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Privacy & Cookie Policy


The General Data Protection Regulation (GDPR) (EU) 2016/679 is a regulation in EU law on data protection and privacy for all individuals within the European Union and the European Economic Area. It also addresses the export of personal data outside the EU and EEA. The GDPR aims primarily to give control to citizens and residents over their personal data and to simplify the regulatory environment for international business by unifying the regulation within the EU.

GDPR regulates the processing of information relating to you and grants you various rights in relation to your personal data.

Replenishh Limited is committed to ensuring that your privacy is protected and that we comply with the obligations of GDPR.

This Privacy Policy explains how we will treat any personal information that you provide us, details your rights and how you can access them and provides assurances on things we will not do.

The Cookie Policy is available here and highlights how we utilise cookies.

The information we collect and how we use it

When you register on our website at or contact us by phone we may collect information about you and your organisation such as company name, address, job title, e-mail address and phone number.

We gather this information to allow us to process your registration and efficiently administer transactions and deliveries, as well as using it to develop and improve our services.

We may use aggregated information for the purposes of tracking the usage of our services and to help us develop and improve the website and such services. We may pass this information to third parties as described within this document. The aggregated information and statistics will not however include details that can be used to identify you.

We will only send marketing material or advertise the products and services of the company by email to subscribers whose contact details the company has obtained either during a transaction or registration. All subscribers will be offered a means of opting out of such communications at the time their details were initially collected and each subsequent communication.

What information is being collected?

  • Order related data:- To process your order efficiently we need information about you and your organisation such as company name, address, the nature of your business, e-mail address and phone number.
  • Cookies:- Information of cookies and how Replenishh uses them is here.


What are cookies?

A cookie is a small text file that tracks our users' navigation of the site and stores that information on the hard drives of their PC, mobile phone or other web-connected device. There is nothing malicious about the use of cookies - in fact they are essential for websites to operate efficiently and to the best expectations of their users. The information collected by cookies cannot be used to identify you personally.

Cookies allow us to understand our visitors' habits and preferences, enabling Replenishh to customise its web services and provide an enhanced user experience. The use of cookies is standard in many industries and you will find them in use on most major websites. We may, for example, use cookies to store registration information so that you do not have to provide it to use on subsequent visits.

What do cookies do?

We use a number of different cookies on our website. Cookies can do a number of things: for example, letting you navigate between pages effectively, storing preferences and generally improving the experience of the website.

Cookies are essential for our website because without them we would not be able to process orders. As a customer you would find it extremely frustrating, if not impossible, to use the website. You would appear as a new customer every time you navigated to a different web page. You would also be logged out on every web page.

Examples of essential cookies we use on the site include:

  • Saving basket contents as you navigate throughout the website and checkout process
  • Remembering your account log in details so you can access your account information easily
  • Purchasing preferences such as VAT and currency selection
  • Remembering what type of customer you are – eg. Industry, Schools or FE/HE
  • Recording how our customers use the website, such as web page visits, length of time on site, products purchased. We use this information to help us improve your experience on the website to make your purchasing easier

Are cookies safe?

Yes, cookies are 100% safe. Cookies do not harm your computer, they do not contain any information that could be used by others to identify you personally and they do not contain any confidential information, such as your email address or payment details.

Different types of cookies on Replenishh

We have categorised the cookies into four different types:

1. Strictly Necessary Cookies

These cookies are essential to enable you to move around our website and use its features, such as adding products to your basket, or logging into your account securely. Without these cookies, our website cannot work properly.

View all our Strictly Necessary Cookies

2. Functionality Cookies

These cookies allow us to remember the choices you make and your personalised features such as what currency you choose to view the site in, your VAT preferences, and your login and password if you choose to save them.

View all our Functionality Cookies

3. Performance Cookies

These cookies collect information about how you use our website, for instance, which pages you go to most often and if you get error messages from those pages. We only use these cookies to improve how our website work.

View all our Performance Cookies

4. Advertising Cookies

Advertising & Tracking advertising cookies are used to work out what advertising might be most relevant to you based on the areas you look at on our website.

View all our Advertising & Tracking Cookies

Third Party Cookies

Some cookies will be created on the website as a result of the services provided by third party organisations we work with. For example, we use external analytics services and these suppliers may set cookies on our behalf in order to report back to us. We also embed videos or other content from sites such as YouTube and these sites may set their own cookies. Details of third party cookies are included on our cookie examples page and you can check the relevant third party's website for more information about their cookie policy.

If you do not know what cookies are, or how to control or delete them, then we recommend you visit for detailed guidance

From 26 May 2012 website owners in the UK became required by law to inform their visitors of the cookies they use on their site and what purpose they have. They must also provide users with the necessary information and guidance in order to disable cookies.

Find out how to manage your cookie settings on your browser, on our site and a list of the cookies used on the site.

