Privacy Policy

1. Who we are

Torbryan ("we", "us", "our") provides AI-assisted cash flow analysis tools and related advisory services to businesses in the United Kingdom. This policy applies to personal data we process as a data controller through our website, consultations, and client onboarding processes. Our registered address is noted in the footer of this site.

2. Information we collect

We may collect the following categories of information:

• Contact details — name, email address, phone number, and company name submitted through forms or during consultations.
• Business and financial data — information voluntarily provided or connected via integrations for the purpose of cash flow analysis, including bank transaction data, accounting records, and forecasting inputs.
• Technical data — IP address, browser type, device identifiers, and usage data collected automatically when you visit our website.
• Communications — records of correspondence, support requests, and consultation notes.

3. How we use information

We process personal and business data to:

• Provide, maintain, and improve our cash flow analysis services and website.
• Respond to enquiries, schedule consultations, and deliver requested information.
• Generate reports and insights for clients using our analysis tools, with human oversight retained by the client at every decision point.
• Monitor website performance, prevent misuse, and maintain security.
• Comply with legal and regulatory obligations applicable to our business.

4. Legal basis for processing

Where UK GDPR applies, we rely on one or more of the following legal bases: performance of a contract with you or your business, our legitimate interests in operating and improving our services, your consent where specifically obtained, and compliance with legal obligations. We do not rely on consent as a blanket basis for all processing described in this policy.

5. Sharing of information

We do not sell personal data. We may share information with:

• Service providers who support our website hosting, communications, and analysis infrastructure, under appropriate confidentiality and data processing terms.
• Professional advisers, such as accountants or legal counsel, where necessary for the provision of services.
• Regulatory or governmental authorities where required by law.
• A successor entity in the event of a merger, acquisition, or sale of business assets, subject to equivalent privacy protections.

6. Data retention

We retain personal and business data only for as long as necessary to fulfil the purposes described in this policy, including satisfying any legal, accounting, or reporting requirements. Retention periods vary depending on the nature of the data and the services provided, and should be defined in an internal retention schedule specific to Torbryan's operations.

7. Data security

We implement reasonable technical and organisational measures designed to protect information against unauthorised access, loss, misuse, or alteration. No method of transmission or storage is completely secure, and we cannot guarantee absolute security of information transmitted to us.

8. Your rights

Subject to applicable law, you may have the right to:

• Request access to the personal data we hold about you.
• Request correction of inaccurate or incomplete data.
• Request deletion of your data, subject to legal and contractual limitations.
• Object to or restrict certain types of processing.
• Request data portability where technically feasible.
• Withdraw consent at any time where processing is based on consent.

To exercise these rights, please contact us using the details on our Contact page. You also have the right to lodge a complaint with the Information Commissioner's Office (ICO) or another relevant supervisory authority.

9. Cookies and tracking technologies

Our website may use cookies and similar technologies to support essential functionality, remember preferences, and understand site usage. Where required, we will present a cookie notice allowing you to manage non-essential cookies. You can also control cookies through your browser settings.

10. Third-party links

Our website and services may contain links to third-party websites or tools, such as banking or accounting integrations. We are not responsible for the privacy practices of third parties, and we encourage you to review their respective privacy policies.

11. International transfers

Where personal data is transferred outside the United Kingdom, we will take steps intended to ensure appropriate safeguards are in place, consistent with UK data protection law, such as the use of approved transfer mechanisms where applicable.

12. Children's privacy

Our services are intended for business use by adults and are not directed at children. We do not knowingly collect personal data from children.

13. Changes to this policy

We may update this Privacy Policy from time to time to reflect changes in our practices or for legal, operational, or regulatory reasons. We will post the revised version on this page with an updated effective date.

14. Contact us

If you have questions about this Privacy Policy or how your information is handled, please reach out via our Contact page.