Privacy Policy

Last Update, Jul 26, 2021.
This privacy policy (“Privacy Policy”) governs how we, Torq Ltd., (“Torq” “we”, “our” or “us”) use Personal Data (defined below) that we collect, receive and store pertaining to you (“User”, “you”) in connection with the following use cases:

When you browse or visit our website, https://torq.io or https://torq.io and any subdomain of torq.io and Torq.com (“Website”) or Platform (defined below)
When you make use of, or interact with, our Website
1. When you contact us and request stay connected with us in the future
2. When you request a product demo
3. When you request to “get started” with the platform
4. When you sign up for different e-books and other assets
5. When we process your job application
When you make use of, or interact with platform (the “Platform”).
1. When you login and make use of our Platform
2. When you connect our platform to your internal systems
3. When you use any service that we offer in conjunction with our Platform, such as, but not limited to our Support Site, Open-Source Repositories, Status Page, Community Forum, etc…
When you attend a marketing event and provide Personal Data
When you exchange business cards with us
When we acquire your Personal Data from third-party sources (such as lead-generation companies)
When we use the Personal Data of our service providers
When we use the Personal Data of, or provided by, our resellers, distributors, agents and/or finders
When we use the Personal Data of our customers
When you interact with us on our social media profiles (e.g., Facebook, Instagram, Twitter, LinkedIn, Medium, Dev.to)

The Website is referred to herein as the “Services”.
We greatly respect your privacy, which is why we make every effort to provide a platform that would live up to the highest of user privacy standards. Please read this Privacy Policy carefully, so you can fully understand our practices and your rights in relation to Personal Data.
Important note: Nothing in this Privacy Policy is intended to limit in any way your statutory right, including your rights to a remedy or means of enforcement.

Introduction
Consent and modification
What information we collect, why we collect it, and how it is used
How we protect and store your Personal Data
How we share your Personal Data
Additional information regarding transfers of Personal Data
Your privacy rights
Use by children
How can I delete my account?
Links to and interaction with third party product
Log files
Cookies and other tracking technologies
Analytic tools
Access/Accuracy
California privacy rights
Our California do not track notice
Deletion of content from California residents
How to contact us

This Privacy Policy may be updated from time to time and therefore we ask you to check back periodically for the latest version of the Privacy Policy, as indicated below. If there will be any significant changes made to the use of your Personal Data in a manner different from that stated at the time of collection, we will notify you by posting a notice on our Website or by other means.

1. INTRODUCTION

We have implemented this Privacy Policy because your privacy, and the privacy of other users, is important to us. This Privacy Policy explains our online information practices and the choices you can make about the way your Personal Data is collected and used in connection with the Services. “Personal Data” means any information that may be used, either alone or in combination with other information, to personally identify an individual, including, but not limited to, a first and last name, a personal profile, an email address, a home or other physical address, or other contact information.

You are not legally obligated to provide us Personal Data, and you hereby confirm that providing us Personal Data is at your own free will. By using the Services, you consent to the terms of this Privacy Policy and to our collection, processing and sharing of Personal Data for the purposes set forth herein. If you do not agree to this Privacy Policy, please do not access or otherwise use the Services. We reserve the right, at our discretion, to change this Privacy Policy at any time. Such change will be effective ten (10) days following posting of the revised Privacy Policy on the Website, and your continued use of the Services thereafter means that you accept those changes.

