Torq Privacy Policy

This Privacy Policy explains how Torq ("Torq," "we," "us," or "our") collects, uses, shares, stores, and protects Personal Data.

It applies when you:

• visit a Torq website or another website that links to this Privacy Policy;
• create or use a Torq account;
• use our products, applications, platforms, or services;
• communicate with our sales, support, or other representatives;
• register for or attend a Torq event; or
• otherwise interact with us.

For purposes of this Privacy Policy, "Personal Data" means information relating to an identified or identifiable individual.

Our Roles When Processing Personal Data

Torq may process Personal Data in two different capacities:

Torq as a controller

Torq acts as a controller when we determine why and how Personal Data is processed. This generally includes Personal Data collected when you:

• register for our services;
• create or manage a Torq account;
• visit our websites;
• contact us;
• attend our events; or
• interact with our marketing, sales, or support teams.

When acting as a controller, we may use Personal Data to provide and improve our services, manage our relationship with you, communicate with you, protect our systems, comply with legal obligations, and promote our products and services.

Torq as a processor or service provider

Torq acts as a processor or service provider when customers use our services to collect, store, manage, or otherwise process Personal Data for their own business purposes.

In these circumstances, the customer determines why and how the Personal Data is processed, and Torq processes it on the customer's behalf and according to the customer's instructions, our agreement with the customer, and any applicable Data Processing Agreement.

If you wish to exercise privacy rights relating to Personal Data that Torq processes on behalf of a customer, please contact that customer directly.

Changes to This Privacy Policy

We may update this Privacy Policy periodically.

When we make changes, we will publish the updated version on this page and revise the "Last updated" date. If we make material changes, we may also provide additional notice, such as by email, through the services, or by displaying a notice on our website.

Terms not defined in this Privacy Policy have the meanings given to them in the Torq Terms of Service.

1. Personal Data We Collect

1.1 Information You Provide to Torq

We may collect Personal Data that you provide directly to us when you interact with our websites, services, representatives, events, or support channels.

1.1.1 Website interactions

When you complete a form or otherwise interact with our websites, we may collect information such as:

• your first and last name;
• business email address;
• telephone number;
• company name;
• job title;
• account credentials;
• information included in messages or support requests; and
• other information you choose to provide.

For example, we may collect this information when you:

• create a Torq account;
• request a demonstration;
• subscribe to communications;
• contact sales or customer support; or
• interact with a chatbot or another website feature.

You may browse certain parts of our websites without providing Personal Data.

1.1.2 Events

When you register for or attend a Torq event, webinar, conference, or similar activity, we may collect information such as your name, email address, company, job title, attendance information, and communication preferences.

We use this information to:

• administer your registration;
• communicate with you about the event;
• provide event materials;
• improve current and future events; and
• comply with applicable legal and operational requirements.

We may share necessary registration information with event platforms, venues, organizers, speakers, sponsors, or other service providers involved in delivering the event. Additional terms may apply to particular events.

1.1.3 Account and user information

When you create, access, or manage a Torq account, we may collect:

• your name;
• business contact details;
• login credentials;
• profile information;
• account role and permissions;
• communication preferences;
• service settings; and
• other information associated with your use of the services.

1.1.4 Payment and billing information

When you purchase a paid product or service, we may collect billing-related information, including:

• billing name and address;
• billing contact details;
• company and tax information;
• subscription details;
• transaction information; and
• partial payment-method information.

Payments may be processed by third-party payment providers. Torq generally does not directly store complete payment-card or online-banking credentials.

Third-party payment providers process payment information in accordance with their own privacy policies and contractual obligations.

1.2 Customer Data Processed Through the Services

Torq provides a platform that enables customers to manage and centralize business activities, relationships, communications, workflows, or operations across multiple channels.

Customers may submit, upload, collect, or otherwise process Personal Data through the services. This may include:

• names;
• email addresses;
• telephone numbers;
• usernames or account identifiers;
• communication history;
• transaction or relationship information;
• profile information;
• content submitted through connected services; and
• other information selected by the customer.

