Data Erasure & Data Security Policy 

Data Erasure & Data Security Policy
Effective Date: 25 September 2026
Last Updated: 25 September 2026

Eco Tech Recycle is a trading name of Tech Cell Limited (Company No. 14338989).


This Data Erasure & Data Security Policy explains how Eco Tech Recycle handles data-bearing devices, storage media, data-security risks, data-erasure processes, device restrictions, failed erasure attempts, reporting, secure fall back routes and related records.
This Policy applies to individuals, businesses, schools, charities, community organisations, trade customers and other organisations that provide, sell, donate, drop off, send or arrange collection of devices or electronic equipment that may contain data.
This Policy should be read together with our:
Privacy Policy;
Collection, Device Acceptance & Valuation Policy;
Recycling & WEEE Policy;
Purchase, Buy-Back & Payment Terms;
Business & School Collection Terms;
Device Grading, Functional Condition & Resale Classification Policy;
Repair, Refurbishment & Returned Device Service Policy;
Delivery, Shipping & Collection Policy;
Complaints Policy; and
any quotation, collection confirmation, data-processing agreement, asset record, erasure report, service confirmation or other written agreement issued by Eco Tech Recycle.
Where a separate written agreement or service confirmation contains specific data-erasure, data-processing or data-security terms for a particular job, those specific written terms will take priority for that job to the extent that they are lawful.
Key Points at a Glance
Customers should back up any data they wish to retain before handing over equipment.
Customers should remove SIM cards, memory cards, accounts, activation locks and device-management restrictions where possible.
Data-bearing equipment is treated as presenting a potential data-security risk until that risk has been appropriately resolved.
Eco Tech Recycle uses licensed Certus data-erasure software for eligible devices where applicable.
A factory reset alone is not represented as certified secure data erasure.
A formal erasure report is only available where the process is applicable, successfully completed, recorded and included in the agreed service.
Devices with unresolved data risk will not knowingly be released into a reuse, resale or donation route.
If software erasure cannot be completed, storage media may be removed, securely destroyed, processed through an appropriate secure downstream route, returned or excluded from reuse.
This public Policy is not a substitute for a Data Processing Agreement where one is legally required.

1. Purpose of This Policy

Eco Tech Recycle handles used, surplus, faulty, damaged, end-of-life and mixed-condition technology equipment.
Many devices may contain:
personal data;
business information;
school or student information;
employee information;
customer records;
photographs;
documents;
account information;
system data;
credentials;
financial information;
confidential information; or
other stored data.
The purpose of this Policy is to explain:
how customers should prepare devices before handover;
what equipment may contain data;
how Eco Tech Recycle approaches data-bearing equipment;
when data erasure may be carried out;
when data-erasure reporting may be available;
what happens if erasure cannot be completed successfully;
how activation locks and device-management restrictions affect processing;
how customer-owned devices are handled;
how business and school data-processing requirements are addressed;
how suspected data incidents are handled; and
how concerns or complaints can be raised.
Eco Tech Recycle takes data security seriously and aims to apply handling measures proportionate to the nature of the device, the information risk and the service agreed.

2. Scope of This Policy

This Policy applies to equipment that contains, or may reasonably be expected to contain, electronic storage media.
Examples include:
laptops;
MacBooks;
desktop PCs;
iMacs;
all-in-one computers;
workstations;
servers;
mini PCs;
thin clients;
mobile phones;
smartphones;
tablets;
iPads;
hard disk drives;
SSDs;
NVMe drives;
USB drives;
memory cards;
external drives;
network-attached storage;
CCTV equipment;
DVRs and NVRs;
routers;
switches;
firewalls;
smart devices;
IoT equipment; and
other devices capable of storing user, system, configuration or credential information.
This Policy applies whether equipment is intended for:
reuse;
repair;
refurbishment;
resale;
redeployment;
donation;
parts recovery;
recycling;
return to the customer;
storage-media removal;
secure destruction; or
another agreed route.