3. WHAT INFORMATION WE COLLECT, WHY WE COLLECT IT, AND HOW IT IS USED

Personal Data we collect	Why is the Personal Data collected and for what purposes?	Legal basis (GDPR)	Third parties with whom we share your Personal Data	Retention period	Consequences of not providing the Personal Data
*When you browse or visit our Website or Platform*
Cookies	Marketing, analytics and statistics Improving our product capabilities	Consent Legitimate interest (e.g. essential cookies)	3^rd party platforms providing storage and analytics such as the following: Google Cloud (storage) Google Analytics (analytics tool) Mixpanel (Customer Experience Analytics) FullStory (tracking user engagement)	Most browsers allow you to control how cookies get used as you’re browsing and for how long they are stored. Some browsers automatically limit or delete cookies. Also, in some browsers, you can set up rules to manage cookies on a site-by-site basis, allowing you to permit cookies only from sites that you trust.	Cannot collect and store the information Cannot use or access parts of the Website
*When you make use of, or interact with our Website*
*When you contact us to stay ahead and get early access or to stay connected*
Email address	Answer your questions Provide you with information about Torq To allow you to purchase our product and/or services To provide you access to updates, resources and assets that you requested	Performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract Legitimate interest (e.g. to answer your questions)	3^rd party platforms providing storage and analytics such as the following: Google Cloud (storage) SalesForce (Customer Relations Management) ZenDesk, StatusPage (Community / Support Management) Hubspot (Customer Service Management) Mixpanel (Customer Experience Management)	For the period of time corresponding to your use of our Services, and the retention of records of service as required by applicable laws and regulations in each geographical region.	Cannot answer your questions Cannot provide you information about Torq Cannot purchase our product and/or services Cannot use our product and/or services
*When you request a product demo, to get started, or to when you sign-up to receive our e-books and other assets*
First name Last name Company name Email address Phone number	To provide a demo To provide you access to updates, resources and assets that you requested	Performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract Legitimate interest (e.g. to provide a demo)	3^rd party platforms providing storage and analytics such as the following: SalesForce (Customer Relations Management) Hubspot (Customer Service Management)	For the period of time corresponding to your interest in or use of our Services, and the retention of records of service as required by applicable laws and regulations in each geographical region.	Cannot provide a demo Cannot provide you with information and updates about our products and services Cannot answer your question
*When we process your job application*
Full name Email address Phone number Resume/CV LinkedIn profile Any other information that you decide to provide/supply us	To process your job application To assess the candidateNote: For the avoidance of doubt, this use case shall apply to the CVs submitted by the Website or by any other methods (e.g., HR and recruitment agencies	Performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract Legitimate interest (e.g. to assess a candidate)	3^rd party platforms providing storage and analytics such as the following: BambooHR (Human Resources and Hiring Management)	For the period of time corresponding to your engagement with us as a candidate for one of our current and/or future open positions.	Cannot process your job application Cannot assess your suitability as a candidate
*When you login and make use of our Platform and/or any services provided in conjunction with our platform*
First name Last name Company name Email address User name / relevant client id Password (Optional, if SSO is not used) Device Type IP Address Usage logs Any other data you choose to share with us	To create an account To fulfill your requests for services and for related activities (e.g., account management, support and to provide other services). To perform/execute the agreement	Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract Legitimate interest (e.g. to sign up to the services)	3^rd party platforms providing storage and analytics such as the following: Google Cloud (storage) SalesForce (Customer Relations Management) ZenDesk, StatusPage (Community / Support Management) Hubspot (Customer Service Management) Mixpanel (Customer Experience Management) FullStory (tracking user engagement)	For the period of time corresponding to your use of our Services, and the retention of records of service as required by applicable laws and regulations in each geographical region.	Cannot create an account Cannot fulfill your request for products and/or services Cannot perform the agreement
*When you attend a marketing event and provide Personal Data*
Email address Full name Phone number Company Job title Email address Any other information you choose to share with us	To establishing a business connection	Depending on the context, consent or legitimate interest (e.g. send you more information about Torq)	3^rd party platforms providing storage and analytics such as the following: SalesForce (Customer Relations Management) Hubspot (Customer Service Management)	For the period of time corresponding to your interest in or use of our Services, and the retention of records of service as required by applicable laws and regulations in each geographical region.	Cannot establish a business connection Cannot send you marketing communications
