Privacy Policy

This Privacy Policy describes how Torque ("Torque", "we", "our", or "us") collects, uses, and shares information about you when you access or use our products and services, including our web-based and mobile application interfaces (collectively, the "Products").

By accessing or using any of our Products, you agree to the collection, use, and sharing of your information as described in this Privacy Policy. If you do not agree with our policies and practices, do not use our Products.

1. Information We Collect

1.1 Information You Provide

We may collect information that you provide directly to us, including:

• Contact information, such as your email address, when you contact us for support or subscribe to our communications
• Account information if you create an account with us
• Transaction information when you use our Products
• Feedback and communications you send to us

1.2 Information We Collect Automatically

When you use our Products, we may automatically collect certain information, including:

• Device information, such as your IP address, browser type, operating system, and device identifiers
• Usage information, such as how you interact with our Products, pages visited, features used, and time spent
• Blockchain information, such as public wallet addresses and transaction data that is publicly available on blockchains
• Log information, such as access times, pages viewed, and referring URLs

1.3 Information from Third Parties

We may receive information about you from third parties, such as wallet providers, blockchain analytics services, and other service providers that help us operate our Products.

2. How We Use Your Information

We use the information we collect to:

• Provide, maintain, and improve our Products
• Process transactions and facilitate your use of our Products
• Communicate with you about our Products, including responding to your inquiries and providing customer support
• Detect, prevent, and address technical issues, fraud, and security threats
• Comply with legal obligations and enforce our Terms of Service
• Analyze usage patterns and trends to improve user experience
• Send you marketing communications (with your consent, where required)

3. How We Share Your Information

We may share your information in the following circumstances:

3.1 Service Providers

We may share your information with third-party service providers who perform services on our behalf, such as hosting, analytics, customer support, and payment processing. These service providers are contractually obligated to protect your information and use it only for the purposes for which it was shared.

3.2 Legal Requirements

We may disclose your information if required to do so by law or in response to valid requests by public authorities, such as court orders or subpoenas. We may also disclose information to protect our rights, privacy, safety, or property, or that of our users or others.

3.3 Business Transfers

In the event of a merger, acquisition, reorganization, bankruptcy, or other sale of all or a portion of our assets, your information may be transferred as part of that transaction.

3.4 With Your Consent

We may share your information with your consent or at your direction.

3.5 Public Blockchain Information

Please note that when you interact with blockchain networks through our Products, certain information, including wallet addresses and transaction details, may be publicly visible on the blockchain and cannot be deleted or modified.

4. Non-Custodial Nature of Our Products

Our Products are non-custodial, meaning we do not have custody, possession, or control of your crypto assets or private keys at any time. You are solely responsible for the custody of your cryptographic private keys and wallet credentials. We do not collect or store your private keys, seed phrases, or other sensitive wallet information.

5. Cookies and Tracking Technologies

We use cookies and similar tracking technologies to collect and use information about you. For more information about our use of cookies, please see our Cookie Policy.

6. Data Security

We implement appropriate technical and organizational measures to protect your information against unauthorized access, alteration, disclosure, or destruction. However, no method of transmission over the internet or electronic storage is 100% secure, and we cannot guarantee absolute security.

7. Your Rights and Choices

Depending on your jurisdiction, you may have certain rights regarding your personal information, including:

• The right to access and receive a copy of your personal information
• The right to rectify inaccurate or incomplete information
• The right to request deletion of your personal information
• The right to object to or restrict processing of your personal information
• The right to data portability
• The right to withdraw consent where processing is based on consent

To exercise these rights, please contact us at hello@torque.fi. We will respond to your request in accordance with applicable law.

8. Children's Privacy

Our Products are not intended for children under the age of 18. We do not knowingly collect personal information from children under 18. If you believe we have collected information from a child under 18, please contact us immediately, and we will take steps to delete such information.

9. International Data Transfers

Your information may be transferred to and processed in countries other than your country of residence. These countries may have data protection laws that differ from those in your country. By using our Products, you consent to the transfer of your information to these countries.

10. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. If we make material changes, we will notify you by updating the date at the top of this Privacy Policy and, where appropriate, providing additional notice. Your continued use of our Products after such changes constitutes your acceptance of the updated Privacy Policy.

11. California Privacy Rights

If you are a California resident, you may have additional rights under the California Consumer Privacy Act ("CCPA"). These rights include the right to know what personal information we collect, the right to delete personal information, the right to opt-out of the sale of personal information (we do not sell personal information), and the right to non-discrimination for exercising your privacy rights.

12. European Privacy Rights

If you are located in the European Economic Area ("EEA"), United Kingdom, or Switzerland, you have certain rights under the General Data Protection Regulation ("GDPR") and applicable data protection laws. These rights are described in Section 7 above. Our legal basis for processing your personal information includes: (a) performance of a contract; (b) compliance with legal obligations; (c) legitimate interests; and (d) your consent.