3. Customer Responsibility Before Handover

Customers are responsible for backing up or otherwise protecting any data they wish to retain before equipment is collected, posted, dropped off or otherwise handed to Eco Tech Recycle.
Where reasonably possible, customers should:
back up important files, photographs, documents and records;
remove SIM cards;
remove memory cards;
remove USB drives;
remove external storage;
remove personal accessories that may contain data;
log out of personal accounts;
remove Apple ID, iCloud and Find My restrictions;
remove Google accounts and Factory Reset Protection where appropriate;
remove Samsung account restrictions;
remove MDM, school, business or organisation-management profiles where appropriate;
remove BIOS, firmware or startup passwords where appropriate;
remove device passcodes where this has been agreed and is appropriate;
provide an asset or serial-number list where available; and
tell Eco Tech Recycle about any special data-security requirement before collection or processing.
Customers should not send or disclose:
passwords;
banking credentials;
recovery keys;
two-factor authentication codes;
account login details; or
other sensitive credentials,
unless Eco Tech Recycle has provided a specific secure process for a clearly defined and legitimate purpose.

4. Data Recovery and Data Preservation Are Separate Services

Data recovery or preservation should not be assumed to be included in a collection, recycling, valuation, refurbishment or repair service.
Where Eco Tech Recycle offers or agrees a data-recovery or data-preservation service, the scope must be agreed separately.
Customers must tell Eco Tech Recycle before work begins if preservation or recovery of existing data is required.
Without such an agreement, equipment may be tested, reset, erased, repaired, reformatted, have storage replaced or otherwise processed in a way that permanently removes or changes stored information.
Customers should therefore back up any information they require before handover.

5. Baseline Data-Security Rule

Eco Tech Recycle treats data-bearing equipment as presenting a potential data-security risk until that risk has been appropriately addressed.
Equipment containing known or suspected data-bearing storage will not knowingly be released into:
retail resale;
wholesale reuse;
donation;
redeployment to another end user; or
another reuse route
while a known material data-security risk remains unresolved.
Depending on the equipment and service route, that risk may be resolved through:
verified software erasure;
appropriate reset and sanitisation steps;
removal of storage media;
replacement of storage media;
secure physical destruction;
secure downstream processing; or
another appropriate method.
A formal certificate or erasure report is separate from this baseline security requirement and is only provided where applicable and agreed.

6. Initial Data-Risk Assessment

When Eco Tech Recycle receives data-bearing or potentially data-bearing equipment, it may carry out an initial assessment.
This may include:
identifying the device type;
identifying visible or expected storage media;
checking whether storage is present;
checking whether the equipment powers on;
checking lock status;
checking organisation-management status;
checking whether storage is removable;
assessing whether software erasure is technically possible;
assessing whether storage-media removal may be required;
recording serial numbers or asset details where agreed;
photographing device condition;
identifying safety issues; and
assigning an appropriate handling route.
An initial assessment is not necessarily a complete technical examination.
Hidden, embedded or inaccessible storage may not always be identifiable immediately, particularly where equipment is:
damaged;
incomplete;
sealed;
unsafe;
locked; or
unable to power on.

7. Data-Erasure and Sanitisation Approach

Eco Tech Recycle uses a risk-aware approach to data erasure and media handling.
Depending on the equipment, storage type, condition, customer instructions and agreed service, handling may include:
software-based data erasure;
licensed Certus data-erasure processing;
device sanitisation;
operating-system reinstallation;
factory reset as an operational step where appropriate;
storage-media removal;
storage-media replacement;
secure physical destruction;
secure downstream processing;
quarantine or hold pending customer action;
return to customer; or
recycling where reuse is unsuitable.
The method selected depends on factors including:
equipment type;
storage technology;
condition;
data risk;
lock status;
hardware functionality;
intended reuse route;
technical feasibility;
customer requirements; and
the agreed service scope.