We refer to this information as "Customer Data."

Torq generally processes Customer Data on behalf of and according to the instructions of the relevant customer. Each customer is responsible for:

• determining the lawful basis for processing Customer Data;
• providing required notices;
• obtaining required permissions or consents;
• responding to individuals' privacy requests; and
• complying with applicable privacy and data-protection laws.

Questions or requests relating to Customer Data should be directed to the customer that collected or controls the information.

1.3 Information Collected When You Use the Services

1.3.1 Usage information

We may collect information about how you and other users interact with the services, including:

• features accessed or used;
• pages, menus, or screens viewed;
• actions performed;
• dates and times of activity;
• frequency and duration of use;
• workflow or feature activity;
• performance information;
• errors and diagnostic information; and
• account-level usage statistics.

We use this information to operate, analyze, secure, maintain, and improve the services.

1.3.2 Device and log information

When you access our websites or services, we may automatically collect technical information such as:

• Internet Protocol address;
• device type;
• browser type and version;
• operating system;
• language and regional settings;
• device or browser identifiers;
• access dates and times;
• referring and exit pages;
• pages and files viewed;
• network and domain information;
• approximate location derived from an IP address; and
• system, error, security, and activity logs.

1.3.3 Third-party integrations

You may choose to connect your Torq account to third-party applications, platforms, or services.

When you authorize an integration, the third party may be permitted to access, send, receive, store, or modify information associated with your Torq account, depending on the permissions you approve.

We may collect information about:

• the integration you connect;
• the permissions granted;
• the integration's use within your account; and
• data exchanged through the integration.

Third-party integrations are governed by the third party's own terms and privacy practices. Torq is not responsible for the privacy, security, or data-handling practices of third-party services that you choose to connect.

You should carefully review an integration's permissions, privacy policy, and security practices before authorizing access.

1.4 Information From Other Sources

Torq may receive Personal Data from other sources where permitted by law, including:

• our customers;
• authorized account administrators;
• business partners;
• event organizers;
• service providers;
• publicly available sources;
• professional networking platforms; and
• third-party applications or integrations.

We may combine this information with information collected directly from you.

2. How We Use Personal Data

We may use Personal Data for the purposes described below.

2.1 Providing and administering the services

We use Personal Data to:

• create and manage accounts;
• provide access to the services;
• authenticate users;
• process subscriptions and payments;
• configure account settings;
• deliver requested features;
• maintain customer records;
• provide technical and customer support; and
• perform our contractual obligations.

2.2 Communicating with you

We may use your contact and account information to send:

• service announcements;
• account notifications;
• billing communications;
• security alerts;
• administrative messages;
• responses to questions or support requests;
• information about service changes; and
• other transactional communications.

Transactional and administrative communications are necessary to operate the services and generally cannot be opted out of while you maintain an active account.

2.3 Supporting customers and resolving issues

We may use Personal Data and service information to:

• respond to support requests;
• troubleshoot technical issues;
• investigate outages;
• diagnose errors and bugs;
• monitor service performance;
• resolve account or billing issues; and
• improve the quality of customer support.

2.4 Improving and developing Torq

We may analyze Personal Data, usage information, logs, feedback, and related information to:

• understand how the services are used;
• evaluate product performance;
• identify usage trends;
• improve usability;
• develop new features, products, and integrations;
• test and optimize functionality;
• improve our communications; and
• conduct research and analytics.

We may create aggregated or de-identified information that does not reasonably identify an individual. We may use and disclose such information for analytics, benchmarking, research, business planning, product development, and other lawful purposes.

For example, we may publish aggregated statistics or reports describing general trends in how customers use Torq without identifying individual users or customers.

