Privacy policy

TOMEI UK – tomei.uk
A trading name of TORQEN Ltd
Version 1.0 · Last updated: 23 June 2026

This privacy policy explains how we collect, use, share and store your personal data when you visit tomei.uk, buy from us, create an account, contact us, or arrange to collect an order in person.

1. Who we are

Data controller: TORQEN Ltd, trading as TOMEI UK.

In this policy, "we", "us" and "our" mean TORQEN Ltd trading as TOMEI UK.

2. Changes to this policy

We may update this policy to reflect changes to our business or legal duties. We publish the current version on tomei.uk and update the date at the top.

3. Personal data we collect

Personal data means information that identifies you or can be linked to you.

Data you give us

• Name, email, phone number
• Billing and delivery address
• Account login details, if you create an account
• Order details, returns, warranty queries and support messages
• Payment status and transaction references. We do not store full card numbers

Data we collect from your device

• IP address, device type, browser type, operating system, language
• Pages viewed, links clicked, basket activity, referral source
• Cookie identifiers and similar technologies, see section 8

Data we receive from third parties

• Payment providers: payment confirmation, fraud indicators, dispute and chargeback status
• Delivery partners: tracking events and delivery outcomes
• Platform and IT suppliers: data needed to run the online shop and support services
• Fraud prevention tools: risk signals linked to transactions

4. If you do not provide personal data

We need some data to take payment, deliver goods and support you. If you do not provide it, you may not be able to place an order, receive delivery or get after-sales support.

5. How we use personal data and our lawful bases

UK law requires a lawful basis for each use.

Contract

• Process orders, take payment and send order updates
• Deliver orders or prepare a pre-arranged collection
• Handle returns, refunds and warranty support
• Provide customer service linked to your purchase

Legitimate interests

• Run, maintain and improve tomei.uk
• Keep records of customer contact and orders
• Prevent fraud, misuse and attacks on our systems
• Protect our rights in disputes and complaints

We balance these interests against your rights.

Legal obligation

• Keep tax and accounting records
• Meet consumer law duties
• Respond to lawful requests from authorities and regulators

Consent

• Non-essential cookies and tracking, meaning analytics
• Some marketing messages, depending on the channel and your relationship with us

You can withdraw consent at any time, see section 19.

6. Shopify platform and hosting

Our online shop runs on Shopify. Shopify provides the platform for checkout, order management and account features. When you browse or buy from tomei.uk, we process your personal data using Shopify systems and Shopify-approved suppliers that support the platform.

Shopify acts as a processor for the customer data we put into the platform to run our store. Shopify may act as a controller for some of its own products and services under its own terms.

7. Payments

When you pay, the payment provider processes your payment and may run fraud checks. We receive payment confirmation and transaction references.

Payment methods we offer

• Card payments through Shopify Payments, where available
• PayPal
• Shop Pay Instalments, where available
• Klarna, where available
• Bank transfer: Barclays for payments in GBP, or Wise for other currencies

What we share for payments

We share the data needed to process payment and manage fraud checks, refunds and disputes. This typically includes your name, contact details, billing and delivery details, order details and transaction information.

Klarna and Shop Pay Instalments

If you choose Klarna or Shop Pay Instalments, we share your contact and order details so the provider can assess eligibility and provide its payment options. The provider then processes your data under its own privacy notice. Shop Pay Instalments in the UK is provided by Klarna.

Bank transfer

If you pay by bank transfer, our bank and your bank or payment service process the transfer details, such as account name, account or IBAN details, reference and amount. We use the reference to match your payment to your order. GBP transfers are handled through Barclays. Transfers in other currencies are handled through Wise.

8. Cookies and Google Analytics

We use cookies and similar technologies for site functions and analytics.

Cookie categories

• Strictly necessary: basket, checkout, security
• Preferences: for example, remembered settings
• Analytics: site performance and usage

We only run analytics cookies if you consent through our cookie banner.

Google Analytics

If you consent, Google Analytics collects information about how you use the site, for example pages viewed, session activity, device and browser information, and referral source. We do not run advertising pixels at this time. If that changes, we will update this policy and our cookie banner before any advertising tracking goes live.

Your choices

You can change your cookie choices at any time using the cookie settings on the site, where available, or your browser settings. If you block cookies, parts of the site may not work.

9. Call recordings

We may record calls for training, quality and to help resolve complaints and disputes.

