1. Who we are
Torvo Ltd (company #17122860, registered in England and Wales) is the data controller for the marketing site at torvo.uk. For data captured inside a Torvo platform vertical (e.g. construction.field.torvo.uk), Torvo Ltd acts as the data processor for the customer organisation, which remains the data controller for its own operational data.
Registered address: 4 Laughing Dog Industrial Estate, London Road, Rugby, CV23 9LP.
ICO registration: 00013608468. Contact: [email protected].
2. What this site collects
The marketing site at torvo.uk only collects what you actively submit:
- Demo request form - name, work email, organisation, role, optional phone, sector of interest, free-text notes, consent record.
- Email contact - anything you put in an email to [email protected].
- Server logs - IP address, browser user-agent, timestamp, requested URL. Held for 14 days for security purposes.
The site does not use third-party analytics, advertising, or social-tracking pixels. There is no Google Analytics, Meta pixel, LinkedIn tag, or similar.
3. Why we hold what you submit
- Demo requests - to schedule and run the demo. Lawful basis: legitimate interest (responding to your stated request) and explicit consent recorded on the form.
- Email contact - to reply to you. Lawful basis: legitimate interest.
- Server logs - to detect abuse and meet our security obligations. Lawful basis: legitimate interest.
4. How long we keep it
- Demo requests: 24 months from last contact, unless you become a customer (in which case the customer record applies) or you ask us to delete sooner.
- Email correspondence: 24 months from last reply.
- Server logs: 14 days.
5. Where it lives
Torvo's core platform infrastructure runs on EU-hosted services (Hetzner Online GmbH, Germany). Data is encrypted at rest and in transit. We do not transfer personal data outside the EU/UK except where strictly necessary to operate a service you have asked us to provide - and where we do, we use providers with UK adequacy decisions or Standard Contractual Clauses in place.
6. Sub-processors we use
For platform operations (not the marketing site), Torvo uses a small number of named sub-processors. Each is bound by a written data-processing agreement.
- Hetzner Online GmbH (Germany) - server hosting.
- Deepgram, Inc. - speech-to-text transcription, where enabled by deployment terms.
- Anthropic PBC - large-language-model inference for document drafting and observation generation, subject to deployment terms and available retention controls.
- Google Maps Platform - reverse geocoding for site context where authorised.
The sub-processor list is reviewed quarterly. Material changes are notified to customers in advance.
7. Your rights
Under UK GDPR you have the right to:
- Be told what we hold about you (access).
- Have it corrected if it's wrong (rectification).
- Have it deleted (erasure), subject to legal retention requirements.
- Restrict or object to our processing of it.
- Receive it in a portable format.
- Withdraw consent at any time.
To exercise any of these rights, email [email protected]. We respond within one calendar month. If you're not satisfied with how we've handled a request, you can complain to the Information Commissioner's Office at ico.org.uk.
8. Cookies
This marketing site sets no analytics or marketing cookies. We use a small number of strictly-necessary cookies to remember your form input if a page reloads. See the full Cookie Policy.
9. Children
The marketing site is not directed at children. The SEND Education vertical may process pupil-related personal data on behalf of customer schools under their lawful basis, DPA, and DPIA. Torvo does not use children's operational data for marketing.
10. Changes to this policy
We update this policy when something material changes. The "last updated" date at the top of the page reflects the most recent change. Material changes are flagged in our customer communications. Older versions are available on request.
Questions? Email [email protected].