Privacy policy

TORQ Labs Inc., incorporated in the British Virgin Islands, is responsible for the personal information it handles through the public TORQ website, email inquiries and related business correspondence.

In this policy, TORQ, we, us and our refer to that company.

TORQ provides software. It does not itself manage client assets. A customer's role as an asset manager, lender, borrower or other participant does not make TORQ the provider of that customer's financial services.

This policy covers website visitors and business contacts. If you use TORQ software, read the notices and agreements provided with that service for additional account, identity, wallet or transaction processing.

Where TORQ processes personal information on a customer's instructions, the applicable customer agreement governs that processing and the customer may be the responsible controller.

If you contact us, your inquiry may include your first and last name, work email address, company, company website, message and any attachments or other information you choose to send. Google Workspace handles our email.

We also receive the correspondence and email metadata needed to handle your message.

The website contact form opens your email application. Filling in the form does not submit its contents to a TORQ server.

Your email provider handles the prepared message, and TORQ receives it when you send it. You may instead email [email protected] directly.

Send only information relevant to your inquiry. Do not send private keys, seed phrases, passwords, identity documents or unnecessary sensitive personal information through this form or ordinary email.

If you provide another person's details, ensure you are entitled to do so and make this policy available to them.

Your browser and the systems delivering the website exchange technical information to display pages and resources.

This can include an IP address, browser and device information, requested URL, referring page, request time, response status and diagnostic information.

Hosting and network providers may handle technical request and security records to deliver the website, diagnose faults and prevent abuse.

The website does not ask for precise location, access to your contacts or access to a cryptocurrency wallet merely to browse its public pages.

We receive information directly from you when you email us, from your browser when it requests website content, and from the providers delivering those communications and requests.

A colleague or business representative may also introduce you to us and provide your professional contact details and the context of the introduction.

You can ask us about the source of personal information we hold about you. We do not need identity documents or financial account details to answer a general website inquiry.

We use inquiry information to answer your questions, discuss software demonstrations or integrations, evaluate the business request you make and manage related correspondence.

We use technical information to deliver and maintain the website, investigate errors and protect it against misuse.

We may also use relevant information to meet legal obligations, handle privacy requests, resolve complaints and establish or defend legal claims. We limit processing to information needed for the relevant purpose.

Sending an inquiry is not permission for unrelated marketing. We do not use the public website to make automated lending, investment or other decisions with legal or similarly significant effects on you.

Where the British Virgin Islands Data Protection Act, 2021 applies, we obtain express consent when required.

The Act also permits processing necessary to perform a contract with you, take steps at your request toward a contract or comply with a legal obligation. Other statutory grounds may apply in specific circumstances.

Where the EEA or UK GDPR applies, responding to a request about a contract with you relies on the steps you request or performance of that contract.

Other business correspondence and website delivery or security may rely on legitimate interests in answering business inquiries and operating a secure website, subject to your rights and interests.

Processing required by law relies on the relevant legal obligation. Optional processing that requires consent relies on your consent.

A legal basis must be available under each applicable law. Reading this policy, browsing the website or acknowledging that you have read a privacy notice does not by itself give consent to optional processing.

Where processing relies on consent, you can withdraw it by contacting us. Withdrawal does not affect earlier lawful processing.

You can browse the public website without sending an inquiry.

Providing inquiry information is voluntary, but without a way to contact you or enough context we may be unable to answer your request or discuss the software you are considering.

We will identify any statutory or contractual requirement to provide additional information when it arises, together with the consequences of not providing it.

Personnel who need information for their work may handle it. Recipients also include Google Workspace for email and providers of website hosting, network delivery, IT support and security.

These providers receive information needed for their service and are subject to the duties applicable to their role.

We may disclose relevant information to legal or other professional advisers, courts, regulators or public authorities where necessary for advice, a legal obligation or the protection of legal rights.

We may also disclose information at your request or with consent where required.

If a business reorganisation, merger or transfer involves personal information, any disclosure must remain limited to the relevant transaction and subject to applicable confidentiality and data-protection requirements.

