Privacy Policy
Draft, awaiting legal review.
What we receive, why, who gets it next, how long we keep it, and what you can control.
Last updated .
1. The short version
- We use your information to run Tools Down for you. We don’t sell it or use it for advertising.
- Your customers’ details are yours. We use them only to provide Tools Down to you.
- What you send Tools Down goes to AI from other companies, which you agree to when you sign in. They’re set not to keep or train on it, with a few exceptions, web searches above all (section 4).
- If you allow location, we get only your town and postcode area, never your exact position.
- You can export your data, or delete your account, from Settings any time; section 6 says what that removes now and what waits.
2. Who we are
Tools Down is a trading name of Blue Ocean Code Ltd, company number 11626451, registered at 1 Cedar Office Park, Cobham Road, Wimborne, England, BH21 7SB. We are the controller for your account, how you use the app and this website. For your customers’ details we act for you (section 3). Contact us at hello@toolsdown.app.
3. Your customers’ details
You are the controller of your customers’ details and we are your processor: we use them only to provide Tools Down to you, under our data processing terms. We use a little ourselves, as a controller, to keep Tools Down secure.
Their details come mostly from you: what you enter, say or send, and a contact you pick from your phone. Some come from your customers, on the pages and emails we provide for you: the pages your quote, invoice and gas safety record links open, the gas safety records we email, and payment reminders if you’ve said yes. We note when a page is opened, and if a quote is accepted or turned down there, so you can see it. Replies go straight to your business email address; if we don’t have one, we ask for it before the first email goes. A message written to our sending address isn’t received: it bounces.
4. What we receive, and why
To use Tools Down you need an email address (or Apple or Google sign-in), your name and your business’s name. The rest is your choice, and for location, voice, photos and notifications your phone asks first.
To run your account and your admin
Lawful basis: contract.
- Your name, email address or Apple or Google ID, and your plan and, from Apple, your subscription’s status. We never see your card.
- Your business details (bank details for invoices, Gas Safe number and signature) and records: customers, jobs, the diary, quotes, invoices, payments you record, costs, reminders, gas safety records and photos. If you give your website address, we read what it shows about your business, for you to check.
- A contact you choose from your phone: its name and one phone number, email and postal address. The iPhone’s own picker shares only that contact, so Tools Down never reads your address book or asks for permission. Apple Maps finishes an address as you type; we see only the address you choose, except on a gas safety record, which saves as you fill it in.
- Your notification address and choices (the words of each notification pass through Expo and Apple), and the rough location of an outdoor job’s postcode area, never its address, for rain alerts.
- Your sign-in: each phone’s session (its IP address and app details), the codes we email you and, with Sign in with Apple, Apple’s token, so we can revoke it when you delete your account. They keep you signed in and secure, which is also in our legitimate interests.
So Tools Down can do what you ask
Lawful basis: contract. Tools Down can’t do the work without sending what you write, say and photograph to AI.
You agree to this when you sign in, and Tools Down sends nothing to the AI until you have. The agreement isn’t what makes the sending lawful, which is the contract above. You can withdraw it by deleting your account, because Tools Down can’t work without it; section 6 says what that removes.
The models that reply to you and read your photos are Claude, made by Anthropic and run for OpenRouter by Google Cloud and Amazon, not by Anthropic itself. Every provider is named in section 5.
- What you type or say, your photos, the replies you get, and a searchable memory of earlier chats, with the titles and summaries Tools Down writes. AI models index your chats and photo descriptions, and read your message and the parts of earlier chats that look relevant.
- Your voice, from when you tap the microphone until you stop. Amazon Transcribe turns it into text in Ireland. Amazon doesn’t keep the recording or use it to improve its services, and we don’t keep it either.
