Privacy Policy

Last Updated: 31 December 2024

This privacy policy (“Privacy Policy”) describes how Torq Technologies Ltd. (together with its affiliated companies, “Torq”, “we”, “our” or “us”) collects, stores, uses and discloses information relating to identified or identifiable individuals (“Personal Data”) when: 

1. entering into our Torq Technologies Master Service Agreement, or other service agreement for the use of our software-as-a-services product (“Product” and “Customer” respectively);
2. working as a channel partner (such as reseller, distributor, MSSP, and other business partners) or supplier of Torq and interacting with our company in the course of doing business or contemplating doing business with us (“Channel Partner” or “Vendor” respectively);
3. using the Product as an authorized user (“Authorized User”); or
4. exploring our Product and similar offering while visiting our website available at: or other landing pages, registering for, attending and/or otherwise taking part in our events, webinars, public community, trainings and certification courses (collectively “Sites”), interacting with digital ads and content we publish, etc. (collectively, “Prospects”). 

The “Product” and the “Sites” are collectively referred to in this Privacy Policy as “Properties”. Customers, Authorized Users, Partners and Prospects may be referred in this Privacy Policy, individually and collectively, as “you”. 

Our Properties are intended to be used by businesses and their representatives. We do not offer any products or services to individuals for personal, family or household use. All Personal Data that we process is treated as belonging to individuals in a business capacity.

This Privacy Policy does not apply to: (i) Personal Data that we process on behalf of our Customers that is uploaded, submitted or otherwise made available through the Product by Authorized Users, which is governed by Torq’s Data Processing Agreement or other data processing agreement entered into between the Customer and Torq; (ii) Personal Data that we process in connection with our recruitment activities, which is covered by Torq Job Candidates Privacy Notice; and (iii) Personal Data collected by third parties whose services are accessible through our Properties.

This Privacy Policy also provides information on privacy choices, how to exercise these rights and how to contact us with any questions. If you do not agree with this Privacy Policy, please do not access or use our Properties or any other aspect of our business.

This Privacy Policy applies to our operations globally. To the extent you are a California resident, additional information regarding our privacy practices is provided to you in Section ‎9 – Supplemental Information for California Residents. For the purpose of this Privacy Policy, any reference to “Personal Data” shall mean and include “Personal Information” as defined under applicable data protection laws.

1. 1. Contact Information and Data Controller Information

Torq Technologies Ltd., incorporated under the laws of the State of Israel, is the controller (as such term is defined under the EU and UK General Data Protection Regulations “GDPR” or equivalent privacy legislation) of certain Personal Data it collects and processes about you.

If you have any questions, inquiries or concerns regarding the processing of your Personal Data, or would otherwise like to contact us in connection with this Privacy Policy, you can contact us through the following means:

By email: [email protected]

By mail: 3 HaMelacha St., Tel Aviv 6721503, Israel

2. 2. Categories of Personal Data Collected, Purpose of Use, Source of Collection and Lawfulness

