Privacy Policy – Tohar Pay Ltd

1. Who We Are
Tohar Pay Ltd (“we”, “us”) is based at Allied Business Centre, Coldharbour Lane, Harpenden AL5 4UT, UK. We are the controller of your personal data under UK GDPR.

2. What Personal Data We Collect

  • Information you provide: Name, address, email, date of birth, ID documents, employment status, financial data, account activity.

  • Automatically collected data: IP address, device/browser type, pages visited, session times. (Via cookies and analytics, see Cookie Policy.)

3. Why We Collect Your Data
We process personal data on legal grounds including:

  • To deliver services (e.g. account access, transactions).

  • Compliance with legal/regulatory obligations (e.g. anti‑money‑laundering, KYC).

  • Fraud prevention and security.

  • Where you have given consent—for marketing or optional features.

4. Sharing Your Data
We may share your data with:

  • Third‑party service providers supporting operations (e.g. IT, customer support).

  • Fraud prevention and credit reference agencies.

  • Law enforcement or regulatory bodies when legally required.

  • Affiliates and carefully selected partners if you consent.

5. International Transfers
Any data transferred outside the UK/EU will be protected through appropriate safeguards (e.g. UK adequacy or standard contractual clauses).

6. Data Retention

  • We retain your data as long as necessary for contract, legal requirements, fraud monitoring and legitimate business needs.

  • Once no longer necessary, we securely delete or anonymise your data.

7. Data Security
We implement industry-standard technical and organisational measures: encrypted transmission (SSL), firewalls, access controls, employee training.

8. Your Rights
Under UK GDPR you have rights to:

  • Access, rectification, erasure, restriction of processing, data portability, object to processing, withdraw consent.
    Requests are processed within one calendar month once identity is confirmed.

9. How to Contact Us
Email us at contact@toharpay.co.uk, or by post:
Data Protection Officer
Tohar Pay Ltd
Allied Business Centre
Coldharbour Lane
Harpenden AL5 4UT

You can lodge a complaint with the Information Commissioner’s Office (ICO) if dissatisfied.

10. Changes to This Policy
We reserve the right to update this policy. We will publish the effective date and notify users if significant changes occur.

GDPR Notice (Summary of Key Rights & Legal Basis)

  • Lawful Bases for Processing

    • Performance of contract (e.g. providing banking services)

    • Legal and regulatory obligations

    • Legitimate interests (e.g. fraud prevention, service improvement)

    • Consent (e.g. marketing, analytics cookies)

  • Your Rights Under GDPR

To exercise these rights, contact contact@toharpay.co.uk or write to our Data Protection Officer.

Cookie Policy

1. What Are Cookies?
Cookies are small text files placed on your device by websites to remember your preferences or activity. They may collect personal data like IP address or device info and are used in compliance with GDPR and PECR.

2. Types of Cookies We Use

  • Strictly necessary cookies: Essential for secure login, session management, fraud prevention. (You must accept these to use core services.)

  • Functional cookies: Remember your preferences (language, display) for improved user experience.

  • Analytics cookies: Collect anonymised data on how you navigate services (e.g. Google Analytics, Hotjar) to help us improve our platform.

  • Targeting/Marketing cookies (if used): To deliver relevant content and adverts via third-party partners (e.g. Google Ads, LinkedIn) with your consent.

3. Consent & Control

  • On first visit, you’ll be asked to accept or reject optional cookies.

  • Functional and analytics cookies can be managed or withdrawn at any time via cookie settings—rejecting optional cookies won’t prevent access to basic services.

4. How Long We Keep Cookies

  • Session cookies: expire after your browser session ends or after inactivity (typically ~10 minutes).

  • Persistent (analytics or preferences): generally expire within 12 months.

5. Manage Cookies Via Your Browser
You can also control or clear cookies using your browser’s settings. Rejecting or deleting cookies may affect functionality.

6. Updates to This Policy
We may amend this policy from time to time. Any significant changes will be notified and the date updated.