Privacy Notice
Effective date: 26 July 2026
Last updated: 26 July 2026
1. About this privacy notice
This privacy notice explains how Fatrao Limited, trading as CouloirIQ, collects, uses, stores, shares and protects personal information.
It applies when you visit the CouloirIQ website; create or use an account; perform an import compliance check; create, manage or participate in a trade workspace; upload, review or manage trade documents; respond to a supplier or business partner request; communicate with us; purchase or trial our services; receive business communications from us; or otherwise interact with CouloirIQ.
This notice also explains your rights under applicable data protection law.
2. Who we are
CouloirIQ is a trade operations and import compliance platform designed to help businesses identify import requirements, collect supplier documentation, manage trade workspaces, review documents, track actions and maintain an audit trail.
The organisation responsible for the personal information described in this notice is:
Fatrao Limited, trading as CouloirIQ
Privacy contact: connect@couloiriq.com
Fatrao Limited’s statutory company information is available on our Company Information page.
For personal information that we collect for our own business purposes, Fatrao Limited acts as the data controller.
When a CouloirIQ customer uploads or submits personal information to a workspace for its own business purposes, that customer will usually be the data controller and Fatrao Limited will process the information on the customer’s behalf as a data processor.
In those circumstances, questions about the customer’s use of your personal information should normally be directed to that customer. We will assist our customers with their data protection responsibilities where required.
3. Personal information we collect
The personal information we collect depends on how you interact with CouloirIQ.
3.1 Account and identity information
We may collect your name, business email address, telephone number, job title, organisation details, account credentials and authentication information, team membership, role and permissions, profile information, and communication and account preferences.
3.2 Trade and workspace information
Information entered into or generated through a CouloirIQ workspace may include:
- buyer, importer, exporter and supplier details;
- freight forwarder, insurer, customs representative or adviser details;
- contact names and business contact details;
- countries of origin and destination;
- product and commodity descriptions and HS or commodity codes;
- transport methods, routes and shipment locations;
- shipment dates and milestones;
- Incoterms, payment methods and commercial terms;
- invoice values and currencies;
- package, weight and volume information;
- vessel, carrier, voyage, consignment, container and seal details;
- compliance requirements and regulatory checks;
- document statuses, actions, approvals and exceptions;
- claims, incidents and closeout information;
- workspace notes and messages; and
- activity and audit records.
3.3 Documents and extracted information
You or another authorised participant may upload trade-related documents, including commercial and pro forma invoices, packing lists, purchase orders, transport documents, bills of lading, air waybills, road transport documents, certificates of origin, customs documents, regulatory certificates, licences, permits, supplier declarations, sustainability documents, insurance and payment documents, letters of credit, inspection reports, supplier questionnaires and other files relevant to a trade transaction.
These documents may contain names, signatures, job titles, business contact details, addresses, identification or reference numbers, bank or payment information and information about individuals involved in a trade transaction.
CouloirIQ may use optical character recognition, document recognition and artificial intelligence-assisted extraction to identify document types; extract relevant information; populate workspace fields; compare information across documents; identify missing information; flag possible inconsistencies; suggest document or compliance actions; and support document review.
You are responsible for ensuring that you are authorised to upload documents and personal information to CouloirIQ. You should avoid uploading personal information that is not necessary for the relevant trade or compliance process.
3.4 Supplier and invited participant information
When a customer invites a supplier or another participant, we may collect the participant’s name, organisation, business contact details and job title; responses and uploaded documents; messages; submission dates; invitation status; activity history; and technical information associated with the invitation link.
A supplier or invited participant may be able to submit documents through a secure link without creating a full CouloirIQ account.
3.5 Subscription, billing and payment information
When you purchase or trial a service, we may collect billing and organisation details, subscription and trial information, transaction amount and currency, payment status, invoice and tax information, subscription dates and limited information about the payment method used.
Payment card information is generally collected and processed directly by our payment service provider. CouloirIQ does not need to store your complete payment card number or card security code.
