Privacy policy.

1. About Toeshee

Toeshee provides crypto-native customer support outsourcing and related operational services for the decentralized economy, together with a website and client portal that help customers evaluate, engage, and manage those services.

Toeshee is designed primarily for business-to-business use. We may process business contact information, company information, public information, customer-provided data, usage data, and AI-generated outputs.

2. Scope of This Policy

This Privacy Policy applies to:

• Visitors to the Toeshee website.
• People who request demos, pricing, information, or sales calls.
• Customers and authorized users of the Toeshee Platform and client portal.
• Business contacts and company representatives whose information may be processed by the Platform.
• Individuals who communicate with Toeshee by email, form, phone, chat, event, or other channel.

This Privacy Policy does not apply to third-party websites, services, platforms, databases, applications, or integrations that we do not control. Those services are governed by their own privacy policies and terms.

3. Information We Collect

3.1 Information You Provide Directly

We collect information that you provide to us, including:

• Name
• Business email address
• Phone number
• Company name
• Job title
• Company website
• Country or region
• Company profile details (such as company type, size, and revenue range)
• Support operation details (such as support team size, volumes, and tools used)
• Service interests and requirements
• Scheduling and contact preferences
• Subscription or billing information
• Support requests
• Messages, comments, or form submissions
• Account registration and user profile information
• Any other information you choose to provide

3.2 Customer Data

Customers and authorized users may submit, upload, connect, or configure data within the Platform, including target lists, records, watchlists, criteria, notes, integration settings, user permissions, and workflow configurations.

Customer Data is controlled by the customer. Toeshee processes Customer Data to provide, secure, support, improve, and administer the Platform.

3.3 Business Contact Information

The Platform may process business-related information about companies and individuals, including business name, business email, job title, employer, work location, company website, business social profile information, public professional information, company news, and other publicly available or commercially available business information.

Toeshee is intended to process business and professional information, not sensitive personal information.

3.4 Automatically Collected Information

When you visit our website, we automatically collect a limited set of technical and usage information: your IP address and the approximate geographic location derived from it (such as city, region, and country); browser type, operating system, device type, screen and viewport size, language, and time zone as reported by your browser; the pages you view, the links and buttons you click, the time and date of your visit, the referring website, and any campaign parameters in the link you followed (for example, UTM tags); and a first-party identifier we store in a first-party cookie or in your browser's local storage so we can recognize a returning visit and group page views into a session. See our Cookie Policy.

3.5 Information from Third Parties

We may receive information from customer-approved integrations, public websites, public records, business data providers, news sources, social and professional platforms, marketing platforms, payment processors, analytics providers, security vendors, event partners, and referral sources.

Third-party data sources may be subject to their own terms and privacy policies.

3.6 AI Inputs and Outputs

When you use Toeshee, the Platform may process prompts, configuration instructions, requests, and other inputs. The Platform may generate outputs such as summaries, recommendations, classifications, suggested responses, and research, including through the Toeshee website assistant.

3.7 Website Visitor Intelligence

Because we are a business-to-business company, we use a process commonly called visitor identification to understand which businesses are interested in our services. We match the IP address of a visit to the organization associated with it using a reverse-IP lookup ("IP-to-company" matching), performed through our IP-intelligence provider. This identifies a company, not necessarily an individual person. Where a company is identified, we may supplement the record with publicly available business information about that organization (such as industry, size, location, and website) and about the professional roles of individuals who work there (such as job title), obtained from a third-party business-data provider.

We use an automated AI service to interpret and summarize this business information — for example, the identified organization, its industry, and the pages viewed. This analysis is applied to organizations and business activity, not to identify or profile you as an individual. We do not use it to track individuals across other websites or to serve advertising.

3.8 What We Do Not Collect Through the Website

To keep our data collection limited, the website does not: record your screen, mouse movements, scrolling, or keystrokes ("session replay" or keystroke logging); capture what you type into a form before you choose to submit it; use third-party advertising, social media, or cross-site tracking pixels or cookies; or knowingly collect sensitive personal information (such as health, biometric, or precise location data) through site tracking.

