Privacy Policy

1. Who we are and what this policy covers

This Privacy Policy explains how TruWord, trading through the TruWord platform (“TruWord”, “we”, “us” or “our”), uses personal information when you visit https://truword.co.uk, create or use a TruWord business account, contact us, use a public TruWord Business Profile or review/referral page, make a booking, submit an enquiry, take part in a referral programme, or otherwise interact with the TruWord service.

Our registered or trading address is Hill Street, Edinburgh, EH2 3JP. Company number (if applicable): Not applicable. VAT number (if applicable): Not applicable. You can contact us about privacy matters at info@truword.co.uk.

TruWord is primarily a business-to-business service. Our customers are businesses and other organisations that use TruWord to ask their own customers for reviews and recommendations, manage referrals and rewards, receive enquiries, offer bookings, publish Business Profiles and manage related activity.

2. Our roles under data protection law

TruWord can act in more than one legal capacity depending on the information and the reason it is being used. For information about our own website visitors, prospective customers, business account holders, billing contacts, support contacts and people who take part in the TruWord business-to-business referral programme, we generally act as a data controller because we decide why and how that information is used.

When a TruWord customer uploads, enters or otherwise provides information about its own customers or prospects and uses TruWord to send review or referral requests, manage referral enquiries, operate a customer referral programme, take bookings or manage customer communications, that business will normally be the data controller and TruWord will normally act as its data processor. In that situation, the business decides why the personal information is being used and is responsible for having an appropriate lawful basis and for giving its customers any privacy information required by law. TruWord processes that information on the business’s instructions and in accordance with our agreement with that business.

Where somebody visits a public TruWord Business Profile, review page, referral page or booking page, the relevant business is normally the controller of information submitted for an enquiry, referral or booking. TruWord may separately act as controller for limited technical, security, fraud-prevention, service analytics and platform administration information generated by the visit.

3. The information we may collect

The information we process depends on how you use TruWord. For business account users, this may include your name, business name, legal or invoice name, email address, telephone number, role, login credentials, business locations, business website, billing details, subscription information, invoice and payment records, referral-code information, support messages, account settings, user permissions and activity within the platform.

For customers and prospects whose information is entered by a TruWord business customer, the information may include names, email addresses, mobile or telephone numbers, company names, service or job details, completion dates, notes, location information, communication preferences, referral identifiers, referral enquiries, referral rewards, booking details, appointment information and other information the business chooses to enter into TruWord.

For people using public pages, we may process information submitted through forms, such as your name, contact details, booking details, enquiry message, referral information or the identity of a customer who recommended the business. We may also process technical information such as browser type, device category, approximate request time, referral URL, page activity, security logs and pseudonymous visitor or referral identifiers.

If you pay TruWord by bank transfer, we process invoice and payment reconciliation information. If card payment is offered and you choose it, card details are handled by our payment provider. TruWord may receive payment status, card type or limited payment references needed to operate the subscription, but we do not need to store your full payment card number or card security code.

4. How we obtain information

We obtain information directly from you when you create an account, complete checkout, edit your business profile, contact support, submit a public form or otherwise give information to us. We also receive information from TruWord business customers when they add their staff, customers, prospects, locations, bookings or referral records to the platform.

Some information is generated automatically when TruWord is used, for example authentication records, audit logs, security information, page activity, booking events, referral attribution, message-delivery events and technical information required to operate the service. Where optional marketing measurement is enabled, additional information may be collected only in accordance with the cookie and consent choices described in our Cookie Policy.

5. Why we use personal information

We use personal information to provide and administer TruWord, create and secure accounts, authenticate users, provide Business Profiles and public pages, process subscriptions, issue and reconcile invoices, deliver support, operate bookings, manage referrals and referral rewards, send service communications, maintain audit trails, detect abuse or fraud, keep the service secure, diagnose faults, improve the service and comply with legal or regulatory obligations.

We may also use information to understand how our public website and service are used, measure the effectiveness of our own marketing where permitted, maintain the TruWord business referral programme, respond to enquiries and communicate with prospective or existing business customers.

