Website Privacy Notice and Cookie Policy

Torre AI Pte Ltd and any other directly controlled entities as may exist from time to time and their web presence via the domain https://torre.capital and any other domains created from time to time, hereinafter referred to as ‘Torre’, ‘we’, ‘us’ or ‘our’ is committed to respect your privacy and choices in accordance with the Personal Data Protection Act 2012 of Singapore (“PDPA”) and other applicable data protection laws. The statement highlights our privacy practices regarding Personal Information that we collect and store through this website and for the Personal Information that you provide us while interacting with us on our website (this “Site”) and participating in our events and campaigns.

What is Personal data and what information do we collect?

For the purposes of this privacy notice, ‘Personal Information’ is any data which relates to an individual who may be identified from that data, or from a combination of a set of data, and other information which is in possession of Persistent.

You may browse the pre-login sections of our website without providing any Personal Information about yourself. However, we collect certain information for the purpose of enabling access to restricted sections and to enable you to make investments through our platform.

  • We collect, use, store and transfer different kinds of personal data about or relating to you, including but not limited to the following:
  • Identity and contact data, which includes your name, passport or other identification number, telephone number, mailing address, email address, images of your passport or identification document, utility bill or driving license;
  • Financial data, which includes information about your financial position, status and history, and payment account details (such as bank, credit, payment or other payment details);
  • Transaction data, which includes details about payments to and from your accounts with us;
  • Technical data, which includes details about the devices and technology you use including internet protocol address, your login data, and other technology on the devices you use to access our website, products and/or services;
  • Usage data, which includes information about how you use our website, products and/or services, including cookies, IP address, and account details

How do we use your information?

We do not sell your personal information to any third parties or try to monetize our user data in any other manner.

We use personal information collected via our Website for a variety of business purposes described below. We process your personal information for these purposes in reliance on our legitimate business interests, in order to enter into or perform a contract with you, with your consent, and/or for compliance with our legal obligations. We indicate the specific processing grounds we rely on next to each purpose listed below.

We use the information we collect or receive:

  • To facilitate account creation and logon process. If you choose to link your account with us to a third-party account (such as your Google or Facebook account), we use the information you allowed us to collect from those third parties to facilitate account creation and logon process for the performance of the contract.
  • To post testimonials. We post testimonials on our Website that may contain personal information. Prior to posting a testimonial, we will obtain your consent to use your name and the consent of the testimonial. If you wish to update, or delete your testimonial, please contact us at [email protected] and be sure to include your name, testimonial location, and contact information.
  • Request feedback. We may use your information to request feedback and to contact you about your use of our Website.
  • To enable user-to-user communications. We may use your information in order to enable user-to-user communications with each user’s consent.
  • To manage user accounts. We may use your information for the purposes of managing our account and keeping it in working order.
  • To send administrative information to you. We may use your personal information to send you product, service and new feature information and/or information about changes to our terms, conditions, and policies.
  • To protect our Services. We may use your information as part of our efforts to keep our Website safe and secure (for example, for fraud monitoring and prevention).
  • To enforce our terms, conditions and policies for business purposes, to comply with legal and regulatory requirements or in connection with our contract.
  • To respond to legal requests and prevent harm. If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond.
  • To deliver and facilitate delivery of services to the user. We may use your information to provide you with the requested service.
  • To respond to user inquiries/offer support to users. We may use your information to respond to your inquiries and solve any potential issues you might have with the use of our Services.
  • To send you marketing and promotional communications. We and/or our third-party marketing partners may use the personal information you send to us for our marketing purposes, if this is in accordance with your marketing preferences. You can opt-out of our marketing emails at any time through settings post login.

Will your information be shared with anyone?

We only share information with your consent, to comply with laws, to provide you with services, to protect your rights, or to fulfil business obligations.

We may process or share your data that we hold based on the following legal basis:

  • Consent: We may process your data if you have given us specific consent to use your personal information in a specific purpose.
  • Legitimate Interests: We may process your data when it is reasonably necessary to achieve our legitimate business interests.
  • Performance of a Contract: Where we have entered into a contract with you, we may process your personal information to fulfil the terms of our contract.
  • Legal Obligations: We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).
  • Vital Interests: We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.

How do we keep your information safe?

We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cyber criminals, or other unauthorized third parties will not be able to defeat our security, and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Website is at your own risk. You should only access the Website within a secure environment.

Our Cookie Policy?

We may collect information, your Personal Data, through cookies on our Platform, website and mobile applications. We use analytics programs such as Google Analytics to manage and improve our websites, mobile applications, the Platform and/or our Services. We may with the help of Google Analytics use your browsing behaviour and prior usage patterns together with any other Personal Data previously provided by you in accordance with this Privacy Policy.

What are your Privacy Rights?

In some regions (like the European Economic Area), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; and (iv) if applicable, to data portability. In certain circumstances, you may also have the right to object to the processing of your personal information. To make such a request, please use the contact details provided below. We will consider and act upon any request in accordance with applicable data protection laws.

If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time. Please note however that this will not affect the lawfulness of the processing before its withdrawal, nor will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

If you are resident in the European Economic Area and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

If you are resident in Switzerland, the contact details for the data protection authorities are available here: https://www.edoeb.admin.ch/edoeb/en/home.html.

If you have questions or comments about your privacy rights, you may email us at [email protected]

Account Information

If you would at any time like to review or change the information in your account or terminate your account, you can Log in to your account settings and update your user account.

Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our Terms of Use and/or comply with applicable legal requirements.

How can you contact us about this notice?

If you have questions or comments about this notice, you may contact our Data Protection Officer (DPO), Sandeep Kumar, by email at [email protected], by phone at +6587932505, or by post to:

Torre AI Pte Ltd 
Sandeep Kumar
128 Prinsep Street
Singapore 188655
Singapore
 

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