- If you allow location, your town and postcode area (such as “Stockport, SK4”), sent with each message so the AI knows roughly where you are. Your phone works it out from its approximate position, with Apple’s help. We never get your exact position and don’t store the area, though a “near me” question and its answer stay in your chat, and a “near me” web search sends the area to Exa (below). Turn it off in your phone’s settings any time.
- Incognito chats aren’t saved to your history, memory or export, and can’t change your records. They still go to the AI model that answers, and a web search from one is checked and goes to Exa like any other. We keep a count of them, what each cost and which tools it used, not what was said.
Every request to an AI model asks for zero data retention, so the providers are set not to keep what we send or train on it, and we don’t train on it either. There are small exceptions. A host may hold the conversation so far, photos included, in a short-lived cache for about five minutes, and the list of tools the AI can use, which is the same for everyone, for an hour. A provider may keep a request where the law requires it, or to deal with misuse. And OpenRouter, which passes our requests on, keeps its own account, billing and security records, which aren’t what you wrote.
The larger exception is a web search. The search words go to Exa, a search engine, which may keep them and use them to improve its service, as its own Privacy Policy says. So every search is checked first. One that names a customer or anyone else, or holds a customer’s or job’s address, a phone number, an email address or a full postcode, isn’t sent, and nor is one the check can’t finish. A town, or a postcode area such as SK4, is allowed. For a “near me” search, your area is added after the checks. No check is perfect, so the AI is also told to leave personal details out.
To keep Tools Down safe, working and better
Lawful basis: legitimate interests, ours in keeping Tools Down secure, working and used for what it’s for, and in looking after the people who contact us.
- Which parts of the app you use, what you created, changed or deleted, how many messages you’ve sent, and what each AI request cost: never what you wrote or said.
- Whether an AI safety check flagged a message, and why. It reads each message you send in a chat, not Incognito, just after you send it, and never blocks anything. We keep only the result, never the words.
- Technical logs: times, error codes and their text, and account and request IDs.
- What you tell us when you contact us.
On this website
Lawful basis: legitimate interests in running a safe, working website.
- Server logs (IP address, browser and time), kept by our hosting provider, and anonymous visit counts, which use no cookies and can’t identify you. You can switch the counting off on our cookies page.
Our Cookies and browser storage page explains what the site keeps in your browser.
5. Who receives it next
Each of these works under a written agreement and gives your information the same protection as this policy, or an equal one: it keeps it secure and uses it only to do this work for us. The exceptions are Apple and Google, who also have their own relationship with you and look after what they hold under their own privacy policies, and Exa, which may keep web search words (section 4). Where a row says “through OpenRouter”, we have no contract of our own with that provider: it works under OpenRouter’s agreement.
This list is kept up to date. Before a provider new to the list receives your customers’ details, we give you 30 days’ notice, as the data processing terms say.
| Provider and what it does for us | Where, and the safeguard for transfers from the UK | Agreement |
|---|---|---|
| Provider and what it does for usAmazon Web Services — hosting, storage, speech to text and email. | Where, and the safeguard for transfers from the UKIreland. Safeguard: none needed. | AgreementAWS Data Processing Addendum, part of the AWS Service Terms |
| Provider and what it does for usOpenRouter — passing our requests to the AI models. | Where, and the safeguard for transfers from the UKUnited States, with an EU address for chats, memory and photos. Safeguard: the UK Addendum to the EU standard contractual clauses. | AgreementOpenRouter Data Processing Agreement, part of the OpenRouter Terms |
