Privacy Policy

Privacy Policy | Torq-Comm

Torq-Comm Inc. (referred to as “Company,” “us,” or “we”) recognizes that your privacy is very important.

This Policy discloses the privacy practices for Torq-Comm’s website (the “Site”), as well as related products and services we may offer to you (the “Service”), including our mobile application. This Policy also covers how personal and other information that we receive or collect about you and your clients (“Clients”) is treated. Please read the information below to learn the following regarding your use of this Site and app.

We reserve the right to change this Privacy Policy from time to time. We will notify you about significant changes in the way we treat personal information by sending a notice to the primary email address specified in your account, by placing a prominent notice on our site, and by updating any privacy information on this page. Your continued use of the Site, app, and/or Services available through this Site or app after such modifications will constitute your (a) acknowledgment of the modified Policy; and (b) your agreement to abide and be bound by that Policy.

IMPORTANT: BY USING THE SITE, APP, AND/OR OFFERINGS AVAILABLE ON THIS SITE OR APP, YOU GIVE YOUR CONSENT THAT ALL PERSONAL DATA THAT YOU SUBMIT MAY BE PROCESSED BY US IN THE MANNER AND FOR THE PURPOSES DESCRIBED BELOW. IF YOU DO NOT AGREE TO THESE TERMS AND CONDITIONS, DO NOT USE THE SITE OR APP.

  1. Types of Information We Collect and Their Usage

In order to better provide you with our Service, we collect two primary types of information about our users: Personally Identifiable Information (PII) and Aggregate Information, alongside data collected through specific app permissions.

Personally Identifiable Information (PII): This refers to information that lets us know the specifics of who you are. When you engage in certain activities on this Site or app, such as registering for an account, downloading or purchasing a product or service, submitting content (e.g., via barcode scanning with camera access), recording voice input (via microphone), or sending us feedback, we may ask you to provide certain information about yourself. Examples of PII may include your first and last name, email address, mailing address (including zip code), employer, job title and department, telephone and facsimile numbers, and other identifying information. This data may be collected through camera, audio, or internet permissions and is used to deliver personalized services, with your consent.

Aggregate Information: This refers to information that does not by itself identify a specific individual. We gather certain information based on your interactions with our Site and app, including the Website’s Uniform Resource Locator (URL) you came from, the URL you visit next, your browser type, Internet Protocol (IP) address, and location data (e.g., for Bluetooth operations). This data is compiled and analyzed on both a personal and aggregated basis to improve app performance, diagnose technical issues, and enhance user experience. Aggregate data may also include device state information (e.g., wake lock usage) and vibration feedback metrics.

Permission-Based Data: To enable app functionalities, we collect data through the following permissions:

Camera Data: We use camera access to enable barcode scanning functionality using Google ML Kit, processed locally on your device.

Audio Data: We use microphone access to record audio for voice input features, processed locally with your consent.

Storage Data: We utilize read and write external storage permissions to manage user-generated content, such as files uploaded or saved within the app, stored locally.

Location Data: We collect fine and coarse location data to support Bluetooth Low Energy (BLE) operations and device discovery, with background location access for continuous connectivity, requiring your consent.

Bluetooth Data: We use permissions for Bluetooth classic, scanning, connecting, and advertising to enable device discovery and communication, including BLE features.

Device State Data: We employ wake lock and boot completion permissions to keep the device awake during critical operations and restart services after reboot.

Vibration Data: We use vibrate permission to provide haptic feedback for user interactions.

Internet Data: We use internet access to deliver app updates, sync content, and communicate with our servers.

Foreground Service Data: We use foreground service permissions, including location-based services, for background tasks with user notification.

Exact Alarm Data: On Android 14 or higher, we use exact alarm permission for precise notifications or tasks.

Data Handling: All sensitive data, including PII and permission-based data, is collected only with your explicit consent where required. Data is primarily processed locally on your device. Any transmission to third parties (e.g., service providers) is encrypted and limited to delivering the service. We do not sell or rent your data.

User Control: You can manage permissions and data collection through your device settings. For details on updating or deleting your information, refer to Section 5.

  1. How We Collect and Use Information

Torq-Comm does not collect any PII about you unless you voluntarily provide it to us. However, you may be required to provide certain PII to us when you elect to use certain products or services available on the Site or app. These may include: (a) registering for an account on our Site; (b) uploading individual transaction data obtained from your third-party invoicing or accounting applications (e.g., “QuickBooks,” “Xero,” “Clio”); (c) uploading user-generated content and other information via camera or storage permissions; (d) sending us an email message; (e) submitting a form or transmitting other information by telephone or letter.

We will primarily use your PII to provide product or service offerings to you. We will also use certain forms of PII to enhance the operation of our Site and app, improve our internal marketing and promotional efforts, statistically analyze usage, improve our product and service offerings, and customize our Site’s and app’s content, layout, and services. We may use certain information about you without identifying you as an individual to third parties for purposes such as analyzing how the Service is used, diagnosing service or technical problems, maintaining security, and personalizing content. This may include location and Bluetooth data for device connectivity. We may also use PII to deliver information to you and to contact you regarding administrative notices. Finally, we may use your PII to resolve disputes, troubleshoot problems, and enforce our agreements with you, including our Site Terms of Use and this Privacy Policy.