8. Licensed Certus Data-Erasure Capability

Eco Tech Recycle uses licensed Certus data-erasure software to support data-erasure workflows for eligible devices.
This does not mean that Eco Tech Recycle is describing itself as an official, authorised or accredited Certus partner unless such status is separately confirmed in writing by Certus.
Certus processing may depend on:
device type;
storage-media type;
drive health;
device condition;
power status;
firmware restrictions;
lock status;
connection method;
hardware faults;
software compatibility; and
successful completion of the erasure process.
Eco Tech Recycle does not guarantee that every device or storage medium can be processed using Certus.
Where the process is applicable and completes successfully, reporting may be available in accordance with the agreed service.

9. Data-Erasure Reports

Where a formal erasure report is included in the agreed service and the relevant process completes successfully, the report may include information such as:
device or drive identification;
serial number;
storage identifier;
erasure method;
result;
processing date;
completion status;
report reference;
verification information generated by the software; and
other technical information generated as part of the erasure process.
A data-erasure report relates only to the process and equipment identified in that report.
It does not certify or guarantee:
ownership;
legal title;
cosmetic condition;
functional condition;
commercial value;
suitability for resale;
wider device history; or
the security of separate storage media that was not included in that process.
A successful erasure report will not be issued where the process:
failed;
was incomplete;
was not performed;
could not be verified; or
cannot reliably be linked to the relevant device or storage medium.

10. Factory Reset

A factory reset may be used as part of:
testing;
repair;
refurbishment;
operating-system preparation;
device configuration; or
resale preparation.
However, Eco Tech Recycle does not represent a factory reset alone as certified secure data erasure.
Where a customer requires formal erasure assurance or reporting, that requirement should be agreed before processing and must be technically possible for the relevant equipment.

11. Failed or Incomplete Data Erasure

Data erasure may fail or be impossible for reasons including:
the device does not power on;
storage media is damaged;
drive health is poor;
storage is not detected;
the equipment is locked;
a BIOS or firmware restriction is present;
MDM or organisation management is active;
storage is encrypted or inaccessible;
physical damage prevents processing;
the device becomes unsafe;
software erasure is unsupported;
technical communication with the storage device fails; or
another technical fault prevents successful completion.
Where erasure cannot be successfully completed, Eco Tech Recycle may:
attempt an alternative suitable process;
remove storage media;
replace storage media;
arrange secure destruction;
use an appropriate secure downstream route;
exclude the device from reuse or resale;
hold the equipment pending customer instructions;
return the equipment;
revise the device classification; or
revise or withdraw a valuation.
A device will not be classified as retail-ready while a known material data risk remains unresolved.

12. Storage-Media Removal and Physical Destruction

Where software erasure is unsuccessful, technically unsuitable or not an appropriate risk treatment, storage media may need to be removed or physically destroyed.
This may apply to:
failed hard drives;
failed SSDs;
inaccessible storage;
storage from no-power devices;
damaged media;
equipment unsuitable for reuse;
media where secure erasure cannot be verified; or
equipment subject to an agreed destruction route.
Physical destruction may be carried out directly where an appropriate capability is available or through an appropriate specialist downstream provider.
Physical destruction normally prevents reuse of the storage medium and may reduce the commercial value of the equipment.
Where destruction is performed, recovery of the stored information should not be expected afterwards.

13. Built-In or Non-Removable Storage

Some devices contain soldered, integrated or difficult-to-remove storage.
Examples may include:
phones;
tablets;
certain MacBooks;
certain iMacs;
modern laptops;
smart devices; and
embedded systems.
Where storage cannot be safely removed and software sanitisation cannot be completed successfully, the device may be unsuitable for reuse.
Depending on the circumstances, it may be:
held pending customer action;
returned;
reclassified for parts;
excluded from resale;
routed to secure destruction;
routed to appropriate recycling; or
assigned reduced or no commercial value.

