Privacy Policy

Effective July 14, 2015

 

The Torch, LLC (“The Torch”, “we”, “us” or “our”) is committed to maintaining the confidentiality, integrity, and security of personal information, if any, collected from our users. This Privacy Policy explains the privacy practices we have adopted to protect our users’ personal information collected from our Site www.thetorch.com, including Sites that may now or in the future be viewable on mobile devices (“Mobile Applications”) and The Torch Mobile Applications. As used in this Privacy Policy, the term “Site” includes all websites and all devices or applications that collect personal information from you that we operate that link to this Privacy Policy, pages within each such website, device, or application, any equivalent, mirror, replacement, substitute, or backup website, device, or application and pages that are associated with each such website, device, or application. The Torch’s privacy and security standards are intended to help guard against identity theft and provide security for your personal information.

In addition to this Privacy Policy, we have established Terms of Service that set forth the general rules and policies governing your use of the Sites. A copy of the Terms of Service can be found https://www.thetorch.com/documents/terms-of-service.

By using a Site and/or providing us your personal information, you signify your assent to this Privacy Policy. If you do not agree with any term in this Privacy Policy, please do not provide us your personal information or use the Sites. Please note: The laws and regulations in different countries impose different (and even conflicting) requirements on the Internet and data protection. The servers that make the Sites available worldwide are located in the United States. All matters relating to the Sites are governed by the laws of the state of North Carolina, without reference to its conflicts of law rules that would result in the application of the laws of another jurisdiction. Please note that any information you provide will be transferred to the United States, and by using the Site or providing us your personal information, you authorize this transfer.

 

1. We limit the information we collect.

The Torch may collect the following categories of personal information about you through the Sites: a) Registration Information: When you register for a Service, you will be asked  for basic registration information, such as an email address and password; b)    Identification Information: You may also be asked to provide identification information to confirm your identity, including your first and last name and zip  code; c)   We may collect the IP address, unique identifier of the device, operating system version and app version for the purpose of providing you with our services.   We do not ask you for, access or track any location based information from your mobile device at any time while downloading or using our Mobile apps or services. We do not store billing details; we leverage a third party provider. We also collect and store any content that you choose to enter “Member Content”.  Such Member Content contains information about you, your dependents, pets, real estate or vehicles and may include photos you upload. It does not include account numbers, passwords or documents with highly confidential information. Please note that all content you enter or upload to the site is intended to be viewed only by yourself and the other users you choose to add as a part of your Torch network.  As the Internet evolves, we may also collect other types of information, consistent with this Privacy Policy and our Terms of Use. Safeguarding information to help protect you from identity theft is a top priority. We do not and will not, at any time, request your credit card information, your login information, or national identification numbers in an unsolicited e-mail or telephone communication.

 

2. We protect the information we collect.

The security of your personal information is important to us. We follow generally accepted industry standards to protect the personal information submitted to us, both during transmission and once we receive it. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, we cannot guarantee its absolute security. If you have any questions about security on our Web site, you can contact us at [email protected].

We take very seriously the privacy of your personal information. We use firewall barriers, SSL encryption techniques, and authentication procedures, among others, to maintain the security of your online session and to protect The Torch accounts and systems from unauthorized access.

 

3. How we use the information we collect:

We do not and will not share, sell or rent your personal information to anyone, for any reason, at any time. We may use the information you provide about yourself to fulfill your requests for our products, programs, and Services, to respond to your inquiries about our Services, and to offer you other products, programs, or services that we believe may be of interest to you. In order to allow you to use certain Services, we may be required to verify your identity. We may also use your information to verify your identity in the event you contact us for assistance with the Sites or Services. In certain situations, we may use or share your personal information:  a)  to respond to subpoenas, court orders, or legal process; b)   in order to investigate, prevent, defend against, or take other action; c)  regarding violations of our Terms of Service, illegal activities, suspected   fraud, or situations involving potential threats to the legal rights or   physical safety of any person or the security of our network, Sites or  Services;  d) to respond to claims that any posting or other content violates the rights of  third parties;  e) in an emergency, to protect the health and safety of our Sites’ users or the  general public;  or  f) as otherwise required by law.

We may outsource some tasks to affiliated companies or third parties and may share your information with those companies or third parties if reasonably necessary to enable them to assist in fulfilling the requests you make or the transactions you conduct via the Sites, including the operation of certain Site functions and Services that require access to information you supply online. In such cases, if such affiliated companies or third parties acting on our behalf are given access to the information you have supplied to us it will be subject to the applicable third party’s privacy policy and terms of service

We may use your information for internal analysis such as analyzing user behavior in aggregate for research and marketing purposes. The Torch may also aggregate transaction data and disclose such data only in aggregate and in a non-personally identifiable manner to third parties for marketing and promotional purposes (e.g., how many users responded to a particular offer). Aggregated information does not identify you individually.

