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Privacy policy

 

Privacy Policy

This Privacy Policy is issued by Solomon and Wu Ltd (company number 07333135), which trades as Low Carbon Industrial (LCI) and as Foresso. References to 'we', 'us', and 'LCI' in this Policy include both trading names.

1. About this Privacy Policy

This Privacy Policy explains how we collect, use, and share personal data. It applies to personal data we collect when you:

  • visit our websites at lowcarbonindustrial.com or foresso.co.uk

  • buy products, place an order, request a quote, or request samples

  • apply for or hold a credit account

  • contact us for customer service or support

  • subscribe to marketing communications or follow us on social media

2. The data we collect

Identification and contact data: name, billing and delivery address, email, phone number, company name and role where applicable.

Order and transaction data: products ordered, quotes, invoices, payment method, and payment details (processed securely by our payment providers).

Credit assessment data (Business Customers only): trade references, credit report data, bank details, director names.

Communications data: emails, messages, call records, sample requests, customer service interactions.

Technical and usage data: IP address, device and browser information, pages visited, actions taken, referral source, and similar data collected via cookies and similar technologies (see our Cookies Policy).

Marketing preferences: whether you have subscribed to or opted out of marketing communications.

We do not intentionally collect special category data (health, ethnicity, political opinions, etc.) or personal data of children under 18.

3. Where we get data from

Most personal data we hold is collected directly from you. We also receive data:

  • from credit reference agencies (where you apply for a credit account). We currently use Creditsafe

  • from trade reference contacts you nominate on a credit application

  • from business partners who refer you to us

  • from publicly available sources such as Companies House

  • automatically from your use of the Website (via cookies, see Cookies Policy)

4. How we use data and our lawful basis

We use personal data for the purposes set out in the table below. Our lawful basis under the UK General Data Protection Regulation (UK GDPR) is shown alongside each purpose.

Purpose

Lawful basis

Processing your order, taking payment, arranging delivery, providing warranty and after-sales support

Contract (UK GDPR Art 6(1)(b))

Managing your credit account, conducting credit checks on the applicant company, reporting to credit reference agencies

Legitimate interest (Art 6(1)(f)): assessing creditworthiness and preventing bad debt

Conducting personal credit checks on a director or personal guarantor, where relevant to the credit application

Consent given on the Credit Application Form (Art 6(1)(a)) and/or legitimate interest (Art 6(1)(f)) with a balancing test

Providing customer service and answering queries

Legitimate interest (Art 6(1)(f)): customer support

Complying with legal obligations (tax records, VAT, AML, statutory returns)

Legal obligation (Art 6(1)(c))

Marketing by email to existing customers about similar products

Legitimate interest (Art 6(1)(f)) for the underlying processing, combined with the soft opt-in under regulation 22(3) of the Privacy and Electronic Communications Regulations 2003

Marketing by email to prospective customers

Consent (Art 6(1)(a))

Website analytics: understanding how the Website is used to improve it (Google Analytics, Shopify built-in analytics)

Consent (Art 6(1)(a)) via the cookie banner

Advertising and conversion measurement (Google Ads, via the Shopify Google and YouTube sales channel)

Consent (Art 6(1)(a)) via the cookie banner

Personalising marketing emails based on your browsing on the Website (Klaviyo onsite tracking)

Consent (Art 6(1)(a)) via the cookie banner

Fraud prevention

Legitimate interest (Art 6(1)(f))


5. Who we share data with

We share personal data only as necessary, and with the following categories of recipient.

Service providers (our data processors):

  • E-commerce platform and payments: Shopify (including Shopify Payments): shopify.com/legal/privacy

  • MRP, production, and customer relationship management: MRPeasy

  • Accounting: Xero: xero.com/uk/about/legal/privacy

  • Credit reference agency: Creditsafe

  • Email, file storage, and workplace tools: Google Workspace

  • Email marketing and onsite browse-behaviour tracking for email personalisation: Klaviyo

  • Website analytics, advertising, and conversion measurement: Google (Analytics, Ads), via the Shopify Google and YouTube sales channel

  • Social commerce: Meta (Facebook and Instagram), via the Shopify Facebook and Instagram sales channel for product catalogue sync. No advertising pixel is currently deployed on the Website

  • Cookie consent management: Avada Boost Sales (cookie banner)

  • Couriers and delivery partners: Kuehne and Nagel, InXpress, DPD, DHL

  • Automation between systems: Zapier

A full list of current service providers, including contact details for each, is available on request.

Credit reference agencies, where you apply for or hold a credit account.

Delivery partners, to arrange delivery and, where necessary, collection.

