1. Introduction

UNIVERSALHOMEANDTECH LTD (Company No. 16534780), trading as TORGEER, is committed to protecting your personal data. This Privacy Policy explains how we collect, use, store and protect your information when you visit torgeer.co.uk or purchase from us.

We are registered with the Information Commissioner's Office (ICO) under registration number ZC044007. Our registered office is 15a Shrubbery Road, London, SW16 2AS, United Kingdom.

For any privacy-related enquiries, please contact us at support@torgeer.co.uk.

2. What Data We Collect

We may collect and process the following personal data:

Information you provide directly:

• Account information: name, email address, phone number, password (encrypted)
• Order information: billing and delivery addresses, payment details (processed securely by our payment provider)
• Communications: messages sent via our contact form, email or live chat
• Reviews and feedback: product reviews and ratings you submit
• Newsletter: your email address if you subscribe to our mailing list

Information collected automatically:

• Device data: IP address, browser type, operating system, screen resolution
• Usage data: pages visited, time spent on site, referral source, click patterns
• Cookies: see our Cookie Policy for full details

3. How We Use Your Data

We use your personal data for the following purposes:

• Order fulfilment: processing and delivering your orders, sending order confirmations and dispatch notifications
• Customer service: responding to enquiries, handling returns and refunds, resolving complaints
• Account management: maintaining your account, order history and wishlist
• Marketing: sending promotional emails and offers (only with your consent; you can unsubscribe at any time)
• Site improvement: analysing usage patterns to improve our website, products and services
• Legal compliance: meeting our legal and regulatory obligations, fraud prevention

4. Legal Basis for Processing

Under the UK General Data Protection Regulation (UK GDPR), we process your data on the following legal bases:

• Contract: processing necessary to fulfil your order or provide services you have requested
• Consent: marketing communications and non-essential cookies (you may withdraw consent at any time)
• Legitimate interest: improving our services, fraud prevention, website security
• Legal obligation: tax records, regulatory requirements

5. Data Sharing

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

• Delivery partners: courier services to deliver your orders (e.g. Royal Mail, DPD, Evri)
• Payment processors: to securely process card payments (e.g. Stripe, PayPal)
• Analytics providers: Google Analytics (anonymised data) to understand site usage
• Email service providers: to send transactional and marketing emails
• Law enforcement: if required by law or to protect our legal rights

All third-party providers are contractually obligated to protect your data and process it only as instructed by us.

6. Data Retention

We retain your personal data only for as long as necessary:

• Account data: for as long as your account is active, plus 2 years after last activity
• Order data: 7 years (as required by HMRC for tax purposes)
• Marketing consent: until you unsubscribe or withdraw consent
• Website analytics: 26 months (anonymised)

7. Your Rights

Under UK GDPR, you have the following rights:

• Right of access: request a copy of the personal data we hold about you
• Right to rectification: request correction of inaccurate data
• Right to erasure: request deletion of your data (subject to legal obligations)
• Right to restrict processing: request limitation of how we use your data
• Right to data portability: receive your data in a structured, machine-readable format
• Right to object: object to processing based on legitimate interest or for marketing purposes
• Right to withdraw consent: withdraw consent at any time where processing is based on consent

To exercise any of these rights, please email support@torgeer.co.uk. We will respond within 30 days.

8. Data Security

We implement appropriate technical and organisational measures to protect your data, including:

• SSL/TLS encryption on all pages
• Encrypted password storage (bcrypt hashing)
• Secure payment processing (PCI-DSS compliant providers)
• Regular security updates and monitoring
• Access controls limiting who can view personal data

9. International Transfers

Your data is primarily stored and processed within the United Kingdom. Where data is transferred outside the UK (e.g. to analytics providers), we ensure appropriate safeguards are in place, such as Standard Contractual Clauses or adequacy decisions.

10. Children

Our website is not directed at children under 16. We do not knowingly collect personal data from children. If you believe we have collected data from a child, please contact us immediately.

11. Changes to This Policy

We may update this Privacy Policy from time to time. The latest version will always be available on this page with the date of last update. Significant changes will be communicated via email or a notice on our website.

12. Contact & Complaints

For any privacy-related questions or requests:

• Email: support@torgeer.co.uk
• Post: Data Protection, UNIVERSALHOMEANDTECH LTD, 15a Shrubbery Road, London, SW16 2AS

If you are not satisfied with our response, you have the right to lodge a complaint with the Information Commissioner's Office (ICO):

• Website: ico.org.uk
• Helpline: 0303 123 1113

Last updated: March 2026