We may also collect Aggregate Information for our third-party advertising partners. For example, we may use your IP address to diagnose problems with our servers, administer our Site and app, and gather demographic information. Our third-party advertising partners may provide us with aggregate, but not individual, reports on ad impressions and clicks.

  1. Cookies

Depending on how you use our Site, we will store cookies on your computer to collect certain aggregate data about our users and to customize aspects of your user experience. A cookie is a small data text file stored on your computer that uniquely identifies your browser. Cookies may include personalized information, such as your IP address, browser type, server details, area code, zip code, and first name to welcome you back. We use cookies to monitor aggregate usage metrics, store passwords (if allowed), save account and advertising preferences, and personalize Services. We do not use cookies to track your browsing behaviors.

Most browsers accept cookies by default, but you can reset your browser to refuse all cookies or notify you when a cookie is sent. Disabling cookies may affect some Site or app functionalities.

  1. Release of Information

Torq-Comm will not sell, trade, or rent your PII to others. We provide some product and service offerings through contractual arrangements with affiliates, service providers, partners, and other third parties (“Service Partners”). We and our Service Partners may need to use some PII to perform tasks between our respective sites or deliver products/services to you, including data processed via internet or Bluetooth permissions.

We encourage our Service Partners to adopt strong privacy policies. However, their use of your PII is governed by their respective privacy policies and is not under our control. Except as discussed in this Privacy Policy, this document addresses only the use and disclosure of information we collect from you. Other Sites or services accessible through this Site or app, including our Advertising and Service Partners, have their own privacy policies. Please consult each Site’s policy. We are not responsible for third-party policies or practices.

We may be required by law enforcement or judicial authorities to provide PII to governmental authorities. In such cases, we will disclose PII upon receipt of a court order, subpoena, or to cooperate with a law enforcement investigation. We fully cooperate with law enforcement to identify illegal activities and reserve the right to report suspected unlawful activities.

We may provide Aggregate Information about customers’ sales, traffic patterns, and related Site/app information to third-party advertisers, but these statistics do not include PII.

  1. Updating and Correcting Information

We believe you should have the ability to access and edit the PII you have provided. You may change any of your PII in your account online at any time by following instructions posted elsewhere on this Site or app.

We encourage you to promptly update your PII if it changes. You may request deletion or removal of your account information; however, some data (e.g., past transactions, technical support logs) may not be fully deleted due to backups or legal requirements.

  1. User Choices on Collection and Use of Information

We may send you emails about new products and services that may interest you. If you indicated upon registration that you are interested in offers from us or our partners, we may occasionally call or send direct mail about relevant products and services. Only Torq-Comm (or agents under confidentiality agreements) will send these solicitations, and only if you have opted in. To opt-out, edit your account preferences online to stop receiving such offers and mailings.

You can also manage cookies as described in Section 3 by adjusting browser preferences. Rejecting cookies may limit some Site or app features.

  1. Security of Your PII

At our Site and app, your PII is secured consistent with current industry standards. We take appropriate measures to protect against unauthorized access, alteration, disclosure, or destruction of your PII. Examples include:

Ensuring data reliability, accuracy, completeness, and currency, with encryption during transmission.

Limiting access to PII to specific employees, contractors, and agents with a need to know, e.g., technical support for troubleshooting.

Employing physical, electronic, and procedural safeguards, including secure servers with firewalls and high-level password protection.

Providing access to your PII via a password and unique customer ID, both encrypted. Do not share your password.

No data transmission over the Internet or wireless networks is 100% secure. While we strive to protect your PII, you acknowledge inherent security limitations beyond our control. Secure your device as needed.

In case of a security breach compromising PII, Torq-Comm will promptly notify affected persons via email or as required by law. You agree to notify us immediately if a breach on your device affects our Site or Service.

  1. Miscellaneous

You must be at least 18 years old to use this Site or app. By agreeing to this Policy, you confirm you are at least 18. We do not knowingly collect, use, or disclose PII about minors.

Voluntarily disclosing PII (e.g., name, email) in public areas like discussion forums may be collected by third parties, leading to unsolicited messages. This is beyond our control, and this Policy does not apply. See our Site Terms and Conditions for conduct policies.

For questions, concerns, or inquiries about our Privacy Policy, use of PII, or privacy practices, contact us at: info@torq-comm.com. You can also reach our Privacy Compliance Officer by sending written correspondence to:

Torq-Comm Inc.

Email: info@torq-comm.com

Attn: Privacy Compliance Officer

  1. GDPR: European or UK Data Subjects

Our clients use the Torq-Comm software to collect and process personal data of individuals, including those in the EU and/or UK, for managing marketing lists and campaigns.

For GDPR (and UK GDPR) purposes, Torq-Comm acts as a processor of data subjects’ personal data. The controller is either our client or their customers.

We process such data only per our clients’ instructions and comply with our obligations as a processor. A data processing agreement with appropriate safeguards is in place with each client.

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