Legal
Privacy Policy
Last updated: April 2026. Applies under both UK GDPR and EU GDPR.
Section 1
Who We Are and How to Contact Us
ReCircle Tech operates as two related legal entities:
- ReCircle Tech GmbH — Plauenerstr. 163-165, Haus G, 13053 Berlin, Germany. HRB 262484 B, Amtsgericht Charlottenburg.
- ReCircle Tech Ltd — Unit 12, Ringmer Business Centre, Chamberlaines Lane, Ringmer, BN8 5NF, United Kingdom. Company Number: 16752790.
Each entity acts as data controller for data collected through its respective operations. For data protection queries: [email protected]
Section 2
What Personal Data We Collect and Why
Enquiries and contact forms
Name, company, email, phone, message content. Legal basis: legitimate interests (Art. 6(1)(f) GDPR) — to respond to your enquiry.
Service delivery
Contact details of authorised representatives as necessary to fulfil contractual obligations. Legal basis: performance of a contract (Art. 6(1)(b) GDPR).
Website usage data
Standard server log data (IP address, browser type, pages visited, access time) for security and performance monitoring. No third-party analytics or advertising trackers are currently in use. Legal basis: legitimate interests (Art. 6(1)(f) GDPR).
Marketing
Only where you have expressly consented or where an existing business relationship exists and the communication is relevant to services previously used. Legal basis: consent (Art. 6(1)(a)) or legitimate interests (Art. 6(1)(f) GDPR).
Section 3
How Long We Keep Your Data
- Enquiry and contact data
- Up to 2 years from last contact, unless a commercial relationship is established.
- Contract and service data
- 6 years from contract end (consistent with statutory limitation periods in Germany and the UK).
- Server log data
- Up to 90 days.
- On withdrawal of consent
- Deletion within 30 days unless another lawful basis exists.
Section 4
Who We Share Your Data With
We do not sell personal data. We may share with:
- Group companies (ReCircle Tech GmbH and ReCircle Tech Ltd) as necessary to deliver services
- IT infrastructure and hosting providers (processors under data processing agreements)
- Professional advisers under strict confidentiality obligations
- Competent authorities where required by law
Data transfers between Germany and the UK: both territories currently maintain adequate data protection standards for this purpose.
Section 5
Your Rights
Under UK GDPR and EU GDPR you have the right to: access, rectification, erasure, restriction of processing, data portability, objection to processing based on legitimate interests, and withdrawal of consent at any time.
To exercise any right: [email protected]. We will respond within one month.
Section 6
Supervisory Authorities
- Germany (Berlin)
- Berliner Beauftragte für Datenschutz und Informationsfreiheit — www.datenschutz-berlin.de
- United Kingdom
- Information Commissioner's Office (ICO) — ico.org.uk
Section 7
Cookies
This website currently uses only functional cookies necessary for the site to operate (such as language preference). These do not track you across websites and do not require consent under applicable law. We do not currently use analytics, advertising or third-party tracking cookies. If this changes, we will update this policy and implement a consent mechanism.
Section 8
Changes to This Policy
We may update this policy periodically. Material changes will be indicated by an updated date at the top of this page.
Questions: [email protected]