Privacy Policy

This Privacy Policy applies to the processing of personal information by Tolmo, Inc. (“Tolmo,” “we,” “us,” or “our”) including on our website available at tolmo.com, our documentation, blog, and newsletter, and the Tolmo platform, and our other online or offline offerings that link to, or are otherwise subject to, this Privacy Policy (collectively, the “Services”).

Disclosure Regarding Customer Data. This Privacy Policy does not apply to the personal information that we process on behalf of our customers pursuant to a written agreement we have entered into with such customers (“Customer Data”). Customer Data includes our customers’ source code, cloud and infrastructure configuration, security testing results and findings, and any personal information contained in the environments and systems our customers connect to the Tolmo platform. Our customers’ respective privacy notices or policies govern their collection and use of Customer Data. Our processing of Customer Data is governed by the contracts that we have in place with our customers, not this Privacy Policy. Any questions or requests relating to Customer Data should be directed to our customer.

Updates to This Privacy Policy
Personal Information We Collect
How We Use Personal Information
How We Share Personal Information
Your Privacy Choices and Rights
International Transfers of Personal Information
Retention of Personal Information
Security
Supplemental Notice for EU/UK GDPR
Children’s Personal Information
Contact Us

1. Updates to This Privacy Policy

We may update this Privacy Policy from time to time in our sole discretion. If we do, we’ll let you know by posting the updated Privacy Policy on our website, and we may also send other communications.

2. Personal Information We Collect

We collect personal information that you provide to us, personal information we collect automatically when you use the Services, and personal information from third-party sources, as described below.

A. Personal Information You Provide to Us Directly

We may collect personal information that you provide to us.

Account Information. We may collect personal information in connection with the creation or administration of your account. This personal information may include, but is not limited to, your name, work email address, job title, company, and the account details and configuration you provide when you sign up for or administer a Tolmo account.
Marketing Forms and Gated Content. We may collect personal information you provide when you request a demo, subscribe to our newsletter, download or unlock a gated resource, contact our response team, or otherwise submit one of our forms, including forms hosted by third parties.
Transactions. We may collect personal information and details associated with your transactions with us, including payment information. Any payments made via our Services are processed by third-party payment processors. We do not directly collect or store any payment card information entered through our Services, but we may receive information associated with your payment card information (e.g., your billing details).
Your Communications with Us. We, and our service providers, may collect the information you communicate to us, such as through email or a support or incident response request.
Surveys. We may contact you to participate in surveys. If you decide to participate, we may collect personal information from you in connection with the surveys.
Conferences, Trade Shows, and Other Events. We may collect personal information from individuals when we attend or host conferences, trade shows, and other events.
Business Development and Strategic Partnerships. We may collect personal information from individuals and third parties to assess and pursue potential business opportunities.
Job Applications. If you apply for a job with us, we will collect any personal information you provide in connection with your application, such as your contact information and resume or CV.

B. Personal Information Collected Automatically

We may collect personal information automatically when you use the Services.

Device Information. We may collect personal information about your device, such as your Internet protocol (IP) address, user settings, cookie identifiers, other unique identifiers, browser or device information, Internet service provider, and the approximate location derived from your IP address.
Usage Information. We may collect personal information about your use of the Services, such as the pages that you visit, items that you search for, the types of content you interact with, information about the links you click, the frequency and duration of your activities, referring URLs, and other information about how you use the Services.
Cookie Notice (and Other Technologies). We, as well as third parties, may use cookies, pixel tags, and other technologies (“Technologies”) to automatically collect personal information through your use of the Services.
- Cookies. Cookies are small text files stored in device browsers.
- Local Storage. We use localStorage (a built-in web storage API) and similar browser storage, for example to remember that you have already unlocked a resource.
- Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded in the Services that collects personal information about use of or engagement with the Services. The use of a pixel tag allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement. We may also include web beacons in emails to understand whether messages have been opened, acted on, or forwarded.