Purposes of Data Processing

Data Processing either by Replenishh or defined contracted third parties are limited to the following:

  • Using customers name and address to complete business transactions including invoicing, credit checking, drop shipment or other order or contract related obligations.
  • Using cookies for web enhancement, remarketing and refining google adwords.
  • Using customers names, phone numbers or e-mail addresses within a defined marketing campaign or sales activity which will be limited by the Legitimate Interest Assessment and in addition individuals consent settings or outcomes from exercising your rights.
  • Using customers and supplier’s transactional data for internal performance reporting.

Categories of Personal Data

Processing of personal data is limited to customer, supplier data and employee personal data.

We do not hold or process personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership and comply with the restrictions regarding the processing of genetic data, biometric data for uniquely identifying a natural person and data concerning health or person's sex life or sexual orientation.

We do not hold or process personal data relating to criminal convictions and offences or related security measures.

Lawful Basis for Processing Personal Data

All processing of personal data is lawful and fair. We ensure transparency with customers, suppliers and employees regarding how personal data concerning them is collected, used, or otherwise processed and to what extent the personal data will be processed.

We ensure all information and communication relating to the processing of personal data is easily accessible, easy to understand, and delivered with clear and plain language.

The lawful basis clauses applicable to personal data we hold, or process are limited to


You have given clear consent to process personal data for a specific purpose.


The processing is necessary for a contract with you or because you have asked us to take specific steps before entering into a contract.

Legal obligation

The processing is necessary to comply with the law.

Legitimate Interests

The processing is necessary for our legitimate interests or the legitimate interests of a third party unless there is a good reason to protect your personal data which overrides those legitimate interests, ie consent is withdrawn.

The following table details data or data processing activities, the group of persons whose data is used and the lawful basis we apply.

Type of Data or Use

Customer Group

Lawful Basis


Qualified Business Customers

Legitimate Interest


Consumers & Education Establishments


E-mail Marketing

Qualified Business Customers

Legitimate Interest

Email Marketing

Consumers & Education Establishments



All Customers


Order Transaction

Online Order Transaction


Order Transaction

Telephone Order Transaction


Order Transaction

E-mail, Fax Customers


Transaction Records

All Customers

Legal Obligation

Credit Check

All Customers


Web functionality

All Customers


Customer Delivery Data

All Customers


Supplier Data

All Customers


We limit personal data collected to what is necessary for the purposes for which they are processed. Personal data is held to ensure contractual obligations are met or to meet legal requirements for the keeping of records.

We apply personal data retention rules and annually review them in a specific GDPR audit process.

Every reasonable step is taken to ensure that personal data that is inaccurate is rectified or deleted. Personal data is processed in a manner that ensures appropriate security and confidentiality of the personal data, including preventing unauthorised access to or use of personal data and the equipment used for the processing.

Legitimate Interest Assessment

Replenishh consider that business customers with past or ongoing contracts with specific criteria achieved can be defined as legitimate interests.

We ensure legitimate interests are the most appropriate basis though a Purpose Test. We check that the processing is necessary through a Necessity Test and complete a Balancing Test to be confident that an individual’s potential interests do not override those legitimate interests.

We apply additional restriction measures to reduce a potential risk of the application of legitimate interest assessment by adding requirements for consent regarding potential consumer customers or sole traders through identifying typical email service providers.

All marketing information has a clearly visible unsubscribe and customers can understand how we utilise their data through this Privacy Policy.

Data processing by third parties

This section will explain who we share your data with and why it is being processed.

  • We will share your data with our relevant partners to ensure your transaction can be completed effectively. The table below details the type of partner and reason for processing.


Nature of the data use


We use third party couriers to deliver your order.

Direct Shipment

We may order products to be sent directly from a manufacturer to you; this requires delivery information to be sent to the manufacturer to complete the transaction.

Payment Providers

We partner with a limited number of payment providers to provide you with a range of ways to pay.

Credit Reference Service

We may use a credit reference agency to determine your suitability for credit terms if you apply and give consent. 

Credit Recovery Services

Failure to pay in an agreed period may result in your details being passed to a credit recovery agent.

Market Places

We sell via a limited number of online platforms that will share your data with us to complete an order you have made.

Online Marketing

We provide select third party service providers with your data to deliver our relevant online marketing campaigns.

Offline Marketing

We use third party service providers to deliver our relevant offline marketing campaigns.


Inbound faxes are processed by a web-based service provider.

Email processing

Our email server provider will process all emails that come to or leave Replenishh Business or employees.

Mail Filtering

Internal and external emails are passed through a filter by a service provider for protection against malware and for PCI compliance.

Phone Answering Service

In the unlikely event of a phone system failure, calls may be routed to a third party answering service.

Web Services

Web Hosting, Live chat services, Payment providers, reviews, survey, postcode lookup and SMS services will all need cookies and customer data to work.

Cookies data usage

This section explains how cookies are being used by Replenishh and our chosen third-party service providers. Cookie data will only be used by the organisation collecting it and will not be shared.

  • Replenishh use several cookies without which our site wouldn’t be able to function and that enable you to navigate around the website and use major features.