Source of Collection	Type of Personal Data	Purpose of Use	Lawful Basis under the GDPR
Customers, Channel Partners and Vendors
Information provided directly by you or by our Channel Partner	Onboarding Information:  We collect certain personal information relating to Customer, Channel Partner and Vendor personnel during onboarding, which may include full name, business email address, job title and business phone number.	We use your onboarding information to facilitate our legal contract with you, and for account management purposes, including billing and invoices, as well as other service-related communication.	We process your onboarding information for the performance of our contract with you.
Authorized Users
Information provided directly by you or as provided by third party authentication providers	Login Information: We will collect your login information used to access the Product including your email address and password, or your login credentials from third-party authentication providers, including your Avatar.	We use this information to facilitate your access to the Product and for authentication purposes.	We process your login information for the performance of our contract with you.
		We use your email address for direct marketing purposes – i.e., to send you marketing-related emails including materials and content regarding the services you are currently using or other new services we may offer in the future.	We use this information for direct marketing subject to our legitimate interest. You can opt-out of receiving direct-marketing emails at any time by selecting the “unsubscribe” option at the bottom of the email. Please note that if you choose to unsubscribe from our direct marketing emails, we will still retain your email address to send you service-related emails regarding event registration, service announcements or security information.
Information we collect automatically	User and Device-Related Data: We use standard automated data collection tools, such as cookies, web beacons, tracking pixels, tags, and similar tools, to collect technical information about how you interact with our Product.  While such data is mostly technical and non-personal in nature, it may be combined with Personal Data such as your user ID, email address, IP address, etc.  This technical data may include the following: the type and number of workflows and/or cases you have created; the pages or features you have accessed or used, and the time spent on those pages or features; terms entered; commands executed; etc.	We collect this user and device-related data to generate and analyse aggregated non-personally identifiable information, which is then used as follows: to provide support and to ensure continued proper functioning of our Product; to protect the security and integrity of the Product, including to detect, prevent, and respond to potential or actual security incidents and to monitor and protect against other malicious, deceptive, fraudulent or illegal activity, including any violations of our use  limitations, Acceptable Use Policy or other terms and policies; to enhance and improve our Product by using information for internal training and research to analyse how Authorized Users use the Product.	We collect this information subject to our legitimate interest.
	We also use standard automated data collection tools to collect information about how Authorized Users interact with our emails.  For example, we may place a pixel in our emails that notifies us once you have opened the email or clicked on a link within an email.	We use these technologies to improve our communications with you.	We collect this information subject to our legitimate interest.
Prospects
Information provided directly by you or provided by third-party sources including data brokers, social media platforms and from our Channel Partners.	Contact Information: We will collect certain personal information pertaining to Prospect personnel, including full name, country and state of residency, business email address, job title, phone number, social media profile, as well as additional information you may choose to provide to us directly (for example, when sending us inquiries or when interacting with our public community).	We use this information to respond to your enquiries, questions, comments and requests; to facilitate our public community (including to allow your login to such community, where you have created an account not as an Authorized User), targeted advertising campaigns; for lead generation; events promotion, etc. This information helps us to update and improve our records and identify new prospects.	We collect this information subject to our legitimate interest.
Information we collect automatically	Usage and Behavioral Data: We use standard automated data collection tools, such as cookies, web beacons, tracking pixels, tags, and similar tools, to collect information about how individuals use our Sites and interact with our emails. For example, when you visit our Sites, we may collect certain information about your computer or device (such as operating system, device identifier, browser language, and Internet Protocol (IP) address), and information about your activities on our Sites (such as how you came to our Site, referring URLs and browsing behaviour, access times, the links you click on, clicks and cursor movements, and other statistical information).  We may also use web beacons and pixels in our emails. For example, we may place a pixel in our emails that notifies us once you have clicked on a link within an email. We may also use your IP address to derive your general location information. The types of data collection tools we use may change over time as technology evolves. You can learn more about our use of cookies and similar tracking tools, as well as how to opt out of certain data collection practices, by visiting our Cookie Notice.	We use this information to help us understand how you are using our Sites, how to improve our Sites, and to facilitate targeted advertising campaigns. We also use these technologies in our emails to improve our communications with you.	Strictly necessary cookies which are required for the proper and basic operation of the Sites are used based on our legitimate interest of operating our Sites. Additional data collected use for analytics and marketing will be processed based on your consent which we will obtain through our consent management platform.
Information we collect directly from you	Audio and/or Visual Recordings: We may collect visual recording of your attendance at events or audio and/or visual recordings of your meetings with our team, in compliance with applicable laws.	We use visual recordings from events to market Torq and our Product. We use recordings of your meetings with our team for internal training and research.	We collect audio and/or visual recordings subject to your consent. Please note that meeting recordings will only occur subject to applicable law – by way of explicit consent or subject to our legitimate interest.

3. 3. Disclosure to Third Parties

We disclose Personal Data to third parties that help us operate, provide, improve, integrate, customize, support and market our Properties, as detailed below.