When you visit our Sites, we may collect technical and navigational information, such as computer browser type, Internet protocol address, pages visited, and average time spent on our Site. This information may be used, for example, to alert you to software compatibility issues, or it may be analyzed to improve our web design and functionality.

When you use the mobile versions of our Sites, we may collect the unique device identifier assigned to that device by phone makers, carriers, or makers of the operating system (the “Device ID”). Device IDs allow app developers, advertisers, and others to uniquely identify your device for purposes of storing application preferences and other data. We may use your Device ID for security purposes. For example, if you have activated a feature that limits access to a Service from a specific device, our systems will access the Device ID from each device you attempt to access the Service with to determine if the device is the specific authorized device. Additionally, we may use Device IDs to monitor suspicious activity. For example, if we detect that a single account on a Site is being accessed from multiple devices, as determined by tracking the Device IDs that access an account, we may contact the user to ensure that such access has been authorized by the user. Advertisements that appear to you via a Site may be delivered by third party advertisers who may access your Device ID, but we do not provide these advertisers any of your personal information. These advertisers may use the Device ID for purposes of determining appropriate advertisements to display to you on a Site. This Privacy Policy does not cover the use of Device IDs by any advertisers.

 

If our company or our assets are acquired by another company, or in the event of a merger, consolidation, change in control, transfer of substantial assets, reorganization, or liquidation, we may transfer, sell, or assign to third parties information concerning your relationship with us, including, without limitation, personal information that you provide and other information concerning your relationship with us you will be notified via email and/or a prominent notice on our Web site of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information, . Such third parties will assume responsibility for the personal information collected by us in connection with our business operations or through our Sites and such third parties will assume the rights and obligations regarding such information as described in this Privacy Policy.

 

4. Emails from which you may “Opt-Out”:

The Torch complies with the Controlling the Assault of Non-Solicited Pornography and Marketing Act of 2003. The Torch provides users periodic Site-related notifications, newsletters, or other information via email. Users may elect to stop receiving such messages at their discretion. If you no longer wish to receive periodic email updates from The Torch, you may update your account preferences on the Site. You may also follow the unsubscribe instructions included in each promotional email. However, please note that certain Services-related email messages that we send users are necessary for the proper functioning and use of the Services, and users who participate in such Services do not have the ability to opt-out of such email messages. If you do not wish to receive them, you have the option to delete your account. To delete your account, log in and select the Account option on the main menu, select the “Delete my Account” link on the Profile tab and then press “Yes”.

 

5. Collection of information by third parties and sponsors:

In certain cases, you may be directed to a third party site to provide information to complete a transaction in connection with one of our Sites (e.g., to purchase a subscription to a Service). In such cases, any information you provide to such third party sites directly to such third party will be subject to the applicable third party’s privacy policy and terms of service. Additionally, the Sites may contain links to other sites whose information practices may be different than ours. Visitors should consult the other sites’ privacy notices, as we have no control over information that is submitted to, or collected by, these third parties.

The Sites may contain third party advertisements or offers that are complementary to your use of The Torch that may be custom matched to you based on information you provided to the Site, queries made through the Site or other information. If you choose to use these separate products or services, disclose information to the providers, or grant them permission to collect information about you, then their use of your information is governed by their privacy policies. You should evaluate their practices before deciding to use their services.

THE TORCH DOES NOT CONTROL AND IS NOT RESPONSIBLE FOR WHAT THIRD PARTIES DO IN CONNECTION WITH THEIR WEBSITES, OR HOW THEY HANDLE YOUR PERSONAL INFORMATION. PLEASE EXERCISE CAUTION AND CONSULT THE PRIVACY POLICIES POSTED ON EACH THIRD PARTY WEBSITE FOR FURTHER INFORMATION.

We may use third party service providers to help us analyze certain online activities. For example, these service providers may help us measure the performance of our online promotions or determine Site activity. We do not share any personal information about our users with these third parties, and these third parties do not collect such information on our behalf. Additionally we may utilize third party ad serving networks and their associated tracking functionality to deliver more targeted advertising to our users and to optimize customer acquisition efforts.

 

6. How we use cookies:

To enhance your experience with our Sites, we use “cookies.” Cookies are text files that are placed on your computer to store your preferences or for other record-keeping purposes. Cookies and other user tracking mechanisms (e.g., local shared objects), by themselves, do not tell us your email address or other personal information unless you choose to provide this information to us by, for example, registering at our Site. However, once you choose to furnish us with personal information, this information may be linked to the data stored in the cookie or other tracking mechanism. We may use cookies and other user tracking mechanisms, including “persistent cookies”, which will remain on your computer even after you close your browser, to understand Site usage and to improve the content and offerings on our Sites. For example, we may use cookies to personalize your experience at our Site (e.g., to recognize you by name when you return to our Site), and to save your password in password-protected areas. We also may use cookies to offer you products, programs, or services. While most browsers are set to accept cookies and other tracking devices by default, you can set yours to refuse tracking devices or to alert you before accepting them. However, by disabling tracking devices, you may not have access to the entire set of features of our Sites. Your browser manufacturer has information on changing the default setting for your specific browser.

