Toolie Privacy Policy.
Last updated: 2 October 2026
This policy explains how STRUTH LTD collects and uses personal data when you visit the Toolie website, sign up or use Toolie. We keep it as short and clear as we can.
1. Who we are
Toolie is provided by STRUTH LTD (company number 17085039), 49 Jamaica Street, Liverpool, England, L1 0AH. For the data described in this policy, we are the controller. We’re registered with the Information Commissioner’s Office (ICO) under number ZC189957.
For any privacy questions, email team@struth.uk.
2. What we collect
| Type | Examples | Where it comes from |
|---|---|---|
| Account details | Name, business name, email, phone, job role, login details | You, when you sign up or add team members |
| Billing details | Billing address, VAT number, payment history | You and our payment provider (we never see or store full card numbers) |
| Support and communications | Emails, chat and WhatsApp messages with us, call notes, feedback | You |
| Usage data | Features used, log-ins, device and browser type, IP address, error logs | Automatically, when you use Toolie |
| Website and marketing data | Pages visited, form submissions, cookie data, how you found us, ad interactions | Our website, cookies and advertising platforms such as Meta |
| What we do | Lawful basis |
|---|---|
| Set up and run your account, deliver Toolie and provide support | Contract |
| Take payments, send invoices and keep financial records | Contract and legal obligation |
| Keep Toolie secure, prevent fraud and misuse | Legitimate interests |
| Improve Toolie and understand how it's used | Legitimate interests |
| Send service updates, such as changes to terms or features | Contract and legitimate interests |
| Send marketing emails or messages about Toolie and Struth services | Consent, or legitimate interests for existing customers (you can opt out any time) |
| Run and measure our ads, including retargeting | Consent (via our cookie banner) |
| Respond to legal requests and enforce our terms | Legal obligation and legitimate interests |
| Data | How long |
|---|---|
| Account and usage data | While your account is open, plus 30 days after it closes |
| Billing and financial records | 6 years after the end of the financial year, as required by HMRC |
| Support conversations | Up to 2 years after your account closes |
| Marketing data | Until you unsubscribe or withdraw consent, or 2 years without engagement |
3. How we use it and why
| Type | Examples | Where it comes from |
|---|---|---|
| Account details | Name, business name, email, phone, job role, login details | You, when you sign up or add team members |
| Billing details | Billing address, VAT number, payment history | You and our payment provider (we never see or store full card numbers) |
| Support and communications | Emails, chat and WhatsApp messages with us, call notes, feedback | You |
| Usage data | Features used, log-ins, device and browser type, IP address, error logs | Automatically, when you use Toolie |
| Website and marketing data | Pages visited, form submissions, cookie data, how you found us, ad interactions | Our website, cookies and advertising platforms such as Meta |
| What we do | Lawful basis |
|---|---|
| Set up and run your account, deliver Toolie and provide support | Contract |
| Take payments, send invoices and keep financial records | Contract and legal obligation |
| Keep Toolie secure, prevent fraud and misuse | Legitimate interests |
| Improve Toolie and understand how it's used | Legitimate interests |
| Send service updates, such as changes to terms or features | Contract and legitimate interests |
| Send marketing emails or messages about Toolie and Struth services | Consent, or legitimate interests for existing customers (you can opt out any time) |
| Run and measure our ads, including retargeting | Consent (via our cookie banner) |
| Respond to legal requests and enforce our terms | Legal obligation and legitimate interests |
| Data | How long |
|---|---|
| Account and usage data | While your account is open, plus 30 days after it closes |
| Billing and financial records | 6 years after the end of the financial year, as required by HMRC |
| Support conversations | Up to 2 years after your account closes |
| Marketing data | Until you unsubscribe or withdraw consent, or 2 years without engagement |
4. Your customers' data
When you store contacts, conversations and other customer details in Toolie, you are the controller of that data and we act as your processor. We only use it to provide Toolie to you, following your instructions and our Data Processing Agreement (toolie.app/dpa). If you’re one of our users’ customers and want to know how your data is used, please contact the business you dealt with directly.
6. International transfers
Toolie’s platform is hosted on Google Cloud and Amazon Web Services in the United States. Our platform provider is certified under the EU-US Data Privacy Framework and its UK Extension (the UK-US Data Bridge), which the UK recognises as giving adequate protection. Some of our providers’ support teams may access data from other countries, including India. Where a country isn’t covered by UK adequacy regulations, we rely on the ICO’s International Data Transfer Agreement or Addendum, or equivalent contractual safeguards.
7. How long we keep it
| Type | Examples | Where it comes from |
|---|---|---|
| Account details | Name, business name, email, phone, job role, login details | You, when you sign up or add team members |
| Billing details | Billing address, VAT number, payment history | You and our payment provider (we never see or store full card numbers) |
| Support and communications | Emails, chat and WhatsApp messages with us, call notes, feedback | You |
| Usage data | Features used, log-ins, device and browser type, IP address, error logs | Automatically, when you use Toolie |
| Website and marketing data | Pages visited, form submissions, cookie data, how you found us, ad interactions | Our website, cookies and advertising platforms such as Meta |
| What we do | Lawful basis |
|---|---|
| Set up and run your account, deliver Toolie and provide support | Contract |
| Take payments, send invoices and keep financial records | Contract and legal obligation |
| Keep Toolie secure, prevent fraud and misuse | Legitimate interests |
| Improve Toolie and understand how it's used | Legitimate interests |
| Send service updates, such as changes to terms or features | Contract and legitimate interests |
| Send marketing emails or messages about Toolie and Struth services | Consent, or legitimate interests for existing customers (you can opt out any time) |
| Run and measure our ads, including retargeting | Consent (via our cookie banner) |
| Respond to legal requests and enforce our terms | Legal obligation and legitimate interests |
| Data | How long |
|---|---|
| Account and usage data | While your account is open, plus 30 days after it closes |
| Billing and financial records | 6 years after the end of the financial year, as required by HMRC |
| Support conversations | Up to 2 years after your account closes |
| Marketing data | Until you unsubscribe or withdraw consent, or 2 years without engagement |
8. Keeping it safe
We use encryption in transit, secure hosting, access controls and two-factor authentication. Only people who need access to help you get it. If a data breach is likely to affect you, we’ll tell you and the ICO where the law requires.
9. Your rights
Under UK data protection law, you can:
- ask for a copy of the personal data we hold about you
- ask us to correct anything that’s wrong
- ask us to delete your data
- ask us to limit how we use it, or object to us using it (including for marketing)
- ask for your data in a portable format
- withdraw consent at any time, where we rely on it
To use any of these rights, email team@struth.uk. We’ll respond within one month. There’s usually no charge.
11. Changes to this policy
We’ll update this policy if how we use data changes. We’ll email account holders about significant changes, and the date at the top always shows the latest version.
12. Contact and complaints
If you have a question or concern, please contact us first at team@struth.uk or STRUTH LTD, 49 Jamaica Street, Liverpool, England, L1 0AH. We’ll always try to put things right.
You also have the right to complain to the Information Commissioner’s Office: ico.org.uk or 0303 123 1113.