*When you exchange business cards with us*
Email address Full name Phone number Company Job title Any other information you choose to share with us	To establish a business connection	Depending on the context, legitimate interest (B2B marketing), pre-contractual discussions or consent	3^rd party platforms providing storage and analytics such as the following: SalesForce (Customer Relations Management) Hubspot (Customer Service Management)	For the period of time corresponding to your interest in or use of our Services, and the retention of records of service as required by applicable laws and regulations in each geographical region.	To establish a business connection
Email address Full name	To send marketing communications	Consent	3^rd party platforms providing storage and analytics such as the following: SalesForce (Customer Relations Management) Hubspot (Customer Service Management)	For the period of time corresponding to your interest in or use of our Services, and the retention of records of service as required by applicable laws and regulations in each geographical region.	Cannot send you marketing communications
*When we acquire your Personal Data from third-party sources (such as lead-generation companies)*
Email address Full name Phone number Company Job title Any other information you choose to share with us	To establish a business connection	Depending on the context, legitimate interest (B2B marketing), pre-contractual discussions or consent	3^rd party platforms providing storage and analytics such as the following: SalesForce (Customer Relations Management) Hubspot (Customer Service Management)	For the period of time corresponding to your interest in or use of our Services, and the retention of records of service as required by applicable laws and regulations in each geographical region.	Cannot establish a business connection
Email address Full name	To send marketing communications	Consent	3^rd party platforms providing storage and analytics such as the following: SalesForce (Customer Relations Management) Hubspot (Customer Service Management)	For the period of time corresponding to your interest in or use of our Services, and the retention of records of service as required by applicable laws and regulations in each geographical region.	Cannot send you marketing communications
*When we use the Personal Data of our service providers*
Email address Full name Phone number Company Job title Any other information you choose to share with us	To contact our service providers To process the order of the product and/or service To performing/execute the agreement	Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract. Legitimate interest (e.g. contract –related communications	3^rd party platforms providing storage and analytics such as the following: Google Cloud (storage) SalesForce (Customer / Patrner Relations Management and Contracts Management)	For the period of time corresponding to your engagement with us as our service provider, and the retention of records of service as required by applicable laws and regulations in each geographical region.	Cannot contact our service providers Cannot process the order of the product and/or service Cannot perform/execute the agreement
*When we use the Personal Data of, or provided by, our resellers, distributors, agents and/or finders*
Email address Full name Phone number Company Job title Any other information you choose to share with us	● To provide our products and Services ● To perform the applicable agreement ● To communicate with our resellers, distributors, agents and/or finders	Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract. Legitimate interest (e.g. contract –related communications)	3^rd party platforms providing storage and analytics such as the following: Google Cloud (storage) SalesForce (Customer / Patrner Relations Management and Contracts Management)	For the period of time corresponding to your engagement with us as our reseller, distributor, agent and/or finder, and the retention of records of service as required by applicable laws and regulations in each geographical region	Cannot provide the services and/or our products Cannot perform the agreement Cannot communicate with our resellers, distributors, agents and/or finders
*When you interact with us on our social media profiles (e.g., Facebook, Instagram, Twitter, LinkedIn)*
Social media profile Any other information you choose to share with us	To reply and/or respond to your request or question To establish a first business connection/discussion	Depending on the context, legitimate interest (B2B marketing), pre-contractual discussions or consent	3^rd party platforms providing storage and analytics such as the following: SalesForce (Customer Relations Management) ZenDesk, StatusPage (Community / Support Management)	For the period of time corresponding to your interest in or use of our Services, and the retention of records of service as required by applicable laws and regulations in each geographical region.	Cannot reply or respond to your request Cannot establish a first business connection/ discussion
Email address Full name	To send marketing communications	Consent	3^rd party platforms providing storage and analytics such as the following: SalesForce (Customer Relations Management) ZenDesk, StatusPage (Community / Support Management)	For the period of time corresponding to your interest in or use of our Services, and the retention of records of service as required by applicable laws and regulations in each geographical region.	Cannot send you marketing communications