4. Information We Do Not Want You to Provide

Unless we expressly agree in writing, you should not submit:

• Social Security numbers
• Government identification numbers
• Personal financial account numbers
• Payment card numbers except through approved payment processors
• Protected health information
• Biometric information
• Precise geolocation
• Children's information
• Passwords unrelated to approved integrations
• Highly sensitive personal information
• Information you are not legally permitted to provide

If you provide prohibited or unnecessary sensitive information, we may delete it, restrict it, or suspend access.

5. How We Use Information

5.1 To Provide the Platform

Create and manage accounts; authenticate users; provide dashboards, the client portal, and workflows; process customer configurations; deliver requested support services; generate outputs; send alerts and reports; provide exports and integrations.

5.2 To Support Customers

Respond to inquiries; schedule demos; provide onboarding; troubleshoot issues; deliver technical support; train users; improve customer success; communicate about subscriptions, billing, security, or service changes.

5.3 To Improve and Develop Toeshee

Analyze Platform usage; improve features and workflows; develop new products; test and refine capabilities; monitor performance; debug errors; enhance security; measure effectiveness.

5.4 For Sales and Marketing

Respond to information and demo requests; send product and pricing information; share relevant updates; invite users to events or webinars; analyze campaign performance; personalize website or email content; identify potential business customers.

You may opt out of marketing emails at any time by using the unsubscribe link or contacting us.

5.5 For Security and Compliance

Prevent fraud; detect abuse; protect accounts; enforce terms; monitor suspicious activity; maintain audit logs; comply with legal obligations; respond to lawful requests; protect rights, safety, and property.

5.6 For Legal and Business Purposes

Maintain business records; process payments; manage contracts; resolve disputes; enforce agreements; support mergers, acquisitions, financing, or corporate transactions; comply with applicable laws and regulations.

6. AI Processing and Model Use

Toeshee uses AI technologies to help generate summaries, recommendations, suggested responses, and related outputs, including through the Toeshee website assistant.

Separately, we use an AI provider to interpret and summarize the business information associated with website visits (see Section 3.7). To that provider we send only business and usage information — such as the identified organization, its industry, and the pages viewed. We do not send it your IP address or any identifier of you as an individual, and it is configured not to retain that information after processing.

We may use customer inputs, usage data, outputs, feedback, and operational data to operate, secure, evaluate, improve, and develop the Platform, subject to our agreements with customers and applicable law.

Where enterprise agreements, data processing addenda, or order forms include different commitments regarding AI training, model improvement, data retention, or customer data segregation, those written agreements will control for that customer.

Toeshee does not intentionally use sensitive personal information to train AI models. Customers should not submit sensitive personal information unless expressly authorized in writing.

AI-generated outputs may be inaccurate, incomplete, outdated, or based on third-party information. Users are responsible for reviewing and verifying outputs before relying on them.

7. How We Share Information

7.1 Service Providers

We may share information with vendors that help us operate our business and Platform, including cloud hosting providers, AI infrastructure providers, analytics providers, email and communication tools, payment processors, customer support tools, security vendors, data storage providers, error monitoring tools, and professional advisors.

These providers are authorized to process information only as needed to provide services to us, subject to contractual obligations.

7.2 Customer-Directed Integrations

If a customer connects Toeshee to a data source, communication tool, analytics platform, or other integration, information may be shared with that integration as directed by the customer. Customers are responsible for ensuring they have appropriate rights and permissions for connected systems.

7.3 Within Customer Accounts

Information may be visible to account administrators, authorized users, managers, and other users based on customer-configured permissions.

7.4 Business Transfers

We may share or transfer information in connection with a merger, acquisition, financing, reorganization, sale of assets, bankruptcy, or similar corporate transaction.

7.5 Legal and Safety Reasons

We may disclose information if we believe it is necessary to comply with law, respond to lawful requests, enforce our terms, protect our rights, prevent fraud or abuse, investigate security incidents, or protect users, customers, Toeshee, or the public.

7.6 Aggregated or De-Identified Information

We may use and share aggregated or de-identified information that does not reasonably identify an individual or customer for analytics, research, product development, benchmarking, marketing, or other lawful business purposes.

