Privacy Notice
TomCRM-POL-003 Rev 1. Last updated: 15 October 2026. Download as PDF
1. Who we are
TomCRM Limited (TomCRM, we, us) is a company registered in England and Wales under number 15662063, with its registered office at 128 City Road, London EC1V 2NX. We are registered with the Information Commissioner's Office under reference ZB691927.
Our data protection lead is Tommy Findlay, Director. Contact us about anything in this notice at hello@tomcrm.co.uk or on 01522 287313. We are not required to appoint a statutory Data Protection Officer and have not done so.
2. The two roles we play
We are the controller of the personal data described in this notice: information about visitors to our website, people who contact us, and the people at our customers who use and pay for TomCRM.
When our customers put their own contacts' personal data into their TomCRM accounts, the customer is the controller and we process that data for them as their processor, under our Data Processing Agreement. If you are a customer's contact and want to exercise your rights, please contact that business first; we will help them respond.
3. What we collect and how
- Information you give us when you fill in a form on our website, take a scorecard or assessment, book a demo, sign up for our newsletter, or email or call us.
- Information about your business's users, billing and support when you become a customer.
- Technical information when you use our website, including analytics data, but only if you accept analytics cookies.
4. How we use it and our lawful basis
- Replying to enquiries and demo requests (name, business, email, phone, your message): legitimate interests.
- Producing the scorecard and assessment reports you request (your answers and contact details): legitimate interests.
- Setting up and running your TomCRM account, support and onboarding (your users' names, job titles, business contact and login details, support correspondence): contract.
- Billing and taking payment (billing contact and address; payment details are collected and held by Stripe, not by us): contract.
- Keeping accounting and tax records: legal obligation.
- Sending our newsletter and product updates (name and email): consent, or for existing customers our legitimate interests under the soft opt-in, with an unsubscribe link in every email.
- Website analytics (pages viewed, device and browser, approximate location): consent, given through our cookie banner.
- Keeping our website and services secure and improving them (technical and usage data): legitimate interests.
5. Who we share it with
We share personal data only with the providers we need to run our business and the service, each under a contract that protects it, and with our professional advisers or public authorities where the law requires. We do not sell personal data.
- HighLevel Inc.: the platform TomCRM runs on; also receives our website form submissions and newsletter sign-ups (United States).
- Google: our email and documents, and website analytics, consent-gated (United States and global).
- Supabase: database for assessment responses (United Kingdom, London).
- Vercel: hosting for our website (United States and global).
- Resend: delivery of assessment report emails (United States).
- Sanity: content management for our website and blog (European Union and United States).
- Stripe: payment processing (United Kingdom, European Union and United States).
- Anthropic: Ai assistance used by our team to read and draft support email (United States).
- iS3 Ltd and TSLTD Limited: delivery, configuration and support of the service by TomCRM's founders (United Kingdom).
6. Transfers outside the UK
Some of our providers, including HighLevel, hold or access data in the United States. Where data leaves the UK we rely on the UK Extension to the EU-US Data Privacy Framework for providers certified under it, or on the UK International Data Transfer Agreement or the UK Addendum to the EU standard contractual clauses. You can ask us for details of the safeguard that applies to a particular provider.
7. How long we keep it
- Website enquiries and contact form submissions: up to 24 months from your last contact with us.
- Scorecard and assessment responses: up to 12 months.
- Google Analytics data: 14 months.
- Newsletter subscription: until you unsubscribe.
- Customer account, contract and support records: for the life of the account and 6 years after it ends.
- Accounting and tax records: 6 years after the end of the financial year they relate to.
- Data in a customer's TomCRM account, where we act as processor: as set out in the Data Processing Agreement, deleted at the end of the 30-day export period after the account ends, unless the law requires otherwise.
8. How we protect it
The TomCRM platform runs on HighLevel, which is certified to ISO/IEC 27001:2022 and encrypts data in transit and at rest. Access to customer accounts is limited to the people who need it, using individual logins and two-factor authentication. Our Security and Continuity Statement gives more detail and is available on request.
9. Your rights
Under the UK GDPR you have the right to ask for a copy of your personal data, to have it corrected or deleted, to restrict or object to how we use it, to have it transferred to you or another organisation, and to withdraw consent at any time where we rely on consent. Email hello@tomcrm.co.uk and we will respond within one month.
If you are unhappy with how we have handled your personal data, please tell us first. You also have the right to complain to the Information Commissioner's Office at ico.org.uk or on 0303 123 1113.
10. Cookies
Our website sets one cookie of its own to remember your cookie choice. Google Analytics cookies are set only after you accept them in our cookie banner. Our chat widget, provided by HighLevel, loads only after you accept or when you click "Chat with us"; it then stores a session ID and how you arrived at our website in your browser's local storage so your conversation can continue. You can change your choice at any time using the Cookie settings link at the bottom of every page, or in your browser settings.
11. Automated decisions and Ai
Our scorecards and assessments produce an automatic score and report from your answers. This does not have any legal or similarly significant effect on you. Our team uses Ai assistance to help read and draft emails, and a person reviews anything that is sent.
12. Changes to this notice
We review this notice at least once a year. The revision number and date at the top show the current version. We will tell customers by email about any significant change. Our other legal documents are on our legal documents page.