Effective date: 16 July 2026
Last updated: 16 July 2026
1. ABOUT THIS PRIVACY POLICY
This Privacy Policy explains how the Toolbox Talks UK mobile application accesses, uses, stores and handles information.
Toolbox Talks UK is developed and published by:
Bullion Apps Ltd
Website: https://www.bullionapps.co.uk
Privacy and support contact: contact@bullionapps.co.uk
In this policy, “Toolbox Talks UK”, “the app”, “we”, “us” and “our” refer to the Toolbox Talks UK application and Bullion Apps Ltd.
This policy applies to the Android and iOS versions of Toolbox Talks UK distributed through Google Play, the Apple App Store and any other authorised distribution channel.
2. PRIVACY SUMMARY
Toolbox Talks UK is designed primarily as an offline application.
Bullion Apps Ltd does not automatically collect, receive or remotely store the names, signatures, attendance records, company information, project information, schedules or other workplace records entered into the app.
The app:
• does not require a user account or login;
• does not contain third-party advertising;
• does not sell personal information;
• does not use personal information for targeted advertising;
• does not use behavioural profiling or cross-app tracking;
• does not provide cloud storage or cloud synchronisation operated by Bullion Apps Ltd; and
• does not automatically upload locally created records to Bullion Apps Ltd.
Information entered into the app is stored locally on the user’s device unless the user deliberately chooses to export, save, print, share or synchronise it using another application or service.
3. INFORMATION PROCESSED ON THE DEVICE
Toolbox Talks UK may process information locally on the user’s device to provide its functions.
This may include:
• names of attendees, supervisors or other workplace personnel;
• handwritten digital signatures;
• company, project, site, team and reference information;
• toolbox-talk attendance and completion records;
• dates, times, schedules and reminder information;
• notes and other user-entered workplace information;
• user-selected company logos or images;
• generated PDF documents;
• calendar entries created at the user’s request; and
• app preferences and settings.
This information is used to provide the app’s features and is not automatically transmitted to Bullion Apps Ltd.
4. RESPONSIBILITY FOR WORKPLACE INFORMATION
Users may enter information relating to employees, contractors, visitors, supervisors or other individuals.
The user and, where applicable, the user’s employer or organisation are responsible for:
• ensuring that they have a lawful reason and appropriate authority to enter and use the information;
• providing any necessary privacy information to the individuals concerned;
• protecting records containing names, signatures or other personal information;
• deciding how long workplace records should be retained; and
• ensuring that exported or shared records are sent only to appropriate recipients.
Bullion Apps Ltd does not control the purposes for which users create their individual workplace records and cannot access records that remain stored only on the user’s device.
5. LOCAL STORAGE
Toolbox Talks UK stores its records, preferences and related information locally using the application storage and local database facilities available on the user’s Android or iOS device.
Locally stored information generally remains on the device until the user:
• deletes the relevant record within the app;
• clears or removes the app’s stored data;
• uninstalls the app;
• resets the device;
• exports or shares the information;
• saves a generated document outside the app; or
• synchronises information with an external service chosen by the user.
Bullion Apps Ltd cannot remotely view, retrieve, change or delete information stored only on the user’s device.
6. DEVICE CALENDAR ACCESS
Toolbox Talks UK may request permission to access the device calendar.
Calendar access is used only to provide calendar-related functions selected by the user, such as adding, updating or removing scheduled toolbox talks or related reminders.
Calendar information is not automatically sent to Bullion Apps Ltd.
If the user’s device calendar is connected to an external provider, such as Apple iCloud, Google Calendar, Microsoft Outlook or another service, that provider may process synchronised calendar information according to its own privacy policy, terms and account settings.
Calendar permission can be refused or withdrawn through the Android or iOS device settings. Calendar-related features may not work correctly when permission is disabled.
7. NOTIFICATIONS
The app may request permission to display local notifications.
Notifications may be used to remind the user about scheduled toolbox talks or other events selected within the app.
Notification scheduling is performed locally on the device. Bullion Apps Ltd does not automatically receive the content of locally scheduled notifications or a record showing when they were displayed.
Notification permission can be disabled through the device settings.
8. PHOTOS, IMAGES, CAMERA AND FILE ACCESS
Toolbox Talks UK may allow the user to select an image, such as a company logo, from the device’s photo library or file storage.
Where a camera-related feature is available, the app may request camera permission only when the user chooses to use that feature.
The selected image may be stored locally and included in records or PDF documents generated by the user.
The app may also allow the user to choose a storage location, open files or save generated documents.
Bullion Apps Ltd does not automatically upload selected images, photographs or files to its own servers.
