1. Privacy Policy Overview
This Privacy Policy provides a transparent overview of how TOR ANALYTICS LTD handles personal data in connection with our information technology and data analytics services. It applies to visitors to our website, prospective and existing clients, individuals who contact us, and, where relevant, individuals whose data may be processed as part of our business intelligence, predictive modelling, data pipeline, dashboard development, and analytics projects.
We act primarily as a data controller for personal data we collect directly (for example, via our website, contact forms, and marketing activities). In some engagements we may also act as a data processor on behalf of our clients, processing personal data strictly in accordance with their documented instructions and applicable data processing agreements. Where we act as a processor, our clients' privacy notices will usually govern how personal data is used.
By using our website or engaging with our services, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with any part of this policy, you should discontinue use of our website and services.
2. Information Collection
We collect a range of personal and non-personal information to provide our services, operate our website, and improve our analytics offerings.
2.1 Information you provide to us
We may collect personal data that you voluntarily provide when you:
- Complete a contact form or enquiry via our website at Contact Us.
- Request a proposal, demonstration, or consultation relating to our services, solutions, or analytics capabilities.
- Subscribe to updates, whitepapers, case studies, or other marketing communications.
- Engage with us during pre-sales, contracting, or project delivery.
- Participate in surveys, feedback exercises, events, or webinars that we host or sponsor.
The types of personal data you may provide include:
- Identification details (such as your name, job title, role, or department).
- Contact details (such as email address, telephone number, organisation name, and postal address).
- Professional information (such as industry, areas of responsibility, and solution interests).
- Content of communications (such as enquiry details, project requirements, technical specifications, or feedback).
2.2 Information collected automatically
When you access or use our website, we may automatically collect certain technical and usage information, including:
- Device and browser information (such as IP address, operating system, browser type and version, device identifiers, and device settings).
- Usage data (such as pages viewed, links clicked, time spent on pages, navigation paths, and referring/exit pages).
- Approximate location data derived from your IP address (such as city, region, and country).
This information is typically collected through cookies and similar tracking technologies described in section 5 below, and is primarily used in aggregated or pseudonymised form for analytical and security purposes.
2.3 Information we receive from third parties
We may receive personal data about you from third-party sources, such as:
- Business partners and referral networks that introduce you to our services.
- Event and webinar platforms, where you register to attend an event that we host or co-host.
- Publicly available sources, such as professional networking sites, company websites, or business registries, where this is permitted by law.
We may combine this information with data we already hold to improve the accuracy and completeness of our records, subject to applicable law.
2.4 Special category and children’s data
Our website and services are directed at business and professional users. We do not knowingly collect special category personal data (such as health, biometric, or sensitive information) or data relating to children. If you believe we have inadvertently collected such data, please contact us using the details in section 11 so that we can delete or restrict it appropriately.
3. Use of Information
We use the personal and non-personal information we collect for the following purposes, in each case to the extent permitted by applicable law:
- Service delivery and account management: To respond to enquiries, provide proposals, design and deliver data analytics, business intelligence, predictive modelling, data architecture, dashboard, and insight generation services, and to manage our relationship with you or your organisation.
- Analytics and service improvement: To monitor website performance, understand how visitors engage with our content, measure the effectiveness of campaigns, and improve our services, solutions, and user experience.
- Communication: To send administrative messages, project updates, service notices, security alerts, and other service-related communications.
- Marketing and business development: To send information about our services, solutions, case studies, events, and insights that we believe may be relevant to you, in accordance with applicable marketing and e-privacy laws and your communication preferences.
- Security and abuse prevention: To protect our website, systems, and data from unauthorised access, cyber threats, misuse, or other harmful activities, and to detect, prevent, and investigate potential fraud or security incidents.
- Compliance and legal obligations: To comply with legal and regulatory requirements, respond to lawful requests from public authorities, and exercise or defend legal claims.
- Business operations: To manage our internal operations, including finance, reporting, audit, governance, and strategic planning.
Where we use your information for marketing purposes, you can opt out at any time by following the unsubscribe instructions in our communications or by contacting us as described in section 11.
4. Legal Basis for Processing
Under UK GDPR, GDPR, and the UK Data Protection Act 2018, we must have a valid legal basis to process personal data. Depending on the context, we rely on the following legal grounds:
- Contractual necessity: Where processing is necessary to enter into or perform a contract with you or your organisation, for example to provide our analytics services, respond to requests for proposals, or manage ongoing projects.
- Legitimate interests: Where processing is necessary for our legitimate interests or those of a third party, provided that these interests are not overridden by your fundamental rights and freedoms. This includes interests such as operating and improving our website, developing our services, securing our systems, and conducting business development. We perform legitimate interest assessments where required.
- Consent: Where we rely on your consent, for example for certain types of marketing communications or the use of non-essential cookies and similar technologies. You may withdraw your consent at any time without affecting the lawfulness of processing before withdrawal.
- Legal obligation: Where processing is necessary to comply with laws and regulations, such as tax, accounting, or regulatory reporting obligations.
In situations where we act as a data processor on behalf of a client, the client is responsible for determining the appropriate legal basis for processing and for providing relevant privacy information to affected individuals.
6. Data Sharing and Disclosure
We do not sell your personal data. We may, however, share personal data with carefully selected third parties where necessary for the purposes described in this policy and subject to appropriate safeguards.
6.1 Service providers and partners
We may share personal data with trusted third-party service providers who assist us with:
- Hosting, infrastructure, and cloud computing services.
- Data storage, backup, and security services.
- Customer relationship management (CRM) and communication tools.