14. Activation Locks, MDM and Security Restrictions

Eco Tech Recycle does not unlawfully bypass security, ownership or organisation-management controls.
Equipment may be refused, returned, held, revalued or redirected away from reuse where subject to:
Apple Activation Lock;
iCloud;
Find My;
Google Factory Reset Protection;
Samsung Account restrictions;
user or screen locks;
BIOS passwords;
firmware passwords;
startup security restrictions;
MDM;
Microsoft Intune;
Windows Autopilot;
Jamf;
Apple Business Manager;
Apple School Manager;
Google Workspace management;
school or organisation management;
finance restrictions;
lease restrictions;
lost or stolen status; or
another third-party ownership restriction.
Customers should remove relevant locks and management restrictions before handover wherever they have authority to do so.

15. Business, School, Charity and Organisation Equipment

Business, education and organisation equipment may contain:
employee information;
pupil or student information;
customer data;
client information;
business records;
security information;
commercially confidential material; or
other personal information.
Organisations should ensure that:
they have authority to release the equipment;
internal asset-release processes have been completed;
device-management systems are updated where appropriate;
MDM or equivalent restrictions are removed where required;
Apple Business Manager, Apple School Manager, Jamf, Intune, Autopilot or equivalent controls are addressed where appropriate;
important organisational information has been backed up;
special security requirements are agreed before collection;
asset lists are supplied where required; and
site, safeguarding and collection requirements are communicated in advance.
Where agreed, Eco Tech Recycle may provide:
asset records;
serial-number records;
handover records;
chain-of-custody information;
erasure reports; or
other agreed documentation.
Detailed reporting may be chargeable where it is outside the standard agreed service.

16. Data Controller and Data Processor Roles

The data-protection role of Eco Tech Recycle depends on the facts and the service agreed.
This Policy does not by itself determine whether Eco Tech Recycle is acting as a controller or processor for any particular processing activity.
Where Eco Tech Recycle processes personal data on behalf of a business, school or other organisation as its processor, an appropriate written Data Processing Agreement or other legally binding processor terms may be required.
Such arrangements should address matters including:
subject matter and duration of processing;
nature and purpose of processing;
categories of personal data;
categories of data subjects;
documented processing instructions;
confidentiality;
appropriate security measures;
use of sub-processors;
support with data-subject rights;
support with data-protection obligations;
end-of-service deletion or return requirements; and
appropriate audit and information rights.
This public Policy is not a substitute for an Article 28 Data Processing Agreement where one is legally required.
Where required processing terms cannot be agreed or supported, Eco Tech Recycle may decline the relevant service.

17. Chain of Custody and Handling Records

Where included in the agreed service, Eco Tech Recycle may create chain-of-custody or handling records.
These may include:
collection confirmation;
handover documentation;
asset lists;
serial-number records;
IMEI records;
intake records;
photographs;
device-condition notes;
lock-status notes;
storage-media status;
erasure results;
erasure reports;
destruction records;
downstream-processing records; and
return or recycling records.
The level of record keeping depends on:
the service agreed;
customer requirements;
equipment quantity;
device type;
operational feasibility; and
reporting requirements.
A basic collection service does not automatically include device-level chain-of-custody reporting unless agreed.

18. Storage, Access and Security Controls

Eco Tech Recycle aims to apply reasonable and proportionate technical and organisational measures to data-bearing equipment and related records.
Depending on the service and risk, measures may include:
restricting access to authorised personnel;
separating or identifying data-bearing equipment;
controlled storage areas;
intake and job records;
device labels or job references;
prioritisation of data-bearing equipment;
avoiding unnecessary access to customer information;
avoiding unnecessary use of customer accounts;
appropriate media-handling procedures;
controlled release into reuse routes; and
appropriate internal escalation where data risk is identified.
Public disclosure of detailed internal security controls may be limited where disclosure itself could create unnecessary security risk.

19. Personal or Confidential Information Seen During Processing

During assessment, repair, testing, reset or erasure, information may occasionally become visible.
Where this occurs, authorised personnel are expected to:
avoid unnecessary viewing;
avoid copying information unless necessary for an agreed lawful purpose;
avoid disclosure;
avoid using the information for unrelated purposes;
restrict access;
continue with the appropriate data-security process; and
escalate a suspected incident where appropriate.
Customers can reduce this risk by backing up required information, signing out of accounts and removing unnecessary personal content before handover.

