Privacy Policy

The privacy and security of your personal information is extremely important to us. This privacy policy explains how and why we use your personal data, to make sure you stay informed and can be confident about giving us your information.  

We’ll keep this page updated to show you all the things we do with your personal data. This policy applies if you’re a customer of First Trace Heating Direct Ltd. or its subsidiary brands or use any of our services, visit our website, use our mobile app, email, call or write to us. In certain circumstances we may also provide an extra privacy notice, which will always refer to this page.

We’ll never sell your personal data and will only share it with organisations we work with when it’s necessary and the privacy and security of your data is assured. 

By continuing to use the website you accept these terms and conditions.

We may need to disclose your personal data where we are under a legal duty to comply with any legal obligation.

Who are ‘we’?

First Trace Heating Direct Ltd. is a company registered in England under company number 3492441. Our registered office is 9 Winckley Square, Preston, Lancashire, PR1 3HP. We are committed to ensuring that your privacy is protected. This policy sets out the basis on which any personal data we collect from you, or that you provide to us will be processed by us.

Information we collect & how we’ll use it

When you use any online form on our website, respond to a survey, or enter a competition or promotion, we need to know your name and other information such as your postal address, email address, telephone number (which are your personal data), as well as your purchase history for our warranty application form.

By submitting this information you consent to our use of the information in accordance with this Privacy Policy as amended from time to time. We gather this information to allow us to process your request.

We may also use aggregate information and statistics for the purposes of monitoring website usage in order to help us develop the website and our service and may provide such aggregate information to third parties. These statistics will not include information that can be used to identify any individual.

We may also wish to provide you with information about special features of our website or any special service or products which we think may be of interest to you. You can unsubscribe to these materials by contacting us via email at or calling us on 01772 761333.

We’ll only use your personal data on relevant lawful grounds as permitted by the EU General Data Protection Regulation (from 25 May 2018)/UK Data Protection Act and Privacy of Electronic Communication Regulation.

Personal data provided to us will be used for the purpose or purposes outlined in any fair processing notice in a transparent manner at the time of collection or registration where appropriate, in accordance with any preferences you express. If asked by the police, or any other regulatory or government authority investigating suspected illegal activities, we may need to provide your personal data.

We will retain your data in line with the lifespan of the business needs. Warranty information and information relating to invoices will be retained for 50 years and quotations which are not followed through to sales will be retained for 5 years. We will delete your data during the following business quarter.

Below are the main uses of your data which depend on the nature of our relationship with you and how you interact with our various services, websites and activities. 

Our use of cookies, internet protocol (ip) addresses and other information gathering technologies

Please note that the information we gather from the following technologies does not specify any specific individual and is used by us as statistical data only about our users browsing actions and patterns.

Technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform and if you access our website via your mobile device we will collect your unique phone identifier.

Information about your visit, including, but not limited to the full Uniform Resource Locators (URL) and query string, clickstream to, through and from our website (including date and time), products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as but not limited to, scrolling, clicks, and mouse-overs), and methods used to browse away from the page.

The terms that you use to search our website.

You can choose to refuse to accept the above by activating the setting on your browser which allows you to refuse the setting of cookies. However, if you select this setting you will be unable to access certain parts of our site. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you log on to our site. Modern browsers provide the ability to navigate the web privately by using “private browsing mode” or you can use a proxy server, which allows web users to see pages via a third party web server.

Marketing communications 

Your privacy is important to us, so we’ll always keep your details secure. We’d like to use your details to keep in touch about things that may matter to you. 

If you choose to hear from us we may send you information based on what is most relevant to you. This might be about new products, services or promotions.

We’ll only send these to you if you agree to receive them and we will never share your information with companies outside First Trace Heating Direct Ltd, or its subsidiaries, for inclusion in their marketing. (We may however share cookie data with third parties to help with our own advertising targeting). If you agree to receive marketing information from us you can change your mind at a later date. 

Personal data provided to us may also be profiled to help us with advertising targeting. For example, we may use your personal data to find online users with a similar profile to yourself who may be interested in our products or services.

We may sometimes use third parties to capture some of our data on our behalf, but only where we are confident that the third party will treat your data securely, in accordance with our terms and inline with the requirements set out in the GDPR.

Use of the SnugStat app data  

The data provided by the SnugStat app user account holder are only used for the handling of your app usage requests and functions, and access to the SnugStat app for registration purposes, including:

How the user uses SnugStat Thermostat products: We will collect information about how the user, and where the user share’s access, others are using SnugStat Thermostat products and services in their property and their performance, what devices are connected to them and how those devices are being used with the SnugStat products. For example, this includes information about the smart devices connected to your SnugStat Thermostat, collect about rooms’ temperatures, temperature settings and heating schedules. In addition, we will collect information about the pages users visit in the SnugStat app and how they use them.

Location information: We will collect information about a user’s exact location when they choose to share that with us. For example, the user may set up their SnugStat app to lower the temperature of the heating as they get further away from their property. To do this, the user will need to opt in, switch on their location settings and set their desired heating distance-based rules. We will also collect location information of the SnugStat Thermostat, as part of the SnugStat app set-up process, but this is only used for when the distance-based rules are activated, as detailed above.

Users are not required to provide any of the personal information described above to us, however, if you do not do so, you may not be able to use our products and services, or the functionality of our products may be reduced.

