1. Introduction
Tone Agency is a trading name of Brandshank Ltd ("Tone", "we", "us" or "our"). This Privacy Policy explains how we collect, use, store and protect personal information when you visit https://tone.co.uk, submit an enquiry, receive marketing communications or use our services. We process personal information under applicable UK data protection legislation, including UK GDPR, the Data Protection Act 2018 and the Privacy and Electronic Communications Regulations (PECR).
Data controller: Brandshank Ltd, trading as Tone Agency. The Bank Building, 34 Burnley Road, Padiham, Lancashire, BB12 8BW. Email: studio@tone.co.uk. Website: https://tone.co.uk. Company registration number: 07744137.
2. Information we collect
We may collect:
- contact details (name, email, telephone, job title and company);
- enquiry and meeting information;
- email subscription preferences, consent records and engagement;
- website information (IP address, browser/device characteristics, pages visited, referral sources, cookie IDs and other online identifiers);
- business and professional information about organisations and contacts; and
- information needed to manage client relationships and projects.
3. How we collect information
We collect information through website enquiry and subscription forms, client relationships, business prospecting, events, networking, referrals, publicly available professional sources and website analytics or visitor-intelligence tools. Where we obtain information indirectly, we provide privacy information as required by law. An enquiry or exchange of business details does not automatically mean consent to email marketing.
4. How we use information and our lawful bases
We process data to:
- respond to enquiries (legitimate interests or pre-contractual steps);
- deliver services (contract or legitimate interests as appropriate);
- manage relationships and relevant B2B prospecting (legitimate interests subject to assessment);
- send opted-in marketing (consent);
- carry out other legally permitted corporate B2B marketing (legitimate interests where appropriate);
- measure website performance and advertising (consent where required for tracking, together with an appropriate UK GDPR lawful basis); and
- meet legal obligations (legal obligation).
We consider individuals’ rights and expectations when relying on legitimate interests.
5. HubSpot
Tone's website is hosted separately from HubSpot. We use embedded HubSpot forms to collect enquiries, HubSpot CRM to manage business contact records, and HubSpot for email marketing, subscription preferences and engagement reporting. Form submissions are stored in our HubSpot account; submitting an enquiry does not automatically subscribe a visitor to marketing. HubSpot's tracking code is deployed through Google Tag Manager (GTM) and may collect website visits, page interactions, referrals and identifiers. Where applicable, activity may be linked to an existing contact record. Optional tracking is subject to consent requirements. HubSpot may act as a processor for our services and as an independent controller for certain activities described in its policies. See https://legal.hubspot.com/privacy-policy and https://legal.hubspot.com/dpa.
6. Google Analytics
We use Google Analytics to understand website traffic, pages viewed, user interactions, approximate location, devices, referral sources and marketing performance. Google Analytics is deployed through GTM. Where required, it operates only following the relevant analytics consent. See https://policies.google.com/privacy.
7. Apollo
We use Apollo for business visitor intelligence and business development. Apollo tracking is deployed through GTM and may process website visits, IP addresses, technical identifiers and details about visiting organisations. Depending on the features enabled, it may help identify visiting businesses or professional contacts. We use relevant information to assess business interest and support proportionate outreach, subject to applicable privacy, marketing and tracking rules. Apollo tracking is categorised as marketing for consent purposes on our website. See https://www.apollo.io/privacy-policy.
8. Meta (Facebook)
We use Meta tracking technology, including the Meta Pixel, through GTM to measure advertising effectiveness and website conversions. Depending on configuration, Meta may process page visits, events, device or browser information, IP addresses and online identifiers. When enabled, this may support audience creation or remarketing. Marketing consent is required before activating non-essential Meta tracking. See https://www.facebook.com/privacy/policy/.
9. Cookies, GTM and consent
We use strictly necessary technologies for essential website functions and optional analytics and marketing technologies. Our cookie banner lets visitors accept or reject analytics and marketing cookies. Analytics includes Google Analytics and non-essential HubSpot tracking; marketing includes Apollo and Meta. GTM manages the deployment of these technologies but is not itself proof of consent. Where required, optional technologies should not activate until the corresponding consent is given. Visitors can change or withdraw their preferences through the website's cookie settings. Embedded HubSpot enquiry forms should remain usable when optional tracking is rejected. Specific cookie names, providers, purposes and expiry periods will be listed in our separate Cookie Policy.
10. Email marketing
Our audience is primarily professional contacts at businesses. Contacts may originate from website enquiries, subscriptions, existing clients, business prospecting, networking, events and referrals. Where individuals actively opt in, we record their preferences and use HubSpot to send relevant updates. We may also carry out legally permitted corporate B2B marketing using legitimate interests after an appropriate assessment. We do not treat a form submission or exchanged business card as automatic marketing consent. Different rules apply to sole traders and certain partnerships. Marketing emails include unsubscribe options; requests can also be made to studio@tone.co.uk. Limited suppression details may be retained to respect objections and opt-outs.
11. Sharing information
We may share relevant personal information with HubSpot (forms, CRM and marketing), Google (analytics and GTM), Apollo (business intelligence), Meta (advertising measurement), website hosting and maintenance providers, communications providers, professional advisers and authorities where legally required. Providers may act as processors or independent controllers depending on the activity. Appropriate data protection arrangements are used where required. We do not sell personal information.
12. International transfers
Some providers, including HubSpot, Google, Apollo and Meta, may process or access information outside the UK. Where personal information is transferred internationally, we take steps to use relevant UK adequacy arrangements or approved contractual safeguards, as applicable. Contact studio@tone.co.uk for information about applicable safeguards.
13. Retention
We keep information only for as long as necessary for its purposes and applicable legal, contractual and business requirements. Enquiries are kept for relevant follow-up; prospecting contacts are reviewed periodically; marketing records are retained while there is a valid basis and reviewed as appropriate; client records are kept for service and legal needs; tracking information follows configured retention settings; and limited unsubscribe information may be retained to respect opt-outs. Information no longer needed is securely deleted or anonymised.
14. Security
We use appropriate technical and organisational controls to protect personal information, including access restrictions, secure platforms, authentication and contractual safeguards with service providers. Access is limited to those who need the information for legitimate business purposes.
15. Your rights
Depending on the circumstances, you may request access, correction, deletion, restriction or portability of your personal information, object to processing, and withdraw consent where it is relied upon. You have an absolute right to object to direct marketing. Contact studio@tone.co.uk to exercise your rights. You can complain to the Information Commissioner's Office at https://ico.org.uk.
16. Profiling and automated decisions
We may analyse website and email engagement, identify potential business interest, and segment professional contacts for marketing or sales prioritisation. We do not use solely automated decisions that produce legal or similarly significant effects on individuals.
17. External links and changes
Third-party websites linked from our site may have their own privacy policies. We may update this notice as our services, technology or legal obligations change, and will publish the latest version with a revised date.
18. Contact
Tone Agency, a trading name of Brandshank Ltd. The Bank Building, 34 Burnley Road, Padiham, Lancashire, BB12 8BW. studio@tone.co.uk | https://tone.co.uk | Company number 07744137.