Professional advisers (auditors, lawyers, insurers) where required.

Regulators and law enforcement, where required by law or to respond to a lawful request.

Potential buyers of the business or its assets, under confidentiality, in the context of a corporate transaction.

We do not sell your personal data.

6. International transfers

Some of our service providers are based outside the UK, including in the European Economic Area and the United States. Where personal data is transferred outside the UK, we ensure appropriate safeguards are in place, including:

  • adequacy decisions by the UK government where applicable

  • the International Data Transfer Agreement or the International Data Transfer Addendum (IDTA) to the EU standard contractual clauses

  • the UK Extension to the EU-US Data Privacy Framework, where applicable

A list of the specific safeguards applicable to each processor is available on request.

7. How long we keep data

We keep personal data only for as long as necessary for the purposes for which it was collected, or as required by law. Typical retention periods are set out in the table below.

Data category

Typical retention period

Order and transaction records

6 years from the end of the accounting year (tax and VAT requirements)

Warranty-related records (proof of supply, delivery, TDS version applicable)

The warranty period plus 6 years (up to 21 years)

Credit application and credit account records

6 years from closure of the account

Marketing contact data: existing customers

Until you unsubscribe, or after 3 years of inactivity

Marketing contact data: prospects

Until you unsubscribe, or after 2 years of inactivity

Website analytics data (Google Analytics 4, Shopify built-in analytics)

Up to 26 months from collection (Google Analytics 4 default retention)

Klaviyo browse-behaviour data linked to a profile

While the profile is active. Profiles inactive for 36 months are deleted. Earlier deletion available on request.

Cookie data

As set out in the Cookies Policy

Customer service correspondence

6 years

Sample requests where no purchase follows

2 years


After these periods we delete or anonymise the data, unless we are legally required or entitled to retain it for longer (for example for litigation or regulatory reasons).

8. Your rights

Under the UK GDPR you have the following rights:

  • Access the personal data we hold about you

  • Rectify inaccurate data

  • Erase data (the right to be forgotten) in certain circumstances

  • Restrict processing in certain circumstances

  • Object to processing based on legitimate interest, including for direct marketing

  • Data portability: receive your data in a structured format and transfer it to another controller

  • Withdraw consent at any time where processing is based on consent. This does not affect processing carried out before withdrawal.

  • Not be subject to decisions based solely on automated processing that have legal or significant effects. We do not make fully automated decisions of this kind. Some automated fraud-prevention checks are carried out by Shopify (for example temporary deny-lists of IP addresses and cards associated with failed transactions); these do not have legal or significant effects.

To exercise any of these rights, contact us at info@lowcarbonindustrial.com. We will respond within one month.

9. Marketing

We may send you marketing emails about products similar to those you have bought, on the basis of legitimate interest combined with the soft opt-in under regulation 22(3) of the Privacy and Electronic Communications Regulations 2003, unless you opt out. You were given the right to opt out when your details were collected and in every marketing email.

For prospective customers and for non-email marketing channels, we only send marketing where you have given consent.

10. Cookies

See our separate Cookies Policy.

11. Data security

We take appropriate technical and organisational measures to protect personal data against unauthorised access, loss, or disclosure. Payment card data is processed by regulated payment providers (such as Shopify Payments and Stripe) and is not stored on our systems beyond what is necessary for accounting.

12. Children

Our websites are not intended for children under 18 and we do not knowingly collect data from children. If you believe a child has provided us with data, please contact us to request deletion.

13. Data Protection Officer and contact

We are not required to appoint a Data Protection Officer under Article 37 of the UK GDPR. Our named contact for data protection enquiries is the Data Protection Lead at info@lowcarbonindustrial.com.

14. Complaints

If you have a concern, please contact us at info@lowcarbonindustrial.com and we will aim to respond within 30 days.

You also have the right to complain to the Information Commissioner's Office (ICO), the UK's data protection regulator:

  • Online: ico.org.uk/make-a-complaint

  • Phone: 0303 123 1113

  • Post: Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF

If you are resident in the European Economic Area, you may also have the right to lodge a complaint with your local supervisory authority.

15. Changes to this Privacy Policy

We may update this Privacy Policy from time to time. The current version is always available on the Website. Where changes are material, we will notify you by email or a prominent notice on the Website.

16. Contact

Questions about this Privacy Policy or how we handle personal data:

Solomon and Wu Ltd trading as Low Carbon Industrial

Unit Q1, Hawthorns Industrial Estate, Middlemore Road, Birmingham B21 0BH

Email: info@lowcarbonindustrial.com

Phone: 0121 272 5537

Last updated: 28/04/2026

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