Storefront Privacy Notice (Customers)

Last updated: March 2026

This notice explains how your personal information is handled when you use the Tern Trade-in Service (the "Service") on a retailer's website.

Who is responsible for your data?

The retailer whose website you are using (the "Merchant") is the data controller for your personal information. This means the Merchant is legally responsible for how your data is collected, used, and protected in connection with your trade-in.

Tern Circular Ltd operates the Service on behalf of the Merchant as a data processor. We act only on the Merchant's instructions and do not use your personal data for our own purposes beyond what is necessary to deliver the Service.

What data is collected and when?

Personal information is accessed and stored at different stages:

• When you visit the trade-in Storefront: We may look up your order history held by the Merchant to identify products that are eligible for trade-in and to present them to you. At this stage, your personally identifiable information (such as your name or address) is not stored by Tern.

• Only if you start a trade-in: If you actively begin a trade-in submission, we will access and store the personal information necessary to process it — such as your name, email address, phone number, postal address, and relevant order details.

We also collect standard technical data (such as IP address and browser type) in server logs for security purposes. These logs are retained for 14 days.

How is your data used?

Your personal data is used solely to provide the trade-in Service — including processing your submission, arranging collection of your items, issuing your discount code, and communicating with you about your trade-in.

Who else can see your data?

To operate the Service, Tern Circular Ltd works with a number of third-party service providers, including providers of cloud hosting, email delivery, shipping and logistics, and payment processing. A full list is available on our Third Party Subprocessors page.

Your data may be transferred to and processed in the United States, subject to appropriate data transfer safeguards.

How long is your data kept?

Trade-in records are retained for up to 7 years from the date of your submission to support merchant reporting, dispute resolution, and regulatory compliance.

If you request deletion, Tern Circular Ltd will remove direct identifiers (such as your name, email address, and postal address) from the trade-in record unless retention is required by law or needed to establish, exercise, or defend legal claims. A de-identified record may be retained for the remainder of the retention period.

If the Merchant stops using the Service or uninstalls the App, Tern Circular Ltd will remove direct identifiers and retain only de-identified trade-in records for the remainder of the retention period.

Your rights

Because the Merchant is the data controller, your primary point of contact for exercising your data rights (such as access, correction, deletion, or objection) is the Merchant, via their own privacy policy which is accessible from their website footer.

The Merchant's privacy policy also explains the lawful basis they rely on for processing your personal data in connection with the trade-in service and provides the Merchant's contact details.

If you have a query specifically about how Tern Circular Ltd has processed your data as a service provider, you may contact us directly at [email protected].

If you are a UK or EU resident and are not satisfied with how your request is handled, you have the right to complain to a supervisory authority — in the UK, this is the Information Commissioner's Office at ico.org.uk.

Further information

For full details of how the Merchant uses your data, please refer to the Merchant's privacy policy on their website.

For full details of Tern Circular Ltd's data processing practices and obligations as a processor, please refer to our Merchant Privacy Policy and Data Processing Agreement.

These terms are governed alongside the Tern Trade-in Terms and Conditions, which apply to your use of the Service.