Privacy Policy

This Privacy Policy explains how ShutterXchange collects, uses and shares your personal information, and how we keep it safe and secure.

Version 2026-10-29-referral-session.1 Effective from: Last updated:

Your privacy matters

We handle your personal information with care, transparency and respect.

You have rights

You have rights over your personal information, including rights to access and correct it and, in certain circumstances, request its deletion.

Secure by design

We use appropriate security measures to protect your information.

Handled responsibly

We limit handling to the purposes described in this policy and work with providers where needed to deliver our services.

1. Who we are

ShutterXchange is the data controller for the personal data described in this policy. We sell, trade, and consign camera equipment. Contact us about privacy at support@shutterxchange.com.

2. Information we collect

  • Account and contact details: name, email, phone number, password credentials, account roles, and communication preferences.
  • Address and transaction details: billing and shipping addresses, items purchased, sold, traded, or consigned, valuations, payouts, returns, and correspondence.
  • Payment details: Stripe processes card information. We receive transaction status and references but do not store full card numbers.
  • Technical and security data: session identifiers, IP address, user agent, authentication activity, security logs, and minimised CSP violation reports.
  • Optional advertising measurement: with separate consent, ad-click identifiers, browser and device information (including IP address and user agent), page information, and purchase order reference, value and currency shared with Google Ads. Our purchase event does not include your name, email address, postal address or card details.
  • Optional analytics: with consent, redacted committed search terms and selections, product interactions, and sell-quote IP-derived country and region. Google Analytics 4 measures visits, acquisition sources, browser/device and approximate location information, browser/session identifiers, product and basket interactions, checkout steps, and completed purchases and refunds. Ecommerce measurements may include product identifiers and names, quantities, order reference, values, discounts, tax, delivery charges and currency. Lead measurements record completion and journey information, not the contents of contact or quote forms. We do not send names, email addresses, phone numbers, postal addresses, account credentials or payment-card details in these analytics events.
  • Consent evidence: choices, timestamps, policy and notice versions, a decision reference, and a keyed session pseudonym. We do not store IP address or user agent solely to prove consent.
  • Newsletter preferences: email address, subscription status, signup source, consent and confirmation timestamps, and the notice and policy versions presented.
  • Privacy-rights records: request type, identity-verification state, decisions, deadlines, and an audit history.

3. How and why we use information

  • To provide accounts, carts, checkout, orders, trade-ins, consignments, payouts, shipping, returns, and support, generally to perform a contract or take requested pre-contract steps.
  • To meet tax, accounting, consumer-law, and other legal obligations.
  • To secure the service, prevent fraud, diagnose faults, and administer the business where necessary or in our legitimate interests.
  • To remember requested interface and session functionality.
  • With analytics consent, to understand acquisition, searches, products, baskets, checkout, purchases, refunds and quote journeys so we can improve the service. Where consented transaction measurements are delivered from our servers, the same choice and data-minimisation rules apply; server-side delivery is not a way to bypass a refusal.
  • With separate advertising measurement consent, to measure which Google advertisements lead to purchases. Personalised advertising remains disabled in our Google tag configuration.
  • With separate marketing consent, to send requested deals, product updates, and photography gear news. A confirmation step is required before subscription.
  • To record and enforce privacy choices, handle privacy-rights requests, and demonstrate compliance.

Cookie consent does not constitute consent to receive marketing email. Newsletter and other direct-marketing choices are managed separately.

4. Sharing and international transfers

We share only what is necessary with providers supporting the relevant service, including Stripe, eBay, shipping and logistics providers, hosting, email, workflow, security and support providers, and declared analytics providers when permitted by your choice. With analytics consent we share the described analytics measurements with Google Analytics 4; with separate advertising measurement consent we share advertising measurements with Google Ads. We do not enable Google signals, user-provided contact-data collection or personalised advertising for this implementation. See Google's Privacy Policy and how Google uses information from partner sites.

Some providers may process data outside the UK or EEA. Where required, we use an adequacy decision, approved contractual safeguards, or another lawful transfer mechanism. We do not sell personal data.

