3. Consent and Modification
4. What Personal Information We Collect and How We Collect It
We do not currently require you to provide Personal Information in order to have access to general information available on the Website. However, we may receive and/or collect Personal Information from you in the following ways:
In order to use certain services that we offer via the Website, you may be required to create an account (“Account”). We may offer different options to create an Account, including:
a. Online Registration Form
You may choose to complete and submit an online registration form. You will be asked to provide us with certain mandatory information such as your name and email address, and also a password that you will use for your Account. You may choose to provide optional information such as your age, gender and any additional information that may relate to your investment portfolio.
b. Third Party Accounts
You may choose to create an Account by clicking on a ‘connect’ or ‘sign-in’ button that we may display on the Website for a designated third party website or service (each a “Third Party Account”), such as Facebook or Gmail.
Doing so will enable you to link your Account and your Third-Party Account. If you choose this option, then you will be required to Approve the connection as well as the types of information (which may include Personal Information) that we will obtain from your Third-Party Account and the types of activities that we may perform in connection with your Third-Party Account. Please note that in order to use this option, you will need to have, and may need to be signed-in to, an existing Third-Party Account.
Regardless of which method you choose to register your Account, we may send an email to your nominated email address to instruct you on how to confirm your registration.
4.2. ‘Contact Us’ Information
If you send us a “Contact Us” request, whether by submitting a form that we make available on the Website or by sending an email to an email address that we display, you may be required to provide us with certain information such as your name and email address.
4.3. Share with Friends Service
The Website may enable you to invite your friends to use our Website by sending them an invitation email or message. You may do so by: (i) using the Website to send or post an invitation message via your Third Party Account; and/or (ii) using the Website to send an invitation email to your friend’s external email address (for example, a Gmail address). If you send or post an invitation message we may collect Personal Information about the recipient such as their email address.
4.4. Log Files
We may make use of log files. The information inside the log files includes internet protocol (IP) addresses, Internet Service Provider (ISP), date/time stamp, referring/exit pages, clicked pages, and any other information your browser may send to us. We may use such information to analyze trends, track users’ movement around the Website, and gather demographic information.
4.5. Cookies and Other Tracking Technologies
Our Website may utilize “cookies”, anonymous identifiers, and other tracking technologies in order for us to provide our Website and present you with information and test results that are customized for you. A “cookie” is a small text file that may be used, for example, to collect information about activity on the Website or on your device. Certain cookies and other technologies may serve to recall Personal Information, such as an IP address, previously indicated by a user. Most browsers allow you to control cookies, including whether or not to accept them and how to remove them. You may set most browsers to notify you if you receive a cookie, or you may choose to block cookies with your browser.
4.6. Google Analytics
4.8. Facebook Pixels and SDKs
We reserve the right to remove or add new analytic tools.
5. The Way We Use Personal Information
If you submit or we collect Personal Information through the Website, then we may use such Personal Information in the following ways:
To provide, maintain and improve our Website.
To send you marketing/advertisement communications that we believe may be of interest to you.
To contact you in connection with the Website and certain programs or offerings that you may have registered for, and to identify and authenticate your access to the parts of the Website that you are authorized to access.
We may use your designated email address to (i) send you updates or news regarding the Website and our products; and/or (ii) respond to a “Contact Us” or administrative request (for example, to change your password).
If you choose to send your friend an invitation email or message we will use the contact information that you provide, or make available, to automatically send your friend an invitation email or message. Your name and email address may be included in the invitation email or message.
We may disclose your Personal Information or any information you submitted via the Website if we have a good faith belief that disclosure of such information is helpful or reasonably necessary to: (i) comply with any applicable law, regulation, legal process, or governmental request; (ii) enforce our Terms, including investigations of potential violations thereof; (iii) detect, prevent, or otherwise address fraud or security issues; or (iv) protect against harm to the rights, property or safety of Torto, our users, yourself or the public.
If you use our payment options, our third-party payments providers may collect payment information from you when you make payment. We do not store your credit card and/or bank account information relating to such payments however we do collect and retain the payment amounts.
7. Use of Anonymous Information
We may use Anonymous Information (as defined below) or disclose it to third-party service providers in order to improve our Website and products and enhance your experience with the Website. We may also disclose Anonymous Information (with or without compensation) to third parties, including advertisers and partners. “Anonymous Information” means information that does not enable identification of an individual user, such as aggregated information about the use of our Website.
8. Opting Out
You may choose not to receive future promotional, advertising, or other Website-related emails from us by selecting an unsubscribe link at the bottom of each email that we send. Please note that even if you opt-out of receiving the foregoing emails, we may still send you a response to any “Contact Us” request as well as administrative emails (for example, in connection with a password reset request) that are necessary to facilitate your use of the Website.
You may choose whether or not to provide or disclose Personal Information. If you choose not to provide mandatory Personal Information, you may still visit parts of the Website, but you may be unable to access or use certain options and/or services that involve our interaction with you.
To the extent that you do provide us with Personal Information, we wish to maintain accurate Personal Information. If you would like to delete or correct any of your other Personal Information that we may be storing, you may use the tools that we may make available on the Website or you may submit an access request by sending an email to firstname.lastname@example.org. Your email should include adequate details of your request.
11. Links to and Interaction with Third Party Products
12. Children’s Privacy
The Website is not structured to attract children under the age of 18 years. Accordingly, we do not intend to collect Personal Information from anyone we know to be under 18 years. If we learn that we have collected Personal Information from a child under 18 years, we will delete that information as quickly as possible.. If you believe that we might have any such information, please contact us at email@example.com. We encourage parents and guardians to monitor their children's use of the internet
The security of Personal Information is important to us. We follow generally accepted industry standards, including the use of administrative, physical, and technical safeguards, to protect the Personal Information submitted to us. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, while we strive to use reasonably acceptable means to protect your Personal Information, we cannot guarantee its absolute security or confidentiality. If you have any questions about security on the Website, you can contact us at firstname.lastname@example.org.
14. Merger, Sale or Bankruptcy
In the event that we are acquired by or merged with a third-party entity, or in the event of bankruptcy or a comparable event, we reserve the right to transfer or assign Personal Information in connection with the foregoing events.