We are committed to taking appropriate technical and organisational measures to protect your personal data against unauthorised or unlawful processing and against accidental loss, destruction or damage to personal data. When you provide your personal data through the SnugStat app, this information is held and stored in an encrypted file. The information that you provide to us will be held in our systems, which are located on our premises or those of an appointed third party. We may also allow access to your information by other third parties who act for us for the purposes of providing and maintaining the SnugStat app. Your personal data may be accessed by and processed outside the European Economic Area (the European Economic Area being the European Union and Iceland, Liechtenstein and Norway, also referred to as the “EEA”) - including by staff operating outside the EEA who work for us or for one of our suppliers. Where your personal data are transferred outside of the EEA, we ensure that appropriate safeguards are in place. 

Personal data created by your involvement with us

Your interaction and involvement with us will result in personal data being created. This could include details of how and when the following takes place: products purchased, enquiries, quotations, sales calls and visits to our stands at exhibitions.

Call recording and monitoring

We monitor and record calls, emails, SMS messages or other communications including those on social media platforms for:

  • Business purposes such as quality control and training
  • Processing necessary information for entering into or performance of a contract
  • Meeting any legal obligation
  • To investigate and analyse any queries or concerns you raise with us
  • For the legitimate interests of the data controller

We are the controller and we are also the processor of this information. This data has been gathered with your consent from your giving of this information over the telephone and your continued use of the telephone system following notification that your call will be recorded. It is also gathered in the legitimate interests of retaining vital information that may be required in the event of a claim for breach of contract or professional negligence.

Recruitment and employment 

In order to comply with our contractual, statutory, and management obligations and responsibilities, we process personal data, including ‘sensitive’ personal data, from job applicants and employees.  

Such data can include, but isn’t limited to, information relating to health, racial or ethnic origin, and criminal convictions. In certain circumstances, we may process personal data or sensitive personal data, without explicit consent. Further information on what data is collected and why it’s processed is given below.

- Contractual responsibilities: Our contractual responsibilities include those arising from the contract of employment. The data processed to meet contractual responsibilities includes, but is not limited to, data relating to: payroll, bank account, postal address, sick pay; leave, maternity pay, pension and emergency contacts.

- Statutory responsibilities: Our statutory responsibilities are those imposed through law on the organisation as an employer. The data processed to meet statutory responsibilities includes, but is not limited to, data relating to: tax, national insurance, statutory sick pay, statutory maternity pay, family leave, work permits, equal opportunities monitoring.

- Management responsibilities: Our management responsibilities are those necessary for the organisational functioning of the organisation. The data processed to meet management responsibilities includes, but is not limited to, data relating to: recruitment and employment, customer service calls, training and development, absence, disciplinary matters, e-mail address and telephone number.

Sensitive personal data

The Act defines ‘sensitive personal data’ as information about racial or ethnic origin, political opinions, religious beliefs or other similar beliefs, trade union membership, physical or mental health, sexual life, and criminal allegations, proceedings or convictions.  

In certain limited circumstances, we may legally collect and process sensitive personal data without requiring the explicit consent of an employee.

(a) We will process data about an employee’s health where it is necessary, for example, to record absence from work due to sickness, to pay statutory sick pay, and to make any necessary arrangements or adjustments to the workplace in the case of disability. This processing will not normally happen without the employee’s knowledge and, where necessary, consent.

(b) We will process data about, but not limited to, an employee’s racial and ethnic origin, their sexual orientation or their religious beliefs only where they have volunteered such data and only for the purpose of monitoring and upholding our equal opportunities stance and related provisions.

(c) Data about an employee’s criminal convictions will be held as necessary.

Disclosure of personal data to other bodies

In order to carry out our contractual and management responsibilities, we may, from time to time, need to share an employee’s personal data with one or more third party supplier. 

To meet the employment contract, we are required to transfer an employee’s personal data to third parties, for example, to pension providers and HM Revenue & Customs.

In order to fulfil our statutory responsibilities, we’re required to give some of an employee’s personal data to government departments or agencies e.g. provision of salary and tax data to HM Revenue & Customs.


First Trace Group Ltd. will notify all members of any changes it makes to its Privacy Policy. If First Trace Group Ltd. decides to change its Privacy Policy, it will post such changes on this page so that you are always aware of how First Trace Group Ltd. uses your personal data.

How to contact First Trace Heating Direct Ltd.

We welcome your views about our website and our Privacy Policy. If you would like to contact us with any queries or comments please send an email to or telephone 01772 761 333. Should you feel that your data is not being handled properly, you can complain to the ICO (Information Commissioners Office).

How can I change my marketing and contact preferences?

We'd love to stay in touch, but we don't want to out-stay our welcome.

We’ll always act upon your choice of how you want to receive communications (for example, by email, post or phone). However, there are some communications that we need to send. These are essential to fulfil our promises to you as a customer. Examples are:

- Transaction messaging, such as invoices or purchase confirmations. warranty information or app updates.

- Product related messaging, such as warranty information or app updates.

If, at any time, you want to update or amend your personal data or marketing preferences please contact us in one of the following ways either by email to or by calling 01772 761 333.

Business purposes such as quality control and training

Processing necessary information for entering into or performance of a contract

Meeting any legal obligation

To investigate and analyse any queries or concerns you raise with us

For the legitimate interests of the data controller

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