5. Retention

  • Google Analytics event-level retention is configured to 2 months and user-data retention to 14 months. New user activity can restart the user-data retention period. These settings do not govern most aggregated standard reports, which may remain available longer. Analytics cookies can last up to 2 years and may have their expiry refreshed by activity; cookie lifetime is separate from report retention.
  • Google Ads first-party measurement cookies normally last up to 90 days. Google handles data it receives under its own published policies; cookie expiry does not mean all measurement records have been deleted.
  • Committed-search analytics is retained for up to 90 days.
  • Optional sell-quote analytics is retained for up to 60 days.
  • Unconfirmed newsletter requests are retained for up to 30 days.
  • Consent evidence, completed privacy-rights cases, and privacy audit records are retained for up to six years unless a legal hold applies.
  • Temporary privacy export files expire after seven days.
  • CSP violation reports are retained for up to 30 days.
  • Transaction and accounting records are retained for applicable statutory periods.

Information may be deleted earlier when no longer needed, or retained longer where required by law or for a live legal claim. Backups age out under the approved backup schedule; completed erasure decisions must be reapplied after a restoration.

6. Your rights

Depending on the processing and applicable law, you may have rights to access, correction, erasure, restriction, objection, portability, and withdrawal of consent. Withdrawal does not make earlier lawful processing unlawful. Contact support@shutterxchange.com to exercise a right. We verify identity before disclosing or erasing data.

Account closure is reversible and is not the same as erasure. For a verified erasure request, we delete optional analytics, remove unnecessary account data, and detach identity from minimal consent evidence retained for accountability. Records required for tax, legal claims, fraud prevention, or transaction integrity may be retained with access restricted.

You may complain to the UK Information Commissioner's Office. If EEA law applies, you may also contact your local supervisory authority.

7. Phone calls to our AI assistant

When you call 0114 319 3190, our published phone number, you speak to "Steve", our AI phone assistant. He can answer questions about our equipment, stock, prices and policies. If you ask, he can also email you a quote, text you a link to an item on our website, set up an email alert for when an item comes into stock, or take your details so our team can contact you. He can also take the details of equipment you want to sell or trade in, check the status of an order, help with your account after you sign in through a secure link, and pass cancellations, returns, faults, delivery problems, order changes, complaints and requests about your personal data to our team. He cannot take payments.

What we collect

  • A written transcript of the call, meaning what you and the assistant said. We do not keep an audio recording.
  • The time and length of the call.
  • Anything you choose to give us, such as your email address when you ask for a quote or a stock alert, or your mobile number when you ask us to text you a link. If you ask us to contact you, we also collect your name, phone number, what it's about and when suits you.
  • If you want to sell or trade in equipment: what each item is, its condition, whether it works and what's included, whether you want to sell or trade in, your name, your email address and, if you give it, your phone number. We file this as a quote request, as if you had used our website. We email you a confirmation, and our team reviews your request and emails you a quote. Steve never gives a value on the call.
  • If you ask about an order: the order number and the postcode on the order, or the postcode together with the number you are calling from (see below). We use them only to look up the order. Steve can tell you its stage, the dates, the courier, the items and any return status. He never reads out your address or payment details. If you ask for the tracking link, we email it to the email address on the order, never to a different address.
  • If you ask for help with your account: the email address or mobile number you give, or the mobile you are calling from. We use it only to ask our system to send a secure sign-in link to the email address or mobile number already on your account. Steve says the same thing whether or not the details match an account, so the call never reveals whether you have one. The link expires after five minutes. If you open it and approve, Steve can read your orders, tracking and returns, including the details of a return, for up to 15 minutes during that call. If you ask, and say yes to each one, he can also email a copy of an order confirmation or invoice to the email address you sign in with, and switch our marketing emails off (or email you a link to confirm switching them on). He cannot change your address, email address, password, payment or payout details, and he never reads out addresses, payment details or contact details from your account.
  • If you ask us to cancel an order, or raise a return, fault, delivery problem, order change, complaint or a request about your personal data: we record the request in our customer service system with your name, the phone number you give, the type of request, the order number if you give one, and when suits you for a call back if you tell us. For a cancellation, we also record your email address if you give one, and email you an acknowledgement. Steve gives you a reference, and our team gets a copy by email. Apart from when suits you for a call back, we do not record your own words in this request.
  • If you tell us that you want to cancel an order or make a request about your personal data, we make sure our team hears about it, even if the call ends before we have taken your details: we email our team a note of it with the number you are calling from as shown by caller ID (or "number withheld"), so they can act on it. Your number is never given to the AI.
  • A short record of what happened in each part of the call, for example "quote sent" or "callback taken". It holds no words, names, numbers, email addresses or items.
  • The number you are calling from, unless you withhold it. If you ask about your account or an order, we may use it to text a secure sign-in link to the mobile number on your account (only if it matches that number), or, together with the postcode you give us, to find your recent orders. We never treat it as proof of who you are on its own, and it is not stored with the transcript.
  • To keep the line available, our phone system allows up to 30 calls a day from each number. To count them, it turns the number you are calling from into a scrambled code on our server straight away, and keeps only that code and a count. The number itself is not stored for this and is never given to the AI. If you withhold your number, your call counts towards one shared allowance of 20 calls a day for all callers who withhold their number.
  • If you start to read out card details, Steve stops you and never repeats the digits. We never take payments by phone.
  • Phone numbers are removed from the stored transcript. So are order numbers, postcodes, spelled-out email addresses and card-like numbers.

