Privacy policy

Last updated 14 January 2025.

This is the privacy and cookies policy of Torc Contracts Ltd, a company registered in England and Wales under company number 14341342 with its registered office at Studio 158, The Light Box, 111 Power Road, London, England, W4 5PY. We are the controller of your personal data.

This policy outlines the personal data we collect about you and your rights regarding this data, such as when you visit our digital platform, visit our website at www.torccontracts.com, complete a contact form on our website, contact us with any enquiry by email, phone or via social media, purchase goods and services from us, or otherwise engage with us.

Our website and platform may contain links to third-party websites not covered by this policy. Therefore, we ask that you review the privacy statements of other websites and applications to understand their information practices.

Information about us

We respect your right to privacy and will only process your personal data in accordance with applicable data protection laws. We comply with the EU law retained version of the General Data Protection Regulation (2016/679) and the UK Data Protection Act 2018 (the “Data Protection Legislation”). If any of these laws are replaced or superseded, we will also comply with those.

We are registered with the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (ico.org.uk), and our registration number is ZB848723. If you have any concerns about data protection, we would appreciate if you contacted us first so we can discuss these with you before you approach the ICO. For data protection matters, please email us at info@torccontracts.com.

What we may collect

Personal data, or personal information, is any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). We may collect, use, store and transfer different kinds of personal data about you when you engage with us. We must have a legal ground (lawful basis) whenever we collect your data.

Type of data

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

• Identity Data includes your full name, marital status, title, date of birth, gender, job title, employer.
• Contact Data includes home address, work address, billing address, email address and telephone number.
• Financial Data includes bank account and payment card details.
• Transaction Data includes details about payments to and from you and other details of the services you have purchased from us.
• Technical Data includes internet protocol (IP) address, your login data, time of access, 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 our website.
• Profile Data includes your username and password (if applicable), purchases or orders made by you, your interests, preferences, feedback, and survey responses.
• Usage Data includes information about how you use our website and services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
• Aggregated Data such as statistical or demographic data for any purpose, is not considered personal data in law as this data will not directly or indirectly reveal your identity to us. We may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature.
• Special Category Data means special categories of personal data and includes information about your health, race or ethnicity, criminal convictions, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, genetic and biometric data. Please note that we do not automatically include any such data.

How is your personal data collected

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

• Direct interactions. You may give us your Identity Data and Contact Data by filling in forms or by corresponding or engaging with us by post, phone, email, social media or otherwise.
• Automated technologies or interactions. As you interact with our website and platform, we will 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 including third-party website tracking technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.
• Public sources. We may collect personal data about you from public sources, such as Google, Companies House, or the electoral register.

How we will use your personal data

We will only use your personal data when we can rely on a legitimate (lawful) basis, such as:

• Contract: Where we need to perform the contract, we are about to enter into or have entered into with you.
• Legitimate Interests: 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.
• Legal Obligation: Where we need to comply with a legal obligation.
• Consent: We rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose, for example if you subscribe to an email newsletter.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use the various categories of your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Direct marketing

You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving the marketing.

We may also analyse your Identity Data, Contact Data, Technical Data, Usage Data and Profile Data to form a view which products, services and offers may be of interest to you so that we can then send you relevant marketing communications.

Third party marketing

We will get your express consent before we share your personal data with any third party for their own direct marketing purposes.

Opting out of marketing

You can ask to stop sending you marketing communications at any time by following the opt-out links within any marketing communication sent to you or by contacting us at info@torccontracts.com.

If you opt out of receiving marketing communications, you will still receive service-related communications that are essential for administrative or customer service purposes for example relating to updates

Cookies

Like many websites, we use cookies to enhance your experience and gather information about visitors to our website and platform. Please refer to the “Information on cookies” section below for information about cookies, how we use them, and what kind. Cookies are small text files placed on your device when you visit our platform and are used to make the users’ experience more efficient. The lawful basis is that we must perform our contract with you (i.e. to give you access to our website’s and platform’s service).

We also need this information to study how you use our website and platform, improve and develop our services, and better inform our marketing strategies.

Analytics

Includes third-party analytics services (such as Google Analytics) to evaluate your use of our website and  platform, compile reports on activity, collect demographic data, analyse performance metrics, and collect and evaluate other information relating to the website, platform and internet usage. These third parties use cookies and other technologies to help analyse and provide us with the data. By accessing and using the platform, you consent to these analytics providers processing data about you in the manner and for the purposes set out in this policy. The purpose is to enable direct marketing.

The lawful basis is that our legitimate interest must present relevant content, products, and services to you.

When you interact with our website and platform – Information on cookies 

We use cookies to the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003 and the Data Protection Legislation 2018.

Cookies are small text files placed on your device when you visit our website and platform. They improve the users’ experience. We can store cookies on your computer where necessary for the website’s and platform’s operation; however, we need your permission to store non-essential cookies.

We use cookies to distinguish users and improve our website and platform. We analyse how you use our website and platform and look at aggregate statistics about your usage and how others use it. These cookies collect certain information, including your IP address, the location where you access our website and platform, the date and time you access our platform, the language you use, and the type of browser you use.

We do not track individual users or use cookies to identify individuals. Instead, we use cookies to recognise you and your preferences, improve our website’s and platform’s performance, and collect analytical information for ourselves and our business partners. We need the knowledge gained to provide the service we provide.

These are the types of cookies we use, which are categorised by the role they fulfil on our website and platform:

• Strictly necessary cookies. These are cookies that are required for the operation of our website and platform.
• Analytical or performance cookies. These cookies allow us to recognise 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.
• Functionality cookies. These cookies are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
• 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 so that they can serve you with relevant advertising on their websites.
• Session cookies. These cookies allow us to track your actions during a single browsing session, but they do not remain on your device afterwards.
• Comment These cookies are used to remember your details (such as name, email address, and website URL) when you leave a comment on our website. This allows you to post additional comments without re-entering your information each time. These cookies are designed to enhance convenience and may remain on your device for a set period.