20. Data Incidents and Personal Data Breaches

A suspected data incident may include:
unauthorised access;
loss or theft;
accidental disclosure;
incorrect release of a device;
loss of storage media;
inappropriate access;
incorrect handling; or
another event affecting confidentiality, integrity or availability of personal data.
Where Eco Tech Recycle identifies a suspected incident, it will assess the circumstances and take appropriate action.
This may include:
securing affected devices or records;
restricting access;
investigating the incident;
recording relevant facts;
taking corrective action;
seeking specialist advice;
contacting the affected customer or controller where appropriate; and
assessing legal notification requirements.
Where Eco Tech Recycle is acting as a processor, it will notify the relevant controller of a personal data breach without undue delay where required.
Where Eco Tech Recycle is acting as a controller, it will assess whether notification to the ICO or affected individuals is required and will make any required notification within the applicable statutory timeframe.

21. Privacy Policy and Administrative Customer Data

This Policy mainly concerns information stored on devices and storage media.
Eco Tech Recycle may separately process customer or business information such as:
names;
contact details;
collection information;
correspondence;
invoices;
payment records;
complaints;
asset records; and
service information.
This information is handled under our Privacy Policy and applicable data-protection law.

22. Repair, Refurbishment and Returned Customer Devices

Where Eco Tech Recycle repairs, refurbishes or assesses a customer-owned device that will be returned to the customer, data handling may differ from a recycling or purchase route.
Repair work may involve:
functionality testing;
accessing system settings;
running diagnostics;
operating-system reinstallation;
replacing storage media;
removing failed storage;
software reset; or
hardware reconfiguration.
Customers should back up information before repair or assessment.
Where loss of data is an inherent and disclosed consequence of an agreed repair or reset process, the customer should not expect the original data to remain available.
Eco Tech Recycle will perform agreed consumer services with reasonable care and skill.
Nothing in this Policy excludes liability or statutory rights where exclusion would be unlawful.

23. Devices Purchased by Eco Tech Recycle

Where Eco Tech Recycle is considering purchasing a device or batch, the final valuation may depend on whether data risk can be appropriately resolved.
A device may have reduced or no value where:
it is locked;
it remains organisation-managed;
storage cannot be accessed;
storage has failed;
it cannot be appropriately sanitised;
it cannot be tested;
required storage is missing;
ownership is uncertain;
it has been reported lost or stolen; or
unresolved data risk prevents lawful or suitable reuse.
A provisional valuation may therefore change following data-security assessment.

24. Devices Collected for Reuse, Donation or Recycling

Where equipment is permanently transferred for reuse, donation, parts recovery or recycling, customers should assume that processing may begin following handover in accordance with the agreed service route.
This may include:
testing;
erasure;
dismantling;
refurbishment;
repair;
parts recovery;
resale;
donation; or
recycling.
Customers must therefore back up anything they wish to retain before handover.
Once equipment has progressed through dismantling, erasure, parts recovery, destruction or downstream recycling, return of the original equipment or recovery of original data may no longer be possible.

25. Data-Erasure Reporting Is Not Automatically Included

Every data-bearing device is subject to an appropriate data-risk decision before it is knowingly released to an end-user reuse route.
However, a formal device-level erasure report or certificate is not automatically included with every:
collection;
recycling service;
valuation;
purchase;
repair;
donation; or
drop-off.
Customers requiring:
device-level reports;
formal erasure records;
storage-media destruction records;
asset-level reporting; or
specific chain-of-custody documentation
must request these requirements before processing where possible.
Additional charges may apply where detailed reporting or specialist processing is outside the agreed service scope.