Why we use it

  • To answer your enquiry and, if you ask, to send you a quote, take the details of equipment you want to sell or trade in, or contact you. Our lawful basis is taking steps at your request before a possible purchase or sale, and our legitimate interest in answering enquiries.
  • To check an order, help with your account (including sending copies and changing your marketing email choice), or deal with a return, fault, delivery problem or order change. Our lawful basis is performing our contract with you.
  • To record cancellations, requests about your personal data and complaints, to make sure our team receives them, and to show later that we dealt with them. Our lawful basis is meeting our legal obligations.
  • To limit how many calls one number can make each day, so the line stays available and is not misused. Our lawful basis is legitimate interests.
  • To check and improve the service, for example by reviewing questions the assistant could not answer. Our lawful basis is legitimate interests.

Who sees it at ShutterXchange

  • Requests for us to contact you, support requests, selling and trade-in requests, and notes of cancellations and requests about your personal data go to our shared customer service inbox, enquiries@shutterxchange.com. Only our customer service team reads it.

Who processes it for us

  • Reception247 runs the phone service, stores transcripts and passes contact requests and notes to our team. Its servers are hosted by DigitalOcean in New York, United States.
  • OpenAI provides the voice model, and the model that writes answers about our products.
  • DeepInfra provides the model that looks up our stock and website information, and a backup for product answers. If DeepInfra is unavailable, Cerebras provides a backup model for the same jobs.
  • Localphone carries the call and relays our emails: notifications to our team, and the emails we send you, such as quotes, confirmations, tracking links and sign-in links.
  • aql (aql Wholesale Ltd, Leeds, UK) sends the text message when you ask us to text you a link, or a secure sign-in link to your account. aql receives only your mobile number and the text itself, which is the item's name and its link on our website, or the sign-in link. The text is sent once and is not used for marketing.
  • Texts to mobile numbers outside the UK are sent by another SMS provider, which receives only the mobile number and the text itself.
  • We have data processing agreements in place with each of these providers, or rely on their published data protection commitments (DeepInfra keeps no inputs or outputs and does not use them for training).
  • Some of them process data in the United States. Where they do, the transfer is protected by the UK International Data Transfer Addendum to the EU Standard Contractual Clauses. Where a provider processes data in another country outside the UK, we use a lawful transfer mechanism as described in section 4.

How long we keep it

  • Call transcripts are deleted after 90 days. We do not keep audio recordings.
  • Records of what happened in each part of the call are deleted after 90 days.
  • Requests for us to contact you, support requests, and notes of cancellations and requests about your personal data, together with the emails about them, are kept for six years, so we can show we dealt with them and deal with any claim. Requests about your personal data are also kept as completed privacy-rights cases (section 5).
  • Order checks create no separate record. Order records are kept as described in section 5.
  • The scrambled codes used for the daily call limit are deleted within three days.
  • Reception247's monthly billing statements to us list the time and length of each call, but no phone numbers. They are kept for six years.
  • Selling and trade-in requests, quote emails and related records are kept as described in the rest of this notice.