Essential Technologies are always active because they are necessary to make the Services work, including remembering that you have unlocked a resource. All other Technologies, including the analytics and advertising Technologies described in this Privacy Policy, are set only if you accept them through the cookie banner we present on your first visit. If you decline, those Technologies are not added to the page. You can change your decision at any time using “Cookie Settings” in the footer of our website.

See “Your Privacy Choices and Rights” below to understand your choices regarding these Technologies.

C. Personal Information Collected from Third Parties

We may collect personal information about you from third parties, including:

Third-Party Services. If you access the Services using a third-party website, application, service, products, or technology (each a “Third-Party Service”), we may collect personal information about you from that Third-Party Service that you have made available via your privacy settings. This includes the code repositories, cloud environments, and other systems that our customers connect to the Tolmo platform.
Advertising and Lead Generation Platforms. We receive contact details from advertising platforms when you submit a form hosted by them, such as a LinkedIn Lead Gen Form.
Business Audience and Visitor Identification Providers. We use providers on our website that identify visiting organizations, and in some cases individual visitors, by matching network and device signals against their own datasets. We may therefore learn your employer, name, role, or professional profile without you having provided it to us directly. For traffic from the European Economic Area or the United Kingdom, these providers identify only visiting organizations, not individual visitors.
Our Customers. Our customers may provide personal information about their personnel when they configure accounts and authorized users on the Tolmo platform.

3. How We Use Personal Information

We use personal information for a variety of business purposes, including to provide the Services, for administrative purposes, and to provide you with marketing materials, as described below.

A. Provide the Services

We use personal information to provide the Services, such as:

Providing access to certain areas, functionalities, and features of the Services;
Creating and administering your account and your organization’s authorized users;
Communicating with you;
Responding to your requests, including support and incident response requests;
Sharing personal information with third parties as needed to provide the Services; and
Processing payments, billing, and usage-based charges.

EU/UK GDPR Lawful Bases: If the EU GDPR or the UK GDPR applies to our processing of personal information under this section, our lawful bases may include performance of a contract, legitimate interest, consent, and/or compliance with legal obligations.

B. Improve the Services and Develop New Products and Services

We use personal information to improve the Services and to develop new products and services, such as:

Producing and analyzing de-identified and aggregated performance, usage, and telemetry data; and
Improving, upgrading, or enhancing the Services.

We do not use Customer Data, or the personal information described in this Privacy Policy, to train, or fine-tune machine learning models or artificial intelligence technologies.

C. Operate Our Business

We use personal information to operate our business, such as:

Pursuing our legitimate interests such as direct marketing, research and development (including marketing research), network and information security, and fraud prevention;
Carrying out analytics;
Creating de-identified and/or aggregated information. If we create or receive de-identified information, we will not attempt to reidentify such information unless doing so is permitted by, or we are required to do so to comply with, applicable laws;
Detecting, investigating, and preventing abuse, security incidents, and other unauthorized or unlawful activity;
Processing applications if you apply for a job we post on our Services;
Allowing you to register for events;
Enforcing our agreements and policies; and
Carrying out activities that are required to comply with our legal obligations.

D. Marketing

We may use personal information in connection with our marketing activities including to tailor and provide you with marketing communications, promotions, and offers that may interest you, to identify and contact organizations likely to benefit from the Services, and to measure and target our advertising. We may also share personal information with co-marketing partners, such as event or webinar co-hosts, where both parties receive the resulting contact list.

EU/UK GDPR Lawful Bases: If the EU GDPR or the UK GDPR applies to our processing of personal information under this section, our lawful bases may include legitimate interest and/or consent.

We may use personal information: (i) for other purposes that are clearly disclosed to you at the time you provide the personal information, (ii) with your consent, or (iii) as otherwise directed by you.

F. Automated Decision-Making

We may use automated means, including profiling, to score and prioritize marketing leads and to detect and prevent abuse of the Services. We do not use automated decision-making that produces legal effects concerning you or that similarly significantly affects you.

