- What data do we collect from you?
1.1 TOMII collects the following data:
1.1.1 Personal contact information such as name and work email address
- 1.1.2 Personal financial information such as annual salary, other income, current liabilities and assets, type of liabilities and assets, and spending figures.
1.2 We will never ask you for any financial identifiers such as your National Insurance Number or Unique Tax Reference.
1.3 This data is necessary for our legitimate interests and for us to fulfil our contractual obligations to you, and we rely on this as a lawful basis to use and process the data described above
2. What data do we collect automatically?
2.1 Each time you visit or use our website, we automatically collect the following information:
- 2.1.1 technical information such as the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, location, network data, browser plug-in types and versions, languages, operating system and platform;
- 2.1.2 information about your visit such as the full Uniform Resource Locators (URL) clickstream to, through and from the website (including date and time); pages you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number.
2.2 We use this information as statistical data about your browsing actions and patterns, for system administration, and to evaluate, provide, protect or improve our services (including by developing new services). Because we collect, use and share this information in the aggregate, it does not identify any individual.
3. How do we collect your data?
3.1 You directly provide TOMII with most of the data we collect. We collect data when you:
- 3.1.1 Contact us by phone, email or otherwise.
- 3.1.2 Voluntarily complete a customer survey or provide feedback on any of our services.
- 3.1.3 Use or view our website.
- 3.1.4 Register for or participate in Financial Coaching Services.
4. How will we use your data?
4.1 To process your order, manage your account, provide you with information you request from us, and to carry out any other obligations arising from any contracts entered into between you and us.
4.2 To provide you with information about our services, including notifying you about changes to our services or website.
4.3 To email you with special offers on other products and services we think you might like.
4.4 To provide financial guidance through Financial Coaching Services you have access through the benefits offered by the Customer.
4.5 To ensure that content from our website is presented in the most effective manner for you and for your device.
4.6 To administer the website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes.
4.7 As part of our efforts to keep the website safe and secure, e.g. by conducting analysis required to detect malicious data and understand how this may affect your IT system.
5. Which third parties do we share information with?
5.1 We use Wix to host our website and Google Drive to communicate and share information with clients who attend Financial Coaching Services. We use Teachable to host our online academy. We also use Zoom for all web (video) conferences, as well as SurveyMonkey, Active Campaign and Calendly to manage the business. These parties have access to the information we share with their platforms. For more information on how these companies handle your personal data, please refer to their privacy policies.
Wix - https://www.wix.com/about/privacy
Google - https://policies.google.com/privacy?hl=en-US
Zoom - https://zoom.us/privacy
Calendly - https://calendly.com/pages/privacy
SurveyMonkey - https://www.surveymonkey.co.uk/mp/legal/privacy/
Teachable - https://teachable.com/privacy-policy
Active Campaign - https://www.activecampaign.com/legal/privacy-policy
5.2 The only other circumstances under which we would share your personal data are:
- 5.2.1 If the third party is a member of our group (which means any subsidiaries or ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006).
- 5.2.2 In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.
- 5.2.3 If TOMII or substantially all of its assets are acquired by a third party, in which case personal data will be one of the transferred assets and the purchaser will be permitted to use the data for the purposes for which it was originally collected by us.
- 5.2.4 If we’re under a duty to disclose or share your personal data in order to comply with any legal obligation, enforce or apply our contractual terms or other agreements, or to protect the rights, property, or safety of TOMII, our clients, or others (including exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction).
6. International Transfers
6.1 Because we use third parties located outside of the UK, the data we collect from you is transferred to and stored at destinations outside of the UK. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated as securely as it would be under the Data Protection Act 2018 and the GDPR.
6.2 For more information on the protection given to your personal data when it is transferred internationally, please contact us
7. How do we store your data?
7.1 All of your personal information is protected and we have put in place appropriate physical, electronic, and management procedures to safeguard and secure the data we collect.
7.2 TOMII securely stores your data on secure cloud databases and on company laptops. We ensure that all your personal data is password protected through two-factor authentication. Your information is only accessible by employees who have authorised access rights to such information.
7.3 Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal data, we cannot guarantee the security of data transmitted via the internet. Any transmission is at your own risk. Once we have received your information, we use strict procedures and the security features described above to try to prevent unauthorised access.
8. How long do we keep your data?
8.1 We only keep your personal information for as long as it’s necessary for our original legitimate purpose for collecting the information and for as long as we have your permission to keep it. If you would like to revoke such permission, please contact us.
9.1 TOMII would like to send you information about products and services of ours that we think you might like. If you agree to receive marketing, you may always opt out at a later date.
You have the right at any time to stop TOMII from contacting you for marketing purposes by following the opt-out link on marketing messages or by contacting us.
10. What are your data protection rights?
10.1 TOMII would like to make sure you are fully aware of all of your data protection rights. Every user is entitled to the following:
- 10.1.1 The right to access – You have the right to request from TOMII copies of your personal data. We may charge you a small fee for this service.
- 10.1.2 The right to rectification – You have the right to request that TOMII corrects any information you believe is inaccurate. You also have the right to request TOMII to complete information you believe is incomplete.
- 10.1.3 The right to erasure – You have the right to request that TOMII erase your personal data, under certain conditions.
- 10.1.4 The right to restrict processing – You have the right to request that TOMII restrict the processing of your data, under certain conditions.
- 10.1.5 The right to object to processing – You have the right to object to TOMII’s processing of your personal data, under certain conditions.
- 10.1.6 The right to data portability – You have the right to request that TOMII transfer the data that we have collected to another organization, or directly to you, under certain conditions.
10.2 If you have a request, we have one month to respond to you.
I10.3 f you would like to exercise any of these rights, please contact us at
- 10.3.1 Email: [email protected]
- 10.3.2 Call us at: +44 788 572 9338
- 10.3.3 Or write to us: Kemp House, 152 - 160 City Road, London EC1V 2NX
11. What are cookies?
11.1 Cookies are text files placed on your computer to collect standard Internet log information and visitor behaviour information. When you visit our website, we may collect information from you automatically through cookies or similar technology. For further information, visit allaboutcookies.org
- 12.1.1 Keeping you signed in
- 12.1.2 Understanding how you use our website
13. What types of cookies do we use?
13.1 There are a number of different types of cookies, however, our website uses:
- 13.1.1 Functionality – We use these cookies so that we recognize you on our website and remember your previously selected preferences, these could include what language you prefer or location you are in. A mix of first-party and third-party cookies is used.
- 13.1.2 Analytics – We use these cookies to collect information about your visit to our website, the content you viewed, the links you followed and information about your browser, device, and your IP address. These cookies allow us to recognise and count the number of visitors and to see how visitors move around the website when they’re using it, which helps us improve the website and the Financial Coaching Services.
- 13.1.3 Advertising – We sometimes share some limited aspects of our Analytics Cookies with third parties for advertising purposes.
14. How to manage cookies?
14.1 You can set your browser not to accept cookies, and the above website tells you how to remove cookies from your browser. However, in a few cases, some of our website features may not function as a result.
15. How to contact us?
- 15.1.1 Email: [email protected]
- 15.1.2 Call us at: +44 788 572 9338
- 15.1.3 Or write to us: Kemp House, 152 - 160 City Road, London EC1V 2NX
16. How to contact the appropriate authority?
16.1 Should you wish to report a complaint or if you feel that TOMII has not addressed your concern in a satisfactory manner, you may contact the Information Commissioner’s Office.
- 16.1.1 Website: https://ico.org.uk
- 16.1.2 Phone: 0303 123 1113