privacy policy

Revised: October 3, 2018

The purpose of this Privacy Policy is to describe how Torque LLC and its affiliates (“Torque”) may collect, use, store, disclose and process (“process”) your information, through your access to or use of the Torque mobile applications, websites, including the site at https://www.thetorqueapp.com/, related content, and other vehicle related services, including those that facilitate the scheduling of vehicle test drives and vehicle maintenance and repair, as well as the related transportation and purchase and sale of goods, and any other Torque services or websites that link to this Privacy Policy (collectively, the “Services”).

Your privacy is important to us. Torque encourages you to read this Privacy Policy in its entirety, but here are a few key points of our privacy practices:

HOW TORQUE COLLECTS AND USES INFORMATION

When you use the Services, Torque collects certain information about you, such as your name, physical address, property description, your location and travel details, email address, telephone number, password, device information, and other personal information. You may further provide Torque messages, media and other content through the Services. Torque may also use cookies and similar technologies to collect information about your activities on the Services. Torque will process this information to provide you the Services, to communicate directly with you (including advertising), to conduct research and for other purposes to which you consent.

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How Torque May Share Your Information

Torque may share information about you with its affiliates, third-party business associates and service providers to help Torque provide the Services.

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How Torque Stores and Protects Your Information

Torque will retain your information as long as necessary for the purposes outlined in this Privacy Policy. Torque takes technological and operational measures to protect the information you provide through the Services against loss, theft and unauthorized access, use, disclosure or modification.

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YOUR rights over YOUR INFORMATION

You may access and modify your personal data through the settings menu on the Services. You may contact privacy@TheTorqueApp.com for additional assistance with your personal data.

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Additional privacy information

Torque is located and will process your information in the United States. The Services are not for use by children under the age of 13 years old. Torque may update this policy from time to time, and you may contact Torque via the information below.

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1. General

(a) Consent. By accessing or using the Services, you consent to the processing of your information in accordance with: (i) this Privacy Policy; (ii) any related terms of use or services subscription agreement; (“Services Terms”) and (iii) as permitted or required by applicable law.

(b) Interpretation. For the purposes of this Privacy Policy, the words “such as,” “include,” “includes” and “including” shall be deemed to be followed by the words “without limitation.”

2. HOW TORQUE COLLECTs AND USEs INFORMATION

(a) Information That You Provide Directly. Torque may ask for or you may provide certain information such as your name, physical address, property description, copies of your driver’s license, insurance card, and vehicle registration, your location and travel details as determined through GPS, IP address and Wi-Fi indicators, email address, telephone number, password, and other information. Torque may retain any such information, as well as messages, media (e.g., photos and video), and other content that you send through the Services or that you otherwise provide to Torque, including via telephone, website chat, and email. Torque processes this information to operate, maintain, improve, and provide the features and functions of the Services, and as further described below.

(b) Information Collected or Received from Third Parties. Torque also may receive information about you from third parties. You should always review and, if necessary, adjust your privacy settings on third-party services before linking or connecting them to the Services. Torque may also collect information about you from Torque’s third-party business associates (e.g., motor vehicle dealerships), publicly-available sources, and Torque’s affiliates.

(c) Analytics information. Torque may collect, measure and analyze traffic and usage trends for the Services, and Torque may use third-party analytics tools, including Google Analytics and other cloud-based tools, to help Torque for such purposes (“Analytics Tools”). This allows Torque to understand, among other things, who is using the Services, how they are using it, and ways to improve the Services. Analytics Tools may use cookies and persistent device identifiers to collect and store information about you, such as time of visit, pages visited, time spent on each page, IP address, location, and type of operating system used. You can learn more about Google Analytics and your options for opting out of interest-based Google ads at https://adssettings.google.com.

(d) Cookies and other Tracking Technologies. When you access or use the Services, Torque may send one or more cookies (small text files containing a string of alphanumeric characters) to your computer that uniquely identify your browser and enhance your navigation within the Services. A cookie may also convey information to Torque about how you use the Services (such as the pages you view, the links you click and other actions you take), and allow Torque or Torque’s third-party business associates to track your usage of the Services. Torque uses at least two different types of cookies: persistent and session cookies. A persistent cookie remains on your device after you close your browser. Persistent cookies may be used by your browser on subsequent visits to the Services. Persistent cookies can be removed by following your web browser’s directions for removal of cookies. A session cookie is temporary and is deleted after you close your browser. You can reset your web browser to refuse all cookies or to notify you when a cookie is being sent; however, some features of the Services may not function properly if cookies are disabled.