3.6 Communications and customer support
When you contact us, we may collect emails, messages, support requests, demonstration and sales enquiries, feedback, survey responses, complaints, attachments and records of our communications with you.
3.7 Technical and usage information
We may collect IP address; browser, device and operating-system information; approximate location derived from an IP address; login dates and times; pages, screens and features used; actions performed; referring source; session and cookie identifiers; diagnostics; and error, security and audit logs.
3.8 Sales and business contact information
We may collect professional information about potential customers, partners and business representatives from information you provide, company websites, professional networking platforms, public business registers, trade directories, industry publications, events, referrals, partners and reputable business information providers.
This may include your name, role, organisation, business contact details, professional profile, industry, organisation size and location, and information indicating that your organisation may have a relevant interest in CouloirIQ.
We do not intend to collect private or sensitive personal information for sales prospecting purposes.
4. How we use personal information
4.1 To provide CouloirIQ
We may use personal information to create and administer accounts; authenticate users; manage teams, roles and permissions; perform import compliance checks; create and manage trade workspaces; enable authorised collaboration; receive, store, analyse and review documents; populate workspace fields; identify missing information or possible inconsistencies; manage supplier requests; track requirements, actions and milestones; produce reports, audit trails and exportable records; provide subscription functions; and deliver support.
Our lawful basis is normally that the processing is necessary to perform a contract with you or to take steps at your request before entering into a contract. Where you use CouloirIQ for an organisation, we may also rely on our legitimate interests and those of your organisation in providing and administering the service.
4.2 Supplier and participant invitations
We may use personal information to send requests; manage secure invitation links; authenticate or validate submissions; associate submissions with the correct workspace; record activity; send reminders; and enable authorised communications.
Our lawful basis is performance of our contract with the relevant customer and our legitimate interest in providing secure document collection and collaboration.
4.3 Payments and subscriptions
We may use billing and transaction information to process payments, administer trials and plans, issue invoices, maintain payment and tax records, prevent fraud and manage cancellations and renewals.
Our lawful bases are performance of a contract, compliance with legal obligations, and our legitimate interests in administering our business and preventing fraud.
4.4 Security and prevention of misuse
We may process personal information to verify identities; authenticate accounts; manage access; detect suspicious activity; prevent fraud and abuse; protect accounts, workspaces and documents; investigate incidents; maintain backups; enforce our terms; and protect CouloirIQ, our customers and others.
Our lawful basis is our legitimate interest in maintaining security, integrity and availability. We may also process information to comply with law or establish, exercise or defend legal claims.
4.5 Improvement and development
We may use service usage information, feedback, errors and performance information to improve user experience; fix problems; understand feature use; test performance; improve document processing and compliance workflows; develop features; and maintain quality and reliability.
Where reasonably possible, we use aggregated, anonymised or de-identified information. Our lawful basis is our legitimate interest in improving and maintaining our services.
We do not use customer trade documents to train general-purpose artificial intelligence models unless we have clearly informed the relevant customer and established an appropriate legal and contractual basis.
4.6 Communications
We may send account, authentication, security, subscription, billing, service, workspace and supplier-request messages; reminders; responses; support communications; important product announcements; and information about relevant features and services.
Operational communications are necessary to provide the service and may not be disabled while the related account, invitation or workspace remains active.
4.7 Promotion
We may use professional contact information to communicate with businesses and representatives who may have a genuine interest in CouloirIQ. Our lawful basis may be consent or our legitimate interest in promoting and growing our business.
Where we rely on legitimate interests, we consider relevance to your role, likely organisational interest, the source and nature of the information, likely effect, proportionality and reasonable expectations.
Electronic marketing will comply with applicable direct marketing rules. Every marketing email will provide a clear way to unsubscribe. You can object at any time using the unsubscribe option or by emailing connect@couloiriq.com. We may retain limited suppression information to respect your preference.