2.5 Security, fraud prevention, and service integrity

We may use Personal Data to:

• verify accounts and sign-ups;
• authenticate users;
• detect suspicious or unauthorized activity;
• prevent fraud, abuse, and misuse;
• investigate security incidents;
• enforce our terms and policies;
• maintain the integrity and availability of the services;
• protect Torq, our customers, users, and others; and
• comply with security, export-control, sanctions, and regulatory requirements.

We may associate technical and automatically collected information with account information for these purposes.

2.6 Marketing and promoting our services

Where permitted by applicable law, we may use Personal Data to:

• send newsletters and promotional communications;
• provide information about products, services, features, or events;
• recommend services that may be relevant to you;
• measure marketing performance;
• personalize marketing content; and
• contact you through email, telephone, messaging applications, or other channels.

Where required, we will obtain your consent before sending marketing communications.

You may unsubscribe from marketing emails by using the unsubscribe link included in the message or by contacting us. Opting out of marketing will not stop transactional, security, billing, or administrative communications.

2.7 Calls and communications

If you participate in a call with Torq, we may record or transcribe the call for training, quality assurance, support, recordkeeping, or business purposes where permitted by law.

Where legally required, we will notify you and obtain your consent before recording. You may be given an opportunity to decline recording.

We may also communicate with you through messaging services such as WhatsApp, Telegram, or similar platforms when you have requested or consented to that communication.

2.8 Legal compliance and protection of rights

We may use Personal Data to:

• comply with legal and regulatory obligations;
• respond to lawful requests;
• establish, exercise, or defend legal claims;
• enforce our agreements;
• conduct audits;
• maintain required business records;
• protect the rights, safety, and property of Torq and others; and
• support corporate transactions.

2.9 Other purposes with your consent

We may use Personal Data for another purpose disclosed to you at the time of collection or with your consent.

3. Legal Bases for Processing

Where applicable law requires a legal basis for processing, Torq relies on one or more of the following:

3.1 Performance of a contract

We process Personal Data where necessary to:

• provide the services you requested;
• create and administer your account;
• process payments;
• provide customer support; or
• perform our obligations under an agreement with you.

3.2 Legitimate interests

We may process Personal Data where necessary for our legitimate business interests, provided those interests are not overridden by your rights and interests.

These interests may include:

• operating and improving our business;
• maintaining and securing our services;
• preventing fraud and abuse;
• communicating with customers and users;
• understanding service usage;
• developing products and features;
• promoting our services; and
• protecting our legal rights.

3.3 Consent

We rely on consent where required, including for certain marketing communications, cookies, call recordings, or other processing activities.

You may withdraw consent at any time. Withdrawal does not affect the lawfulness of processing carried out before consent was withdrawn.

3.4 Legal obligations

We may process Personal Data where necessary to comply with applicable legal, tax, accounting, regulatory, or law-enforcement obligations.

3.5 Protection of vital interests

In limited circumstances, we may process Personal Data where necessary to protect an individual's vital interests or safety.

Questions about our legal bases for processing may be directed to: support@[TORQ_DOMAIN]

4. How We Share Personal Data

We may disclose Personal Data in the circumstances described below.

4.1 Service providers

We may share Personal Data with vendors and service providers that perform services on our behalf, including providers of:

• cloud hosting and infrastructure;
• data storage;
• cybersecurity;
• application development;
• analytics;
• customer support;
• communications;
• sales and marketing support;
• payment processing;
• billing and accounting;
• event management;
• professional consulting; and
• other business and technical services.

These providers may access Personal Data only as necessary to perform services for us and are required to protect the information in accordance with applicable contractual and legal obligations.

4.2 Payment providers

Payment and financial information may be shared directly with payment processors, banking providers, or other financial-service providers selected by Torq.

These providers process Personal Data according to their own privacy policies and their contractual obligations to Torq.

Current payment provider: [Insert provider name and privacy-policy reference, or remove this sentence.]

