1. Introduction
TPTracker Ltd respects the privacy of individuals and is committed to protecting personal data. This Privacy Policy explains how TPTracker Ltd collects, uses, stores and shares personal data, and the rights available to individuals.
This Privacy Policy applies to personal data processed by TPTracker Ltd in connection with:
· Operation of the TPTracker website
· Provision and support of TPTracker software services
· Communications with clients, prospective clients, suppliers and business contacts
This Privacy Policy should be read alongside the Cookie Policy and other published privacy information. This Privacy Policy also reflects applicable requirements under the Data Use and Access Act 2025 where relevant to TPTracker Ltd’s activities.
2. Who we are
TPTracker Ltd is a UK-based software provider.
For the purposes of UK data protection law, TPTracker Ltd acts as a data controller for its own business and website activities described in this Privacy Policy, such as managing client and supplier relationships, account administration, billing, service communications, and operating the TPTracker website.
When providing the TPTracker software services to clients, TPTracker Ltd typically processes personal data contained within the client’s account on the client’s instructions and therefore acts as a data processor, with the client acting as the data controller. The terms governing that processing are set out in the relevant client agreement and data processing terms.
ICO registration number: Z970774X
3. How to contact us
If you have questions about this Privacy Policy or how your personal data is used, you can contact us using the details below.
Data Controller TPTracker Ltd
Address Office, 31 Cattle Market St, Norwich NR1 3DY
Email support@tptracker.com
Telephone 01508 333090
TPTracker Ltd is supported by a dedicated, independent Data Protection Officer (DPO), who may be contacted directly regarding data protection matters.
Data Protection Officer Keith Hebborn, Hebborn Consultancy Ltd
Contact keith@hebborn.co.uk
4. Personal data we collect
Depending on your relationship with TPTracker Ltd, we may collect and process the following categories of personal data:
· Contact details such as name, job title, organisation, email address and telephone number
· Account and user information relating to use of TPTracker software
· Communications, including emails, electronic messages and records of telephone calls
· Technical data such as IP address, browser type and usage information
· Any other personal data you choose to provide when contacting us
We do not intentionally collect special category data. TPTracker does not require special category data to provide its services and clients should avoid entering such data into free-text fields unless strictly necessary for their own purposes and lawful bases and remain responsible for ensuring compliance with their own data protection obligations.
5. How we use personal data and lawful bases
TPTracker Ltd processes personal data only where a lawful basis under UK GDPR applies. These include:
· Contract – the agreed written terms governing use, support, and data protection for TPTracker
· Legitimate interests – to manage our business, communicate with organisations, improve services and maintain security, subject to balancing tests
· Legal obligation – where processing is required to comply with law
Further details on lawful bases for specific processing activities are recorded in our internal Records of Processing Activities. Where we rely on legitimate interests, individuals may object to such processing as set out in section 11 below.
Certain data access, information sharing, and accountability obligations may also arise under the Data Use and Access Act 2025. Where applicable, these obligations are addressed through TPTracker Ltd’s internal governance documentation, accountability records, and contractual arrangements rather than this Privacy Policy.
6. Cookies and similar technologies
TPTracker Ltd uses cookies and similar technologies on its website.
Details of cookies used, purposes, consent mechanisms and how you can manage your preferences are set out in our Cookie Policy, available on the website.
7. Sharing personal data
We may share personal data with the following categories of recipient, where necessary for the purposes described in this Privacy Policy:
· Service providers and suppliers who support our business operations
· Professional advisers where necessary
· Public authorities where required by law
Where third parties process personal data on our behalf, appropriate contractual safeguards are put in place in accordance with UK GDPR requirements.
8. International transfers
Personal data is primarily processed within the UK.
Where personal data is transferred outside the UK, appropriate safeguards will be applied in accordance with UK data protection law, such as adequacy regulations or approved contractual mechanisms.
9. Data security
We implement appropriate technical and organisational measures to protect personal data against unauthorised access, loss or misuse, proportionate to the nature of the data processed and the risks involved.
10. Data retention
Personal data is retained only for as long as necessary for the purposes for which it was collected.
Retention periods are set out in internal retention documentation. Further information about retention periods can be requested using the contact details in section 3.
11. Your data protection rights
Individuals have rights under UK GDPR, including:
· The right to be informed
· The right of access
· The right to rectification
· The right to erasure
· The right to restrict processing
· The right to data portability
· The right to object
· Rights relating to automated decision-making and profiling
Where applicable, individuals may also have rights of access or information under the Data Use and Access Act 2025, which are managed in accordance with statutory requirements.
Requests are managed in accordance with applicable statutory timescales and legal requirements.
TPTracker Ltd does not conduct automated decision-making or profiling that produces legal or similarly significant effects on individuals.
12. Complaints
If you have concerns about how your personal data is used, please contact us first so we can try to resolve the matter.
You also have the right to complain to the Information Commissioner’s Office:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
www.ico.org.uk
13. Changes to this Privacy Policy
We may update this Privacy Policy from time to time. The most recent version will always be published on our website.