Finally, please note that some of the abovementioned Personal Data will be used for fraud or other illegal activity detection and prevention, to identify and repair errors, to conduct audits and for security purposes. Personal Data may also be used to comply with applicable laws, with investigations performed by the relevant authorities, law enforcement purposes, and/or to exercise or defend legal claims. In certain cases, we may or will anonymize or de-identify your Personal Data and further use it for internal and external purposes, including, without limitation, to improve the Services and for research purposes. “Anonymous Information” means information which does not enable identification of an individual user, such as aggregated information about the use of our Services. We may use Anonymous Information and/or disclose it to third parties without restrictions (for example, in order to improve our Services and enhance your experience with them).

4. HOW WE PROTECT AND STORE YOUR INFORMATION

Security. We have implemented appropriate technical, organizational and security measures designed to reduce the risk of accidental destruction or loss, or the unauthorized disclosure or access to such information appropriate to the nature of the information concerned. However, please note that we cannot guarantee that the information will not be exposed as a result of unauthorized penetration to our servers. Nevertheless, we make commercially reasonable efforts to make the collection and security of such information consistent with this Privacy Policy and all applicable laws and regulations. As the security of information depends in part on the security of the computer, device or network you use to communicate with us and the security you use to protect your user IDs and passwords, please make sure to take appropriate measures to protect this information.
Retention of your Personal Information. We shall retain your Personal Data until we no longer need it and proactively delete it or you send a valid deletion request. Without derogating from the foregoing and in addition to the retention periods mentioned above, in some circumstances we may store your Personal Data for longer periods of time, for example (i) where we are required to do so in accordance with legal, regulatory, tax or accounting requirements, or (ii) for us to have an accurate record of your dealings with us in the event of any complaints or challenges, or (iii) if we reasonably believe there is a prospect of litigation relating to your Personal Data or dealings. We have an internal data retention policy to ensure that we do not retain your Personal Data perpetually

5. HOW WE SHARE YOUR PERSONAL INFORMATION

In addition to the recipients described in Section 4, we may share your information as follows:

To the extent necessary, with regulators, courts or competent authorities, to comply with all applicable laws, regulations and rules (including, without limitation, federal, state or local laws), and requests of law enforcement, regulatory and other governmental agencies or if required to do so by court order;
If, in the future, we sell or transfer some or all of our business or assets to a third party, we will (to the minimum extent required) disclose information to a potential or actual third party purchaser of our business or assets. In the event that we are acquired by or merged with a third party entity, or in the event of bankruptcy or a comparable event, we reserve the right to transfer or assign Personal Data in connection with the foregoing events, including, in connection with, or during negotiations of, any merger, sale of company assets, consolidation or restructuring, financing, or acquisition of all or a portion of our business by or to another company;
Where you have provided your consent to us sharing the Personal Data (e.g., where you provide us with marketing consents or opt-in to optional additional Services or functionality); and
Where we receive requests for information from law enforcement or regulators, we carefully validate these requests before any Personal Data is disclosed.

If you want to receive the list of recipients of your Personal Information, please make your request by contacting us at privacy@torq.io

6. ADDITIONAL INFORMATION REGARDING TRANSFERS OF PERSONAL INFORMATION

Internal transfers: We ensure transfers within the Torq group will be covered by an agreement entered into by members of the Torq group (an intra-group agreement) which contractually obliges each member to ensure that Personal Data receives an adequate and consistent level of protection wherever it is transferred to
External transfers: Where we transfer your Personal Data outside of the EU/EEA, for example to third parties who help provide our products and services, we will obtain contractual commitments from them to protect your Personal Data. Where we receive requests for information from law enforcement or regulators, we carefully validate these requests before any Personal Data is disclosed.