We share personal information with third parties for a variety of business purposes, including to provide the Services, to protect us or others, or in connection with a major business transaction such as a merger, sale, or asset transfer, as described below.

A. Disclosures to Provide the Services

We may share any of the personal information we collect with the categories of third parties described below.

Service Providers. We may share personal information with service providers that assist us with the provision of the Services. This may include, but is not limited to, service providers that provide us with hosting services, customer service, AI or machine learning services, analytics, marketing services, IT support, and related services. In addition, personal information and chat communications may be shared with service providers that help provide our chat features.
- Google Analytics. For more information about how Google uses your personal information, please visit Google Analytics’ Privacy Policy. To learn more about how to opt out of Google Analytics’ use of your personal information, please visit the Google Analytics Opt-out Browser Add-on.
Visitor Identification Providers. We share network and device signals with providers that identify visiting organizations and, in some cases, individual visitors. For traffic from the European Economic Area or the United Kingdom, these providers identify only visiting organizations, not individual visitors.
Third-Party Services You Share or Interact With. The Services may link to or allow you to interface with, interact with, share information with, direct us to share information with, access, and/or use a Third-Party Service. Any personal information shared with a Third-Party Service will be subject to the Third-Party Service’s privacy policy. We are not responsible for the processing of personal information by Third-Party Services.
Tolmo Customers (Authorized Users Only). In cases where you use our Services as an employee, contractor, or other authorized user of a Tolmo customer, we may share any information associated with your use of the Services with the Tolmo customer, including, but not limited to, account information, usage information, files, and the contents of the communications associated with your account. Your personal information may also be subject to the Tolmo customer’s privacy policy. We are not responsible for the Tolmo customer’s processing of your personal information.
Affiliates. We may share your personal information with our corporate affiliates.
Professional Advisers. We may share personal information with our professional advisers, including our lawyers, auditors, accountants, and insurers.
Advertising Partners. We may share your personal information with third-party advertising partners. These third-party advertising partners may set Technologies on our Services to collect personal information regarding your activities and your device (e.g., IP address, cookie identifiers, page(s) visited, location, time of day). These advertising partners may use this personal information (and similar information collected from other services) to tailor and deliver personalized ads to you when you visit digital properties within their networks. This practice is commonly referred to as “interest-based advertising,” “personalized advertising,” or “targeted advertising.”
The advertising Technologies we currently use include among others:
- LinkedIn, including the LinkedIn Insight Tag. For more information about LinkedIn’s use of your personal information, please visit LinkedIn’s Privacy Policy.

B. Disclosures to Protect Us or Others

We may share your personal information and related information with external parties if we, in good faith, believe doing so is required or appropriate to comply with law enforcement requests, national security requests, or other government requests; comply with legal process, such as a court order or subpoena; protect your, our, or others’ rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual unauthorized or illegal activity.

C. Disclosure in the Event of Merger, Sale, or Other Asset Transfers

If we are involved in a merger, acquisition, financing, reorganization, bankruptcy, receivership, purchase or sale of assets, transition of service to another provider, or other similar corporate transaction, your personal information may be shared, sold, or transferred as part of such a transaction.

5. Your Privacy Choices and Rights

Your Privacy Choices. The privacy choices you may have about your personal information are described below.

Email Communications. If you receive an unwanted email from us, you can use the unsubscribe functionality found at the bottom of the email to opt out of receiving future emails. Note that you will not be able to opt out of certain communications (e.g., communications regarding the Services or updates to this Privacy Policy).
“Do Not Track.” Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. Please note that we do not currently respond to DNT signals or similar mechanisms transmitted by web browsers.
Cookies. You may change your cookie choices at any time using the cookie banner in the footer of our website. You may also stop or restrict the placement of Technologies on your device or remove them by adjusting your preferences as your browser or device permits. However, if you adjust your preferences, the Services may not work properly.

The online advertising industry also provides mechanisms that may allow you to opt out of receiving targeted ads from organizations that participate in self-regulatory programs. To learn more, visit the Network Advertising Initiative, the Digital Advertising Alliance, and the European Digital Advertising Alliance.