- Web analytics, performance monitoring, and marketing platforms.
- Professional services such as legal, accounting, or consultancy support.
These providers only process personal data on our instructions, are bound by confidentiality obligations, and are required to implement appropriate technical and organisational measures to protect the data.
6.2 Business transfers
In the event of a merger, acquisition, restructuring, or sale of some or all of our assets, personal data may be transferred as part of the transaction, subject to confidentiality arrangements and continued protection consistent with this policy.
6.3 Legal and regulatory disclosures
We may disclose personal data where required to do so by law, regulation, or legal process, or in response to valid requests by public authorities (such as law enforcement or regulatory bodies). We may also share information where we believe it is necessary to protect our rights, privacy, safety, or property, or that of our clients, staff, or the public.
7. Data Security Measures
We take data security seriously and implement a range of technical and organisational measures designed to protect personal data against unauthorised access, accidental loss, alteration, or disclosure.
These measures include, as appropriate:
- Use of secure, access-controlled environments for data processing and storage.
- Encryption of data in transit and, where appropriate, at rest.
- Role-based access controls and the principle of least privilege for staff and contractors.
- Regular patching, monitoring, and maintenance of systems and infrastructure.
- Logical and physical security controls at our office and data centres operated by our providers.
- Staff awareness, confidentiality obligations, and guidance on responsible data handling.
- Vendor due diligence and data processing agreements with relevant third parties.
While we strive to protect personal data using commercially reasonable safeguards, no system can be completely secure. If we become aware of a personal data breach that is likely to result in a high risk to your rights and freedoms, we will notify you and relevant authorities in line with our legal obligations.
8. Data Retention
We retain personal data only for as long as necessary to fulfil the purposes for which it was collected, including to meet legal, regulatory, accounting, or reporting requirements.
Retention periods may vary depending on the nature of the data and our relationship with you, but in general:
- Enquiry and contact information is typically retained for a period that allows us to respond fully, manage follow-up discussions, and maintain appropriate business records.
- Client and project-related data is retained for the duration of the engagement and for a period thereafter as required for contract management, audit, compliance, and limitation periods for legal claims.
- Marketing-related data is retained while you remain subscribed or otherwise engaged with our communications, or until you object or opt out, after which we may retain limited information to respect your preferences.
When personal data is no longer required, we will either securely delete or anonymise it so that it can no longer be associated with an identifiable individual.
9. International Data Transfers
TOR ANALYTICS LTD is based in the United Kingdom, and personal data may be processed and stored in the UK, the European Economic Area (EEA), or other countries where our service providers operate.
Where personal data is transferred outside the UK or EEA to a country that has not been deemed to provide an adequate level of data protection, we implement appropriate safeguards, such as:
- Using Standard Contractual Clauses (SCCs) or International Data Transfer Agreements (IDTAs) approved by relevant authorities.
- Conducting transfer risk assessments and implementing supplementary measures where appropriate.
- Ensuring that recipients maintain robust security measures and respect data protection principles.
You may contact us for more information about the specific safeguards used for international data transfers that involve your personal data.
10. Your Rights
Subject to applicable law and certain limitations, you have a range of rights in relation to the personal data we hold about you. These may include:
- Right of access: To obtain confirmation as to whether we process your personal data and, if so, to receive a copy and certain information about how it is used.
- Right to rectification: To request correction of inaccurate or incomplete personal data.
- Right to erasure: To request deletion of your personal data in certain circumstances, for example where it is no longer needed for the purposes for which it was collected or where you withdraw consent.
- Right to restriction: To request that we restrict the processing of your personal data in certain situations, such as while we verify its accuracy or assess an objection.
- Right to data portability: To receive personal data you have provided to us in a structured, commonly used, and machine-readable format and, where technically feasible, have it transmitted to another controller.
- Right to object: To object to processing based on our legitimate interests or for direct marketing purposes. We will respect your objection to marketing in all cases.
- Rights relating to consent: Where we rely on consent, you have the right to withdraw that consent at any time.
You also have the right to lodge a complaint with a supervisory authority. In the United Kingdom, this is the Information Commissioner's Office (ICO). Further information is available at www.ico.org.uk.
To exercise any of your rights, please use the contact details provided in section 11. We may need to verify your identity before fulfilling your request and will respond within the timeframes set by applicable law.
11. Contact for Privacy Matters
If you have any questions about this Privacy Policy, our data handling practices, or wish to exercise your data protection rights, you can contact us using the following details:
TOR ANALYTICS LTD
Apollo House Hallam Way
Whitehills Business Park
Blackpool, England, FY4 5FS
United Kingdom
Telephone: +44 207 353 6170
Email: [email protected]
When contacting us about your privacy rights, please provide sufficient information for us to identify you and understand your request. We may ask for additional information where necessary to confirm your identity and ensure we protect your data.
If you are an end user whose data is processed by us on behalf of a client (for example, your employer), we may need to direct your request to that client, who acts as the primary data controller.
12. Policy Updates
We may update this Privacy Policy from time to time to reflect changes in our services, technologies, legal requirements, or data protection best practices.
When we make material changes, we will take appropriate steps to inform you, such as updating the effective date at the top of this page, providing a prominent notice on our website, or contacting you directly where appropriate.
We encourage you to review this page periodically to stay informed about how we protect your information. Your continued use of our website or services after any changes to this Privacy Policy signifies your acceptance of the updated terms.
This Privacy Policy is intended to complement, not replace, our Terms and Conditions and Cookie Policy. In the event of any inconsistency, applicable data protection laws shall prevail.