Photo-library, camera and file permissions can be refused or withdrawn through the device settings. Relevant app features may not work when the required permission is disabled.
9. GENERATED PDF DOCUMENTS
Toolbox Talks UK may create PDF documents containing information entered or selected by the user.
These documents may include:
• toolbox-talk information;
• company, project and site details;
• attendance information;
• names and signatures;
• dates and references;
• company logos; and
• register or completion records.
Generated PDFs remain under the user’s control.
The user may choose to save, print, export or share a PDF through another application or service.
Bullion Apps Ltd does not automatically receive copies of generated PDFs.
Documents saved outside the app must be managed and deleted separately by the user.
10. SHARING AND EXTERNAL APPLICATIONS
Toolbox Talks UK may allow the user to initiate sharing through applications and services installed on the device.
These may include:
• email applications;
• messaging applications;
• cloud-storage services;
• printing services;
• Microsoft Teams;
• document-management services; or
• other applications selected by the user.
The app may also open an external website or another installed application at the user’s request.
Information is not shared merely because a sharing option is displayed. Sharing occurs when the user actively chooses a destination and confirms the action.
Once information is sent to another application, service or recipient, its processing is governed by the privacy policy, security arrangements and terms of that third party.
Bullion Apps Ltd does not control information after the user has deliberately exported or shared it.
Users should check documents, destinations and recipients carefully before sharing records containing personal or confidential information.
11. THIRD-PARTY PLATFORM SERVICES
The app relies on standard services and functions provided by Android, iOS, Google Play, the Apple App Store and the user’s device.
These platform providers may process technical, diagnostic, purchase, security or account information independently according to their own privacy policies and terms.
Data processed independently by Google, Apple, the device manufacturer, mobile network provider or another third party is not controlled by Bullion Apps Ltd.
Toolbox Talks UK does not use third-party advertising networks or cross-app tracking technologies.
12. APP-STORE PURCHASES AND PAYMENTS
Toolbox Talks UK may be purchased through Google Play, the Apple App Store or another authorised app-distribution platform.
The applicable app store processes the user’s payment method, purchase account and transaction.
Bullion Apps Ltd does not receive or store the user’s complete payment-card number, bank-account details or app-store password through Toolbox Talks UK.
Bullion Apps Ltd may receive limited transaction information from the applicable app store where necessary to administer purchases, refunds, financial reporting, fraud prevention or customer support.
The applicable app store’s privacy policy and payment terms apply to information processed as part of the purchase.
13. INFORMATION SENT DIRECTLY TO BULLION APPS LTD
The app does not automatically send personal information to Bullion Apps Ltd.
A user may voluntarily contact Bullion Apps Ltd by email or through the company website for support, feedback or another enquiry.
In that situation, Bullion Apps Ltd may receive:
• the user’s name;
• email address;
• company or organisation name;
• the content of the enquiry;
• technical information voluntarily provided by the user;
• screenshots, documents or files voluntarily attached by the user; and
• information necessary to investigate a purchase or support request.
This information is used to:
• respond to the enquiry;
• provide customer support;
• investigate reported faults;
• improve the app;
• manage purchases or refunds where applicable;
• protect the security and integrity of the business; and
• maintain appropriate legal and business records.
Where applicable, the lawful basis for this processing may include performing or taking steps connected with a contract, the legitimate interests of Bullion Apps Ltd in providing support and operating its business, compliance with legal obligations, or the individual’s consent.
14. SERVICE PROVIDERS
Bullion Apps Ltd may use reputable service providers to operate its business website, email, file storage, accounting, payment administration or customer-support functions.
These providers may process information supplied directly to Bullion Apps Ltd only as necessary to provide their services, maintain security, comply with the law or support the relevant enquiry.
Bullion Apps Ltd does not permit service providers to sell support-contact information or use it for unrelated targeted advertising on behalf of Bullion Apps Ltd.
15. DATA SHARING AND SALE
Bullion Apps Ltd does not sell personal information entered into Toolbox Talks UK.
Bullion Apps Ltd does not receive or share locally stored app records when those records remain only on the user’s device.
Information may be disclosed where:
• the user deliberately exports or shares it;
• the user asks Bullion Apps Ltd to provide support and supplies the information;
• a service provider processes information on behalf of Bullion Apps Ltd;
• disclosure is reasonably necessary to prevent fraud, misuse or a security threat;
• disclosure is required to establish, exercise or defend legal claims; or
• Bullion Apps Ltd is legally required to disclose the information.
Bullion Apps Ltd does not share personal information for cross-context behavioural advertising.
16. ANALYTICS, ADVERTISING AND TRACKING
Toolbox Talks UK does not contain third-party advertising.
Bullion Apps Ltd does not use information entered into the app for:
• targeted advertising;
• behavioural profiling;
• cross-app or cross-website tracking;
• sale to data brokers; or
• automated marketing decisions.
The app does not request advertising permission for the purpose of tracking users across applications or websites.
The operating system, app store or device manufacturer may separately collect diagnostic or usage information under the user’s device and privacy settings. Such processing is controlled by the applicable platform provider rather than Bullion Apps Ltd.
17. SECURITY
Toolbox Talks UK uses the standard application-storage and security controls provided by Android and iOS.
Bullion Apps Ltd takes reasonable steps to protect information that users voluntarily send directly to the company.
Users should protect their device with an appropriate security method, such as:
• a PIN;
• password;
• fingerprint recognition;
• facial recognition; or
• another device-locking method.
Users are responsible for protecting PDFs, exported files and other copies saved or shared outside the app.
Users should avoid entering personal or confidential information that is not necessary for the intended workplace record.
No electronic storage or transmission method can be guaranteed to be completely secure.
18. RETENTION AND DELETION
Records stored inside Toolbox Talks UK remain on the device until the user deletes them, removes the app’s stored data, uninstalls the app or resets the device.
Generated PDFs, exported files, shared documents and calendar entries stored outside the app may remain after Toolbox Talks UK is uninstalled.
These items must be deleted separately from the relevant:
• file location;
• calendar;
• photo library;
• email account;
• cloud-storage service;
• messaging application; or
• other third-party service.
Because Bullion Apps Ltd does not receive locally stored app records, it cannot remotely access or delete those records on the user’s behalf.
Information voluntarily sent to Bullion Apps Ltd for support is retained only for as long as reasonably necessary to:
• respond to and resolve the enquiry;
• investigate technical issues;
• maintain appropriate support and business records;
• meet legal, accounting or regulatory requirements; or
• establish, exercise or defend legal claims.
Information that is no longer reasonably required will be deleted or securely disposed of in accordance with applicable requirements.
19. ACCOUNT DELETION
Toolbox Talks UK does not require users to create an account with Bullion Apps Ltd.
There is therefore no Toolbox Talks UK online account requiring a separate account-deletion process.
Users can manage and delete locally stored information through the app and device controls described in this policy.
20. CHILDREN
Toolbox Talks UK is a professional workplace application intended for adult users.
It is not designed or directed towards children.
Bullion Apps Ltd does not knowingly collect personal information from children through the app.
If Bullion Apps Ltd becomes aware that a child has directly submitted personal information to the company, reasonable steps will be taken to review and delete it where appropriate.
21. AUTOMATED DECISION-MAKING
Toolbox Talks UK does not use personal information for automated decision-making that produces legal or similarly significant effects.
The app does not assess workers, determine employment outcomes or make automated health and safety decisions.
Users remain responsible for reviewing all app content, workplace records and safety information and for making their own professional and legal decisions.
22. USER RIGHTS
Where Bullion Apps Ltd holds personal information received directly through a support enquiry or other communication, individuals may have rights under applicable data-protection law.
Depending on the circumstances, these may include rights to:
• request access to personal information;
• request correction of inaccurate information;
• request deletion of personal information;
• request restriction of processing;
• object to certain processing;
• request a portable copy of information;
• withdraw consent where processing is based on consent; and
• complain to a data-protection authority.
Requests can be sent to:
Bullion Apps Ltd may need to verify the requester’s identity before completing a request.
These rights do not give Bullion Apps Ltd access to information stored only on the user’s device. Locally stored information must be managed by the user through the app, device, calendar, file system or relevant third-party service.
23. COMPLAINTS
Individuals who have concerns about how Bullion Apps Ltd handles personal information are encouraged to contact:
Individuals may also have the right to raise a complaint with the UK Information Commissioner’s Office.
Information Commissioner’s Office website:
24. CHANGES TO THIS PRIVACY POLICY
Bullion Apps Ltd may update this Privacy Policy when:
• the app’s functions change;
• data-handling practices change;
• new operating-system or app-store requirements apply;
• legal or regulatory requirements change; or
• clarification is required.
The latest version will be published on the Bullion Apps Ltd website.
The “Last updated” date at the top of this page will show when the policy was most recently revised.
25. CONTACT
Questions, requests or concerns about this Privacy Policy or Toolbox Talks UK can be sent to:
Bullion Apps Ltd
Email:
Website:
© 2026 Bullion Apps Ltd. All rights reserved.
Bullion Apps Ltd is a company registered in England and Wales.
Registered Office: 67 Brynmore, Bretton, Peterborough, PE3 8JG.
Telephone: +44 (0)7727122029
Company Registration Number: 17324046
ICO registration reference: ZC209057