• What we collect: your phone number, call audio and information you share on the call
• Lawful basis: legitimate interests, and contract where the call relates to an order or support
• Retention: 90 days, then deletion, unless we need a recording for an open complaint, dispute, fraud investigation or legal claim
• Your choices: tell us at the start of the call if you want another contact method

10. WhatsApp and other messaging

If you message us on WhatsApp, we process the message content and any files you send so we can support you, for example order queries, returns and product support.

WhatsApp is provided by Meta. Meta processes data under its own terms, which may include processing outside the UK.

• Lawful basis: contract, for support linked to an order, and legitimate interests, for customer support and record-keeping
• Retention: 12 months after the last message, then deletion, unless we need it for an open issue or legal claim

Do not send card details by WhatsApp.

11. CCTV

If you collect an order in person or visit our premises, our CCTV may record you, your vehicle, and the time and location of your visit. We run CCTV around the site for safety, crime prevention and incident investigation.

• Lawful basis: legitimate interests in protecting people and property, and investigating incidents
• Sharing: we may share footage with the police, insurers, advisers or other parties involved in an incident, where lawful
• Retention: 14 days, then automatic overwrite, unless we need footage for an active investigation or dispute
• Your rights: you can request access to footage that includes you. Give us the date, time and location so we can find it within the 14-day window

12. Who we share personal data with

We share personal data only as needed to run the store and supply your order.

• Shopify: platform hosting and store operations
• Payment providers: Shopify Payments, PayPal, Klarna, Shop Pay Instalments, Barclays, Wise
• Delivery and logistics partners
• Fraud prevention and security providers
• Customer support tools
• Google Analytics, only if you consent to analytics cookies
• Professional advisers: accountants, insurers, lawyers
• Authorities and regulators where the law requires it

We do not sell personal data.

13. Email hosting

We host our business email on a dedicated server at OVHcloud. Personal data in emails you send us, and emails we send you, may be stored and processed on that server as part of running our email service. OVHcloud acts as a processor for the underlying hosting under its terms. We administer the email system ourselves.

14. International transfers

Some suppliers, including Shopify, Google, Meta (WhatsApp) and OVHcloud, may process personal data outside the UK. Where the law requires it, we rely on recognised safeguards for international transfers, such as the UK International Data Transfer Agreement, the UK Addendum to the EU Standard Contractual Clauses, or the UK Extension to the EU-US Data Privacy Framework where the recipient is certified.

Email tomei@torqen.uk for more detail about the safeguards that apply.

15. How long we keep personal data

We keep personal data only for as long as needed for the purposes in this policy.

• Orders, invoices and tax records: 6 years after the end of the relevant financial year
• Customer support records: 24 months after the case closes
• Account data: while your account stays open, then 24 months after closure, unless we need it for legal reasons
• Marketing lists: until you unsubscribe, or 24 months after your last meaningful interaction
• Call recordings: 90 days, see section 9
• WhatsApp messages: 12 months, see section 10
• CCTV: 14 days, see section 11
• Security logs: 12 months

If we need data for a live dispute, fraud investigation or legal claim, we keep it for as long as that purpose requires.

16. Security

We use access controls and other measures to protect personal data. No online service is risk-free. Use a strong password for any account you create and keep it private.

17. Automated decision-making

We may use automated tools to help detect fraud and protect transactions. If a tool blocks a transaction, contact us and we will review it. We do not make decisions with legal or similarly significant effects on you by automated means alone.

18. Marketing choices

You can opt out of marketing at any time using the unsubscribe link in an email, or by contacting us.

If you buy from us, we may email you about similar products where UK rules allow it. You can opt out at any time.

19. Your rights

Under UK data protection law, you can:

• ask for access to your personal data
• ask us to correct inaccurate data
• ask us to delete data in some cases
• ask us to restrict processing in some cases
• object to processing based on legitimate interests, including direct marketing
• ask for data portability in some cases
• withdraw consent at any time where we rely on consent

Email tomei@torqen.uk to exercise your rights. We may ask for proof of identity.

20. Complaints

Contact us first and we will try to resolve your concern. You can also complain to the UK regulator, the Information Commissioner's Office, at ico.org.uk.

21. Third-party websites

Our site may link to third-party sites. Their privacy practices differ. Read their privacy information before you provide personal data.

22. Children

Our services are not intended for children under 16. If you think a child has given us personal data, contact us and we will take appropriate steps.