1. Information We Collect through our Site and Services
1.1 Information We Collect and Receive. In order for you to engage other members on the Torrch platform, or otherwise use our Site and Services, we may collect and process certain information to maximize the benefit you receive from our Services. Depending on your use of our Site and Services, this may include:
- Information you or your organization provides to us by creating your account and other forms on our Site or through our app. For example, your email, contact information, or any other information you may provide in any request, form, or communication from the Site or related to the Services;
- Information you provide to us by contacting us: Any personal information you may provide to us when you email or call us, such as name, organizations you work with, project details, email addresses, and any other details you provide.
- Login information, such as username that you may use in connection with our Services;
- Information about the ways people visit and interact with each other and with our Site, such as preferred communication methods, traffic analytics, geolocation information, and other statistics; and
- Information about your activity through our Services, including your device information (such as your IP address, the type of device, signal information, etc.).
We will only use personal information to provide you with services you have requested, or to connect you with other members with similar interests or goals. Personal information does not include aggregate information from which individual identities have been removed.
1.2 Information from Children. Torrch does not knowingly solicit or collect any personal information from anyone under 13 years of age, and children under 13 are not permitted to register for or use our Site or Services, including by subscribing to receive information from Torrch. Parents can contact our customer service department to access, change, or delete the personal information that has been submitted by a minor or child. If we become aware that a child under the age of 13 has provided us with personal information, we will delete it.
2. How We Use Information to Make Connections for You
Torrch may use the personal information you provide for the following purposes:
- To allow you to log into and access your account or profile;
- To help you connect with other members with similar employment, volunteer, or other interests;
- To improve our Services and your experience;
- To provide customer service and our support services;
- To keep your information secure, and to be able to verify your identity and contact information;
- To alert you about updated information and other news and services from Torrch;
- To contact you in response to requests or any other communications submitted by you regarding your profile, your connections, or other aspects of our networking platform.
3. How Information May Be Shared with Members and Others
Torrch will never sell or rent any of your personal information, and we will never share your personal information publicly without your consent. We may share your information with certain trusted third-party vendors to help us provide, improve, promote, or protect your information, our Site, and Services. For example, we may partner with other companies to provide data security services. Whenever we share data with third-party services, we require that they use your information only for the purposes we’ve authorized, and that they protect your personal information at least to the same standards we do.
We also reserve the right to disclose personal information when it is reasonably necessary to connect with other users of our social platform, protect Torrch’s legal rights and property, and to comply with the law or law enforcement. Otherwise, your personal information is never shared with any individual or other organization.
4. Protection of your Personal Information
The information you provide us will improve our ability to help you make connections, communicate, and coordinate with others through our Services. Accordingly, we take the security of your personal information seriously, and follow industry-standard practices to protect the data we collect and process. Torrch has therefore put in place commercially reasonable physical, electronic, and managerial procedures to safeguard and secure the personal information that Torrch collects. Access to personal information will be restricted to our authorized personnel who require the information as part of their duties to make our network function. In addition, access will be limited to only that information that is strictly necessary for the performance of those duties.
Remember, the safety and security of your information also depends on you. You must protect the security and confidentiality of the user name and password for your profile and account. No transmission over the internet is completely secure, so Torrch cannot guarantee its absolute security.
5. Data Transfers
6. European Union Residents
Data protection law in Europe requires a “lawful basis” for collecting and retaining personal information from residents of the European Economic Area. Our lawful bases include:
- Providing you with the services you have requested: We need your personal data to comply with our contractual obligation to provide you with our Services, and assist with any questions you may have. Without your information, it would be impossible to connect you with others with similar interests.
- Consent: we may ask your consent to process, store, and share your personal information as part of our Services.
- Legal compliance: Sometimes the law says we need to collect and use your data.
- Legitimate interests: This is a term in data protection law that allows us to process your personal information if we have a fair reason to use your data, and only if we do so in ways which do not hurt your interests and rights. We sometimes require your data to pursue our legitimate interests in running our business, including for delivering our Services, fraud prevention, quality assurance, and marketing purposes, as long as our use of your data does not materially impact your rights, freedom or interests. This allows us to improve and develop the quality of the online experience we offer all our users.
7. Email Notifications
We try to keep email communications to a minimum, and give you the ability to opt in to any communications regarding networking opportunities, news, or marketing communications we send. For example, we may send you emails relating to opportunities for expanding your social, faith, volunteer, and/or business network. You may also elect to receive certain marketing emails, in accordance with your preferences, and from which you may opt out at any time. If we have sent you a promotional email or mobile device notification, you may send us a return email or mobile device communication asking to be omitted from future communications. You may also opt out by logging into the Site and adjusting your preferences in your account information, or by sending us an email at firstname.lastname@example.org stating your request. This opt out does not apply to information provided to Torrch to create or maintain your membership as part of our Services, service experience, or other communications regarding your registration, correction of data, change of password, or other administrative needs.
We will hold your personal information on our systems for as long as is necessary to perform the relevant processing activity for that information, or as long as is set out in any relevant contract you hold with us. This is a case by case determination that depends on things like the nature of the data, why it is collected, why it is processed, and any relevant legal or operational retention needs. For example, we may retain your data for as long as you maintain an account on our Site. We may also be legally required to hold some types of information to fulfill our statutory obligations. We review our retention periods for personal information on a regular basis. When the relevant processing activity has been completed, we may destroy your data, or alternatively anonymize the data in such a way that you are not personally identifiable, either directly or indirectly.
9. Control of your Information
Members that reside in certain countries, such as the EU, are afforded certain rights regarding their personal information. Except where an exception or exemption applies, these rights may include the ability to access, correct, and/or request deletion of your personal information. While these rights are not globally applicable, our customers are entitled to access the personal information that we hold about them. You can review the personal data you have provided us by accessing your account profile through our Site. To ensure that your personal information is accurate, complete, and up to date, update your account through the Site or mobile app, or contact us through the email address below regarding any errors or updates affecting the personal information that we may hold. To delete your membership or other personal information you’ve provided to us, please log into your account and delete your account from the account settings page.
You may also send us an email at email@example.com to request access to, correct, or delete any personal information that we hold about you. To protect your privacy and security, Torrch may take reasonable steps to verify your identity before granting access to, correcting, or deleting data. We will generally respond to your request for information within thirty (30) days, unless, for reasons beyond our control, a longer response time is necessary, in which case, you will be advised accordingly. Please note that we may retain certain information as required by law or as necessary for our legitimate business purposes.
10. Questions, Comments, or Complaints
Torrch strives to satisfy our members’ privacy concerns. However, if you have contacted Torrch about your issue and are still unhappy with our response, and if you are also a resident of the European Economic Area, subject to applicable law, you may also have the right to object to Torrch’s use of your personal information, and to lodge a complaint with your local data protection authority. More information is available here.
 Note to draft: please let me know if user data will be used in any other way.
 Note to draft: We’ll want to discuss the information to confirm these methods of updating or changing information accurately describes how the new app will work.