4.3 Account administrators

If your Torq account is provided or managed by an organization, the organization's authorized administrators may be able to:

• access account information;
• manage users and permissions;
• control account settings;
• access Customer Data;
• view activity or usage information; and
• restrict, suspend, or terminate account access.

Your organization's handling of Personal Data is governed by its own policies.

4.4 Business partners

We may disclose Personal Data to business partners where necessary to jointly provide a product, service, integration, event, or promotion.

Where required, we will provide notice or obtain consent before doing so.

4.5 Advertising and marketing partners

Subject to applicable law and your preferences, we may disclose identifiers such as an email address, cookie identifier, or similar information to advertising or marketing partners for purposes such as:

• measuring campaign performance;
• identifying relevant audiences;
• displaying Torq advertisements on third-party websites or applications; and
• limiting repetitive or irrelevant advertising.

Where required by law, we will obtain consent before sharing information for personalized advertising.

You may be able to manage these uses through our cookie settings, communication preferences, or by contacting us.

4.6 Legal requirements and protection

We may use or disclose Personal Data where we reasonably believe it is necessary to:

• comply with applicable law or regulation;
• respond to a subpoena, court order, warrant, or other lawful request;
• cooperate with law-enforcement or regulatory authorities;
• investigate fraud, abuse, or security incidents;
• protect the rights, property, or safety of Torq, our customers, users, or others;
• enforce our agreements; or
• establish, exercise, or defend legal claims.

4.7 Corporate transactions

We may disclose or transfer Personal Data in connection with an actual or proposed:

• merger;
• acquisition;
• financing;
• reorganization;
• sale of assets;
• joint venture;
• bankruptcy;
• insolvency; or
• similar corporate transaction.

Where required by law, we will notify you of material changes to the ownership or use of your Personal Data and any choices available to you.

4.8 With your direction or consent

We may disclose Personal Data to another party when you direct us to do so or provide consent.

5. International Data Transfers

Torq, its affiliated companies, customers, and service providers may operate in countries other than the country in which you live.

As a result, Personal Data may be transferred to and processed in jurisdictions that have different data-protection laws.

Where required by law, Torq uses appropriate safeguards for international transfers, which may include:

• adequacy decisions;
• approved standard contractual clauses;
• contractual data-protection commitments;
• data-processing agreements;
• supplementary technical and organizational measures; or
• another legally recognized transfer mechanism.

Additional information about international transfers may be included in Torq's Data Processing Agreement.

6. Data Storage, Security, and Retention

6.1 Data security

Torq uses reasonable and appropriate technical, organizational, and physical safeguards designed to protect Personal Data against:

• unauthorized access;
• accidental or unlawful destruction;
• loss;
• alteration;
• misuse; and
• unauthorized disclosure.

These measures may include access controls, authentication procedures, encryption, network protections, monitoring, employee confidentiality obligations, vendor-management procedures, and incident-response processes.

No method of transmission or storage is completely secure. Accordingly, we cannot guarantee absolute security.

6.2 Data retention

We retain Personal Data for as long as reasonably necessary to:

• provide the services;
• maintain our relationship with you;
• fulfill the purposes described in this Privacy Policy;
• comply with legal, accounting, tax, or regulatory requirements;
• resolve disputes;
• enforce our agreements; and
• protect our legal rights.

The applicable retention period depends on factors such as:

• the type and sensitivity of the information;
• the purpose for which it was collected;
• the duration of the customer or user relationship;
• legal and contractual obligations;
• security requirements; and
• applicable limitation periods.

When Personal Data is no longer required, we will delete, anonymize, or securely isolate it, unless continued retention is required or permitted by law.

We may retain limited information about marketing preferences to ensure that we continue to respect an opt-out request.

Customer Data is retained and deleted according to the applicable customer agreement, Terms of Service, and Data Processing Agreement.

