Privacy Policy
Version 1.0 · Effective from 9 October 2026
This notice explains what personal data TUPPIN LTD collects when you use Tuppin, why we hold it, and what you can do about it.
TUPPIN LTD is registered in England and Wales under company number 17469830. Our registered office is 71-75 Shelton Street, Covent Garden, London, United Kingdom, WC2H 9JQ. For anything in this notice, email legal@tuppin.uk.
The short version
This summary is not the legal text. The sections below are.
- We collect the least we can: your email address, what you do in Tuppin, and the bookkeeping records you enter.
- Your bookkeeping data is yours. We hold it to run the service, not to learn from it.
- We do not sell data, run advertising, or use your records to train AI models.
- Your data is stored in the United Kingdom.
- You can export your transactions at any time, and ask us for a copy of everything else, or to delete it.
- If we get it wrong, you can complain to us and to the Information Commissioner's Office.
1. Two kinds of data, two different roles
This distinction runs through the whole notice, so it's worth getting straight first.
Your data, where we are the controller. Your email address, sign-in records, support messages and billing details. We decide how these are used, and this notice governs them.
Your customers' and suppliers' data, where we are the processor. The names, addresses and transaction details you enter about the people you trade with. You decide what goes in and why. We only act on your instructions, and our Data Processing Agreement governs that, not this notice.
If you are one of our users' customers or suppliers and want your data corrected or removed, contact the business you traded with. We cannot act on your request directly, but if you email legal@tuppin.uk we will point you in the right direction where we can.
2. What we collect
| Category | What it includes |
|---|---|
| Account data | Your email address, the business name you give us, your legal name and address if you add them for your invoices, and the date you signed up. |
| Sign-in data | Records of sign-in links sent and used, including timestamps and the IP address the link was used from; the browser and IP address of each signed-in session; and, if you add one, your passkey's public key. |
| Bookkeeping data | The income, expenses, transactions, categories, notes and documents you enter, including anything you record about your customers and suppliers. |
| HMRC connection data | If you connect Tuppin to HMRC: your National Insurance number, the identifiers HMRC gives your businesses, the access tokens HMRC issues when you authorise Tuppin, and a record of everything Tuppin sends to HMRC for you and what HMRC replies. We never see or store your HMRC sign-in details — you give those to HMRC directly, on HMRC's own website. |
| Fraud prevention data | Each time Tuppin contacts HMRC for you, details of the device and connection you are using: an identifier stored in your browser, your browser's user agent, screen and window size, time zone, your public IP address, and your Tuppin user identifier. HMRC requires this. We send it with each request and do not keep a copy, apart from the identifier in your browser. |
| Usage data | Which pages and features you use, and when, collected through Vercel Web Analytics without cookies. Used to understand what works, not who you are. |
| Technical data | IP address, browser type and version, device type, and error logs generated when something breaks. |
| Support data | Emails you send us and our replies. |
| Billing data | None during the free early access period. When subscriptions start we will hold the plan you are on, payment history and invoices; card details are handled by our payment processor and never reach us. |
We do not ask for and do not want special category data — health, ethnicity, religion, political opinions, biometric or genetic data, or anything about sex life or sexual orientation. Please do not enter it in free-text fields.
3. Where it comes from
Almost all of it comes from you: what you type into Tuppin, what you send us by email, and what your browser sends when you use the service.
Some comes from third parties acting for us — our payment processor confirms whether a payment succeeded, and our email provider tells us whether a message was delivered.
We do not buy personal data, scrape it, or enrich your account with information from data brokers or social networks.