We use a third-party:

  • to increase the performance of the website, cookies will track visits and conversions on the website.
  • to send our abandoned basket emails, cookies are used to deliver the basket data to ensure that the emails are relevant and delivered.
  • for affiliate tracking services, cookies let us know when a visitor is referred from a third-party website and makes a purchase.
  • to assist with targeted advertising, cookies are used to deliver adverts that are relevant to you and your interests once you have left our site and are displayed on a third-party advertising network.
  • to assist with targeted advertising on external websites, cookies will track visits & conversions on the website from online advertising.
  • cookie to allow our analytics supplier to provide statistics and information on how our website is used, e.g. which pages are visited, so that we can understand what interests our users, measure effectiveness of campaigns and try to improve how the website works
  • to provide live chat sessions to offer you online support

Your Rights

Right to be informed

This Privacy Statement sets out clear principles of when, how and why we collect data. At the point of personal data collection, we explicitly detail the personal data required and how it will be used. If we change how data is being processed or unrestricted the use of personal data, we will communicate this change.

The right to object will be clearly communicated separately to the privacy statement on all electronic customer communications.

Communicate the processing of children’s personal data

We do not hold or process children’s personal data.

Right of access

You have the right to request personal information held and details regarding how it is being processed and who by.

On request either by phone or in writing we provide free information regarding personal data held within 28 days of the request if successful verification of identity has been complete.

The information we provide will be in electronic format, contain the personal data we hold, when and how it was obtained, names of third parties who have processed the data and our statement of intent.

Right to rectification and data quality

On request either by phone or in writing we will update or improve the data we hold within 28 days of the request if successful verification of identity has been complete.

Personal data is reviewed periodically to check the quality of information improve the quality through planned activities.

Right to erasure including retention and disposal

Individuals have the right to be forgotten and can request the erasure of personal data if:

  • it is no longer necessary for the purpose originally collected.
  • if the individual withdraws consent for processing the data.
  • when we are relying on legitimate interests as the basis for processing.
  • if the individual objects to the processing of their data, and there is no overriding legitimate interest to continue this processing.
  • when processing personal data for direct marketing purposes and the individual objects to the processing.
  • if personal data must be erased to comply with a legal obligation.

On request either by phone or in writing we will review the request and respond within 28 days of the request if successful verification of identity has been complete.

Personal data is stored as per the personal data retention and deletion policy.

Right to restrict processing

Individuals have a right to block or restrict the processing of their personal data.

On request either by phone or in writing we will block or restrict the processing of personal data within 28 days of the request if successful verification of identity has been complete.

If necessary, we will continue to hold the personal data but restrict further processing.

Right to data portability

Individuals have the right to request their personal data to move it to another provider.

On request either by phone or in writing we provide free information regarding personal data held within 28 days of the request if successful verification of identity has been complete.

Right to object

Individuals have a right to object to the processing of their personal data. All policies and procedures will be reviewed to resolve the objection and act.

On request either by phone or in writing we will reply to an objection regarding the processing of personal data within 28 days of the request if successful verification of identity has been complete.

Individuals have an absolute right to object to any processing undertaken for the purposes of direct marketing and all processing for this purpose will stop immediately.

Rights related to automated decision making including profiling

We understand an individual’s rights and do not make decisions regarding individuals through automated decision making.

Links to other websites

This privacy policy covers the activity and operations of Replenishh Limited. Replenishh Limited accepts no responsibility or liability for the third-party websites we provide links to. We recommend that visitors consult the respective privacy policies of these websites.

Unsubscribing from promotional emails

Customers who wish to stop receiving marketing email communications can do so quickly and easily. All marketing emails include an 'Unsubscribe' link. Alternatively, an email with the subject line of 'Unsubscribe' can be sent to Your email address will be removed from our mailing lists used for marketing purposes. Please note that emails relating to the status of orders, transactions and updates will still be sent.

Payment card information

Replenishh conform to PCI (Payment Card Industry) Legislation regarding the protection of cardholder’s data and personal information. All transactions take place within a secure area of the website. Personal payment card information is not published in any form on the website and is not accessible to staff of Replenishh.

Changes to this privacy policy

This privacy policy is reviewed annually and was last updated on 24 May 2018.

How to contact us

If you have any concerns or queries relating to your personal information, cookies or any aspect of our privacy policy, please e-mail, write or call our customer experience team.

Rapid Electronics Limited
Severalls Lane

01206 751166

Conrad Group has appointed a Group DPO who has power of attorney for the Conrad group of companies including Replenishh. Their leadership and guidance support our internal review, planning and ongoing compliance.

Data Protection Officer is:
Christian Volkmer
Projekt 29 GmbH & Co. KG
Ostengasse 14
93047 Regensburg
Tel. 0941-2986930
Fax 0941-29869316

Regulatory Authority

You have the right to appeal to the regulatory authority, the Information Commissioner’s Office.

The UK’s independent authority set up to uphold information rights in the public interest, The UK’s independent authority set up to uphold information rights in the public interest, promoting openness by public bodies and data privacy for individuals.