(e) Log File. Log file information is automatically reported by your browser each time you access a web page. When you access or use the Services, Torque’s servers may automatically record certain log file information, such as your web request, internet protocol (IP) address, browser type, referring/exit pages and URLs, number of clicks and how you interact with links within the Services, domain names, landing pages and pages viewed.

(f) Clear GIFs/Web Beacons. Clear GIFs (also known as web beacons) allow for the tracking of a user’s response to an email or usage of a website in a manner that does not reveal personally-identifiable information. Torque may use clear GIFs or similar technologies to assess responses to emails and usage of the Services, such as tracking when emails are opened and which links are clicked by recipients. You can disable the ability of clear GIFs to capture information by blocking cookies.

(g) Device Identifiers. When you access or use the Services using a mobile device, Torque may access, collect, monitor and remotely store one or more “device identifiers,” such as a universally unique identifier (UUID) on your device. Device identifiers are small data files or similar data structures stored on or associated with your device that uniquely identify your device. A device identifier may consist of data stored in connection with the device hardware, operating system or other software, or data sent to the device by Torque. A device identifier may convey information to Torque about how you browse and use the Services. A device identifier may remain persistently on your device to enhance your navigation within the Services. Some features of the Services may not function properly if use or availability of device identifiers is impaired or disabled.

(h) Advertising Identifiers. Advertising identifiers are unique strings associated with your mobile device that are provided by the operating system. Advertising identifiers may be modified or disabled by users in the device operating system’s settings.

(i) Location Data. When you access or use the Services, Torque may access, collect, monitor and remotely store “location data,” which may include GPS coordinates (such as latitude and/or longitude) or similar information regarding the location of your device. Location data may convey to Torque information about how you browse and use the Services, where you traveled for vehicle services or test drives, and the duration of your travel. Some features of the Services, particularly location-based services, may not function properly if use or availability of location data is impaired or disabled.

(j) Commercial Communications. Torque may use the information Torque collects or receives to communicate directly with you, such as sending you SMS and emails containing newsletters, promotions and special offers. Torque may also use the information to send you service-related notices (such as account verification, services reminders and status updates, and technical and security notices).

(k) Use of Certain Services-Type Data. Torque may process the information described in this Section 2 to: (i) remember information so that you will not have to re-enter it during your visit or the next time you visit the Services; (ii) provide custom, personalized content or information; (iii) monitor and improve the effectiveness of the Services; (iv) monitor aggregate metrics, such as total number of visitors, traffic and demographic and transportation patterns; (v) diagnose or fix technology problems; (vi) provide advertising to your browser or device; and (vii) conduct research or surveys.

(l) Use of Information with Your Consent. Torque may further process your information for any other purpose for which you provide consent.

(m) Account Login. If you have an account with the Services and log in while you access or use the Services, the information described in this Section 2 may be collected and maintained in a manner that associates such information with your name or contact information.

(n) Combining Information. Torque may combine any of the information that Torque collects from or about you, from one or multiple sources, and process it in the manner described in this Privacy Policy.

3. How Torque May Share Your Information

(a) Business Associates and Services Providers. Torque may share information about you with third-party business associates and service providers that perform services on Torque’s behalf in connection with the Services, including motor vehicle sellers and service providers, and consumers of products and services from such sellers and providers. Torque may also share information about you with any of Torque’s affiliates for purposes consistent with this Privacy Policy and the Services Terms.

(b) Business Change. If Torque becomes involved in a merger, consolidation, acquisition, sale of assets, joint venture, securities offering, bankruptcy, reorganization, liquidation, dissolution or other transaction, or if the ownership of all or substantially all of Torque’s business otherwise changes, Torque may share or transfer your information to third parties in connection with such transaction or change in ownership, including as part of the due diligence process conducted by the parties to a potential transaction.

(c) Necessary Disclosure: Regardless of the choices you make concerning your information and to the extent permitted or required by applicable law, Torque may disclose information about you to third parties to: (i) enforce or apply this Privacy Policy or the Services Terms; (ii) comply with laws, subpoenas, warrants, court orders, legal processes or requests of government or law enforcement officials; (iii) protect Torque’s rights, reputation, safety or property, or that of Torque’s users, consumers, business associates, or others; (iv) protect against legal liability; (v) establish or exercise Torque’s rights to defend against legal claims; or (vi) investigate, prevent or take action regarding known or suspected illegal activities; fraud; violation of the Services Terms; or as otherwise required by law.

