TOVOData Privacy Notice
Created: January 2026
Last Updated: October 2026
1. Who We Are
TOVOData Limited ("TOVOData", "we", "us" or "our") provides business intelligence, professional contact data and market insight services to organisations operating in business-to-business (B2B) markets.
TOVOData collects, analyses, enriches and provides information relating to organisations and individuals acting in a professional or business capacity. This Privacy Notice explains how we collect, use, store and share personal data and how individuals can exercise their privacy rights.
For the purposes of UK data protection law, TOVOData is the data controller in respect of the processing activities described in this notice.
For privacy enquiries, rights requests or complaints please contact:
Email: privacy@tovodata.co.uk
2. What Information We Process
TOVOData may process professional and business-related personal data, including:
Name
Job title and professional role
Employer or organisation
Business contact details
Regulatory registrations and permissions
Directorships and corporate affiliations
Professional profile information
Sector, industry and organisational information
Communication preferences and suppression records
We do not intentionally collect special category personal data unless required by law or made publicly available through an official public register.
3. Where We Obtain Information
TOVOData obtains information from a range of lawful sources, including:
The Financial Conduct Authority (FCA) Register
Companies House filings and corporate records
Company websites
Publicly available business information
Professional directories and industry publications
Licensed third-party data providers
Trade associations and industry bodies
Information supplied directly by organisations or individuals
The information we process generally relates to individuals acting in a professional, regulatory or business capacity.
4. How We Use Information
We use personal data to:
Provide business intelligence services
Maintain and improve our data products
Verify and validate business information
Support customer search, segmentation and prospecting activities
Conduct research and market analysis
Manage customer relationships
Comply with legal and regulatory obligations
Maintain data quality, accuracy and security
Respond to enquiries and exercise of rights requests
5. Lawful Basis for Processing
TOVOData primarily relies upon Article 6(1)(f) UK GDPR (Legitimate Interests) for the collection, enrichment, storage, analysis and provision of professional and business-related personal data.
Our legitimate interests include:
Providing business intelligence and market insight services
Supporting B2B business development activities
Maintaining accurate and reliable datasets
Facilitating professional networking and commercial engagement
Conducting due diligence and market research
Improving data quality and reducing inaccurate or duplicate records
Where appropriate, we may also rely upon:
Performance of a contract (Article 6(1)(b))
Compliance with legal obligations (Article 6(1)(c))
Consent (Article 6(1)(a))
6. Business Information Services
TOVOData maintains databases containing information relating to organisations and individuals acting in a professional capacity.
To maintain the quality and relevance of our services, we may undertake:
Data collection
Data matching
Data enrichment
Data verification
Data cleansing
Categorisation and segmentation
Professional profiling
These activities help ensure information remains accurate, current and relevant for legitimate business purposes.
7. Enrichment, Verification and Profiling
TOVOData may enrich, match, categorise, verify and profile professional and business-related information obtained from public records, regulatory registers and licensed data providers.
These activities may include:
Verifying professional roles and employer information
Validating regulatory status and authorisations
Matching records from multiple sources
Identifying and removing duplicate records
Categorising organisations and professionals by sector, function or seniority
Assessing business relevance to particular markets or industry segments
Any profiling undertaken by TOVOData is limited to professional and business-related characteristics and is not used to make solely automated decisions which produce legal or similarly significant effects on individuals.
8. Article 14 Transparency
In many cases, TOVOData obtains personal data indirectly rather than directly from the individual concerned.
Where personal data is obtained from sources such as the FCA Register, Companies House, company websites, industry directories, public records or licensed third-party providers, we seek to provide transparency through this Privacy Notice and other accessible mechanisms.
In certain circumstances, TOVOData may rely upon the exemption contained within Article 14(5)(b) UK GDPR where providing individual notice to every affected individual would involve a disproportionate effort.
When this exemption is relied upon, we implement alternative safeguards including:
Maintaining a publicly available Privacy Notice
Providing clear information about our data sources and processing activities
Publishing contact details for privacy enquiries
Maintaining objection, erasure and suppression processes
Responding to rights requests without undue delay
Implementing data governance, minimisation and accuracy controls
We regularly review our approach to ensure it remains proportionate, transparent and aligned with applicable data protection requirements.
9. Who We Share Information With
TOVOData may share personal data with:
Customers using our business intelligence services
Technology and service providers
Professional advisers
Auditors and compliance providers
Regulatory authorities where required by law
Law enforcement agencies where legally required
Customers receiving information from TOVOData are responsible for ensuring their own use of personal data complies with applicable data protection and electronic marketing laws.
10. Client Responsibilities
Where personal data is used by a customer for marketing, outreach, business development or related activities, the customer remains independently responsible for complying with applicable data protection laws.
This includes:
Providing legally required notices
Offering appropriate opt-out mechanisms
Recording and honouring objections
Maintaining suppression lists
Monitoring unsubscribe requests
Ensuring individuals are excluded from future communications where required
TOVOData's own suppression processes do not replace a customer's obligation to operate and maintain its own suppression controls.
11. Objections, Erasure and Suppression
Individuals may object to processing, request deletion of personal data or request suppression from future processing activities.
TOVOData maintains procedures to assess and respond to such requests in accordance with applicable data protection legislation.
Where appropriate, we may:
Delete personal data
Restrict processing
Remove information from active datasets
Suppress information from future enrichment activities
Exclude records from future marketing and business intelligence processing
Where complete deletion is not possible due to legal, regulatory or compliance requirements, we may retain a minimal suppression record solely for the purpose of ensuring that the individual's preferences continue to be respected and the information is not reintroduced into future datasets.
12. International Transfers
Where personal data is transferred outside the United Kingdom, TOVOData will implement appropriate safeguards in accordance with applicable data protection laws.
These safeguards may include:
UK International Data Transfer Agreements
International Data Transfer Addenda
Adequacy Regulations
Other legally recognised transfer mechanisms
13. Security
TOVOData maintains technical and organisational measures designed to protect personal data against unauthorised access, loss, misuse, alteration or disclosure.
These measures are reviewed periodically and are proportionate to the nature, volume and sensitivity of the information processed.
14. Data Retention
We retain personal data only for as long as necessary to fulfil the purposes described in this notice, including maintaining data quality, providing services, complying with legal obligations and responding to rights requests.
Retention periods are reviewed periodically and information that is no longer required is deleted, anonymised or appropriately suppressed.
15. Your Rights
Subject to applicable law, you may have the right to:
Access your personal data
Correct inaccurate information
Request deletion
Restrict processing
Object to processing
Request data portability
Withdraw consent where consent has been relied upon
Lodge a complaint with the Information Commissioner's Office (ICO)
Requests may be submitted to:
16. Automated Decision-Making
TOVOData does not undertake solely automated decision-making that produces legal effects or similarly significant effects on individuals.
17. Changes to This Privacy Notice
TOVOData may update this Privacy Notice from time to time to reflect changes in legislation, regulatory guidance, business operations or processing activities.
The most current version will always be published on our website.
18. Contact Us
For questions regarding this Privacy Notice, our data processing activities or the exercise of your privacy rights, please contact:
TOVOData Limited
Email: privacy@tovodata.co.uk
If you are not satisfied with our response, you have the right to lodge a complaint with the Information Commissioner's Office (ICO).