At ToolUp, we are committed to protecting and respecting your privacy. This Privacy Policy explains how we collect, use, store, and protect your personal information when you interact with our website and our services. ToolUp (referred to as "we", "us", or "our") acts as the data controller for the personal data described in this policy.

1. Information we collect

We may collect and process the following types of information:

• Personal Information:

Such as your name, email address, phone number, job title, and company name when you fill out forms, contact us, subscribe to updates, or engage our services.

• Technical Information:

Including IP address, browser type, device type, and browsing behaviour on our website via cookies and analytics tools.

• Business Information:

Information relating to your company and marketing activities if relevant to providing our consultancy services.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data).

We do not knowingly collect data from children under 16 years of age. If we learn that we have collected personal data from a child, we will take steps to delete that information.

2. How we use your information

We use the information we collect to:

• Respond to your enquiries or requests
• Provide, develop, and improve our services
• Communicate marketing updates, insights, or thought leadership (only if you opt-in)
• Understand website usage and improve user experience
• Comply with legal obligations

Legal basis for processing

We process your personal data on the following legal grounds:

• Contractual necessity: When processing is necessary to fulfill a contract with you or take steps at your request before entering into a contract

• Legitimate interest: When processing is necessary for our legitimate interests (or those of a thirdparty), provided your fundamental rights do not override these interests

• Consent: When you have given clear consent for us to process your personal data for a specific purpose

• Legal obligation: When processing is necessary for compliance with a legal obligation

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

3. How we share your information

We do not sell, rent, or trade your data.

We may share your information with:

• Service providers and third parties assisting us with website hosting, analytics, CRM, and marketing tools (e.g. Google Analytics, HubSpot)
  
• Law enforcement or regulatory bodies if legally required

All third parties are required to maintain confidentiality and process data in compliance with GDPR.

4. Cookies

We use cookies to improve site functionality and understand visitor behaviour.

You can control cookies through your browser settings or opt out where applicable.

5. Your data protection rights

Under GDPR, you have the right to:

• Access the personal information we hold about you
• Request correction or deletion of your information
• Object to or restrict processing
• Request the transfer of your data to you or a third party (data portability)
• Withdraw consent at any time
• Lodge a complaint with a supervisory authority (e.g., the UK Information Commissioner's Office)

To exercise these rights, please contact us at: info@toolup.pro

We will respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made several requests. In this case, we will notify you and keep you updated.

You will not have to pay a fee to access your personal data or exercise other rights. 

However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

6. International transfers

If we transfer your personal data outside the UK or European Economic Area (EEA), we ensure a similar degree of protection by implementing at least one of the following safeguards:

• Transferring to countries deemed to provide an adequate level of protection for personal data
  
• Using specific contracts approved for use in the UK/EEA which give personal data the same protection
  
• Where we use providers based in the US, transferring data to them if they are part of an approved framework

7. How we protect your data

We have implemented appropriate technical and organisational measures to protect your personal information from loss, misuse, or unauthorised access, including:

• Encryption of sensitive data
• Regular security assessments
• Access controls and authentication procedures
• Staff training on data protection
• Incident response procedures
  

We have procedures to deal with any suspected personal data breach and will notify you and applicable regulators when legally required to do so.

8. Data retention

We retain personal data only for as long as necessary to fulfil the purposes for which it was collected or as required by law. Typically, we retain:

• Customer account data for the duration of our relationship plus 7 years for tax and legal purposes
• Marketing data until you opt-out or withdraw consent
• Website analytics data for 26 monthsWhen personal data is no longer needed, we securely delete or anonymise it.

9. Changes to this policy

We may update this Privacy Policy from time to time. Changes will be posted on this page with a revised effective date.

10. Contact us

If you have any questions about this Privacy Policy or our data practices, please contact: ToolUp

Email: info@toolup.pro

Last updated: 30.04.25