes to this policy

We may update this privacy policy from time to time. The “last updated” date at the top of this page shows when it was most recently revised. Where changes are material we will take reasonable steps to bring them to your attention.