Please note you must separately opt out in each browser and on each device.

Your Privacy Rights. In accordance with applicable law, you may have the right to:

Request Access to or Portability of Your Personal Information;
Request Correction of Your Personal Information;
Request Deletion of Your Personal Information;
Request Restriction of or Object to Our Processing of Your Personal Information; and
Withdraw Your Consent to Our Processing of Your Personal Information. Please note that your withdrawal will take effect only for future processing and will not affect the lawfulness of processing before the withdrawal.

If you would like to exercise any of these rights, please contact us as set forth in “Contact Us” below.

We will process such requests in accordance with applicable laws.

To protect your privacy, we may take steps to verify your identity before fulfilling requests. These steps may involve asking you to provide sufficient information that allows us to reasonably verify that you are the person about whom we collected personal information or an authorized representative. Examples of our verification process may include asking you to confirm the email address we have associated with you.

If your personal information is subject to the applicable data protection laws of the European Economic Area or the United Kingdom, you have the right to lodge a complaint with the competent supervisory authority if you believe that our processing of your personal information violates applicable law.

6. International Transfers of Personal Information

All personal information processed by us may be transferred, processed, and stored in the United States and in other countries where our service providers operate, which may have data protection laws that are different from the laws where you live. These countries may or may not have adequate data protection laws as defined by the data protection authority in your country.

If we transfer personal information from the European Economic Area, Switzerland, and/or the United Kingdom to a country that does not provide an adequate level of protection under applicable data protection laws, one of the safeguards we may use to support such transfer is the EU Standard Contractual Clauses.

For more information about the safeguards we use for international transfers of your personal information, please contact us as set forth below.

7. Retention of Personal Information

We store the personal information we collect as described in this Privacy Policy for as long as you use the Services, or as long as necessary to fulfill the purpose(s) for which it was collected, or as long as necessary to pursue our business purposes.

To determine the appropriate retention period for personal information, we may consider applicable legal requirements; the amount, nature, and sensitivity of the personal information; certain risk factors; the purposes for which we process your personal information; and whether we can achieve those purposes through other means.

8. Security

We take reasonable technical and organizational measures designed to protect personal information, which are described in our Trust Center (https://trust.tolmo.com/). No website, product, or method of transmission is completely secure, and we cannot guarantee absolute security.

This Supplemental Notice for EU/UK GDPR applies only to our processing of personal information that is subject to the EU or UK General Data Protection Regulation.

In some cases, providing personal information may be a requirement under applicable law, a contractual requirement, or a requirement necessary to enter into a contract. If you choose not to provide personal information in cases where it is required, we will inform you of the consequences at the time of your refusal to provide the personal information.

Our EU/UK GDPR representative’s contact details are set forth in “Contact Us” below.

10. Children’s Personal Information

The Services are directed to businesses and are not directed to children under 16 (or other age as required by local law outside the United States), and we do not knowingly collect personal information from children.

If you are a parent or guardian and believe that your child has uploaded personal information to the Services in violation of applicable law, you may contact us as set forth below.

11. Contact Us

Tolmo, Inc. is the controller of the personal information we process under this Privacy Policy.

If you have any questions about our privacy practices or this Privacy Policy, or to exercise your rights as detailed in this Privacy Policy, please contact us at: legal@tolmo.com

Tolmo, Inc., 2261 Market Street, Suite 63212, San Francisco, CA 94114, United States

EU/UK GDPR Representative: We have appointed Prighter Group with its local partners as our representative in the European Union and the United Kingdom pursuant to Article 27 of the EU GDPR and Article 27 of the UK GDPR. If you are located in the EU or the UK, you may contact our representative in addition to, or instead of, us at https://app.prighter.com/portal/17002647500, or by mail at:

EU. Prighter EU Rep GmbH, Schellinggasse 3, 1010 Vienna, Austria
UK. Prighter Ltd, 20 Mortlake High Street, London, SW14 8JN, United Kingdom

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