(d) Sharing Information. Torque may share certain service-type information, including information obtained through tools such as cookies, log files, device identifiers, location data and clear GIFs (such as anonymous usage data, referring/exit pages and URLs, platform types, number of clicks) with Torque’s third-party business associates for the purposes described in Section 2. Torque may also aggregate or otherwise remove all personally-identifying characteristics from your information and share that aggregated, de-identified data with third parties.

4. How Torque Stores and Protects Your Information

(a) Personal data collected by Torque may be stored and processed in your region, in the United States, and in any other country where Torque or its service providers operate facilities. Torque will retain your data as long as necessary for the purposes outlined in this Privacy Policy and for a commercially reasonable time thereafter for backup, archival, fraud prevention or detection or audit purposes, or as otherwise required by law.

(b) Torque takes technological and organizational measures to protect the information you provide through the Services against loss, theft, and unauthorized access, use, disclosure or modification. Torque encrypts your information and complies with applicable data protection laws, including applicable data breach notification laws, to protect your information. However, Torque cannot ensure or warrant the security of any information you transmit to Torque or guarantee that information within the Services will not be accessed, disclosed, altered or destroyed. Communications sent to or from the Services may not be secure. You should use caution whenever submitting information online and take special care in deciding what information you send to Torque via email.

5. YOUR rights over YOUR INFORMATION

(a) Accessing and Managing Your Personal Data. You may access and modify your personal data through the settings menu on the Services. To delete, download or restrict use of your personal data, or for any additional assistance or inquiry regarding such data, please contact privacy@TheTorqueApp.com. To help protect your privacy and maintain security, Torque may take steps to verify your identity before granting you access to the personal data. To the extent permitted by applicable law, a charge may apply before Torque provides you with a copy of any personal data that it maintains about you.

(b) Controlling Your Settings. You can manage settings through the settings menu on the Services. You can limit your browser or mobile device from providing certain information by adjusting the settings in the browser, operating system or device. Please consult the documentation for the applicable browser, operating system or device for the controls available to you. You can also stop receiving promotional emails from Torque by following the unsubscribe instructions in those emails. Note that unsubscribe is not available for certain emails, such as those concerning your relationship or dealings with Torque and those necessary to provide the Services.

(c) Targeted Advertising. You can learn more about targeted ads and your choices to prevent third parties from delivering targeted ads to your browser or device by visiting http://optout.networkadvertising.org/ and http://optout.aboutads.info/. You should be aware that even if you opt out of targeted ads, you may still see ads within the Services, although the ads may not be tailored to your interests.

(d) Do Not Track. At this time, Torque does not recognize “do not track” signals sent from web browsers. Third-party services that Torque uses may collect personal information about individual users and their activities over time and across different websites. In some cases, you may be able to disable tracking mechanisms, but doing so may disable certain features of the Services. To disable tracking, please consult the documentation for your browser, operating system or device. For some devices, it may not be possible to disable tracking mechanisms. Section 2 of this Privacy Policy provides more detail on how Torque uses cookies and similar technologies.

6. Additional privacy information

(a) Data Transfer. The Services may be hosted or operated in countries other than the country in which you reside. Those countries may have different data protection laws and regulations from those that apply in your home country and you are solely responsible for complying with such laws and regulations. By accessing or using the Services, you authorize Torque to process and transfer your data in the United States and in any other country where it operates. Please be aware that the governments, courts, and law enforcement, security or agencies of a particular jurisdiction may be able to obtain access to or disclosure of your information as permitted by the laws of that jurisdiction.

(b) Children’s Privacy. The Services are not directed to children and is intended for use by adults only. Torque does not knowingly collect personal information from individuals under 13 years of age. If you are under the age of 18, you may not use the Services or submit any personal information through the Services.

(c) Third-Party Services and Services. The Services may reference or provide links to other websites or resources. If you access any website or resources provided by a third party, this Privacy Policy will not apply. Your interactions with such websites and resources are subject to the privacy policies of the third parties that operate them. Please review those policies carefully to understand how those parties will treat your information.

(d) Updates to this Privacy Policy. Torque may update this Privacy Policy from time to time, and the updated version of this Privacy Policy will be effective upon posting. Please check this page to review the most up-to-date version of this Privacy Policy. By continuing to use the Services after an updated version has been posted, you agree that the new policy will apply to you.

(e) How to Contact Us. You can e-mail us at privacy@TheTorqueApp.com or write to us at Torque LLC, Attn: Raj Jangareddy, 700 Lavaca Street, Suite 1401, Austin, TX 78701.

Click to download a copy of this Privacy Policy