Togra Transparency

Privacy notice

Version 2026-11-04.2
Draft. This text describes what the product does and has not been reviewed by counsel. Highlighted items are facts the operator still has to supply.

How Togra Transparency handles personal data. It serves two kinds of people: producers who issue Article 19 transparency reports, and the participants those reports are issued to.

1. Who is responsible

Togra Software, [operator registered address to insert] ("we") runs Togra Transparency. Contact for everything in this notice: contact@togra.online.

Our role depends on the data:

2. What we hold

DataWhoseWhy
Name, email address, password (stored only as a one-way hash), two-step sign-in secret if switched on, sign-in timesProducer usersTo run the account and keep it secure.
Company legal name, address, CRO and VAT numbers, logoThe producer's companyTo head the reports the company issues.
Titles, deal terms, receipts, shares, the reports themselvesThe producer's companyTo calculate and issue reports. Entered by the producer.
Name, email address, role and share of each participantParticipantsTo calculate each participant's figures and send them their report. Entered by the producer.
When a report was sent, opened and acknowledged; the name and IP address given when a confidentiality agreement is signedParticipantsSo the producer can show a report was delivered. The producer sees this.
The report files, a summary of the figures, and the participant's name, email address and role, when a producer publishes from a connected Togra accountParticipantsSo the participant sees the report on their page here. Sent by the producer's own account; the producer is the controller.
Email address, IP address and time of each request for a sign-in linkAnyone who asks for oneTo send the link and to limit abuse. Deleted after 30 days.

3. Who sees what

A producer who also uses the main Togra service can connect that account so the reports they issue appear on their participants' pages here. A connection is registered by us only after the producer has accepted the terms and the data processing agreement, and the producer chooses, each time they issue reports, whether to publish them here. The email a participant receives says when a report is also on their page.

4. Who else handles it

Hosting: Hetzner. Email delivery: Scaleway (Transactional Email). We use no analytics, no advertising and no scripts loaded from other sites.

5. Cookies

One session cookie keeps you signed in. It is needed for the service to work and is removed when your session ends or you sign out.

6. How long we keep it

7. Your rights

You can ask us for a copy of your personal data, to correct it, to delete it, to restrict or object to its use, and to receive it in a portable format. If your data was entered by a producer, we pass your request to that producer, who decides it, and we help them act on it. Write to contact@togra.online. You can complain to the Data Protection Commission (dataprotection.ie).

8. Changes

Each change gets a new version number, shown at the top of this page.

Privacy notice · Terms of use · Data processing agreement
Questions, data requests and abuse reports: contact@togra.online