The Torch may use standard Internet technology, such as web beacons and similar technologies, to track your use of the Site or to track your response to email messages that we send you in connection with the Sites or Services. Web beacons (sometimes called transparent GIFs, clear GIFs, or web bugs) are small strings of code that provide a way for us to deliver a small graphic image (usually invisible) on a web page or in an email. Web beacons can recognize certain types of information on your computer such as cookies, the time and date a page is viewed, and a description of the page where the web beacon is placed. The Torch may use web beacons to improve your experience on the Site, including to provide you with content customized to your interests and to understand whether users read email messages and click on links contained within those messages so that the Site can deliver relevant content. Our web beacons may collect some contact information (for example, the email address associated with an email message that contains a web beacon). The Sites also may include third-party web beacons so that these third parties may receive auditing, research, and reporting information about advertisements viewed on the Site.

Our affiliates use cookies to make it easier for you to navigate our site and access special features.  The use of cookies by our affiliates is not covered by our privacy policy.  We do not have access or control over these cookies.

We may use analytics software to allow us to better understand the functionality of our Mobile Applications on your phone. This software may record information such as how often you use the application, the events that occur within the application, aggregated usage, performance data, and where the application was downloaded from.

 

7. Blog

Our Web site offers publicly accessible blogs or community forums. You should be aware that any information you provide in these areas may be read, collected, and used by others who access them. To request removal of your personal information from our blog or community forum, contact us at [email protected].  In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why.

 

8. Social Media Features and Widgets

Our Web site includes Social Media Features, such as the Facebook Like button [and Widgets, such as the Share this button or interactive mini-programs that run on our site]. These Features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the Feature to function properly. Social Media Features and Widgets are either hosted by a third party or hosted directly on our Site. Your interactions with these Features are governed by the privacy policy of the company providing it

 

9. Ownership of data and changes to your personal information:

Your data belongs to you, and you can remove it anytime you want. To cancel your The Torch account and delete all account information associated with your account, log in to your account at www.thetorch.com, click “Account”, then click the “Delete My Account” link on the profile page. If you ask us to delete your account, we will use commercially reasonable efforts to remove your data from our servers. Despite such removal, portions of your data may remain on our production and back-up servers indefinitely.

If you wish to access personal information that you have submitted to us or to request the correction of any inaccurate information you have submitted to us, you may correct certain information via your user account. Alternatively, you can send an email that includes your contact information to [email protected]  to request any corrections to your personal information.

If you provide us personal information about others, we will only use that information for the specific reason for which it was provided to us. Your family member or friend may contact us at [email protected] to request that we remove this information from our database.

We will retain your information for as long as your account is active or as needed to provide you services. If you wish to cancel your account or request that we no longer use your information to provide you services contact us at [email protected].  We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

 

10. Children:

The features, services, and other aspects of our Sites requiring the submission of personal information are not intended for anyone under 18 years of age. We do not knowingly collect personal information from children under the age of 13. If you are a parent or guardian of a child under the age of 13 and believe he or she has disclosed personal information to us please contact us at [email protected]

 

 

11. Your California privacy rights:

California Civil Code Section 1798.83, also known as the “Shine The Light” law (as modified from time to time), permits our customers who are California residents to request and obtain from us once a year, free of charge, information about the personal information (if any) we disclosed to third parties for direct marketing purposes in the preceding calendar year. If applicable, this information would include a list of the categories of personal information that was shared and the names and addresses of all third parties with which we shared information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to [email protected]. In your request, please attest to the fact that you are a California resident and provide a current California address for our response. Please be aware that not all information sharing is covered by the California Privacy Rights requirements and only information on covered sharing will be included in our response.

 

12. Changes to this Privacy Policy:

We regularly re-evaluate our privacy and security policies and adapt them as necessary to deal with new challenges. We reserve the right, at our discretion, to make changes to this Privacy Policy from time to time, so please review it frequently. You may review updates to our Terms of Service and Privacy Policy at any time via links on www.thetorch.com. You agree to accept electronic communications and/or postings of revised versions of this Privacy Policy on www.thetorch.com and agree that such electronic communications or postings constitute notice to you of the revised version of this Privacy Policy. If we make material changes to this Privacy Policy, we will notify you here, by email or by posting a notice on our home page prior to the change becoming effective.

 

Questions?

If you have questions or concerns regarding this statement, or if you have any questions or suggestions, please contact us at [email protected] or The Torch, LLC, 222 South Church Street, Suite 100, Charlotte, NC 28202.