Privacy Policy
Last updated: June 2026
Related agreements. This is our general privacy policy. It works alongside our Terms of Use, and where we process personal data on a business customer's behalf as their processor, that processing is also governed by our Data Processing Agreement.
1. Introduction
Fashion Business Collective Ltd, trading as SureTariff, is committed to protecting your privacy and handling your data with transparency. This Privacy Policy explains how we collect, use, store, and protect your information when you use our platform and services.
SureTariff is a business-to-business (B2B) service exclusively. We do not provide services to individual consumers and do not knowingly collect personal data from individuals acting in a consumer capacity.
2. Data Controller
The data controller responsible for your personal data is:
Fashion Business Collective Ltd
124 City Road, London, EC1V 2NX
United Kingdom
We are governed by the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.
3. Information We Collect
3.1 Information You Provide
- Account registration details (name, email address, company name, job title)
- Business contact details and billing address for invoicing purposes
- Product data submitted for classification (descriptions, materials, images, and related information)
- Communication preferences
- Support correspondence and contact enquiries
- Password (stored in hashed form only)
3.2 Information Collected Automatically
- IP address and approximate location
- Browser type, device information, and operating system
- Pages visited and features used within the platform
- Access timestamps
- API usage metrics and request volumes
4. How We Use Your Information
We use your data solely for the following purposes:
- Service provision - processing product descriptions to generate tariff classifications, maintaining the platform, and delivering results
- Account management - maintaining your account, authentication, and billing
- Request processing and support - responding to enquiries, support requests, and service communications
- Service improvement - analysing usage patterns to improve accuracy, performance, and reliability
- Legal compliance - meeting our obligations under applicable law
- Fraud prevention - detecting and preventing misuse of the platform
We do not sell, rent, or share your personal data with third parties for marketing purposes. Product data submitted for classification is never used to train models for other customers or shared externally.
5. Legal Basis for Processing
Under UK GDPR, we rely on the following lawful bases:
- Contractual necessity - processing required to deliver the service you have subscribed to
- Legitimate interests - service improvement, security monitoring, and fraud prevention, where these interests are not overridden by your rights
- Explicit consent - where you have opted in to non-essential communications
- Legal obligation - where required by law or regulation
6. Data Sharing and Disclosure
We do not sell, rent, or trade your personal data to third parties.
6.1 Other Fashion Business Collective Brands
SureTariff is one of several brands operated by Fashion Business Collective Ltd. Your data may be shared, with your consent, with other brands within the same company to support integrated service delivery. These brands include:
- fashion.business
- id.codes
Any such sharing within the company is subject to the same data protection standards described in this policy.
6.2 Delivery Partners
We work with delivery partners - independent companies that represent one or more of our brands and provide implementation and client account management, often within a specific industry segment or region - under partner agreements that specifically require them to keep your data confidential. A delivery partner is only given access to the data relevant to the clients and enquiries they handle (for example, a partner responsible for one region would not have access to another region's client data), and only to the extent required to perform their services.
6.3 Service Providers
We may use a limited number of third-party service providers to assist in delivering our service (for example, payment processors, hosting providers, and email delivery services). These providers are contractually bound to process data only on our behalf and in accordance with this policy. We do not permit them to use your data for their own purposes.
6.4 Other Permitted Disclosures
We may disclose your information where required by:
- Legal or regulatory authorities in response to a lawful request
- The need to protect the rights, safety, or property of SureTariff, our users, or the public
- A business transaction such as a merger, acquisition, or sale of assets, in which case your data would remain subject to this policy
7. Data Storage and Security
All data is stored within the United Kingdom at a Tier IV, ISO 27001 certified data centre. We implement appropriate technical and organisational measures to protect your data, including:
- Encryption at rest and in transit (TLS 1.2+)
- Role-based access controls with least-privilege principles
- Regular security audits and penetration testing
- Automated backups with geographic redundancy within the UK
- Staff training on data protection and security protocols
8. International Data Transfers
We do not transfer personal data outside of the United Kingdom unless required for service delivery. Where an international transfer is necessary, we ensure appropriate safeguards are in place, including Standard Contractual Clauses approved by the Information Commissioner's Office.
9. Data Retention
We retain your data for as long as necessary to fulfil the purposes described in this policy. Specifically:
- Account and service data - retained for the duration of your account plus at least six years to meet legal and regulatory compliance requirements
- Product data - automatically deleted within 24 hours of classification acceptance, as described in our Terms of Use
- Billing records - retained for at least 7 years in accordance with HMRC requirements
- Contact enquiries - retained for at least 12 months after resolution
10. Cookies and Tracking
By default, SureTariff uses only essential cookies required for the service to function. These include:
- Session cookies - to maintain your authenticated session
- Preference cookies - to remember settings such as theme preference
- Security cookies - to support CSRF protection and fraud prevention
We do not use third-party tracking or advertising cookies. If we introduce optional analytics cookies in the future, we will obtain your explicit consent before setting them.
11. Your Rights Under UK GDPR
Under the UK General Data Protection Regulation, you have the following rights:
- Right of access - request a copy of the personal data we hold about you
- Right to rectification - request correction of inaccurate or incomplete data
- Right to erasure - request deletion of your data where there is no compelling reason for continued processing
- Right to restrict processing - request that we limit how we use your data in certain circumstances
- Right to data portability - receive your data in a structured, commonly used, machine-readable format
- Right to object - object to processing based on legitimate interests
- Right to withdraw consent - withdraw any previously given consent at any time
- Rights related to automated decision-making - request human review of any solely automated decisions that significantly affect you
To exercise any of these rights, please contact us using the details in Section 14. We will respond within one calendar month. If you are not satisfied with our response, you have the right to lodge a complaint with the Information Commissioner's Office (ICO) at ico.org.uk.
12. Consent Declaration
By using the SureTariff platform, you explicitly consent to:
- The collection and processing of your data as described in this policy
- Shared storage of your data across other brands operated by Fashion Business Collective Ltd where necessary for integrated service delivery
- Cross-platform service delivery where it supports the functionality you have subscribed to
You may withdraw your consent at any time by contacting us. Withdrawal of consent does not affect the lawfulness of processing carried out before withdrawal.
13. Changes to This Policy
We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. When we make material changes, we will notify you by email or through a prominent notice on the platform. We encourage you to review this page periodically.
14. Contact
If you have any questions, concerns, or requests relating to your privacy or this policy, please contact us:
SureTariff (Fashion Business Collective Ltd.)
124 City Road, London, EC1V 2NX
United Kingdom