Last updated: 10 October 2026
This policy explains what personal data we collect on toctoolkit.org and download.toctoolkit.org, why, who else handles it, and your rights.
Who we are
Theory of Change Toolkit is run by James Freeman-Gray, a sole trader in England, trading as Theory of Change Toolkit. James Freeman-Gray is the controller of the personal data described here, including the records of past orders. In this policy, “we” and “us” mean James Freeman-Gray, trading as Theory of Change Toolkit.
- Business address: 86–90 Paul Street, London, EC2A 4NE
- Email: hello@toctoolkit.org
We haven’t appointed a data protection officer. Email us with any question about your data.
What we collect and why
Buying the toolkit
Checkout is run by Onelink (Sold through Link, LLC, a Stripe affiliate in the US), the merchant of record. Onelink and Stripe handle your payment details under their own privacy policies (see Onelink’s), and we never see your full card number. Any Onelink account you create is between you and Onelink.
Onelink and Stripe send us your order details. These are your name, email address, billing country and postcode, the brand, expiry date and last four digits of your card, the business details you give (such as a VAT number) if you buy as a business, any discount code, and what you bought, when, and for how much. The checkout asks for your email address, name and billing country and postcode, and you can’t buy without them.
We use them to deliver the toolkit, re-send lost links, answer questions and arrange refunds (lawful basis: contract), and to keep the sales records that tax law requires (legal obligation).
Your download page
After checkout, you go to your download page on download.toctoolkit.org. The page checks your purchase with Stripe, using the checkout reference in the page’s address. It stores nothing about you and sets no cookies.
If a check fails, our own logs record a shortened checkout reference and the reason, never your name or email address. Vercel, which hosts the page, keeps request logs that include the full page address and your IP address. Lawful basis: contract, and our legitimate interest in keeping downloads working and stopping misuse.
Anyone with your page’s address can download the toolkit, so please keep it private.
If you bought through our old checkout
Until October 2026, sales went through our old checkout (SureCart) and Stripe, and we hold the order records. You may also have an account on our old members’ area. It holds your name, email address, a hashed password and your orders. These accounts close when the old site is retired.
We’ll email you once with your new download link and two optional questions about how you use the toolkit and its price. We’ll use answers only to understand use and pricing, never for marketing. Answers arrive by email and are kept in our mailbox. Lawful basis: contract for the link; our legitimate interest in improving the toolkit for the questions.
Contacting us
When you email hello@toctoolkit.org, we use what you send to reply. For a lost link, we find your purchase in Stripe by your email address. For a concession (for students, and for organisations in low- and middle-income countries), we check whether you qualify and send a discount code. Lawful basis: contract, where your email is about a purchase, including one you’re about to make; otherwise our legitimate interest in replying.
Our enquiry form (toctoolkit.org/enquiry/) collects your name, email address, enquiry type, subject and message, stores them in our website’s database, and sends a copy to our toctoolkit.org mailbox. Concessions are handled by email only.
Visiting toctoolkit.org
Our host, Infomaniak, logs requests to the site, including IP addresses. Lawful basis: our legitimate interest in running the site and keeping it secure.
We use Matomo, which runs on our own website hosting rather than on Matomo’s servers, to count visits and see which pages people read. It’s set up without cookies, and records a shortened version of your IP address, your browser and device type, the pages you visit and the site that sent you. We share none of it. Lawful basis: our legitimate interest in knowing which pages help people. You can object at any time (see “Your rights”).
toctoolkit.org sets no cookies, apart from WordPress’s sign-in cookies if you sign in to the old members’ area. Those are strictly necessary for signing in.
We don’t run a newsletter, and we don’t make automated decisions about you.
Who we share it with
We don’t sell personal data. We share it only with:
- Stripe and Onelink, which take payment. They also use payment data for their own purposes, such as preventing fraud, tax and legal compliance, as controllers in their own right. Stripe also stores our order records for us.
- Vercel Inc. (US), which hosts the download page and stores the toolkit file, in London, on our instructions. It also uses some technical data, such as logs, for its own purposes.
- Infomaniak Network SA (Switzerland), which hosts toctoolkit.org and our email.
- SureCart Inc. (US), which ran our old checkout and holds the records of those orders.
- Our accountant, for tax and accounts.
- Authorities, where the law requires it, and anyone the business is sold or transferred to, such as a company set up to run the toolkit.
Outside the UK
Infomaniak is in Switzerland, which UK law recognises as protecting personal data adequately.
Stripe, Onelink, Vercel and SureCart are US companies, and Stripe transfers data to Stripe, LLC in the US. Where a provider is certified under the UK–US data bridge, UK adequacy regulations cover the transfer; otherwise we rely on contract clauses approved for UK transfers, in the provider’s data protection terms. The download page’s code runs in London. Email us for details.
How long we keep it
- Order records, including those from our old checkout: 6 years from the end of the tax year of the sale.
- Emails: kept with the order records if they’re about a purchase; otherwise 2 years after our last reply.
- Download page logs in our Vercel account: a short time (currently one day). Vercel keeps some technical data for its own purposes under its own policy.
- Website logs at Infomaniak: for a limited period set by Infomaniak.
- Matomo visit data: 13 months, then totals only.
- Old members’ accounts and enquiry form messages: deleted when the old site is retired.
- Past buyers’ answers: 12 months, then an anonymous summary.
Your rights
You can ask for a copy of your data. You can also ask us to correct it, delete it, limit how we use it, or send it to you or to another organisation in a machine-readable format. Some of these rights apply only in certain circumstances, and if one doesn’t apply we’ll tell you why. You can also object to anything we do on the basis of legitimate interests, including analytics. Where we rely on your consent, you can withdraw it at any time.
Email hello@toctoolkit.org. We’ll reply within one month, and may ask you to confirm who you are. If a request is complex, the law lets us take up to two more months, and we’ll tell you if we need to. Onelink and Stripe handle deletion requests sent to them, for their own records; requests about our records come to us.
Complaints
Please tell us first. Email hello@toctoolkit.org with “Privacy complaint” in the subject, or write to James Freeman-Gray, Theory of Change Toolkit, 86–90 Paul Street, London, EC2A 4NE. We’ll acknowledge your complaint within 30 days, look into it without undue delay, keep you updated on progress and tell you the outcome.
You can also complain to the UK regulator, the Information Commission, which still uses the name ICO: ico.org.uk/make-a-complaint, helpline 0303 123 1113.
Changes to this policy
We’ll update this policy when what we do changes, including when toctoolkit.org moves to its new platform. The date at the top shows the latest version.
