Privacy Policy

Last updated: 20th August 2026

This Privacy Policy explains how TOPDRAWERMANAGEMENT LTD (“TDM”, “we”, “us”, “our”) collects, uses, shares and protects your personal data when you visit tdmchattingservice.com (the “Website”), contact us, apply to work with us, or use our services. It also explains your privacy rights and how the law protects you.

1. Who we are and how to contact us

Controller: TOPDRAWERMANAGEMENT LTD, registered in England and Wales under company number 13816810, with registered office at 8a Bore Street, Lichfield, Staffordshire, WS13 6LL.

Data protection contact: [privacy@tdmchattingservice.com] (or use the contact details on our Website).

We are the controller of your personal data when you use the Website or otherwise interact with us, unless we inform you otherwise.

You can complain to the UK Information Commissioner’s Office (ICO) at any time (ico.org.uk). We would, however, appreciate the chance to deal with your concerns first.

2. Scope of this Policy

This Policy covers:

● Visitors to our Website

● People who contact us or request information

● Prospective and existing clients, creators and suppliers

● Job applicants and attendees at our events/webinars

It does not cover personal data we process purely as a processor on behalf of a client. In those cases, our client’s privacy notice will apply and we act on their instructions.

3. Personal data we collect

We may collect and process the following categories of data:

Information you provide to us

● Identity and contact details (name, email, phone, company/brand, country)

● Enquiry details, meeting notes and preferences

● Creator onboarding information where relevant (e.g. age affirmation, niche, links to public profiles)

● Recruitment information (CV, cover letter, work history)

Information we collect automatically

● Technical data: IP address, browser type/version, device identifiers, time zone, operating system

● Usage data: pages viewed, referring sites/UTMs, clicks, scrolls, session duration

● Cookies and similar technologies (see Cookies below)

Information from third parties

● Publicly available sources (e.g. LinkedIn, social media, Companies House)

● Referrals from partners and clients

● Service providers that help us run our Website, marketing and operations

We do not intentionally collect special category data via the Website. Please do not share sensitive information unless we have specifically asked for it.

4. How and why we use your data (lawful bases)

We only use your personal data where the law allows. Our purposes and lawful bases include:

● Providing and improving the Website (to deliver pages, keep the site secure and perform analytics). Legal bases: legitimate interests (running our business, site performance and security) and consent for non‑essential cookies/analytics.

● Responding to enquiries, scheduling calls and providing proposals. Legal bases:performance of a contract or steps prior to entering a contract; legitimate interestsin responding to prospective clients and creators.

● Client and creator onboarding and service delivery (including account management, invoicing and support). Legal bases: performance of a contract, legitimate interests.

● Marketing (sending insights, event invites or service updates). Legal bases: consentfor electronic marketing to individuals; legitimate interests for B2B contacts where permitted by law. You can opt out at any time.

● Recruitment (assessing applications, arranging interviews). Legal bases: legitimate interests, consent where appropriate.

● Compliance, security and fraud prevention (including record‑keeping and legal claims). Legal bases: legal obligation, legitimate interests.

Where we rely on consent, you can withdraw it at any time via the unsubscribe link in emails or by contacting us.

5. Cookies and analytics

We use cookies and similar technologies to operate the Website, understand performance and improve content. Non‑essential cookies (e.g. for analytics or advertising) will only run with your consent via our cookie banner.

You can update your preferences at any time via the banner or your browser settings. For more detail on the cookies we use, please see our Cookie Policy (linked in the Website footer).

6. Disclosing your data

We may share personal data with trusted recipients, strictly as necessary:

● Service providers / processors (website hosting, cloud storage, CRM/email tools, analytics, conferencing, project management, payment services)

● Professional advisers (lawyers, accountants, insurers)

● Business partners and referrers where you ask us to connect or we co‑host an event

● Group companies (if applicable)

● Authorities where required by law or to protect rights, safety or property

● Corporate transactions (e.g. merger, acquisition or restructuring), subject to appropriate safeguards

We do not sell your personal data.

7. International transfers

Some recipients may be located outside the UK/EEA. Where we transfer personal data internationally, we rely on appropriate safeguards such as an adequacy decision, the UK International Data Transfer Agreement (IDTA) or EU Standard Contractual Clauses, plus supplementary measures where necessary. You can contact us for details of the safeguards in place.

8. Data retention

We keep personal data only for as long as necessary for the purposes set out in this Policy, including to satisfy legal, accounting or reporting requirements. Typical retention periods include:

● Enquiry records: up to 24 months after last contact

● Contract/transaction records: 6–7 years (statutory)

● Marketing preferences and suppression lists: retained indefinitely to honour opt‑outs

● Recruitment data: normally 6 months from decision unless you consent to a longer period

9. Security

We use a combination of organisational and technical measures to protect personal data, including access controls, encryption in transit, employee training and vendor due diligence. No system is 100% secure; if we become aware of a personal data breach that is likely to result in a risk to you, we will notify you and regulators where required.

10. Your rights

Under UK data protection law you may have the right to:

● Access your personal data

● Rectify inaccurate or incomplete data

● Erase your data where there is no good reason for us to continue processing

● Restrict processing in certain circumstances

● Object to processing based on legitimate interests or to direct marketing

● Data portability for information you provided to us

● Withdraw consent at any time (where we rely on consent)

● Complain to the ICO (ico.org.uk)

To exercise your rights, contact us using the details above. We may need to verify your identity and we will respond within one month (or explain if more time is needed for complex requests).

11. Children

Our Website and services are intended for adults. We do not knowingly collect data relating to persons under 18 via the Website. If you believe a child has provided us with personal data, please contact us so we can delete it.

12. Third‑party links and platforms

The Website may contain links to third‑party sites, plugins or platforms. Those sites have their own privacy policies; we are not responsible for them. If you interact with embedded third‑party features (e.g. social media), that third party may collect data about you.

13. Automated decision‑making

We do not carry out automated decision‑making that produces legal or similarly significant effects about you via the Website.

14. Changes to this Policy

We may update this Policy from time to time. The latest version will always be posted on this page, and where appropriate we will notify you of significant changes.

15. How to contact us

Questions, requests or complaints regarding this Policy can be sent to:

TOPDRAWERMANAGEMENT LTD
8a Bore Street,
Lichfield,
Staffordshire
WS13 6LL

Email: privacy@tdmchattingservice.com

Alternatively, you can contact the Information Commissioner’s Office:

● www.ico.org.uk

● Telephone: 0303 123 1113

● Address: Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF