Privacy Policy

1. Who we are

The data controller is Tough Industries Limited, with its principal place of business at Building 22, Wanyang Zhongchuang City, No. 82 Xiaotang Industrial Avenue, Nanhai District, Foshan, Guangdong, China. For any privacy question or request, contact us at info@toughlighting.com.

2. What information we collect

a. Information you provide

When you submit an inquiry, quote, or catalogue request, we collect the details you enter:

• Name and email address (required)
• Company, country, and customer type (e.g. distributor, OEM)
• Phone / WhatsApp number (optional)
• Product of interest, quantity, and your message

b. Information collected automatically

When you browse the site we may collect, and store in your browser’s local storage:

• Approximate location (country and city) derived from your IP address by our hosting provider — we do not store your full IP address
• Device type, the website that referred you, your landing page, and the product/application pages you view
• Number of visits
• Marketing attribution parameters (UTM tags) and the Google Click Identifier (gclid)

With your consent, this browsing and attribution data is attached to your inquiry so our sales team can respond in context, and the gclid may be used to measure advertising conversions.

Separately, when you submit a form we also record your browser language, your timezone, and the time taken to complete the form, and automatically screen your submission for signs of spam or fraud. This screening data is not stored in your browser, is used solely to protect against abusive or fraudulent submissions, and is processed on the basis of our legitimate interests rather than consent.

c. Cookies, analytics, and advertising

We use Google Tag Manager to load Google Analytics 4, Google Ads (including conversion measurement and offline conversion import using the gclid), and Microsoft Clarity. These tools set cookies and similar identifiers only after you accept. Until then, Google Consent Mode keeps analytics and advertising storage disabled by default, and our own attribution tracking does not run.

3. How we use your information

• To respond to and fulfil your inquiry, quote, or catalogue request
• For sales follow-up and to send you the product information you asked for
• To measure and improve our website and advertising performance
• To import offline conversions to Google Ads where you became a customer after clicking an ad
• To screen form submissions for spam and fraudulent activity

4. Legal bases (for visitors in the EEA / UK)

• Consent — for analytics and advertising cookies and related tracking (you can withdraw it at any time)
• Legitimate interests / steps prior to a contract — to respond to your business inquiry, pursue B2B sales, and protect our business against spam and fraudulent submissions
• Legal obligation — where we must retain records to comply with the law

5. Sharing and service providers

We share data only with providers that help us operate the site and respond to you:

• Google LLC — Tag Manager, Analytics, and Ads
• Microsoft Corporation — Clarity (session analytics)
• Vercel Inc. — website hosting and IP-based geolocation
• Our email delivery provider — to send inquiry notifications and replies

We do not sell your personal data.

6. International data transfers

We operate internationally, and your data may be processed outside the EEA/UK, including in China and the United States. Where required, such transfers are protected by appropriate safeguards, such as the EU Standard Contractual Clauses where applicable.

7. How long we keep your data

Inquiry data is retained for up to 24 months, after which personal identifiers are removed from our records. Aggregated, non-identifying statistics may be kept longer.

8. Your rights

Depending on your location, you may have the right to:

• Access the personal data we hold about you
• Correct inaccurate data or complete incomplete data
• Request deletion (“right to be forgotten”)
• Restrict or object to processing
• Receive your data in a portable format
• Withdraw consent to analytics and advertising at any time

To exercise any of these rights, email info@toughlighting.com. EEA/UK visitors also have the right to lodge a complaint with their local data protection authority.

9. Your cookie choices

You can decline non-essential cookies using the consent banner shown on your first visit. To change your choice later, clear this site’s stored data in your browser, then reload the page — the banner will appear again. You can also manage cookies through your browser settings.

10. Children

Our site is intended for business customers and is not directed to children under 16.

11. Changes to this policy

We may update this Privacy Policy from time to time. The date at the top shows when it was last revised.

12. Contact us

For any question about this policy or your personal data, contact us at info@toughlighting.com or write to Tough Industries Limited, Building 22, Wanyang Zhongchuang City, No. 82 Xiaotang Industrial Avenue, Nanhai District, Foshan, Guangdong, China.