Privacy Policy

Last Updated: October 17, 2024

This Privacy Policy applies to The Torch Academy’s website, accessible at https://thetorchacademy.com (the “Website”), and the online learning platform also accessible through the Website. Together, these are referred to as the “Site,” which is owned and operated by The Torch Academy (“we,” “our,” or “us”). This Privacy Policy outlines how we collect, use, share, and protect your personal data through our Site, and explains your rights regarding the use of, access to, and correction of your personal data.

We collect personal data in the following ways:

1. Personal Data We Collect

The types of personal data you may provide include:

  • Contact details (e.g., name, email address, phone number, organization, job title),
  • Account and profile information,
  • Payment and billing details (processed by secure third-party providers),
  • Feedback or inquiries submitted via forms, surveys, or other communication.

You provide personal data when you interact with us, such as when you:

  • Fill out forms on our Site,
  • Engage with our chatbot or customer support,
  • Contact us via phone or email,
  • Participate in events, forums, or surveys hosted by The Torch Academy.

1.1 Personal Data You Provide Directly

We automatically collect certain data when you visit or interact with the Site. This includes:

  • Technical data: IP address, device information, browser type, operating system.
  • Usage data: pages visited, time spent on each page, courses viewed or completed, and other behavioral data.

1.2 Automatically Collected Data

For any transactions, your payment and billing details are encrypted and processed by third-party payment providers that are PCI DSS-compliant. We do not store or control your payment information directly.

1.3 Payment Data

We may receive personal data from third parties we work with, such as analytics providers, payment processors, or marketing partners.

1.4 Data from Third Parties

We use personal data for the following purposes:

  • To Provide Services: Your data is used to provide access to our courses, manage your account, and offer customer support. We process this data based on contractual necessity.
  • To Improve Our Platform: We analyze data to enhance our services, add features, and improve user experience (legitimate interests).
  • For Personalization: We use your data to tailor content and features to enhance your experience, with your consent where required.
  • To Communicate with You: We may send notifications, updates, and marketing communications, provided you have opted in. You may withdraw consent at any time.
  • For Legal Compliance: We may process personal data to comply with legal obligations, respond to legal requests, or protect our rights, property, or safety.

2. How We Use Your Personal Data

We only share personal data with third parties when necessary for the following purposes:

  • Third-Party Service Providers: We share data with vendors such as payment processors, email marketing services, and analytics providers. These providers are contractually bound to safeguard your data and use it only for the specific services they provide to us.
  • Business Transfers: In the event of a merger, acquisition, or asset sale, your personal data may be transferred to the acquiring entity.
  • Legal Obligations: We may share personal data if required by law or to protect the rights, property, or safety of The Torch Academy or its users.

3. Sharing Your Personal Data

We are committed to securing your personal data. We implement appropriate technical and organizational measures, including encryption, pseudonymization, and access control, to protect your data from unauthorized access, loss, or disclosure. However, no system can be completely secure. You acknowledge that any transmission of personal data is at your own risk.

4. Security of Personal Data

We retain your personal data for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required by law. Once no longer needed, your personal data will be securely deleted or anonymized. 

5. Data Retention

As a global platform, we may transfer your personal data outside the European Economic Area (EEA), including to countries that may not offer the same level of data protection. In such cases, we implement safeguards, such as the EU Standard Contractual Clauses, to ensure your data is protected in accordance with applicable law. 

6. International Data Transfers

Under the General Data Protection Regulation (GDPR) and other applicable data protection laws, you have the following rights:

  • The right to access the personal data we hold about you,
  • The right to request corrections or updates to your data,
  • The right to request deletion of your data,
  • The right to object to or restrict the processing of your data,
  • The right to data portability (i.e., the right to receive your data in a structured, commonly used format),
  • The right to withdraw consent where processing is based on consent.

To exercise any of these rights, please contact us at legal@thetorchacademy.com. If you feel your rights have been violated, you may also file a complaint with your local data protection authority or the Irish Data Protection Commission. 

7. Your Rights

8. Cookies Policy

Cookies are small text files placed on your device to store information when you visit our Site. They help improve your experience by remembering your preferences and providing insights into how our Site is used. 

8.1 What Are Cookies?

We use the following types of cookies:

  • Essential Cookies: Necessary for the basic functioning of the Site (e.g., security, network management).
  • Analytics Cookies: Help us analyze how users interact with the Site by collecting anonymous data.
  • Functionality Cookies: Remember your preferences and help personalize your experience.
  • Targeting Cookies: Used to deliver advertisements relevant to you and measure the effectiveness of our advertising campaigns.

8.2 Types of Cookies We Use

We comply with European regulations requiring user consent for cookies. Upon your first visit to our Site, you will be prompted to consent to or manage the use of cookies. You can adjust your preferences at any time by visiting our cookie settings or using your browser’s settings.

8.3 Cookie Consent and Management

You can manage cookies in your browser’s settings. Please note that disabling certain cookies may impact the functionality of the Site and your overall experience.

8.4 How to Disable Cookies

We reserve the right to modify this Privacy Policy at any time. If we make significant changes, we will notify you via email or through a notice on our Site. We encourage you to review this policy periodically for updates. 

9. Changes to This Privacy Policy

For questions or concerns regarding this Privacy Policy or the way we handle your personal data, please contact us at: The Torch Academy Email: legal@thetorchacademy.com

10. Contact Us

While we take all reasonable steps to secure your personal data, no system can guarantee absolute security. By using our Site, you acknowledge that the transmission of personal data is at your own risk. In the event of a data breach, we will notify you and the relevant supervisory authority within 72 hours as required by the European law.

11. Limitation of Liability for Data Breaches

Our Site may contain links to third-party websites, including payment processors and analytics providers. These websites have their own privacy policies, and we do not accept any responsibility or liability for their data protection practices. We encourage you to review their policies before providing any personal data. 

12. Third-Party Websites Disclaimer

Our services are not directed toward children under the age of 16. We do not knowingly collect personal data from individuals under 16 without obtaining verifiable parental consent, in compliance with the GDPR. If we become aware that personal data from a child under 16 has been collected without parental consent, we will take steps to delete that information as soon as possible. 

13. Children’s Privacy

Any disputes arising out of or relating to this Privacy Policy, including disputes regarding the processing of personal data, will first be attempted to be resolved through negotiation in good faith. If such negotiation does not resolve the issue, the dispute will be submitted to binding arbitration or mediation, in accordance with Irish law. By using our Site, you agree to submit to the exclusive jurisdiction of the Irish courts.

14. Dispute Resolution and Governing Law

For customers residing outside the EU, such as in California (under the California Consumer Privacy Act – CCPA) or Brazil (under the Lei Geral de Proteção de Dados – LGPD), you may have additional rights, such as the right to know what personal data we hold about you, the right to request deletion, and the right to opt-out of the sale of personal data. To exercise these rights, please contact us at legal@thetorchacademy.com.

15. Additional Rights for Non-EU Customers

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