Privacy Notice
Last updated 17 August 2026
This notice explains what personal data Tortomingo Ltd handles in connection with the Kokoro HACCP system, why, and what rights you have over it.
Who we are
Tortomingo Ltd is a company registered in England and Wales, company number 16156549. Registered office: Flat 135 Mayford, Oakley Square, London, NW1 1PA.
For anything in this notice, contact privacy@tortomingo.com. We have not appointed a Data Protection Officer, as we are not required to.
When we are the controller, and when we are not
This distinction matters, because different people are responsible depending on the data.
We are the controller for data about the people who buy and administer the service: manager and head office account details, billing contacts, and correspondence you send us. This notice covers that data.
We are a processorfor the food safety records created inside the system — the checks, temperatures, photos and staff names recorded at each branch. Each branch (or its operating company) is the controller of its own records; we store and process them on that branch's instructions. If you are a member of branch staff asking about your own records, your employer is the right first point of contact, though you are welcome to contact us and we will help.
What we handle, why, and on what basis
| Data | Purpose | Lawful basis |
|---|---|---|
| Manager and head office account details (name, work email, sign-in records) | Providing access to the service and keeping it secure | Contract |
| Billing contact details | Invoicing and taking payment | Contract, and legal obligation for tax records |
| Correspondence you send us, including complaints | Answering you and evidencing that we did | Legitimate interests, and legal obligation for data protection complaints |
| Branch check records: staff name recorded against a completed check, times, readings, and photographs of food and equipment | Producing the branch's food safety records | Handled as processor, on the branch's instructions |
| Server logs kept by our hosting provider | Keeping the service running and secure | Legitimate interests |
Branch staff sign in with a shared branch PIN rather than personal accounts, so we do not hold individual staff logins. A staff name may still be recorded against a completed check, and photographs taken in a kitchen may incidentally include people.
We do not use analytics, advertising or tracking tools, we do not profile anyone, and we do not sell or share personal data for marketing.
How long we keep it
- Check photographs — deleted automatically after 13 months.
- Monthly report PDFs — deleted automatically after 1 year.
- Check records themselves— retained for as long as the branch's contract runs, since they are the branch's food safety records; deleted or returned on request from the branch afterwards.
- Account details — deleted when the account is removed.
- Billing records — kept for six years, as UK tax law requires.
- Complaints — kept for two years after closure, as evidence we handled them.
The photo and report periods above are enforced by scheduled jobs that run automatically, not by anyone remembering to do it.
Who else processes it
We use a small number of service providers to run the system. Some process data outside the UK, which we rely on the UK's international transfer safeguards to cover. We list each of them, what they do, and where they actually process data, on our sub-processors page.
Your rights
You have the right to:
- ask what personal data we hold about you, and get a copy
- have inaccurate data corrected
- ask us to delete data
- ask us to restrict how we use it
- object to us using it
- ask for it in a portable format, or sent to someone else
Email privacy@tortomingo.com and we will respond within one month. There is no charge. Where we hold the data as a processor for a branch, we will pass your request to that branch and help them answer it.
Complaints
If you are unhappy with how we have handled your personal data, please tell us first using our data protection complaints form. We will acknowledge it within 30 days, look into it, and tell you the outcome.
You also have the right to complain to the Information Commissioner's Office at any time, without coming to us first — ico.org.uk/make-a-complaint, or 0303 123 1113.