7. YOUR PRIVACY RIGHTS

Rights: The following rights (which may be subject to certain exemptions or derogations) shall apply to certain individuals (some of which only apply to individuals protected by the GDPR):

You have a right to access Personal Data held about you. Your right of access may normally be exercised free of charge, however we reserve the right to charge an appropriate administrative fee where permitted by applicable law;
You have the right to request that we rectify any Personal Data we hold that is inaccurate or misleading;
You have the right to request the erasure/deletion of your Personal Data (e.g. from our records). Please note that there may be circumstances in which we are required to retain your Personal Data, for example for the establishment, exercise or defense of legal claims;
You have the right to object, to or to request restriction, of the processing;
You have the right to data portability. This means that you may have the right to receive your Personal Data in a structured, commonly used and machine-readable format, and that you have the right to transmit that data to another controller;
You have the right to object to profiling;
You have the right to withdraw your consent at any time. Please note that there may be circumstances in which we are entitled to continue processing your data, in particular if the processing is required to meet our legal and regulatory obligations. Also, please note that the withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal;
You also have a right to request certain details of the basis on which your Personal Data is transferred outside the European Economic Area, but data transfer agreements and/or other details may need to be partially redacted for reasons of commercial confidentiality;
You have a right to lodge a complaint with your local data protection supervisory authority (i.e., your place of habitual residence, place or work or place of alleged infringement) at any time or before the relevant institutions in your place of residence. We ask that you please attempt to resolve any issues with us before you contact your local supervisory authority and/or relevant institution.

You can exercise your rights by contacting us at privacy@torq.io. You may use an authorized agent to submit a request on your behalf if you provide the authorized agent written permission signed by you. To protect your privacy, we may take steps to verify your identity before fulfilling your request. Subject to legal and other permissible considerations, we will make every reasonable effort to honor your request promptly in accordance with applicable law or inform you if we require further information in order to fulfil your request. When processing your request, we may ask you for additional information to confirm or verify your identity and for security purposes, before processing and/or honoring your request. We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive.

In the event that your request would adversely affect the rights and freedoms of others (for example, would impact the duty of confidentiality we owe to others) or if we are legally entitled to deal with your request in a different way than initial requested, we will address your request to the maximum extent possible, all in accordance with applicable law.

8. USE BY CHILDREN

We do not offer our products or Services for use by children and, therefore, we do not knowingly collect Personal Data from, and/or about children under the age of 18. If you are under 18, you may not use the Website, or provide any Personal Data to the Website without involvement of a parent or a guardian. For the purposes of the GDPR, we do not knowingly collect information from, and/or about children and we do not intend to offer information society services directly to children. In the event that we become aware that you provide Personal Data in violation of applicable privacy laws, we reserve the right to delete it. If you believe that we might have any such information, please contact us at privacy@torq.io.

9. HOW CAN I DELETE MY ACCOUNT?

Should you ever decide to delete your Account, you may do so by emailing privacy@torq.io . If you terminate your Account, any association between your Account and information we store will no longer be accessible through your Account. However, given the nature of sharing on the Services, any public activity on your Account prior to deletion will remain stored on our servers and will remain accessible to the public.

10. LINKS TO AND INTERACTION WITH THIRD PARTY PRODUCTS

The Site may enable you to interact with or contain links to your Third Party Account and other third party websites and Services that are not owned or controlled by us (each a “Third Party Service”). We are not responsible for the privacy practices or the content of such Third Party Services. Please be aware that Third Party Services may collect Personal Data from you. Accordingly, we encourage you to read the terms and conditions and privacy policy of each Third Party Service that you choose to use or interact with.

11. LOG FILES

We make use of log files. The information inside the log files includes internet protocol (IP) addresses, type of browser, Internet Service Provider (ISP), date/time stamp, referring/exit pages, clicked pages and any other information your browser may send to us. We may use such information to analyze trends, administer the Site, track users’ movement around the Site, and gather demographic information.

12. COOKIES AND OTHER TRACKING TECHNOLOGIES

Our Site utilizes “cookies”, anonymous identifiers and other tracking technologies in order to for us to provide our Site and present you with information that is customized for you. A “cookie” is a small text file that may be used, for example, to collect information about activity on the Site. Certain cookies and other technologies may serve to recall Personal Data, such as an IP address, previously indicated by a user. Most browsers allow you to control cookies, including whether or not to accept them and how to remove them. You may set most browsers to notify you if you receive a cookie, or you may choose to block cookies with your browser.