| Provider and what it does for usGoogle Cloud (Vertex AI) — runs Claude for your chats, photos, web results, and chat titles and summaries, and Google’s embedding model that finds your earlier chats and photos, for OpenRouter. | Where, and the safeguard for transfers from the UKEuropean Union; web search results may be read elsewhere. Safeguard: none in the EU; elsewhere, the UK Addendum to the EU standard contractual clauses, through OpenRouter. | AgreementThrough OpenRouter’s agreement |
| Provider and what it does for usAmazon Bedrock (Amazon Web Services) — runs Claude for your chats, photos, web results, and chat titles and summaries, for OpenRouter. | Where, and the safeguard for transfers from the UKEuropean Union; web search results may be read elsewhere. Safeguard: none in the EU; elsewhere, the UK Addendum to the EU standard contractual clauses, through OpenRouter. | AgreementThrough OpenRouter’s agreement |
| Provider and what it does for usDeepInfra — the safety check’s Llama Guard model, on each chat message. | Where, and the safeguard for transfers from the UKUnited States. Safeguard: the UK Addendum to the EU standard contractual clauses, through OpenRouter. | AgreementThrough OpenRouter’s agreement |
| Provider and what it does for usTypeSafe — its Jev model: a second safety check, the web search name check, finding earlier chats. | Where, and the safeguard for transfers from the UKUnited States. Safeguard: the UK Addendum to the EU standard contractual clauses, through OpenRouter. | AgreementThrough OpenRouter’s agreement |
| Provider and what it does for usExa — web searches. | Where, and the safeguard for transfers from the UKUnited States. Safeguard: the UK Addendum to the EU standard contractual clauses, through OpenRouter. | AgreementThrough OpenRouter’s agreement |
| Provider and what it does for usExpo — notifications, words and all. | Where, and the safeguard for transfers from the UKUnited States. Safeguard: the UK Extension to the EU-US Data Privacy Framework. | Agreementthe data processing terms in the Expo Terms of Service (section 3.2) |
| Provider and what it does for usApple — Sign in with Apple, subscriptions, address suggestions (Apple Maps), turning your approximate location into a town and postcode area if you allow it, and notifications. | Where, and the safeguard for transfers from the UKIreland, and the United States. Safeguard: Ireland is covered by UK adequacy regulations; Apple’s onward transfers are under its Standard Contractual Clauses. | AgreementApple Developer Program License Agreement, and Apple’s own Privacy Policy for what it controls |
| Provider and what it does for usGoogle — Sign in with Google. | Where, and the safeguard for transfers from the UKUnited States. Safeguard: the UK Extension to the EU-US Data Privacy Framework. | AgreementGoogle Controller-Controller Data Protection Terms, which apply under the Google APIs Terms |
| Provider and what it does for usGoogle Workspace — our support and company email: what you write to hello@toolsdown.app. | Where, and the safeguard for transfers from the UKUnited States and other countries. Safeguard: the UK Extension to the EU-US Data Privacy Framework. | AgreementGoogle Cloud Data Processing Addendum, which covers Google Workspace |
| Provider and what it does for usVercel — website hosting and anonymous visit counts. | Where, and the safeguard for transfers from the UKUnited States. Safeguard: the UK international data transfer addendum in Vercel’s data processing addendum, with the EU standard contractual clauses. | AgreementVercel Data Processing Addendum, part of the Vercel Terms |
| Provider and what it does for usCloudflare — domain name services, and forwarding the email people send to hello@toolsdown.app to our mailbox. | Where, and the safeguard for transfers from the UKUnited States and other countries. Safeguard: the UK Extension to the EU-US Data Privacy Framework, with the EU standard contractual clauses and UK Addendum as the fallback. | AgreementCloudflare Data Processing Addendum |
6. What deleting does
What you add stays until you delete it or delete your account. Some of it you may have to keep: VAT records are generally kept for six years, and a landlord’s gas safety records generally for two. We can’t advise on that, so check what applies to you.
Gone at once
- A customer. Their contact details, notes, jobs with their diary entries and reminders, photos and drafts, the quotes they never accepted, chat messages only about them, and what Tools Down remembers of them. Messages that also mention someone else stay, and so do the issued records that name the customer (below).
- A chat. Its messages, and any photos from it that weren’t filed on a job, a customer or a cost. Anything it made, such as a quote or a job, stays.