7.7 Website Service Providers

For the website and the visitor-intelligence described in Section 3.7, the specific service providers that act on our behalf, under contract and only to provide services to us, are:

• our IP-intelligence / geolocation provider (IPinfo);
• our business-data / enrichment provider (Apollo);
• our AI analysis provider (Anthropic), to which we send only business and usage information — not your IP address or any identifier of you as an individual — and which is configured not to retain that information after processing; and
• our hosting and infrastructure provider (GoDaddy).

We do not sell your personal information, and we do not share it for cross-context behavioral (targeted) advertising.

8. Selling or Sharing Personal Information

Toeshee does not sell personal information in the traditional sense of exchanging it for money.

Some privacy laws define "sale" or "sharing" broadly to include certain advertising, analytics, or data-sharing activities. If our activities are considered a sale or sharing under applicable law, eligible individuals may have the right to opt out.

If required, we will provide a "Do Not Sell or Share My Personal Information" link or equivalent opt-out mechanism.

Universal opt-out signals. We recognize and honor opt-out preference signals, including the Global Privacy Control (GPC), transmitted by your browser. If we detect a GPC signal, we treat it as a request to opt out of any processing for which an opt-out applies — and we do so in every region, regardless of any prior choice.

9. Cookies and Tracking Technologies

We use only first-party cookies and similar first-party storage — to remember your preferences, recognize a returning visit, group page views into a session, and understand website traffic and which businesses are interested in our services. We do not use third-party advertising, social media, or cross-site tracking cookies, and we do not use cookies to serve advertising or retargeting.

How tracking starts, by region. Where required by the law of your region (for example the EU/EEA, the United Kingdom, and Switzerland), site analytics run on an opt-in basis: nothing beyond the consent manager itself runs until you choose "Accept" in our consent banner. In other regions, site analytics run on a notice and opt-out basis: first-party analytics begin when the page loads, and the banner explains how to opt out at any time (through the banner, or the persistent "Cookie preferences" control). We determine your region from your IP address at the moment of the request; that address is used only for that lookup and is not stored. If we cannot determine your region, we default to opt-in.

You can decline or withdraw consent to non-essential tracking through our consent banner and the "Cookie preferences" control, and you can manage cookies through your browser settings. Global Privacy Control and Do Not Track signals are honored as an opt-out in every region. See our Cookie Policy for the full list of cookies and details.

10. Data Retention

We retain information for as long as reasonably necessary to provide the Platform, maintain customer accounts, fulfill contracts, support legitimate business purposes, comply with legal obligations, resolve disputes, enforce agreements, maintain security, preserve audit logs, and meet tax, accounting, and reporting requirements.

Retention periods may vary based on the type of information, customer settings, legal requirements, and business needs.

Our standard retention period for website usage and visitor-intelligence data is 24 months, unless a longer period is required by law or to resolve disputes or enforce our agreements, after which we delete or de-identify it. We use your IP address only transiently to perform the reverse-IP company lookup and to derive approximate location; we do not store the raw IP address. Where we need to recognize repeat activity or honor an opt-out, we retain only a salted, irreversible hash of it.

Customers may request deletion of Customer Data subject to contractual terms, legal obligations, backup retention, dispute preservation, and technical limitations.

11. Data Security

We use commercially reasonable administrative, technical, and organizational safeguards designed to protect information from unauthorized access, disclosure, alteration, and destruction.

Security measures may include access controls, authentication controls, encryption in transit, encryption at rest where appropriate, secure credential management, logging and monitoring, vendor security review, role-based permissions, backup and recovery procedures, and incident response processes.

No system is completely secure. We cannot guarantee that unauthorized third parties will never defeat security measures. Customers are responsible for securing their own accounts, passwords, devices, networks, users, and integrations.

12. International Data Transfers

Toeshee may process information in the United States and other countries where we or our service providers operate.

If information is transferred from the European Economic Area, United Kingdom, Switzerland, or other regions with data transfer restrictions, we will use appropriate safeguards where required, such as standard contractual clauses or other lawful transfer mechanisms.

13. Your Privacy Rights

Depending on your location and applicable law, you may have rights to access, correct, delete, or receive a copy of personal information; opt out of certain processing, sale, sharing, or targeted advertising; restrict or object to processing; withdraw consent; appeal a denied privacy request; and not be discriminated against for exercising privacy rights.

