Privacy Policy

1. Who we are

WatchTradeSale is a trade name owned by 309 LTD, a company registered in England and Wales (Company No. 17104057). References to "WatchTradeSale", "we", "us" or "our" in this policy refer to 309 LTD.

We operate a trade-only price-discovery platform at watchtradesale.com that connects professional watch dealers. We do not purchase, sell, take ownership of or physically hold watches.

2. Data we collect

Account data: name, email address, password (hashed), account number, and the date you accepted our Terms & Conditions.

Dealer verification data: legal company name, business email, telephone number, principal name, registered address, trading address, and any supporting documentation you submit during the KYC process.

Listing data: watch brand, model, reference, year, condition, description, asking price, and photographs.

Transaction data: bid amounts, accepted prices, trade status, QR scan events, inspection outcomes, and any notes recorded during the trade questionnaire.

Usage data: IP address, browser type, pages visited, and timestamps, collected automatically via server logs.

Communications: emails and messages you send to us, including support requests.

3. How we use your data

To operate the platform: creating and managing your account, running daily Price Discovery sessions, facilitating trades between dealers, and sending transactional emails and SMS alerts.

To verify your identity: conducting KYC and AML checks as required by applicable law and our own compliance obligations.

To improve the platform: analysing usage patterns to fix bugs and develop new features.

To comply with legal obligations: retaining records as required by UK law, responding to lawful requests from regulatory authorities.

To communicate with you: sending service notifications, security alerts, and (where you have consented) platform updates.

4. Legal basis for processing

Contract: processing necessary to perform the contract between you and WatchTradeSale (e.g. running your account, processing listings and trades).

Legal obligation: processing required to comply with applicable law (e.g. AML record-keeping).

Legitimate interests: processing for fraud prevention, platform security, and improving our services, where these interests are not overridden by your rights.

Consent: where we rely on consent (e.g. optional marketing communications), you may withdraw it at any time.

5. Who we share data with

Other dealers: your company name and listing details are visible to verified dealers on the platform. Your personal contact details are not shared without your consent.

Service providers: we use third-party services to operate the platform, including email delivery (transactional email), SMS (Twilio), and cloud hosting. These providers process data only on our instructions.

Regulatory authorities: we may disclose data to HMRC, the FCA, or law enforcement where required by law.

We do not sell your personal data to third parties.

6. How long we keep your data

Account data is retained for the duration of your membership and for 7 years after account closure, in line with UK AML record-keeping requirements.

Transaction records are retained for 7 years from the date of the transaction.

Listing data is retained for 3 years after a listing is closed or withdrawn.

When you delete your account, your personal data is anonymised within 30 days. Anonymised records (with no link back to you) may be retained indefinitely for audit and statistical purposes.

7. Your rights

Under UK GDPR you have the right to: access the personal data we hold about you; correct inaccurate data; request erasure (subject to legal retention obligations); restrict or object to processing; and data portability.

To exercise any of these rights, email us at support@watchtradesale.com. We will respond within 30 days.

You also have the right to lodge a complaint with the Information Commissioner's Office (ICO) at ico.org.uk.

8. Cookies

We use strictly necessary cookies to maintain your session and keep you logged in. We do not use advertising or tracking cookies.

A cookie consent banner is displayed on your first visit. You may withdraw consent at any time by clearing your browser cookies.

9. Security

We use industry-standard measures to protect your data, including TLS encryption in transit, hashed passwords, and access controls. No method of transmission over the internet is 100% secure; we cannot guarantee absolute security.

10. Changes to this policy

We may update this policy from time to time. We will notify you of material changes by email or by displaying a notice on the platform. The date at the top of this page shows when the policy was last updated.