Privacy Policy

Privacy Notice

We respect your privacy and are committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data and how the law protects you.

Important information and who we are

Purpose of this privacy notice

This privacy notice aims to give you information on how we collect and process your personal data. It is important that you read this privacy notice together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your personal data.

Third-party links

Our website may include links to third-party websites, plug-ins, and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed. This is known as anonymous data. Anonymous data is outside the scope of data protection laws.

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together:

• Identity data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
• Contact data includes billing address, delivery address, email address and telephone numbers.
• Financial data includes bank account and payment card details.
• Transaction data includes details about payments to and from you and other details of services you have purchased from us.
• Technical data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
• Profile data includes your username and password, your interests, preferences, feedback, and survey responses.
• Usage data includes information about how you use our website, products and services.
• Marketing and communications data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use, and share aggregated data such as statistical or demographic data for any purpose. Aggregated data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

How is your personal data collected?

We use different methods to collect data from and about you through:

• Direct interactions. You may give us your identity, contact and financial data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you: apply for our services, create an account on our website, subscribe to our service or newsletters, request marketing to be sent to you, or enter a competition, promotion, or survey.
• Automated technologies or interactions. As you interact with our website, we may automatically collect technical data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive technical data about you if you visit other websites employing our cookies.
• Third parties or publicly available sources. We may find your contact details on publicly available sources, such as public registers, networking sites, or your corporate website. We may receive personal data about you from various third parties and public sources. For example, search information providers such as Google based outside the EU, or public registers such as Companies House and LinkedIn.

How we use your personal data: our purpose and lawful bases

We will use your personal data in the following circumstances:

• Where we need to perform a contract or to take steps prior to entering a contract with you.
• Where it is necessary for our legitimate interests or those of a third party, and your interests and fundamental rights do not override those interests. Our legitimate interest will include, for example, market research purposes, marketing purposes, business development, and technical measures to ensure our services are running effectively in particular, but not limited to, unauthorised access and use. You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
• Where we need to comply with a legal or regulatory obligation.

You will receive marketing communications from us if you have requested information from us or purchased our services or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have opted in to receive marketing communications.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any company outside Torchlight AI for marketing purposes.

Opting out

You can ask us or third parties which we may use from time to time, to stop sending you marketing messages at any time by clicking on the relevant link on any marketing communications we send you.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.  If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Cookies and other technologies:

Information about our cookies

Cookies are small text files stored on your device when you access most websites on the internet or open certain emails. Among other things, cookies allow a website to recognize your device and remember if you have been to the website before. We use the term cookie to refer to cookies and technologies that perform a similar function to cookies (e.g. tags, pixels, and web beacons).

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and allows us to improve our site. By continuing to browse the site, you are agreeing to our use of cookies.

Our online use of cookies

Cookies on the website are used for many purposes including but not limited to:

• Where applicable, enabling a subscriber to register on the site to be verified and to have such details remembered for later by utilizing a subscriber login to access Torchlight services.
• Where applicable, enabling a subscriber to use the Torchlight services via the site.
• Recognizing your computer when you visit the site.
• Improving the site and the site’s usability.
• Analyzing the use of the Torchlight services.
• Administrating the site.
• Preventing fraud and improving the security of the site.
• Analyzing the use of the services through analytics software such as Google Analytics.
• Providing regulatory news that uses a third-party site and a cookie plug in Brighter IR.

We use Google Analytics, a popular web analytics service provided by Google. Google Analytics are used to collect information about how visitors use our site. We use the information to compile reports and to help us improve the site. The cookies collect information in an anonymous form, including the number of visitors to the site, where visitors have come to the site from and the pages they visited. If you would like more information about the privacy policy of the Google Analytics service, please click here. If you would like to opt out of being tracked by Google Analytics you can use the opt-out tool at: http://tools.google.com/dlpage/gaoptout.

We use the following cookies:

Strictly necessary cookies. These cookies are essential, as they enable a user to move around a website and use its features, such as accessing secure areas. Without these cookies, access to secure areas cannot be provided. These cannot be restricted or blocked.

Analytical/performance cookies. These cookies allow us to recognize and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily. These cookies don’t collect information that identifies you. All the information that these cookies collect is anonymous and is only used to improve how a website works. These can be restricted or blocked.

Functionality cookies. These are used to recognize you when you return to our website. This enables us to personalize our content for you, greet you by name and remember your preferences. These can be restricted or blocked.

Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose. These can be restricted or blocked.

To give you a better experience, we use first-party cookies and third-party cookies. A first-party cookie is a cookie that we set when you directly visit our website. A third-party cookie is one that is placed on your device by a website from an address not directly from us. We have no control over these cookies from third parties. Please refer to these third-party websites for their respective cookie policies.

Most web browsers allow some control of most cookies through the browser settings. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.allaboutcookies.org.

To opt out of being tracked by Google Analytics across all websites visit http://tools.google.com/dlpage/gaoptout.

Potential candidates for employment

We are delighted to hear that you would like to work with us. Get in touch with us at info@torchlight.ai for further information on how we specifically use your personal data for recruitment purposes.

Disclosures of your personal data (sharing)

We may have to share your personal data with third parties for example:

• Service providers acting as controllers or processors based inside or outside the European Economic Area (EEA) who provide IT and systems administration services and support to us.
• Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers who are based within the EEA who provide consultancy, banking, legal, insurance and accounting services.
• Regulators and other public authorities acting as processors or joint controllers who are based inside or outside the EEA.
• Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

International transfers

Some of our external third parties for example, cloud storage providers or our administrative management systems providers, will be based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented.

• We will transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
• We will use Standard Contractual Clauses (SCC) established by the European Commission or its equivalent approved by the European Commission. Please contact us should you require further information of our use of SCC.
• Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and US. If the US provider is not part of the US Privacy Shield program, we will use SCC established by the European Commission.

Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

By law we must keep basic information about our customers including contact, identity, financial and transaction data for six years after they cease being customers for tax purposes. In some circumstances you can ask us to delete your data: see “Request erasure” below for further information.

In some circumstances we may anonymize your personal data so that it can no longer be associated with you for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

Your data protection rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. You can:

• Request access to your personal data. This is commonly known as a “data subject access request”. This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of your personal data. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you.
• Object to processing of your personal data. For example, where we are relying on a legitimate interest or those of a third party and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
• Request restriction of processing your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
• Request transfer of your personal data (data portability). We will provide you, or a third party you have chosen, with your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Exercise the right to withdraw consent – where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

What we need from you

You will not have to pay a fee to access your personal data or to exercise any of the other rights. However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data or to exercise any of your other rights. This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made several requests. In this case, we will notify you and keep you updated.

If you wish to exercise any of the rights set out above, please contact us.

Right to complain

We want you to be happy with us. Naturally, if you have any concerns, we would like the chance to deal with them first. Please contact us in the first instance by emailing to info@torchlight.ai. However, you shall have the right to lodge a complaint with a supervisory authority in your place of habitual residence, place of work or place of the alleged infringement. For the UK the supervisory authority this is the Information Commissioner’s Office (ICO). The ICO can be contacted on 0303 123 1113. Alternatively, you can contact them at https://ico.org.uk/concerns/.

Changes to the privacy notice and your duty to inform us of changes

Where we make changes to our privacy notice we shall let you know. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

This version was last updated in August 2021.