This policy does not authorise unrestricted disclosure for a new purpose.

The public website has no advertising profiles, advertising pixels or mechanisms for selling visitor information or sharing it for cross-context behavioural advertising.

TORQ is incorporated in the British Virgin Islands. Website and email services may involve processing in other countries, whose laws can differ from those where you live.

You can contact us for information about the recipients and locations relevant to your information.

Transfers are subject to the safeguards or other conditions required by applicable law. The British Virgin Islands Act requires adequate data-protection safeguards or valid consent for transfers outside the Virgin Islands.

Where EEA or UK transfer rules apply, an applicable adequacy decision, appropriate safeguards or a permitted exception is also needed.

You may request information about the safeguards relevant to a transfer, including a copy where applicable.

We keep personal information only for as long as needed for the purpose for which it was collected, including any applicable legal requirements.

Inquiry records depend on whether the request is resolved, related discussions are ongoing, and information is needed for a resulting business relationship or legal claim.

Technical and security records depend on the operational need to diagnose faults, investigate misuse and protect the service. Privacy-request and objection records may be kept to demonstrate the response and respect your choices.

Information subject to a legal preservation duty may be retained until that duty ends.

When information is no longer needed, we delete or irreversibly anonymise it. A deletion request may be subject to lawful retention exceptions. We will explain an applicable exception when responding.

We take practical steps proportionate to the information and risks to protect personal information against loss, misuse and unauthorised access or disclosure.

Providers processing information on our behalf must offer the protections required by applicable law.

No website, email system or transmission method can guarantee absolute security. Avoid sending sensitive information through ordinary email. If a personal-data incident occurs, we will provide notifications required by applicable law.

Under applicable law, you may request confirmation of whether we hold personal information about you, access to that information and correction of inaccurate or incomplete information.

You may withdraw consent where processing relies on it and object to direct marketing.

Depending on the law and processing involved, you may also have rights to deletion, restriction, objection to processing based on legitimate interests, and a portable copy of information. These rights have conditions and lawful exceptions.

This policy does not limit rights you have by law.

Where applicable law provides a right to opt out of a sale, sharing or targeted advertising, you may exercise that right by contacting us. The public website does not operate those advertising or data-sale mechanisms.

We will not penalise you for exercising a protected privacy right.

Send a request to [email protected] with enough detail to identify the information or correspondence involved. We may ask for proportionate information to verify your identity or an authorised representative's authority.

Do not send identity documents unless we arrange a suitable way to receive them.

We will respond within the time required by applicable law and explain any lawful refusal, retention requirement or extension. Requests are handled without a fee except where applicable law permits one.

You can also object to direct marketing or withdraw consent through this email address.

You may complain to the competent data-protection authority or pursue another remedy available under applicable law.

Where the EEA or UK GDPR applies, this includes the authority for your habitual residence, place of work or the alleged infringement, as applicable.

You do not have to contact TORQ first before exercising an available complaint right.

The public website does not use analytics, advertising or preference cookies, tracking pixels, or browser storage to build visitor profiles.

Our Cookie policy, linked in the website footer, explains the current use of cookies and similar technologies and your browser controls.

If we introduce a technology that requires consent, it will be subject to a separate choice before it is used. A privacy-policy acknowledgment is not a cookie-consent choice.

Links to documentation, social networks, third-party resources or the TORQ application take you to services with their own processing context. Following a link may disclose technical information to its destination.

Review the notices presented there before providing information.

This public-website policy does not replace a software customer's privacy obligations or notices for its financial activities.

Contact the responsible customer about information it controls. TORQ will assist with requests where required by its role and applicable agreement.

The website is intended for professional and business use and is not directed at children.

If you believe a child has provided personal information to TORQ, contact us so we can assess the information and take appropriate action.

We will update this policy when relevant practices or legal requirements change. The date above identifies the latest version.

For a material change, we will provide any additional notice and obtain any new consent required by applicable law before relying on that change.