4.8 Legal and regulatory obligations
We may use or disclose personal information to maintain tax and accounting records; respond to lawful requests; cooperate with regulators; investigate suspected unlawful activity; comply with law; manage disputes; and establish, exercise or defend legal claims.
Our lawful basis is compliance with a legal obligation or our legitimate interest in protecting our legal rights.
5. Artificial intelligence and automated processing
CouloirIQ may use automated technologies and artificial intelligence-assisted tools to classify documents; extract and compare information; suggest relevant trade requirements; detect missing information; identify possible inconsistencies or exceptions; prioritise actions; generate summaries and draft requests; and produce supporting materials.
These tools assist business users and do not replace professional legal, customs, regulatory, financial or tax advice. Automated outputs may be incomplete or inaccurate. Users should review important results, source documents and regulatory requirements before making decisions.
CouloirIQ does not intend to make decisions about individuals that produce legal or similarly significant effects solely through automated processing. Authorised users should review underlying information and exercise their own judgement.
6. Special category and sensitive information
CouloirIQ is not designed for routine collection of special category personal information, including health, race or ethnic origin, beliefs, political opinions, trade union membership, sexual orientation, sex life, genetic information or biometric information used for identification.
Please do not upload this information unless genuinely necessary, lawful and appropriate. Trade documents may occasionally contain identification documents, signatures, bank details or other sensitive information. Customers and users should minimise and redact information that is not required.
7. Where we obtain personal information
We may obtain personal information directly from you; from the organisation administering your account; from a customer or authorised workspace participant; from uploaded documents; from payment, authentication, hosting and communication providers; from public business sources and professional networks; and from referrals, partners and reputable business information providers.
When another organisation provides your information, it is responsible for ensuring an appropriate lawful basis.
8. Who we share personal information with
8.1 Authorised workspace participants
Workspace information may be available to authorised customer representatives and invited trade participants, including buyers, importers, exporters, suppliers, freight forwarders, customs representatives, insurers, banks, advisers and other authorised transaction participants.
Access depends on permissions. Customers decide whom they invite and what access each participant receives.
8.2 Service providers
We may use providers supporting cloud hosting, databases, file storage, authentication, email, messaging, payments, document recognition, optical character recognition, artificial intelligence-assisted processing, analytics, error monitoring, support, cybersecurity, accounting, legal and other professional services.
They may process personal information only as necessary to provide their services and subject to appropriate contractual, organisational and security requirements.
8.3 Professional advisers and authorities
We may disclose information to lawyers, accountants, auditors, insurers, regulators, law enforcement, courts, tax authorities and other authorities where reasonably necessary, legally required or appropriate to protect rights.
8.4 Business transfers
If Fatrao Limited is involved in a merger, investment, financing, acquisition, restructuring, insolvency or asset sale, relevant information may be disclosed to advisers, potential investors or purchasers, lenders and other participants under appropriate safeguards.
We do not sell personal information.
9. International transfers
CouloirIQ may use providers or infrastructure outside the United Kingdom, and authorised participants may access information from other countries.
Where information is transferred outside the UK, safeguards may include UK adequacy regulations, the UK International Data Transfer Agreement, the UK Addendum to approved standard contractual clauses, transfer risk assessments and additional contractual, technical and organisational measures.
Contact connect@couloiriq.com for more information.
10. How long we keep personal information
We retain personal information only for as long as reasonably necessary. Retention depends on the nature and sensitivity of the information; purpose; customer relationship and instructions; security and contractual requirements; legal limitation periods; and tax, accounting or regulatory obligations.
In general:
- account information is retained while active and for a reasonable period after closure;
- workspace information and trade documents are retained according to subscription, settings and contractual arrangements;
- supplier submissions are retained with the workspace unless deleted under customer instructions or law;
- invoices, transactions and accounting information may be retained for at least six years where required;
- contractual and important customer communications may be retained for up to six years after the relationship ends;
- support records are retained as reasonably necessary;
- security, access and technical logs are normally retained for shorter periods unless needed for an investigation;
- sales prospect information is periodically reviewed and deleted, updated or suppressed; and
- unsubscribe and objection records may be retained to respect preferences.