None of the cookies employed are classified as Behavioural Targeting.

Session cookies and persistent cookies can be first-party or third-party cookies. Persistent cookies are cookies that remain on your device for a set period or until you delete them manually. These cookies are used to enhance your browsing experience by remembering your preferences and actions across multiple visits to our website. For example, they may be used to store your language settings, login information, or preferences for personalised content. Persistent cookies can belong to any of the cookie categories outlined above, depending on their purpose.

The visited website sets a first-party cookie, while a different website sets a third-party cookie. We or our business partners may use both types of cookies.

There are other types of cookies that are classified as Behavioural Targeting.

• Analytical or performance cookies. These cookies allow us to recognise 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.
• 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 so that they can serve you with relevant advertising on their websites.

The third-party cookies we use are:

• Google Analytics. Google Analytics is a web analytics service provided by Google, Inc. Its cookies help us analyse user usage of our website and platform and count the number of people who use it. Google Analytics stores your IP address anonymously and does not associate it with any personally identifiable information.
• WordPress cookies are used to support the functionality of our website, such as remembering your login details, managing your session, or saving your preferences. These cookies may also be used for administrative purposes, such as maintaining security and preventing fraudulent use of the website and platform.
• LinkedIn cookies are used to enable social sharing features and to analyse how our content is shared on LinkedIn. They may also track user behaviour for advertising purposes, allowing us to provide more relevant content to visitors who access our website and platform fvia LinkedIn.
• Yoast cookies are used to optimise the content and functionality of our website and platform. These cookies support search engine optimisation (SEO) and help us analyse the readability and performance of our web pages to ensure they meet user expectations.

We will always ask for your consent to use non-essential cookies. You are free to withhold consent, but we may not be able to provide you with the whole website experience, including some video advertising elements.

If you wish to turn off cookies at any time, you may do so through your browser’s settings or whenever the pop-up appears on our website and platform (each time you access our website and platform).

Information about how to configure your browser to block cookies can be found at:

• Google Chrome
• Microsoft Edge
• Internet Explorer
• Firefox
• Safari
• Safari Mobile
• Opera

How we store and secure your data your personal data

Our website and cloud storage is hosted by Hostinger, where data is stored on cloud servers located in various data centres worldwide. The available server locations include:

• Europe: France, Germany, Lithuania, the United Kingdom
• Asia: India, Indonesia
• North America: the USA
• South America: Brazil

Data security is of great importance to us, and to protect your data, we have put in place suitable physical, electronic, and managerial procedures to safeguard and secure data collected through our website and platform. In addition, we limit access to your data to those employees, agents, contractors and other third parties who need to know. They will only process your data on our instructions and are subject to a duty of confidentiality.

If there is an incident where we become aware that there has been a data breach, we will let you know without undue delay. We will then take all necessary steps, including informing the ICO, to limit the extent of the breach and to prevent a further recurrence.

Where we have given you (or where you have chosen) a password which enables you to access certain parts of our website, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your information transmitted to our website; any transmission is at your own risk.

International transfers

We may transfer your collected data to storage outside the European Economic Area (EEA) or the United Kingdom, or where we engage third-parties to provide services on our behalf. It may be processed outside the EEA or the United Kingdom so that you may receive the services our website and platform provide. Suppose we store or transfer data outside the EEA or the United Kingdom. We ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data
• We may use specific standard contractual terms approved for use in the UK which give the transferred personal data the same protection as it has in the UK, namely the International Data Transfer Addendum to the European Commission’s standard contractual clauses for international data transfers.

We regularly review our data retention obligations to ensure we retain data for only what we are legally obliged to. Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK or the EEA.

Data retention

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

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 unauthorised 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, regulatory, tax, accounting or other requirements.

By law we have to 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 the section headed ‘Your rights’ below for further information).

In some circumstances we will anonymise 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 rights 

You have a number of rights under data protection laws in relation to your personal data. You have the right to:

• Request access to your personal data (commonly known as a “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 the personal data that we hold about you. 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 in certain circumstances. 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, if applicable, at the time of your request.
• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third-party) as the legal basis for that particular use of your data (including carrying out profiling based on our legitimate interests). In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your right to object.
• You also have the absolute right to object any time to the processing of your personal data for direct marketing purposes (see ‘Opting out of marketing’ in for details of how to object to receiving direct marketing communications).
• Request the transfer of your personal data to you or to a third-party. We will provide to you, or a third-party you have chosen, 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.
• Withdraw consent at any time where we are relying on consent to process your personal data (see the table in the section headed ‘Purposes for which we will use your personal data’ for details of when we rely on your consent as the legal basis for using your 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.
• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in one of the following scenarios:
  • If you want us to establish the data’s accuracy;
  • Where our use of the data is unlawful but you do not want us to erase it;
  • 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
  • You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

If you wish to exercise any of the rights set out above, please contact us at info@torccontracts.com.

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. Alternatively, we could refuse to comply with your request in these circumstances.

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 could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

What happens when we link to other websites?

This policy only applies to our website and platform. Our website and platform might contain links to other websites with their terms and conditions and privacy policies. You should check these policies before providing your data to those websites.

Please note that our terms, conditions, and policies do not apply to other websites you can access via a link from our website and platform. We have no control over how other websites collect, store, or use your data, and we advise you to check the privacy policies of any such websites before providing any data to them.

The changes we may make to this policy

We can update this policy from time to time as laws change or as our website and platform change. If we make material changes to this policy and need your consent, we will contact you by email.