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General Draft — Please Review Before Publishing
This Privacy Policy is a general template intended to be customized by Torch Kapitmoor with legal counsel to reflect actual data practices, applicable laws, and jurisdiction-specific requirements. It does not constitute legal advice.
1. Introduction
Torch Kapitmoor ("we," "us," or "our") respects your privacy and is committed to protecting the personal information you share with us. This Privacy Policy describes how we collect, use, disclose, and safeguard information when you visit our website, create an account, or use our AI-driven portfolio setup and risk management tools (the "Services"). By accessing or using the Services, you agree to the practices described in this Policy.
2. Information We Collect
We may collect the following categories of information:
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Account Information
Name, email address, phone number, and other details you provide when registering for an account or contacting us.
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Financial and Investment Information
Information related to your investment preferences, risk tolerance, portfolio holdings, and transaction history, provided by you or generated through your use of the Services.
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Technical and Usage Data
IP address, browser type, device identifiers, pages visited, and interaction data collected automatically through cookies and similar technologies.
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Communications
Records of correspondence when you contact us via email, contact forms, or other channels.
3. How We Use Your Information
We use the information we collect to: provide, operate, and maintain the Services; generate and manage AI-driven portfolio recommendations; personalize your experience; communicate with you about your account or inquiries; monitor and improve the security and performance of our platform; comply with applicable legal and regulatory obligations; and detect, prevent, and address fraud or technical issues.
4. Legal Basis for Processing
Where applicable law requires a legal basis for processing personal information, we rely on one or more of the following: your consent, the necessity of processing to perform a contract with you, our legitimate interests in operating and improving the Services, and compliance with legal obligations.
5. Sharing of Information
We do not sell your personal information. We may share information in the following circumstances:
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Service Providers
With third-party vendors who perform functions on our behalf, such as hosting, analytics, and customer support, subject to confidentiality obligations.
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Legal and Regulatory Requirements
Where required to comply with applicable law, respond to lawful requests, or protect our rights, property, or safety.
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Business Transfers
In connection with a merger, acquisition, reorganization, or sale of assets, subject to appropriate confidentiality safeguards.
6. Cookies and Tracking Technologies
We use cookies and similar technologies to operate our website, remember preferences, and analyze usage patterns. You can control cookie settings through your browser; disabling certain cookies may affect the functionality of the Services.
7. Data Retention
We retain personal information for as long as necessary to provide the Services, comply with legal obligations, resolve disputes, and enforce our agreements. Retention periods vary depending on the type of information and applicable regulatory requirements.
8. Data Security
We implement reasonable administrative, technical, and physical safeguards designed to protect personal information from unauthorized access, disclosure, alteration, or destruction. However, no method of transmission or storage is completely secure, and we cannot guarantee absolute security.
9. Your Rights and Choices
Depending on your jurisdiction, you may have the right to access, correct, delete, or restrict the processing of your personal information, as well as the right to data portability and to withdraw consent where processing is based on consent. To exercise these rights, please contact us using the details on our Contact page.
10. International Data Transfers
Your information may be processed and stored in countries other than your own. Where required, we take steps intended to ensure that such transfers comply with applicable data protection laws.
11. Children's Privacy
Our Services are not directed to individuals under the age of 18. We do not knowingly collect personal information from minors. If you believe a minor has provided us with personal information, please contact us so we can take appropriate action.
12. Third-Party Links
Our website and Services may contain links to third-party sites. This Privacy Policy does not apply to those sites, and we encourage you to review the privacy policies of any third-party services you access.
13. Changes to This Policy
We may update this Privacy Policy from time to time to reflect changes in our practices or applicable law. We will post the revised policy on this page and update the effective date. Your continued use of the Services after changes take effect constitutes acceptance of the revised Policy.
14. Contact Us
If you have questions or concerns about this Privacy Policy or our data practices, please reach out via the details provided on our Contact page.