Information may remain temporarily in encrypted or protected backups after removal from active systems. Backups are isolated from ordinary use and deleted or overwritten according to our schedule.
Where CouloirIQ acts as a processor, retention and deletion may be governed by our agreement with the customer.
11. Security
We use appropriate technical and organisational measures designed to protect personal information against unauthorised access, accidental loss, unlawful disclosure, alteration, misuse and destruction.
Measures may include encryption in transit and at rest where appropriate; authentication and role-based controls; secure invitation links; access restrictions; audit and security logging; backups; vulnerability management; provider assessments; monitoring; incident response; and internal access restrictions.
No online service can guarantee absolute security. You are responsible for protecting credentials, using secure devices and networks, assigning appropriate permissions, keeping invitation links secure and notifying us promptly of suspected unauthorised access.
Report security concerns to connect@couloiriq.com.
12. Cookies and similar technologies
CouloirIQ may use cookies, local storage and similar technologies to keep users signed in; maintain secure sessions; remember preferences; operate core functions; prevent fraud; protect accounts; understand usage; identify and fix errors; and improve performance.
Strictly necessary cookies may be used without consent where permitted. Non-essential analytics or marketing cookies will be used only where appropriate consent or another lawful basis applies.
Where a preference tool is provided, you can manage non-essential cookies through it. You can also control cookies in your browser; disabling necessary cookies may prevent parts of CouloirIQ from working correctly.
Further details may be provided in a separate Cookie Notice.
13. Your data protection rights
Depending on the circumstances and applicable law, you may have the right to:
- request access to your personal information;
- request correction of inaccurate or incomplete information;
- request deletion;
- request restriction of processing;
- object to processing based on legitimate interests;
- object to direct marketing at any time;
- request transfer of certain information in a portable format;
- withdraw consent where processing is based on consent;
- raise concerns about certain automated processing; and
- complain about how your information is used.
These rights are not absolute and may be subject to legal conditions or exemptions.
To exercise a right, email connect@couloiriq.com. Describe your request clearly and provide enough information to identify relevant records. We may need to verify your identity.
Where CouloirIQ acts for a customer, we may refer your request to that customer, ask you to contact it directly or assist it in responding.
You will not normally be charged. We may charge a reasonable fee or refuse to act where permitted by law, including where a request is manifestly unfounded or excessive.
14. Complaints
If you have a concern, contact connect@couloiriq.com first. Include your name, contact details, a description, the relevant account, workspace or communication, and the outcome you seek.
We will acknowledge a data protection complaint within 30 days and respond without undue delay.
You also have the right to complain to the UK Information Commissioner’s Office:
Information Commissioner’s Office
Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, United Kingdom
Telephone: 0303 123 1113
Current contact information and complaint guidance are available through the Information Commissioner’s Office website. If you are outside the UK, you may also have the right to contact your local data protection authority.
15. Children
CouloirIQ is a business-to-business trade platform and is not intended for children. You must be at least 18 years old to create an account or use CouloirIQ on your own behalf.
We do not knowingly collect personal information directly from children. If you believe a child has provided personal information, contact connect@couloiriq.com.
16. Third-party websites and services
CouloirIQ may link to third-party websites, services or resources. Those third parties are responsible for their privacy practices. This notice does not apply to information they process independently. Review their privacy notices before providing information.
17. Changes to this privacy notice
We may update this notice when our services, data practices, providers, technologies or legal requirements change, or to clarify how information is handled.
The latest version will be published with an updated date. Where a change materially affects how we use personal information, we may notify affected users by email, through their account or another appropriate method.
18. Contact us
For privacy questions, data protection requests, complaints or concerns, contact:
Fatrao Limited, trading as CouloirIQ
Email: connect@couloiriq.com
Fatrao Limited’s statutory company information is available on our Company Information page.