13. ANALYTICS TOOLS

Google Analytics. The Site uses a tool called “Google Analytics” to collect information about use of the Site. Google Analytics collects information such as how often users visit this site, what pages they visit when they do so, and what other sites they used prior to coming to this Site. We use the information we get from Google Analytics to maintain and improve the Site and our products. We do not combine the information collected through the use of Google Analytics with personally identifiable information. Google’s ability to use and share information collected by Google Analytics about your visits to this Site is restricted by the Google Analytics Terms of Service, available at http://www.google.com/analytics/terms/us.html/, and the Google Privacy Policy, available at http://www.google.com/policies/privacy/. You may learn more about how Google collects and processes Information specifically in connection with Google Analytics at http://www.google.com/policies/privacy/partners/. You may prevent your Information from being used by Google Analytics by downloading and installing the Google Analytics Opt-out Browser Add-on, available at https://tools.google.com/dlpage/gaoptout/.
Mixpanel. We collect personal information such as your email address and your user activity through the use of Mixpanel. Mixpanel’s ability to use and share information is governed by the Mixpanel Terms of Use, available at https://mixpanel.com/terms/, and the Mixpanel Privacy Policy, available at https://mixpanel.com/privacy/. You can opt-out of Mixpanel’s services by clicking on the following link: https://mixpanel.com/optout/.
Fullstory. The Platform uses a tool called “Fullstory” to collect information about use of the Website and the Platform. Fullstory collects information such as usage patterns (clicks, mouse movements, scrolling, typing – except sensitive information), technology specs (browser, device type, operating system, viewfinder size, script error, IP address) and navigation (referrers, session duration). We use the information we get from Fullstory to maintain and improve the Website, Platform and our products. We do not combine the information collected through the use of Fullstory with personally identifiable information. Fullstory’s ability to use and share information collected by Fullstory about your visits to this Website is restricted by Fullstory Terms of Service, available at https://www.fullstory.com/legal/terms-and-conditions/, and the Fullstory Privacy Policy, available at https://www.fullstory.com/legal/privacy/, you can opt-out of the FullStory Services.

We reserve the right to remove or add new analytic tools.

14. ACCESS/ACCURACY

To the extent that you do provide us with Personal Information, we wish to maintain accurate Personal Information. If you would like to delete or correct any of your other Personal Information that we may be storing, you may submit an access request by sending an email to privacy@torq.io. Your email should include adequate details of your request.

15. CALIFORNIA PRIVACY RIGHTS

California Civil Code Section 1798.83 permits our customers who are California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please send an email to privacy@torq.io. Please note that we are only required to respond to one request per customer each year.

16. OUR CALIFORNIA DO NOT TRACK NOTICE

We do not currently respond or take any action with respect to web browser “do not track” signals or other mechanisms that provide consumers the ability to exercise choice regarding the collection of personally identifiable information about an individual consumer’s online activities over time and across third-party web sites or online services. We may allow third parties, such as companies that provide us with analytics tools, to collect personally identifiable information about an individual consumer’s online activities over time and across different web sites when a consumer uses the Services.

17. DELETION OF CONTENT FROM CALIFORNIA RESIDENTS

If you are a California resident under the age of 18 and a registered user, California Business and Professions Code Section 22581 permits you to remove content or Personal Information you have publicly posted. To remove, please follow email us privacy@torq.io. Please be aware that after removal you will not be able to restore removed content. In addition, such removal does not ensure complete or comprehensive removal of the content or Personal Information you have posted and that there may be circumstances in which the law does not require us to enable removal of content.

18. CONTACT US

If you have any questions, concerns or complaints regarding our compliance with this notice and the Information protection laws, or if you wish to exercise your rights, we encourage you to first contact us at privacy@torq.io.

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