Recipient	Purpose of Disclosure
Torq Affiliates	We may share certain Personal Data internally within our group of companies, for the purposes described in the table above under Section ‎2. In addition, should Torq or any of its affiliates be the subject of any change in control, including by means of merger, acquisition or purchase of all or substantially all of its assets, your Personal Data may be shared with additional parties as necessary to fulfill such reorganization.
Service Providers	We may disclose Personal Data to third party service providers for general business purposes and to support our internal operations, including IT solutions vendors; hosting services; customer relationship and customer service management services; learning management services; sales engagement services; event sponsors; content, lead generation and marketing services; billing and payment processing services; as well as other consultants and professional advisers including lawyers, bankers, auditors and insurers. We may also disclose Personal Data where we believe it necessary in order to protect, exercise, establish or defend our legal rights. If a service provider needs to access information about you to perform services on our behalf, they do so under close instruction from us, including appropriate security and confidentiality procedures designed to protect your information.
Other Authorized Users	At the direction of an Authorized User, Personal Data may be shared with other Authorized Users within the same organization (for example when communicating through the Product or sending an invite to an individual who is not a User yet, to access and use the Product).
Shared Communities	Any Personal Data or other information you choose to submit in our public community, forums or blogs on our Sites may be read, collected and used by others who visit these forums, including other users of the Sites.
Integrations	When integrating third-party services directly within Torq workflows, Torq may disclose certain data with the external third-party service.  Third-party services are independent of Torq, and each third-party service provider has its own privacy policies and practices in place for its collection, use, and sharing of your Personal Data. Please check the permissions, privacy settings, and notices for these external services or contact the provider directly with any questions.
Channel Partners	We engage selected Channel Partners in order to explore and pursue growth opportunities. In such instances, we may share certain relevant Personal Data with the respective Channel Partner to allow them to engage with those Customers for such purposes. If you directly engage with any of our Channel Partners, any aspect of that engagement which is not directly related to our Product and/or directed by Torq is not subject to the terms of this Privacy Policy, and is governed by the relevant Channel Partner’s terms and privacy policy.
Law Enforcement	We may disclose Personal Data to a third party where we are legally required to do so in order to comply with any applicable law, regulation, legal process or governmental request, including government authorities, law enforcement and others; or where we have a legitimate interest in disclosing such data to enforce our and our personnel’s rights.

We may also share your Personal Data in ways other than those mentioned above, if you provide your consent or if we are legally obligated to do so, or if such data has become non-personal and anonymous.

4. 4. Data Retention

We retain your Personal Data for so long as we have an ongoing legitimate business need to do so (in connection with the purposes set out in Section ‎2 above). We determine our retention periods by taking in account the amount, nature, and sensitivity of the applicable Personal Data, the original purposes for which such Personal Data was collected, the potential risk of harm from unauthorized use or disclosure of such data, and applicable legal requirements. When we have no ongoing legitimate business need to process your Personal Data, we will either delete or anonymize your Personal Data.

5. 5. Cookies and Other Tracking Technologies

You can manage your cookie preferences by visiting our consent management platform to customize your cookie settings. Please see our Cookie Notice for further information on cookies and other tracking technologies.

6. 6. Security

We use industry-standard physical, procedural and technical security measures, including encryption as appropriate, to protect your Personal Data from loss, misuse and unauthorized access or disclosure. However, regardless of any security measures used, we are unable to guarantee the absolute protection and security of any Personal Data stored with us or with any third parties as described in this Privacy Policy. To learn more about our current practices and policies regarding security, please visit Torq’s Trust Centre.

7. 7. International Transfers of Personal Data

In order to facilitate our business operations, we may transfer your Personal Data to countries outside of your country of residence. We, as well as our Vendors, collect, process, maintain and store Personal Data in Israel, the United States, Europe, and other locations as reasonably necessary for the proper performance and delivery of the Properties or as may be required by applicable laws. Torq ensures compliance with the requirements of appliable data protection laws and regulations with regards to the transfer of Personal Data overseas.

For individuals located in the EEA, the UK and Switzerland, Personal Data is transferred to Israel on the basis that Israel is considered by applicable data protection authorities as a jurisdiction which offers an adequate level of protection for Personal Data. With regards to transfer of Personal Data to countries which are not considered to offer an adequate level of data protection, we and the relevant data importers enter into Standard Contractual Clauses as approved by the European Commission, UK Information Commissioner’s Office, and the FDPIC (as appropriate). 

When we process Personal Data on behalf of a Customer, such Personal Data is processed in the territories as permitted in our MSA and DPA with such Customer. 

8. 8. Your Privacy Choices

You have certain choices available to you when it comes to Personal Data that Torq collects in accordance with this Privacy Policy. 

Not all jurisdictions grant the same privacy rights, and the nature of those rights will be determined by multiple factors, including the lawful purpose under which we process your Personal Data as detailed in the table under Section ‎2 above, as well as the location, country, state, or your place of residence. Below is a summary of those choices, how to exercise them and any limitations. 