- Your account. In Settings, choose Delete account. Your records, chats, photos and files go; backups, logs and emails sent to us follow the timetable in section 7. Deleting your account doesn’t cancel Pro, which is with Apple: cancel it first, in Settings under Plan.
Hidden now, erased when your account closes
Other things you delete, such as a job or a diary entry, disappear at once. We keep a copy so you can undo, until your account closes or you delete the customer they belonged to. A deleted photo’s file is erased within minutes.
What stays
Issued invoices, issued quotes and gas safety records can’t be deleted one by one: a mistake is voided, cancelled or corrected, and they go when you delete your account. If you delete a customer, their accepted quotes, any quote an issued invoice came from, and the issued invoices and gas safety records that name them, with who each was sent to, stay and still show their details; costs and their receipts stay too, with the customer taken off.
7. How long we keep it
This is what we keep, and for how long.
| What we keep | How long, and why |
|---|---|
| What we keepEverything you add: records, chats, photos, what Tools Down remembers, and the history of your changes, which lets you undo | How long, and whyWhile your account is open, unless you delete them first. section 6 says which records can’t be deleted one by one. |
| What we keepHow you use the app, never what you wrote or said: which parts you use, and what each AI request cost | How long, and whyWhich parts you use: 24 months, or until your account closes if that comes first. What each AI request cost: while your account is open. |
| What we keepWhat the AI providers receive | How long, and whyNot kept, apart from the exceptions in section 4. |
| What we keepThe result of each safety check | How long, and why90 days. Never the words. |
| What we keepTemporary files: a photo you add but never send or file, and an export | How long, and whyA photo: 24 hours. An export: 24 hours after it’s ready, and each download link lasts 15 minutes. |
| What we keepSigning in: your sessions and, if you use Sign in with Apple, its token | How long, and whyA session lasts until you sign out, or 30 days without use; its record goes when you sign out, and otherwise with your account. Apple’s token goes when you delete your account: we ask Apple to revoke it, and delete it within a month whether or not Apple confirms. |
| What we keepLogs: technical logs, and the website’s server logs | How long, and whyTechnical logs: 30 days. Website server logs: about a day, with our hosting provider. |
| What we keepDatabase backups | How long, and why14 days. Deleted data can sit in a backup until then. If a backup is ever restored, we delete again what you deleted since it was taken. |
| What we keepWhat you send us when you contact us | How long, and whyTwo years after the last message, even if you have deleted your account. |
| What we keepAnonymous website visit counts | How long, and why12 months. A visitor is told apart from others for 24 hours at most, to count them once. |
9. Your rights, and complaints
Depending on the circumstances, UK data protection law gives you rights to be informed and see your information, correct it, ask for erasure or restriction, object to processing based on legitimate interests or direct marketing, receive it in a portable format, and withdraw consent at any time without affecting earlier lawful processing.
In the app you can see and change your details, and take your data away, chats included, with Export everything in Settings.
Email hello@toolsdown.app to use a right. We’ll reply within one month and may need to verify your identity. If a tradesperson who uses Tools Down holds your details, we’ll pass your request to them and help them answer it.
No decision that has a legal or similarly significant effect on you is made by automated means alone.
Complaints
To complain to us about how we handle personal information, email hello@toolsdown.app. We’ll acknowledge it within 30 days, look into it and tell you what we found and what we’ll do. This is separate from asking to use a right above. If your complaint is about a tradesperson’s records, we’ll pass it on to them.
If you’re not happy with our answer, you can complain to the Information Commissioner’s Office at ico.org.uk/make-a-complaint. The ICO usually expects you to have complained to us first.
10. Children
Tools Down is a business service, for people running a business, and not intended for anyone under 18.
11. Changes and contact
If we change this policy, we’ll update this page and the date above, and if a change affects how we use your information, tell you first, in the app or by email if you have an account. Questions: hello@toolsdown.app. Our Terms of Service set out the rest of our agreement with you.