4. Why we use it, and our lawful basis
| Purpose | Lawful basis |
|---|---|
| Creating your account and letting you sign in | Performance of our contract with you |
| Storing and displaying your bookkeeping records | Performance of our contract with you |
| Sending your figures, claims and declarations to HMRC, and reading back what HMRC holds, when you ask us to | Performance of our contract with you |
| Sending fraud prevention data to HMRC with each of those requests | Legal obligation: HMRC requires software that connects to Making Tax Digital to send it |
| Keeping a record of what was sent to HMRC and what HMRC replied | Our legitimate interests in being able to show what was filed and when, which is also in yours |
| Sending service messages — sign-in links, security notices, changes to these terms | Performance of our contract with you |
| Providing support when you ask for it | Performance of our contract with you |
| Taking payment and issuing invoices | Performance of our contract, and legal obligation for tax records |
| Keeping Tuppin secure, investigating abuse, and diagnosing faults | Our legitimate interests in running a secure and reliable service |
| Understanding which features are used, in aggregate | Our legitimate interests in improving the product |
| Keeping accounting and company records | Legal obligation |
| Establishing or defending legal claims | Our legitimate interests in protecting the business |
| Sending occasional product updates by email | Consent, which you can withdraw at any time |
Where we rely on legitimate interests, we have considered whether our interest is outweighed by your rights. You can ask us to explain that assessment, or object to the processing, using the contact details in section 15.
5. What we never do
- We do not sell your personal data, or your bookkeeping records, to anyone.
- We do not share your data with advertisers, data brokers or marketing networks.
- We do not use your bookkeeping records to train artificial intelligence models, ours or anyone else's. If we ever build a feature that would need that, we will ask you to opt in first, and you will be free to say no and keep using Tuppin.
- We do not profile you or your business for any purpose other than running and securing the service.
- We do not read your records out of curiosity. Access to production data is limited to what is needed to fix a problem, and is logged.
6. Who we share it with
We share personal data only with the service providers we need to run Tuppin, each bound by a written contract that limits what they may do with it. The current list is published at tuppin.uk/subprocessors and includes:
| Provider | What they do | Where |
|---|---|---|
| Neon | Hosts the database holding your records | United Kingdom |
| Vercel | Hosts and serves the application, which runs in London, and provides cookieless page-view analytics. Its platform logs and support are mainly in the United States | United Kingdom and United States |
| Brevo | Sends transactional email, including sign-in links | European Union |
| Cloudflare | DNS, and routing of inbound email to our addresses | Global network |
| [Stripe] | [Payment processing, once Subscriptions start] | [To be confirmed] |
We may also disclose personal data:
- to our professional advisers — accountants, lawyers, insurers — where they need it and are bound by confidentiality;
- where the law requires it, such as a court order or a valid request from HMRC or the police, and we will tell you unless we are legally barred from doing so; and
- if the business is sold or merged, to the buyer, who will be bound by this notice until they give you a new one.
HMRC. When you connect Tuppin to HMRC and ask it to send or fetch something, we send HMRC what that needs: your National Insurance number, your business identifiers, the figures, and the fraud prevention data in section 2. HMRC is not one of our service providers. It receives this as a public authority, in its own right, under its own personal information charter. To stop Tuppin acting for you, email legal@tuppin.uk and we will delete your HMRC connection data.
7. Sending data outside the UK
Your bookkeeping records are stored in the United Kingdom.
Some of our providers process data elsewhere:
- Brevo processes email in the European Union, which the UK has recognised as offering adequate protection, so no further safeguard is needed.
- Cloudflare operates a global network and is incorporated in the United States. We rely on its certification under the UK Extension to the EU-U.S. Data Privacy Framework (the UK–US data bridge), with its Standard Contractual Clauses and the UK Addendum as a fallback.
- Vercel runs the application in London, but its platform processing — request logs and support — is mainly in the United States. Those transfers are covered by Vercel's data processing terms, which incorporate the UK International Data Transfer Addendum.
Some providers are UK-based but owned by companies elsewhere, and their staff may access systems from outside the UK for support. That counts as a transfer, and the same safeguards apply.
You can ask us for details of the safeguards in place for any provider by emailing legal@tuppin.uk.
