Privacy Policy

This Privacy Policy describes how Torch ("we," "us," or "our") collects, uses, and shares information when you visit torchapp.io (the "Site") or interact with our waitlist, communications, and related services (collectively, the "Service").

The Service is currently a marketing website and a pre-launch waitlist. Features described elsewhere on the Site that are not yet generally available are aspirational, and this Policy will be updated before any such features go live.

By using the Service, you agree to the practices described in this Policy. If you do not agree, please do not use the Service.

1. Information we collect

1.1 Information you provide

When you join the waitlist or otherwise interact with us, you may provide:

• Contact information — your name and email address.
• Stated preferences — whether you are interested in buying, selling, or both, and where you describe yourself as being in the process (learning, discovering, executing).
• Other communications — anything you send us by email or other means (including questions, feedback, or requests).

You are not required to provide this information, but some parts of the Service (such as joining the waitlist) will not work without it.

1.2 Information collected automatically

When you visit the Site, we and our infrastructure providers may automatically collect:

• Log and device data — IP address, user agent string, browser type, operating system, referring URL, and the pages and resources you request.
• Usage events — high-level events such as page views, signup attempts, and form completions, recorded together with a randomly-generated session identifier stored in your browser's local storage.
• Approximate location — derived from IP address, used for security, analytics, and basic localization.

We currently do not use third-party advertising, marketing, or analytics trackers (no Google Analytics, no Meta/LinkedIn/X pixels, no third-party tag managers). We may add these in the future and will update this Policy accordingly.

1.3 Cookies and similar technologies

We use browser local storage to store a randomly-generated session identifier so we can group page views and events from the same browser session. This identifier is not tied to your name or email unless you submit them through a form. We may use first-party cookies in the future; if we do, this Policy will be updated.

You can clear local storage and cookies at any time through your browser settings.

2. How we use information

We use the information we collect to:

• Operate, maintain, and improve the Service.
• Send you the communications you signed up for (waitlist updates, early access invitations, and related content).
• Personalize what we send you based on the preferences you shared (such as buyer vs. seller).
• Measure how the Site is used so we can make it better.
• Detect, prevent, and respond to fraud, abuse, security incidents, or violations of our Terms.
• Comply with legal obligations and enforce our agreements.

We do not sell your personal information. We do not use your personal information to train third-party generative AI models.

3. How we share information

We share information only as described below:

• Service providers. We use third-party vendors to host the Site, store data, send email, and provide related infrastructure. These providers process information on our behalf under contractual obligations to use it only for the services they provide to us.
• Legal and safety. We may disclose information when we believe in good faith that disclosure is required by law, legal process, or government request, or is necessary to protect the rights, property, or safety of Torch, our users, or others.
• Business transfers. If we are involved in a merger, acquisition, financing, reorganization, bankruptcy, or sale of assets, your information may be transferred as part of that transaction. We will provide notice before personal information is transferred and becomes subject to a different privacy policy.
• With your direction or consent. We may share information for any other purpose with your direction or consent.

4. Your choices

• Email. Every marketing email we send includes an unsubscribe link. You can also email us at hello@torchapp.io and we will remove you from our list.
• Browser controls. Most browsers let you clear cookies and local storage, block third-party cookies, and send a "Do Not Track" or Global Privacy Control (GPC) signal. We treat valid GPC signals as an opt-out of any sale or sharing of personal information for cross-context behavioral advertising (we do not currently engage in either).
• Account deletion. Because we do not currently offer accounts, deletion requests are handled manually — see Section 5.

5. Your rights

Depending on where you live, you may have rights under privacy laws, including the right to:

• Access the personal information we hold about you.
• Correct information that is inaccurate.
• Delete your personal information.
• Receive a copy of your information in a portable format.
• Object to or restrict certain processing.
• Withdraw consent where we rely on consent as our legal basis.
• Lodge a complaint with a data protection authority.

To exercise any of these rights, email us at hello@torchapp.io. We may need to verify your identity before responding. We will not discriminate against you for exercising your rights.

California residents have additional rights under the California Consumer Privacy Act, including the right to know what categories of personal information we collect, the categories of sources, the purposes for which we use it, and the categories of third parties with whom we share it. We do not "sell" personal information as that term is defined under the CCPA.

Residents of the EEA, UK, and Switzerland — our legal bases for processing are typically (a) your consent, (b) the performance of a contract or pre-contractual steps you request (e.g., joining the waitlist), (c) our legitimate interests in operating and improving the Service, and (d) compliance with legal obligations.

6. Data retention

We keep personal information for as long as we have a legitimate business reason to do so — for example, to operate the waitlist, communicate with you, or comply with legal obligations. When we no longer need information, we delete or anonymize it. You may request earlier deletion at any time using the contact information below.

7. Security

We use reasonable administrative, technical, and organizational measures to protect the information we hold. No method of transmission or storage is completely secure, and we cannot guarantee the security of information transmitted to or from the Service. You use the Service at your own risk.

8. International transfers

We are based in the United States, and the information we collect is stored and processed in the U.S. and other jurisdictions where our service providers operate. These jurisdictions may have data protection laws that are different from those in your country. Where required, we use appropriate safeguards for international transfers.

9. Children

The Service is intended for adults 18 years of age or older and is not directed to children under 13. We do not knowingly collect personal information from children under 13. If you believe a child under 13 has provided us with personal information, please contact us and we will delete it.

10. Third-party links

The Service may contain links to third-party websites or services (for example, our YouTube channel). We are not responsible for the privacy practices of those third parties. We encourage you to review their privacy policies before providing them with information.

11. Changes to this Policy

We may update this Policy from time to time. When we do, we will revise the "Last updated" date at the top of this page. If the changes are material, we will provide additional notice (for example, by email or a prominent notice on the Site). Your continued use of the Service after the changes take effect constitutes your acceptance of the updated Policy.

12. Contact us

If you have questions about this Policy or our privacy practices, contact us at:

Torch
Email: hello@torchapp.io