Your choices

  • If you would rather not speak to an AI assistant, you can email us at enquiries@shutterxchange.com.
  • Please don't give card or bank details, passwords or PINs on the call. We never take payments by phone.
  • You have the usual rights to access, correct or delete your data, and to object. See section 6, "Your rights", above.

8. Chatting with our AI assistant on our website

The chat window on our website is answered by "Steve", our AI assistant. Anyone can use it, whether or not they are logged in. He can answer questions about our equipment, stock, prices, compatibility and policies, and give you links to the right pages on our website, for example a product, our cancellation form or our contact page. He cannot take orders or payments, change your account, or give a value for equipment you want to sell.

What we collect

  • What you type in the chat and Steve's replies, with the time of each message.
  • If you are logged in, which account the chat belongs to.
  • The page of our website you are on when you send a message, so Steve knows which product you're looking at.
  • Anything you choose to type, such as an order number or an email address. Please don't type card or bank details, passwords or PINs: if you do, we don't store that message, and Steve asks you not to share them.
  • If you tell us in the chat that you want to cancel an order, or make a request about your personal data, we email our team a note of it with the time, your account if you are logged in, and what you wrote, so they can act on it. Steve also asks you to complete our cancellation form or contact our team, so we have everything we need.
  • A short record of each reply, such as whether it was answered from our stock. It holds no words.
  • If you are not logged in, your IP address, which we use only to limit how many messages one visitor can send in a day. We hold it only in a scrambled form, for 24 hours.

Why we use it

  • To answer your question. Our lawful basis is taking steps at your request before a possible purchase, and our legitimate interest in answering enquiries.
  • To pass on cancellations and requests about your personal data, and to show later that we dealt with them. Our lawful basis is meeting our legal obligations.
  • To limit how many messages one visitor can send, so the chat stays available and is not misused. Our lawful basis is legitimate interests.
  • To check and improve the service, for example by reviewing questions Steve could not answer. Our lawful basis is legitimate interests.

Who processes it for us

  • We store chat transcripts on our own servers, hosted by DigitalOcean in London.
  • Reception247 runs the assistant that answers your messages. It keeps the conversation in memory only while the chat is open and does not store your messages. Its servers are hosted by DigitalOcean in New York, United States.
  • OpenAI provides the model that writes Steve's replies. DeepInfra provides the model that understands your question and looks up our stock and website information, and a backup for replies. If DeepInfra is unavailable, Cerebras provides a backup model for the same jobs.
  • We have data processing agreements in place with each of these providers, or rely on their published data protection commitments (DeepInfra keeps no inputs or outputs and does not use them for training).
  • Some of them process data in the United States. Where they do, the transfer is protected by the UK International Data Transfer Addendum to the EU Standard Contractual Clauses.

How long we keep it

  • Chat transcripts, and the short record of each reply, are deleted after 90 days. We keep daily totals, which do not identify anyone, for up to 13 months.
  • Notes of requests about your personal data are kept as completed privacy-rights cases (section 5). Notes of cancellations, and the emails about them, are kept for six years.
  • The scrambled form of your IP address is deleted after 24 hours.

Your browser

  • While you browse our website, your usual website session keeps your chat open from page to page, and the chat window remembers whether you left it open in your browser's session storage. This is cleared when you close the tab and is not used for tracking.

Your choices

  • You don't have to use the chat. You can email us at enquiries@shutterxchange.com or use our contact page.
  • You have the usual rights to access, correct or delete your data, and to object. See section 6, "Your rights", above. To find a chat, tell us roughly when it took place and, if you were logged in, your account email.

9. Cookies and similar technologies

Necessary technologies support security, accounts, carts, checkout, quote continuity, the website chat, and privacy choices. Analytics and advertising measurement are separate optional choices, disabled until you consent to each. The analytics and advertising integrations wait for the corresponding opt-in before collection. We pass the relevant choices to Google using Consent Mode and keep personalised advertising disabled. You can reject either without losing core store functionality and change your choices at any time through Cookie settings. See our Cookie Policy for the current approved inventory.