8. How long we keep it
| Data | Kept for |
|---|---|
| Bookkeeping records | While your account is open. After you close it, 30 days so you can still export, then deleted from live systems within 30 days, falling out of backups within a further 10 days. |
| Account and sign-in data | While your account is open, then deleted on the same schedule as your records. |
| HMRC connection data | While your account is open, unless you ask us to delete it sooner; then deleted on the same schedule as your records. The record of what was sent to HMRC is kept with your bookkeeping records. |
| Technical and application logs | 30 days. |
| Support emails | 12 months from the last message, so we can pick up a thread you return to. |
| Invoices and payment records relating to you | Six years from the end of the accounting period they relate to, because HMRC requires a company to keep its own records for that long. |
Separately, you have your own record-keeping duties. HMRC generally expects a sole trader to keep business records for at least five years after the 31 January submission deadline for the tax year. Export before you close your account.
9. Your rights
Under UK data protection law you can:
- ask what we hold about you and get a copy;
- have inaccurate data corrected;
- have data deleted, where we no longer need it and no legal duty requires us to keep it;
- restrict how we use it while a dispute is resolved;
- object to processing based on legitimate interests, and to direct marketing at any time;
- take your data elsewhere, as CSV, a structured, commonly used, machine-readable format; and
- withdraw consent where consent is the basis, without affecting what we did beforehand.
Some of this you can do yourself inside Tuppin: edit your records, and export your transactions as CSV. For a copy of everything else we hold, to close your account, or for anything else, email legal@tuppin.uk.
We will respond within one month. If a request is complex we may extend that by up to two further months, and we will tell you why within the first month. There is no charge unless a request is manifestly unfounded or excessive.
We may need to verify who you are before acting, usually by confirming you control the email address on the account.
10. Cookies
Tuppin uses only the cookies it needs to work. These keep you signed in, keep your session secure, and remember basic preferences such as light or dark mode. Strictly necessary cookies of this kind do not require your consent.
We use Vercel Web Analytics to see which pages are visited and how the service is performing. It does not use cookies: visitors are identified by a hash generated from the incoming request, which resets each day and cannot follow you between days or across other websites. Because nothing is stored on your device, no cookie banner is needed. We use no advertising or tracking cookies at all.
If we ever add anything that stores or reads information on your device beyond the essentials — analytics that uses cookies, advertising, or embedded third-party content — we will ask for your consent first and update this section.
You can block or delete cookies in your browser settings, but Tuppin will not be able to keep you signed in if you block the essential ones.
11. Emails we send you
Service emails are part of using Tuppin and you cannot unsubscribe from them while your account is open: sign-in links, security alerts, billing notices, and changes to the terms or this notice.
Product emails — new features, tips, occasional news — are optional. We will only send them if you have agreed, and every one has an unsubscribe link. Unsubscribing has no effect on your account.
We do not pass your email address to anyone for their own marketing.
12. Children
Tuppin is business software and is not intended for anyone under 18. We do not knowingly collect data about children. If you believe a child has given us personal data, email legal@tuppin.uk and we will delete it.
13. Automated decisions
We do not make decisions about you by automated means that produce legal effects or otherwise significantly affect you.
Tuppin does suggest categories for transactions and calculates totals. Those are aids, and nothing happens until you accept them. You can change any suggestion, and no suggestion is reported to HMRC or anyone else on your behalf.
14. Changes to this notice
We will update this notice when what we do with personal data changes, or when the law does.
For material changes we will email you at least 30 days beforehand and post a notice in Tuppin. Smaller corrections take effect when published. Every version carries a date and a version number at the top, and previous versions stay available at tuppin.uk/privacy/archive.
15. Contact and complaints
TUPPIN LTD
Registered in England and Wales, company number 17469830
Registered office: 71-75 Shelton Street, Covent Garden, London, United Kingdom, WC2H 9JQ
Email: legal@tuppin.uk
We have not appointed a data protection officer. We are not required to, and queries come to the address above.
If you are unhappy with how we have handled your data, tell us first — we would rather fix it. If you are still unhappy, you can complain to the Information Commissioner's Office, the UK's data protection regulator, at ico.org.uk/make-a-complaint or on 0303 123 1113. Complaining to the ICO does not affect any other rights you have.