26. Data-Bearing Parts and Parts Recovery

Devices processed for parts may contain both data-bearing and non-data-bearing components.
Where reasonably practicable, Eco Tech Recycle will identify and appropriately control data-bearing storage before non-data-bearing components are released for reuse.
This may involve:
removing drives;
separating storage from other components;
erasing eligible storage;
destroying unsuitable storage;
retaining non-storage parts for repair or resale; and
recycling unsuitable components.
Eco Tech Recycle aims not to knowingly release storage media into reuse or resale while unresolved customer data risk remains.

27. Network, CCTV and Smart Devices

Network, CCTV and smart equipment may store:
configuration information;
credentials;
logs;
Wi-Fi information;
account details;
video footage;
user information; or
business information.
Examples include:
routers;
switches;
firewalls;
wireless access points;
CCTV systems;
DVRs;
NVRs;
smart hubs;
IoT equipment; and
managed network devices.
Customers should decommission, reset and remove account or management links before handover where reasonably possible.
Eco Tech Recycle may reset, reclassify, dismantle, return or recycle equipment where the data-security risk cannot be appropriately resolved for reuse.

28. Sensitive, Special Category and High-Risk Information

Customers should tell Eco Tech Recycle before handover where equipment is known to contain information requiring enhanced security or special contractual handling.
This may include:
health information;
children’s information;
pupil or student records;
criminal-offence data;
legal information;
financial records;
employee or HR records;
customer databases;
confidential client information;
access credentials;
sensitive government information;
intellectual property;
special category personal data; or
other highly confidential information.
Customers should not send copies of the sensitive information itself merely to notify Eco Tech Recycle of the risk.
Depending on the requirements, Eco Tech Recycle may require:
a separate written agreement;
specific processing instructions;
enhanced chain-of-custody records;
defined destruction arrangements;
a Data Processing Agreement; or
other agreed controls.
Eco Tech Recycle may decline a service where the requested level of handling cannot reasonably or lawfully be supported.

29. Customer Instructions

Customers requiring a particular data-security outcome should provide instructions before processing begins.
Examples include:
formal erasure report required;
serial-number report required;
asset-level reporting required;
storage-media destruction required;
storage media must be returned;
device must not be reused;
recycling-only route required;
specific chain-of-custody records required;
specific processor terms required.
Instructions should be agreed in writing where they materially affect the service.
Where no special instruction is provided, Eco Tech Recycle will follow its standard data-aware handling process appropriate to the equipment, condition and service route.

30. Return of Storage Media

Where a customer requires original storage media to be returned, this must be agreed before processing begins.
Return may no longer be possible once media has been:
erased and reassigned;
destroyed;
replaced;
separated from an unidentified mixed batch;
recycled; or
transferred through an agreed downstream processing route.
Where a return is agreed, it may be subject to:
reliable identification of the media;
customer ownership confirmation;
safety considerations;
handling costs;
courier or collection charges; and
written acknowledgement or release requirements.

31. Subcontractors and Downstream Providers

Eco Tech Recycle may use appropriate third parties for services such as:
specialist data destruction;
downstream recycling;
transport;
specialist repair;
secure processing;
software services; or
other operational support.
Where Eco Tech Recycle acts as a processor and proposes to use a third party as a sub-processor for personal-data processing carried out on behalf of the customer, the applicable requirements for controller authorisation and contractual protection will be followed.
Where required, equivalent data-protection obligations will be imposed on relevant sub-processors.
Where a customer requires prior approval of specific downstream providers or processing routes, this must be agreed before the service begins.

32. Retention of Records

Eco Tech Recycle may retain records relating to:
collections;
assets;
serial numbers;
erasure results;
erasure reports;
destruction records;
customer instructions;
quotations;
complaints;
invoices;
payments; and
service correspondence.
Records are retained only for as long as reasonably necessary for purposes such as:
service delivery;
legal compliance;
accounting;
audit;
dispute resolution;
fraud prevention;
customer support; and
regulatory or contractual requirements.
Specific retention arrangements may vary by record type.
Personal data contained within these records is handled in accordance with our Privacy Policy and applicable data-protection requirements.
Records that are no longer required should be securely deleted, anonymised or otherwise appropriately disposed of where applicable.