Where we process personal information on behalf of a TruWord business customer, our purpose is to provide the functions that customer has chosen to use. We do not decide which of its customers should be contacted, what message should be sent, what referral reward should be offered or whether a booking or referred enquiry should be accepted. Those decisions belong to the TruWord business customer.

6. Our lawful bases

Under UK data protection law, we must have a lawful basis for processing personal information when we act as controller. We commonly rely on performance of a contract where processing is necessary to provide TruWord to a business customer or to take steps requested before entering into a contract. We rely on legitimate interests where the processing is reasonably necessary to operate, protect, improve and administer TruWord, prevent misuse, maintain records, respond to business enquiries or understand the use of our services, provided those interests are not overridden by the rights and interests of the person concerned.

We rely on legal obligation where we need to process or retain information to comply with tax, accounting, legal, regulatory, security or law-enforcement requirements. Where consent is required, including for certain optional marketing or advertising technologies, we rely on consent and you may withdraw that consent at any time. Withdrawing consent does not make earlier processing unlawful.

7. Review and referral requests sent by TruWord businesses

TruWord allows a business to store customer contact details and send or organise requests asking customers to leave a review, recommend the business or take another permitted action. The business using TruWord is responsible for deciding whether it is lawful and appropriate to contact each person, for keeping its customer information accurate and for respecting opt-outs, objections and other communication preferences.

Where TruWord sends an email or processes a communication on behalf of a business customer, we act on that customer’s instructions. We may maintain suppression information so that an email address that has opted out is not repeatedly contacted through the same business account. Businesses must not use TruWord to send unlawful unsolicited marketing, misleading messages, abusive content or communications that breach the Privacy and Electronic Communications Regulations, UK GDPR or other applicable law.

8. Referral tracking and rewards

TruWord can create referral links and referral identifiers so that a business can see when an existing customer recommends it and a new person later makes an enquiry. Referral attribution may use a first-party identifier stored in the browser for the attribution period configured by the business. The normal customer-referral attribution period may be up to 180 days unless the business configures another permitted period.

A business may choose to offer its own customers a reward for a successful referral. The business, not TruWord, is responsible for the reward terms, eligibility decision, payment or fulfilment of the reward, tax treatment where relevant, and any promises made to its customers. TruWord records the information needed to help the business administer the programme.

TruWord also has a separate business-to-business referral programme through which an existing TruWord customer may recommend TruWord to another business. Where this programme is active, we process referral codes, attribution records, programme eligibility and payment or credit information as controller for the purpose of operating that programme.

9. Public Business Profiles, enquiries and bookings

TruWord businesses can publish Business Profiles or focused pages containing information such as their business name, logo, services, photos, contact details, opening hours, service areas, review links, booking options and referral tools. The business is responsible for the accuracy, legality and rights in the content it publishes.

If you submit an enquiry, booking or referral form through a business’s TruWord page, the information is provided to that business so it can respond to you or provide the service you requested. TruWord provides the technical platform for the interaction but does not itself provide the trade, professional or other service offered by the business.

10. Payments and billing information

We process subscription, invoice and payment information to administer business accounts, confirm whether a subscription is active, issue invoices, reconcile bank transfers, record card-payment results where card payment is offered, deal with failed or outstanding payments and keep appropriate financial records.

Our lawful bases for this processing are normally performance of our contract, our legitimate interests in administering and protecting the service, and legal obligations relating to accounting, tax and financial records.

11. Service, security and administrative communications

We may send account holders emails or notifications that are necessary or reasonably related to the service, such as email verification, password reset messages, payment confirmations, invoices, renewal reminders, subscription status messages, security notices, support replies and important operational updates. These are service communications rather than optional marketing messages.

If we send promotional communications about TruWord, we will do so only where permitted by applicable law and will provide an appropriate way to opt out.

12. Cookies, browser storage and similar technologies

TruWord uses cookies and similar storage technologies for secure sign-in, persistent login where enabled, security, theme preferences, referral attribution, service analytics, cookie-choice storage and other functions described in our Cookie Policy. Some are necessary to provide the service or remember a choice you have made. Others, particularly advertising or marketing measurement technologies, are used only where the required consent has been given.

Please read our Cookie Policy for more detail about the technologies used, their purposes and the choices available to you.