7. Cookies and Similar Technologies

Torq and its service providers may use cookies, pixels, software development kits, local storage, and similar technologies to:

• operate our websites and services;
• remember preferences;
• maintain sessions;
• authenticate users;
• understand website and service usage;
• analyze performance;
• identify and resolve errors;
• prevent fraud and abuse;
• measure marketing campaigns; and
• provide relevant advertising where permitted.

Some cookies are necessary for the operation of our websites and services. Other cookies may require consent, depending on your location.

You may manage cookie preferences through our cookie banner or settings tool, where available. You may also be able to control cookies through your browser settings.

For more information, please review the Torq Cookie Policy at [insert link].

8. Your Privacy Rights and Choices

Depending on your location and applicable law, you may have some or all of the following rights.

8.1 Access

You may request confirmation of whether we process your Personal Data and obtain a copy of that information.

8.2 Correction

You may request that inaccurate or incomplete Personal Data be corrected or completed.

8.3 Deletion

You may request deletion of Personal Data in certain circumstances, including where the information is no longer necessary for the purpose for which it was collected.

8.4 Restriction

You may request that we limit the processing of Personal Data in certain circumstances.

8.5 Data portability

You may request certain Personal Data in a structured, commonly used, machine-readable format or ask that it be transferred to another controller where technically feasible.

8.6 Objection

You may object to processing based on legitimate interests.

You may object at any time to the processing of Personal Data for direct-marketing purposes.

8.7 Withdrawal of consent

Where processing is based on consent, you may withdraw that consent at any time.

Withdrawal does not affect processing lawfully carried out before the withdrawal.

8.8 Automated decision-making

Where applicable, you may have the right not to be subject to a decision based solely on automated processing, including profiling, when that decision produces legal or similarly significant effects.

8.9 Complaints

You may have the right to lodge a complaint with a data-protection or supervisory authority, particularly in the country where you live, work, or believe an infringement occurred.

Individuals in the European Economic Area may find supervisory-authority contact information through the European Data Protection Board.

8.10 Exercising your rights

To submit a privacy request, contact:

Email: support@[TORQ_DOMAIN]

We may need to verify your identity before completing a request. The verification method will depend on the nature and sensitivity of the request.

Where permitted by law, an authorized agent may submit a request on your behalf. We may require evidence of the agent's authority and may need to verify your identity directly.

We will not discriminate against you for exercising a privacy right.

Privacy rights are not absolute. We may decline or limit a request where permitted by law, including where fulfilling it would:

• adversely affect the rights of another person;
• disclose confidential or protected information;
• prevent us from complying with a legal obligation;
• interfere with the establishment or defense of legal claims; or
• prevent us from providing a service you requested.

We will respond within the period required by applicable law and explain our decision where required.

8.11 Customer-controlled Personal Data

If Torq processes your Personal Data on behalf of one of our customers, please contact that customer directly.

We will assist customers with verified requests as required by our contractual and legal obligations, but we generally cannot respond directly to requests involving data controlled by a customer.

8.12 Marketing preferences

You may unsubscribe from marketing communications by:

• selecting the unsubscribe link in a marketing email;
• updating your communication preferences, where available; or
• contacting us at [insert email].

Even after opting out of marketing, you may continue to receive necessary service, billing, security, account, and administrative communications.

9. Children's Privacy

Torq's websites and services are not directed to children under the age of 18, and we do not knowingly collect Personal Data from children under 18.

If you believe that a child has provided Personal Data to Torq, please contact us at [insert privacy email]. We will investigate and take appropriate action, including deleting the information where required.

If a different minimum age applies under local law or to a particular Torq service, we will provide appropriate notice.

10. Third-Party Websites and Services

Our websites and services may contain links to third-party websites, applications, integrations, or services.

Torq does not control and is not responsible for the privacy, security, or data-handling practices of those third parties. We encourage you to review their privacy policies before providing Personal Data or authorizing access.

11. Contact Us

Questions, concerns, or requests relating to this Privacy Policy may be directed to:

Torq
Email: support@[TORQ_DOMAIN]

You may also contact us through our Contact page.