33. Unauthorised, Stolen or Mis described Equipment

Customers must not knowingly provide equipment they do not own or are not authorised to release.
Eco Tech Recycle may refuse, hold, return or suspend processing where there is a reasonable concern involving:
theft;
lost property;
third-party ownership;
finance or lease arrangements;
school or employer ownership;
organisation-managed devices;
inaccurate ownership information; or
suspected fraud.
Where lawful and appropriate, Eco Tech Recycle may cooperate with relevant authorities, insurers, legal advisers or other appropriate parties.
A customer may be responsible, to the extent permitted by law, for reasonable losses resulting directly from materially false information or from knowingly supplying equipment without lawful authority.

34. Staff, Contractors and Confidentiality

Personnel authorised to handle customer equipment or associated records are required to follow relevant internal procedures.
These may include requirements relating to:
confidentiality;
data-aware handling;
approved erasure routes;
avoiding unnecessary access;
accurate recording;
escalation of lock or ownership issues;
escalation of suspected data incidents;
separation of storage media where appropriate; and
compliance with specific customer instructions.
Internal procedures may be updated as technology, legal requirements, software, equipment types and operational risk change.

35. Limitations and Liability

Eco Tech Recycle will take reasonable care when handling equipment and storage media.
However, used and end-of-life equipment may already be:
faulty;
unstable;
encrypted;
corrupted;
physically damaged;
liquid-damaged;
locked;
incomplete;
unsafe; or
close to hardware failure.
Eco Tech Recycle cannot guarantee that:
every device will power on;
every storage medium will be detected;
every storage medium can be successfully erased;
every successful process will qualify for formal reporting;
every device can be reused;
every storage medium can be removed without damage;
every damaged device can be safely processed;
every hidden storage component can be identified immediately; or
data can be preserved where preservation was not expressly agreed.
Where an agreed erasure or destruction service is successfully performed, loss of the target data is an intended result of that service.
Nothing in this Policy excludes or restricts liability for:
death or personal injury caused by negligence;
fraud or fraudulent misrepresentation;
failure to exercise reasonable care and skill where required by law;
statutory consumer rights that cannot lawfully be excluded; or
any other liability that cannot lawfully be excluded or restricted.

36. Complaints and Data-Security Concerns

Customers should contact Eco Tech Recycle promptly if they have concerns about:
data erasure;
data security;
storage-media handling;
incorrect device release;
reporting;
destruction;
confidentiality; or
another data-related issue.
Concerns should be sent to:
Email: info@ecotechrecycle.co.uk
Subject: Data Security Concern / Data Erasure Complaint
Where possible, please include:
customer name;
organisation name;
contact details;
collection or job reference;
device details;
serial number or IMEI;
relevant date;
description of the concern;
relevant evidence; and
the outcome requested.
Eco Tech Recycle will review the matter under its Complaints Policy and applicable legal obligations.
Nothing in this Policy prevents an individual from exercising any rights or making a complaint to the ICO where applicable.

37. Changes to This Policy

Eco Tech Recycle may update this Policy to reflect changes in:
law or regulatory guidance
business operations;
security practices;
data-erasure software;
device technology;
processing routes;
customer requirements;
internal procedures; or
industry guidance.
The version applying to a confirmed service will normally be the version in force when the service was agreed, together with any specific written terms applicable to that service.
Later changes will not normally alter a confirmed contract retrospectively unless:
the customer agrees;
the change is required by law; or
another lawful basis permits the change.
The current version will be available on our website.

38. Contact Us

Eco Tech Recycle
A trading name of Tech Cell Limited
Company No. 14338989
Email: info@ecotechrecycle.co.uk
Telephone: +44 7777 239555
Website: www.ecotechrecycle.co.uk
Contact Address:
Suite 2, First Floor
16 Industrial House
Grand Arcade
London
N12 0EH