• Information: you can request more information about how we process your Personal Data. 
• Access: you can request access to the Personal Data we hold about you.
• Rectification: you can request us to modify or correct your Personal Data which is currently inaccurate or incomplete.
• Erasure: you can request that we delete any Personal Data we hold about you.
• Restriction: you can request that we restrict the use of your Personal Data.
• Objection: you can object to the processing of your Personal Data based on legitimate interests.
• Portability: you can request a copy of your Personal Data in a structured, commonly used, machine-readable format, to allow you to transfer your Personal Data to another provider. Note that where you have asked us to disclose data to third parties, you will need to contact those third-party service providers directly to have your information deleted or otherwise restricted. 
• Automated decision making: you can request not to be subject to a decision based solely on automated processing, where it produces a legal or similar effect.
• Opt out from the “sale” or “sharing” of Personal Data and targeted advertising.

You have the right to exercise any of those applicable privacy rights free from discriminatory treatment and retaliation. If you wish to exercise any of these requests, please fill out our Data Subject Request Form. For certain rights, such as where you request access to Personal Data, we will need to confirm your identity, by requesting your ID or otherwise. 

• Promotional communications & cookies and other tracking technologies: At any time, you have the right to opt-out from: (i) the collection of your Personal Data for behavioural advertising and analytics by using the consent manager platform settings within our Site, (ii) any marketing communications that we send by clicking the ‘Unsubscribe’ link at the footer of the communication. 

The above-mentioned rights are not absolute, and in certain cases we may decline, in whole or in part, your request as permitted by law (for example, if fulfilling your request would reveal information about another person, or if you ask to delete information which we are permitted by law or otherwise have compelling legitimate interests to retain). Also note that your rights may generally be exercised free of charge, however we reserve the right to charge an appropriate administrative fee were permitted by law.

If you have unresolved concerns, you may have the right to file a complaint with a data protection authority in the country where you live, where you work or where you feel your rights were infringed. You may also contact us as provided in the “Contact Us” Section ‎12 below to appeal any decision we make relating to your request to exercise your rights.

If your request relates to Personal Data that is processed on our Customer’s behalf in our capacity as a data processor, please note that it is the Customer who exclusively determines how Personal Data is processed by Torq, as well as if and how your request should be handled. We recommend that you submit your requests directly to the relevant Customer. 

9. 9. Supplemental Information for California Residents

If you are a California resident, this information provided in this section applies to you in addition to the rest of the Privacy Policy. It provides further details on how we collect, use and disclose Personal Information of California residents in operating our business, and their rights with respect to that Personal Information. For purposes of this Section 9, the term “Personal Information” has the meaning given in the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (“CCPA”). However, this Section 9 does not apply to:

• Information exempted from the scope of the CCPA; and
• Information exempted from the scope of this Privacy Policy as detailed in the preamble of this Privacy Policy.

10. 9.1 Categories of Personal Information Collected, Purpose of Use, and Recipients

The table below describes the categories of Personal Information we have collected in the past 12 months, the purposes for which we have collected this information, the categories of recipients of disclosures made for business purposes in the past 12 months, and the categories of recipients of disclosures made in the past 12 months that may be considered “sale” of Personal Information or “sharing” of Personal Information for cross-context behavioural advertising under the CCPA.