13. Sharing information with service providers

We use trusted suppliers to help us operate TruWord. Depending on the features being used, these may include hosting and infrastructure providers, email-delivery providers, payment processors, security and anti-abuse services, technical support providers, analytics or marketing measurement providers, and other suppliers required to operate the platform.

We only give service providers the information reasonably necessary for the services they provide. Where a provider processes personal information on our behalf, we require appropriate contractual and security protections. Where TruWord acts as processor for a business customer, sub-processors are appointed in accordance with the data processing terms in our Terms & Conditions.

14. Other circumstances in which information may be disclosed

We may disclose information where reasonably necessary to comply with law, a court order, regulatory requirement or lawful request from a public authority; to establish, exercise or defend legal claims; to investigate fraud, security incidents or misuse; to protect the rights, property or safety of TruWord, our customers or other people; or as part of a genuine business sale, restructuring, financing or transfer, subject to appropriate confidentiality and data protection safeguards.

We do not sell personal information to advertisers.

15. International transfers

Some suppliers may process information outside the United Kingdom. Where personal information is transferred internationally, we take reasonable steps to ensure that an appropriate legal transfer mechanism is in place, such as UK adequacy regulations, the UK International Data Transfer Agreement, the UK Addendum to approved standard contractual clauses, or another mechanism permitted by UK data protection law.

16. How long we keep information

We keep personal information for no longer than is reasonably necessary for the purpose for which it was collected, taking account of the nature of the information, account status, security requirements, contractual obligations, legal limitation periods and tax or accounting requirements.

Business account information is normally retained while the account is active. If an account expires or is closed, account and customer data may be retained for a limited period to allow reactivation, resolve disputes, complete payment or support activity and meet legal obligations. The normal expired-account retention setting is currently 12 months, although some records may be deleted earlier or retained for longer where there is a lawful reason.

Invoices, payment and accounting records may be retained for the period required by UK tax and accounting law, which can extend for several years after the relevant transaction or accounting period. Security logs and backups may persist for limited additional periods before being overwritten. Where appropriate, information may be anonymised rather than deleted.

17. Security

We use technical and organisational measures designed to protect personal information against unauthorised access, loss, alteration, disclosure or destruction. These measures include access controls, authentication, secure transport where supported, restricted administrative access, logging, backups and other safeguards appropriate to the nature of the service.

No online service can guarantee absolute security. Business customers are also responsible for protecting their own account credentials, controlling staff access, keeping devices secure and notifying us promptly if they believe an account has been compromised.

18. Your data protection rights

Depending on the circumstances and applicable law, you may have rights to ask for access to your personal information, correction of inaccurate information, deletion, restriction of processing, objection to certain processing, and transfer of information in a portable form. Where processing is based on consent, you may withdraw that consent. These rights are not absolute and may be subject to legal conditions or exemptions.

If the information is being processed by TruWord on behalf of one of our business customers, the quickest route will usually be to contact that business directly because it is the controller and decides how the information is used. We will provide reasonable assistance to the business where required to help it respond to a valid request.

19. Children

TruWord is a business service and is not designed for use by children as business account holders. Business customers should not use TruWord to collect children’s information unless they have a lawful basis, appropriate safeguards and any permissions required by law.

20. Automated decision-making

TruWord may use rules, status logic and automated processes to operate the platform, for example to identify duplicate referrals, manage subscription states, send scheduled messages or flag activity for review. We do not use your personal information to make decisions that produce legal or similarly significant effects about you solely by automated means unless we separately explain that processing and the safeguards that apply.

21. Changes to this Privacy Policy

We may update this Privacy Policy when the service, our suppliers or the law changes. The current version will be published on https://truword.co.uk with the updated date shown on the page. If a change materially affects how we use personal information, we will take reasonable steps to bring it to the attention of affected business account holders where appropriate.

22. Questions, requests and complaints

If you have a privacy question or want to exercise a data protection right in relation to information for which TruWord is the controller, please contact us at info@truword.co.uk. Please give enough information for us to understand the request and, where necessary, verify your identity.

You also have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection. We would appreciate the opportunity to address your concern first, but you are not required to contact us before approaching the ICO.