10. Automated decisions and changes

We do not use the optional analytics described here to make decisions producing legal or similarly significant effects about you.

Our phone system may decline a call from a number that has already called five times that day, or once callers who withhold their number have used their shared daily allowance. This is a simple limit, not an assessment of you, and you can still email us.

We publish controlled policy revisions with a version, effective date, content hash, author, approver, and change reason. Where a change materially affects consent purposes, providers, or categories, optional processing remains disabled until a new choice is made.

Referral partners and commission attribution

When you follow a recognised affiliate link, we retain the referring partner and optional campaign reference in your existing server-side shopping session for same-visit commission and seller-reward accounting. This does not depend on optional advertising consent and does not set a separate referral cookie. The referral expires after 30 minutes without customer shopping activity and no later than two hours after the referral. Background refreshes do not extend it. The latest eligible affiliate wins. When checkout creates an order, or you submit a selling quote, we save the affiliate and agreed commercial terms against that transaction; later payment and processing do not depend on your browser returning.

We record whether attribution came from the shopping session or a consented return-visit cookie. Same-visit records do not claim that advertising consent was given. Transaction and commission records follow the accounting retention provisions of this policy. Rejecting advertising cookies still prevents optional return-visit tracking and advertising measurement.

With your advertising permission, we use a first-party referral cookie to remember the partner whose link brought you to ShutterXchange for the partner’s attribution window (normally 30 days, up to 90 days). This optional choice helps us attribute purchases and submitted selling quotes and calculate referral commission. You can reject or withdraw it through Privacy choices; without permission we do not set this referral cookie or attribute new orders or selling quotes from it.

For an attributed selling quote, we retain the partner reference, referral time, consent decision reference and agreed GBP reward terms. They pass to its selling transaction. After a completed positive cash payout or store-credit issue, we use prior paid purchase and completed sell-to-us history matched to the known account/email to determine the new- or returning-customer reward. The private affiliate report shows transaction references, dates, status and fixed rewards; it does not show seller identity, equipment or seller payout amounts. These accounting records follow the retention and rights provisions elsewhere in this policy.

For an attributed order, we retain the partner reference, attribution time, consent decision reference, agreed commission rate and order amounts for internal commission accounting. Refunds reduce the commission due. These records do not subscribe you to marketing emails or enable personalised advertising. We do not send your name, email or delivery address to the referring partner through this attribution feature. Order accounting records remain subject to the retention and rights provisions elsewhere in this policy.

With both analytics and advertising permission, we also count referral visits in daily partner totals, at most once per browser session, partner and day. The aggregate totals contain no IP addresses or visitor identifiers. A short-lived pseudonymous marker on our server prevents repeated counts and expires at the end of each day. It contains a keyed hash of the browser session and partner rather than the session identifier itself. Withdrawing either permission stops further measurement; visits that decline either optional choice are not counted.

Referring partners can access a private report showing only their attributed order references, dates, statuses, currency, discounted merchandise amounts, commission rates and commission balances, together with daily aggregate consented visit counts. The report does not show customer names, email addresses, delivery addresses or purchased product details. Access is controlled by a separate revocable partner token.

Affiliate programme applications

We use an applicant’s name or business name, contact name, email, public website or profile and promotion description to review their application, contact them about it and administer an approved affiliate relationship. Applications are reviewed by authorised staff and are not published or shared with other affiliates. Applying does not subscribe the applicant to marketing emails or record acceptance of an affiliate agreement. The application includes the version and hash of the information-use notice shown at submission. These records remain subject to the retention and rights provisions elsewhere in this policy.

For approved affiliates, we retain the name of the authorised signatory, acceptance time, exact agreement text, commercial terms and their version/hash as evidence of the relationship. Payment schedules, approval and transfer-confirmation records support our accounting and dispute handling. Bank details are arranged separately with staff and are not collected through the affiliate portal. Agreement and payment evidence may remain retained where needed for accounting or legal claims, subject to the rights and retention provisions elsewhere in this policy.

Still need help?

Our support team is here to help with questions about your privacy or anything else.

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