Privacy Policy

We are committed to protecting and respecting your privacy. This Privacy Policy (together with any applicable Terms of Use and Cookie Policy) (the “Policy”) describes our privacy practices regarding the collection, use and transmissions of personal information collected from you, or that you provide to TOC, its affiliates or licensees (“TOC”, “we” or “us”). By visiting this website, application, software, program, platform, or tool (the “Site”), you are accepting the practices described in this Policy.

Collection of Your Personal Information

At various times TOC may collect personal information, such as your email address, name, home or work address or telephone number, VAT number, financial and credit card information or anonymous demographic information. This is information you give TOC by filling in forms on the Site, registering on the Site or placing an order online. It also includes personal information you provide to us offline, such as when you attend an exhibition, trade show or event, place a verbal order over the phone, contact customer service or visit one of our offices.

There is also information about your computer hardware and software that may be automatically collected by TOC. This information can include: your IP address, your login information, browser type and version, browser plugins, domain names, products or services you viewed or searched for, download errors, clickstream history through and from the Site, access times and referring website addresses. This information is used by TOC for the operation of the service, to conduct business activities, to maintain quality of the service, and to provide general statistics regarding use of the Site. We also work with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies) and may receive or provide information about you from them.

Use of Your Personal Information

We only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
Where we need to perform the contract we are about to enter into or have entered into with you.

Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Where we need to comply with a legal or regulatory obligation.

More specifically, TOC collects, uses, transmits and stores the personal information you provide to deliver the services you have requested; to inform you of other products or services available from TOC; to notify you about changes to our service; and to ensure that content from the Site is presented in the most effective manner for you and for your device. TOC also may use your personal information to operate the Site; for internal operations, including troubleshooting, data analysis and testing; or to contact you via survey to conduct research about your opinion of current services or of potential new services that may be offered.

TOC will disclose your personal information, without notice, only if required to do so by law or in the good faith belief that such action is necessary to: (a) conform to the edicts of the law or comply with legal process served on TOC, its licensees or the Site; (b) protect and defend the rights or property of TOC; and, (c) act under exigent circumstances to protect the personal safety of users of TOC, the Site, or the public.

TOC may provide your personal information to (a) TOC affiliates that are located overseas which may not be bound by to US privacy laws; and (b) anyone authorized by you to receive your personal information. Personal information collected, however, will always remain in the sole possession of TOC, and will not be given to any third party except in accordance with the terms hereof. TOC may aggregate and amalgamate your personal information with other data, for internal reporting purposes, to improve the delivery of services and for benchmarking services. TOC will only use your personal information under circumstances where you will not be, and could not reasonably be, identified as the source or origin of the information.


TOC will retain your personal information for the period necessary to fulfill the purposes outlined in this Policy unless a longer retention period is required or permitted by law.

Security of Your Personal Information

TOC secures the personal information you provide on servers in a controlled, secure environment, protected from unauthorized access, use or disclosure. Personal information is transmitted to other websites through the use of Transport Layer Security (TLS) encrypted protection. Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to the Site; any transmission is at your own risk. Once TOC has received your personal information, TOC will use strict procedures and security features to try to prevent unauthorized access.

From time to time, TOC reviews its security procedures in an effort to make the security of personal information better. However, please be aware that no security measures are perfect or impenetrable.

Changes to this Statement

If there are material changes to this Policy or in how TOC will use your personal information, TOC will prominently post such changes prior to implementing the change. TOC encourages you to periodically review this Policy to be informed of how we are protecting your information.

Cookie Policy

Use of Cookies

The web site, application, software, program, platform, or tool (the “Site”) may utilize "cookies" to help you personalize your online experience. A cookie is a text file that is placed on your hard disk by a web page server. Cookies cannot be used to run programs or deliver viruses to your computer. Cookies are uniquely assigned to you, and can only be read by a web server in the domain that issued the cookie to you.

One of the primary purposes of cookies is to provide a convenience feature to save you time. The purpose of a cookie is to tell the web server that you have returned to a specific page. For example, if you personalize the Site's pages, or register with services, a cookie helps Freeman or its licensees to recall your specific information on subsequent visits. This simplifies the process of recording your personal information, such as billing addresses, shipping addresses and so on. When you return to the same Site, the information you previously provided can be retrieved, so you can easily use the features that you customized.

You will have been given information regarding cookies when first visiting this Site. If you continued navigating the Site without acknowledging this option, cookies were automatically accepted. If you wish to opt-out, most browsers allow you to turn off cookies or to receive a warning before a cookie is stored on your hard drive. Please refer to your browser instructions or help screen to learn more about how to do this. You may also wish to refer to Please note, if you choose to decline cookies, you may not be able to fully experience the interactive features of the services or the site.

Use of Beacons

The Site may contain electronic images known as web beacons - sometimes called "clear GIFs", "single-pixel GIFs", or "web bugs". Web beacons are used to deliver cookies on the Site, count clicks/users/visitors, and deliver co-branded content or services. We may include web beacons in our promotional e-mail messages or newsletters to determine whether messages have been opened and acted upon. The Site may also contain web beacons from third parties to help us compile aggregated statistics regarding the effectiveness of our promotional campaigns or other Site operations. These web beacons may allow the third parties to set or read cookies on your device.

For more information on data privacy, please see our Privacy Policy.

Data Protection

As your trusted data processing partner, we’re committed to helping our customers on their GDPR compliance journey. Across our product portfolio, TOC operates as a “Data Processor” of personal information, and seeks to establish transparent, privacy-centric relationships with our customers (as "data controllers") and our partners.

Key Product and Security Information

All TOC cloud-based products offer customizable data retention configurations which ensures that consumer data is only retained for the period of time allowed by our contractual agreements. All consumers personal information is removed upon expiration of this retention period. Some customers may choose to store data with TOC for longer periods to help meet their regulatory requirements. In all cases, customer data is always encrypted whether in transit or at rest on TOC servers using the latest encryption technology and techniques.

Policies and Processes

In support of the new privacy options available to consumers in the EU, we have updated our policies and internal processes to ensure our compliance with GDPR requirements and to easily facilitate the privacy related requests from our customers. Specifically, EU residents can perform their rights and may request removal of their personal information from our systems. TOC is committed to removing this data in an expeditious manner and will do so regardless of residency. More detailed procedures will be sent to our customers separately.


In order to retain the confidentiality of your personal data TOC has NDA's, a code of conduct & screening in place and conducts privacy training as part of their security program to raise privacy awareness among its personnel.

Data Processing Agreements & Legal Updates

We offer GDPR-compliant Data Processing Agreements for all customers and partners for whom we process personal data in the EU. Updates in the DPA's you will find are referrals to the new legislation; data subjects rights, audit rights, sub processors, data storage & specifications of processing.