Category of Personal Information	Purpose(s) for Collecting & Disclosing	Recipients of Disclosures for Business Purposes	Recipients of “Sales” or “Sharing”
Identifiers, such as name, email address, phone number, unique identifiers associated with a User or a User account, IP address, and UID.	User authentication Service access controls Billing Analytics and research Responding to inquiries Marketing purposes such as direct marketing, lead generation and personalized communications Detecting security incidents Debugging Internal research Properties enhancements	Torq affiliates  Service providers Channel Partners and Vendors Shared communities Other Users	We share this information for cross- context behavioural advertising with our third-party advertising providers
Commercial information, about what an individual has purchased or obtained from Torq, including tickets to Torq sponsored events, or about publications and content where an individual has attended webinars, joined our courses, or downloaded content.	Facilitating access to the applicable service, webinar, course, etc. Billing Analytics and research Marketing Detecting security incidents Debugging Internal research Site enhancements	Torq affiliates  Service providers	NA
Internet or other electronic network activity information, such as information about your usage of the Properties, clickstream data, device and connection information, browser information, crash data, referring/exit URLs, IP address, etc.	Internal research Security operations Properties enhancements	Torq affiliates  Service providers	We share this information for cross- context behavioural advertising with our third-party advertising providers
Visual information, such as photos or avatars, with your consent, recordings of your attendance at our events; and audio information, such as recordings from our call and meetings.	Internal research Marketing	Torq affiliates  Service providers	NA
Professional or employment information, such as job title, company name, company domain.	Facilitate our legal contract with you and comply with your inquiries account management purposes, including billing and invoices, as well as other service-related communication	Torq affiliates  Service providers Channel Partners	NA
Geolocation data, such as your approximate location, IP address, and time zone.	User authentication Service access controls Analytics and research Marketing purposes Detecting security incidents Debugging Internal research Properties enhancements	Torq affiliates  Service providers	We share this information for cross- context behavioural advertising with our third-party advertising providers
Inferences (drawn about you based on other Personal Information we collect), such as preferences, interests, user behaviour data.	Personalized targeted advertising Lead generation Internal research	Torq affiliates  Service providers	We share this information for cross- context behavioural advertising with our third-party advertising providers
Sensitive Personal Information which is your access credentials to our Sites. Note – this type of Sensitive Personal Information is treated as Personal Information, therefore you do not have the right to direct us to limit our use of such information for the business purposes mentioned in this table.	User authentication Service access controls	Torq affiliates  Service providers	NA

11. 9.2 Your California Privacy Choices

As a California resident, you have information, access, rectification, erasure, and non-discrimination rights as described in Section 8. 

• The Sale and Sharing of Personal Information

In addition to those rights mentioned above in Section ‎8, you have the right to opt-out of the “sale” or “sharing” of Personal Information as those terms are defined by the CCPA. We do not “sell” Personal Information in the traditional sense of exchanging information for monetary payment. However, we share your Personal Information for cross-contextual behavioural advertising as detailed in the table above. You have the right to opt out of these activities by: 

1. clicking the “Do not Sell or Share My Personal Information” link in the footer of our website and follow the instructions therein, to opt out from the use of your Personal Information for targeted advertising through cookies and other online tracking technologies within our Sites.
2. use the consent management platform settings within our Sites to opt out of the sharing of Personal Information for behavioural advertising.
3. set your device settings to opt out of the sharing of Personal Information for behavioural advertising.
4. submit this Data Subjects Rights Form.
5. enabling Global Privacy Control (“GPC”) in your web browser or browser extension, which we recognize to the extent required by applicable law. Enabling GPC will automatically set your cookie settings to opt out of the sharing of Personal Information for behavioural advertising. If you choose to use GPC, you will need to turn it on for each supported browser or browser extension you use. 

Please note that your opt-out from sharing your Personal Data for targeted advertising shall not affect our right to request your consent to such share again after twelve (12) months.
Also note that we do not knowingly “sell” or “share” the Personal Information of individuals under 16 years of age.

• De-Identified Data

We do not to attempt to re-identify de-identified information that we derive from Personal Information, except for the purpose of testing whether our de-identification processes comply with applicable law.

• Authorized Agent

If you have appointed an authorized agent to act on your behalf, your authorized agent may request to exercise these rights on your behalf upon our verification of the agent’s identity and our receipt of a copy of a valid power of attorney given to your authorized agent pursuant to applicable California law. If you have not provided your authorized agent with such power of attorney, we may ask you and/or your authorized agent to take additional steps permitted by law to verify that your request is authorized, such as information required to verify your identity and that you have given the authorized agent permission to submit the request.

12. 10. Children

We do not knowingly collect Personal Data of children under the age of 16, and do not wish to receive such Personal Data. We will attempt to block any use of our Services by any child under the age of 16 and use our best efforts to promptly delete any Personal Data stored with us pertaining to such child. If you believe that we may be in possession of any such Personal Data, please notify us immediately.

13. 11. Amendments 

We reserve the right to periodically change this Privacy Policy. The amended version will be effective as of the date it is published and appears in the header of this Privacy Policy. When we make material changes to this Privacy Policy, we will give notice as appropriate under the circumstances. Your continued use of our Properties after the changes have been implemented will constitute your acceptance of these changes.

14. 12. Contact Us

If you have any comments, questions or complaints regarding our Privacy Policy or our privacy practices, or if you have any concerns regarding your Personal Data held with us, please contact Torq by emailing [email protected], or at our mailing address at 3 HaMelacha St., Tel Aviv, 6721503, Israel.