To exercise privacy rights, contact us at compliance@toeshee.com.

We may need to verify your identity before responding. We may deny requests where permitted by law, including where the request is fraudulent, unverifiable, excessive, conflicts with legal obligations, affects the rights of others, or relates to data controlled by one of our customers. If we process personal information on behalf of a customer, we may direct you to contact that customer.

14. California Privacy Notice

This section applies to California residents where the California Consumer Privacy Act, as amended, applies.

Categories of Personal Information We May Collect

• Identifiers, such as name, email, phone number, IP address, and account identifiers
• Commercial information, such as subscription details, demo requests, and billing records
• Internet or network activity, such as website usage and Platform activity
• Geolocation information, such as approximate location from IP address
• Professional or employment-related information, such as employer, job title, and company
• Inferences, such as preferences, interest in services, or potential fit
• Sensitive personal information only if voluntarily provided or required for limited security, account, or compliance purposes

Sources, Purposes, Disclosure, and Retention

We collect personal information from you, your company, authorized users, customers, public sources, third-party business data providers, integrations, analytics tools, and service providers. We use and disclose it for the purposes described in this Privacy Policy, including providing the Platform, sales, support, security, analytics, product improvement, and legal compliance, and we retain it for as long as reasonably necessary for those purposes, subject to legal, contractual, and operational requirements.

California Rights

California residents may have the right to know, access, correct, delete, opt out of sale or sharing, limit certain uses of sensitive personal information, and not be discriminated against for exercising privacy rights. To submit a request, contact compliance@toeshee.com.

15. European, UK, and Swiss Privacy Rights

Where GDPR, UK GDPR, or Swiss data protection law applies, this section provides additional information.

Controller and Processor Roles

For website visitors, demo requestors, and our own sales and marketing contacts, Toeshee generally acts as a data controller. For Customer Data processed on behalf of a customer within the Platform, Toeshee generally acts as a processor or service provider, and the customer acts as the controller.

Legal Bases

Where required, our legal bases for processing may include performance of a contract, legitimate interests, consent, compliance with legal obligations, and protection of rights, safety, and security. Legitimate interests may include providing and improving the Platform, securing systems, communicating with business contacts, marketing to business prospects, analyzing usage, and preventing fraud.

Rights

Individuals may have the right to access, correct, delete, restrict, object, transfer data, withdraw consent, and lodge a complaint with a supervisory authority. To exercise rights, contact compliance@toeshee.com.

16. Children's Privacy

Toeshee is not intended for children. We do not knowingly collect personal information from children under 13 or under the age required by applicable law.

If we learn that we have collected children's personal information without required consent, we will take reasonable steps to delete it.

17. Marketing Communications

If you receive marketing emails from us, you may opt out by clicking the unsubscribe link or contacting us.

Even if you opt out of marketing emails, we may still send transactional or administrative messages, such as account, billing, security, or service-related communications.

18. Third-Party Links and Services

Our website and Platform may contain links to third-party websites, applications, services, or integrations.

We are not responsible for the privacy practices, security, content, or policies of third parties. You should review their privacy policies before providing information or connecting services.

19. Customer Responsibilities

Customers are responsible for providing required notices to their users and contacts; obtaining required consents and permissions; ensuring Customer Data is lawfully collected and submitted; configuring user access appropriately; complying with privacy, marketing, communications, and data protection laws; responding to privacy requests where the customer controls the data; and ensuring use of Toeshee outputs complies with applicable law.

20. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. The updated version will be posted on this page with a revised effective date.

If we make material changes, we may provide additional notice, such as by email, dashboard notice, or website banner.

Continued use of Toeshee after an updated Privacy Policy becomes effective means you acknowledge the updated Privacy Policy.

21. Contact Us

The controller responsible for your information, and for questions, requests, or concerns about this Privacy Policy or our privacy practices, is:

Toeshee
8 The Green, #21722
Dover, DE 19901
Privacy & Compliance: compliance@toeshee.com
Support: webmaster@toeshee.com
Phone: +1 (866) 715-7327