PRIVACY POLICY – TOOLIGO

1. INTRODUCTION – WHAT ARE PERSONAL DATA?

When you use Tooligo as a visitor, renter or lender, you provide personal data to us. "Personal data" means any information relating to an identified or identifiable natural person. Tooligo LTD ("Tooligo", "we", "our", "us") is the data controller for personal data submitted to and processed on tooligo.com.tr and within our mobile applications available on Google Play and the App Store. This Privacy Policy explains how Tooligo processes personal data and the principles we apply. These principles do not limit any rights you may have under applicable law, including the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

2. GENERAL PRINCIPLES FOR PERSONAL DATA PROCESSING

Tooligo processes personal data:
• lawfully, fairly and transparently;
• only for specified, explicit and legitimate purposes;
• in a manner that is adequate, relevant and limited to what is necessary;
• accurately and kept up to date;
• securely and confidentially.

All processing is based on a lawful basis under UK GDPR.

3. COLLECTION OF PERSONAL DATA

4. PURPOSES OF PROCESSING

Tooligo processes personal data for the following purposes:
• creating and managing user accounts;
• facilitating rentals between lenders and renters;
• processing payments and payouts via Stripe;
• identity verification, fraud prevention and platform security;
• customer support and dispute resolution;
• compliance with legal and regulatory obligations;
• analysing and improving the Service;
• sending service-related communications and onboarding messages;
• marketing activities where permitted by law or based on consent.

Further information is provided at the point of data collection and in our Terms of Use.

5. LEGAL BASIS FOR PROCESSING

Tooligo processes personal data based on:
• performance of a contract (provision of the Service);
• compliance with legal obligations;
• legitimate interests (such as fraud prevention, platform integrity and security);
• consent, where required (e.g. certain marketing communications).

6. CONSENT

Where processing is based on consent, you may withdraw your consent at any time. Withdrawal of consent does not affect the lawfulness of processing carried out before withdrawal. Please note that even if consent is withdrawn, Tooligo may continue processing personal data where required to fulfil contractual obligations or comply with legal requirements.

7. AUTOMATED DECISION-MAKING AND PROFILING

Tooligo may use automated processes, including risk scoring and fraud-prevention tools, to:
• verify identity;
• detect suspicious activity;
• prevent misuse of the Service;
• assess compliance with payment and security requirements.

These processes may result in account restrictions, transaction reviews or suspensions. Users may request human review of automated decisions where required by law.

8. DISCLOSURE OF PERSONAL DATA

Tooligo may share personal data with trusted third parties where necessary, including:
• Stripe, Inc. (payments, identity verification and fraud prevention);
• insurance and protection partners;
• hosting and infrastructure providers;
• customer support and communication providers;
• IT, security and compliance consultants;
• UK authorities where legally required.

All third parties acting as processors are subject to contractual data protection obligations.

9. INTERNATIONAL DATA TRANSFERS

Some of Tooligo's service providers are located outside the United Kingdom. Where personal data is transferred outside the UK, Tooligo ensures appropriate safeguards are in place, including standard contractual clauses or other lawful transfer mechanisms recognised under UK GDPR.

10. SECURITY

Tooligo implements appropriate technical and organisational measures to protect personal data against loss, misuse, unauthorised access, alteration or disclosure, taking into account current technological standards and risks.

11. DATA RETENTION

Tooligo retains personal data only for as long as necessary for the purposes described in this Privacy Policy or to comply with legal, accounting and regulatory requirements (including tax, fraud prevention and dispute resolution).

12. CHILDREN'S PRIVACY

The Service is not intended for children under the age of 18. Tooligo does not knowingly collect personal data from children. If we become aware that personal data of a child has been collected, it will be deleted without undue delay.

13. YOUR RIGHTS

Under UK GDPR, you have the right to:
• access your personal data;
• request correction or deletion;
• restrict or object to processing;
• request data portability where applicable;
• lodge a complaint with the Information Commissioner's Office (ICO).

Requests can be sent to:
📧 [email protected]

Tooligo will respond in accordance with statutory time limits.

14. COOKIES

Tooligo uses first-party and third-party cookies to:
• enable essential website functionality;
• analyse website traffic and usage (e.g. Google Analytics);
• improve user experience;
• measure and optimise marketing performance.

Some cookies are session-based, while others may persist for up to two (2) years. You can manage or withdraw cookie consent via the cookie banner on our website or through your browser settings.

For questions regarding cookies, contact:
📧 [email protected]

15. CHANGES TO THIS PRIVACY POLICY

Tooligo may update this Privacy Policy from time to time. Any changes will be published on this page and, where appropriate, communicated through the Service.

16. CONTACT DETAILS – DATA CONTROLLER

Tooligo LTD
Company Number: 16599095
📍 Address: Flat 1, 31 Long Acre, London, England, WC2E 9LA
📧 Email: [email protected]

Tooligo has not appointed a statutory Data Protection Officer. All data protection enquiries should be directed to the contact details above.