Privacy Policy

This is the privacy policy (“Privacy Policy”) that governs how we, Torto AI Ltd. (“Torto”, “we”, “our” or “us”), use Personal Information (as defined below) that we collect, receive and store about individuals in connection with the use of our website and platform,, available at https://torto.ai/ (the “Website”) and the services provided in the Website (all referred to as the “Platform”)
We do not ourselves host any of the services – all hosting is done by third-party service providers that we engage. This means that data you provide us or that we collect from you (including any Personal Information) – as further described in this Privacy Policy – is hosted with such third party service providers on servers that they own or control, and that your data may be transferred to various third party service providers located in various jurisdictions in the world.

We have implemented this Privacy Policy because your privacy, and the privacy of other users, is important to us. This Privacy Policy explains our practices and the choices you can make about the way your Personal Information is collected and used in connection with the Website. “Personal Information” means any information that may be used, either alone or in combination with other information, to personally identify an individual, including, but not limited to, a first and last name, a personal profile, an email address, a home or other physical address, or other contact information.

This Privacy Policy forms part of our Customer Terms and Conditions which is available at https://torto.ai/customer-terms-of-use (“Terms”). Any capitalized but undefined term in this Privacy Policy shall have the meaning given to it in the Terms.

You are not legally obligated to provide us Personal Information, and you hereby confirm that providing us Personal Information is at your own free will. By using the Website, you consent to the terms of this Privacy Policy and to our collection, processing and sharing of Personal Information for the purposes set forth herein. If you do not agree to this Privacy Policy, please do not access or otherwise use the Website. We reserve the right, at our discretion, to change this Privacy Policy at any time. Such change will be effective ten (10) days following posting of the revised Privacy Policy on the Website, and your continued use of the Website thereafter means that you accept those changes.

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:

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.

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.

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.

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.

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.

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.

The Website may use a tool called “Google Analytics” to collect information about the use of the Website. Google Analytics collects information such as how often users visit this Website, what pages they visit when they do so, and what other sites or Websites they used prior to coming to this Website. We use the information we get from Google Analytics to maintain and improve the Website and our products. We do not combine the information collected through the use of Google Analytics with personally identifiable information. Google’s ability to use and share information collected by Google Analytics about your visits to this Website is restricted by the Google Analytics Terms of Service, available at http://www.google.com/analytics/terms/us.html, and the Google Privacy Policy, available at http://www.google.com/policies/privacy/. You may learn more about how Google collects and processes data specifically in connection with Google Analytics at http://www.google.com/policies/privacy/partners/. You may prevent your data from being used by Google Analytics by downloading and installing the Google Analytics Opt-out Browser Add-on, available at https://tools.google.com/dlpage/gaoptout/.

We collect personal information such as your email address and your user activity through the use of Mixpanel. Mixpanel’s ability to use and share information is governed by the Mixpanel Terms of Use, available at https://mixpanel.com/terms/, and the Mixpanel Privacy Policy, available at https://mixpanel.com/privacy/. You can opt out of Mixpanel’s services by clicking on the following link: https://mixpanel.com/optout/.

We use Facebook pixels or SDKs, which are tools that provide help to website owners and publishers, developers, advertisers, business partners (and their customers), and others integrate, use and exchange information with Facebook, as such the collection and use of information for ad targeting. Please note that third parties, including Facebook, use cookies, web beacons, and other storage technologies to collect or receive information from your websites and elsewhere on the internet and use that information to provide measurement services and target ads. Facebook’s ability to use and share information is governed by the Facebook Tools Terms, available at: https://www.facebook.com/legal/technology_terms/. You can prevent your data from being used by Facebook Pixels and SDKs by exercising your choice through these mechanisms: http://www.aboutads.info/ choices or http://www.youronlinechoices.eu/.

We reserve the right to remove or add new analytic tools.

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 transfer your Personal Information to our local or foreign subsidiaries or affiliated companies for the purpose of storing or processing such information on our behalf. Such information may be transferred to other countries. We require that these parties agree to process such information in compliance with our Privacy Policy.

We may share your Personal Information with our third-party service providers and partners, but only to assist us with our business operations and to provide our Website to you and other users. Such information may be transferred to other countries. We use commercially reasonable efforts to only engage or interact with third-party service providers and partners that post a privacy policy governing their processing of Personal Information.

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.

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.

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 support@torto.ai. Your email should include adequate details of your request.

The Website may enable you to interact with or contain links to your Third-Party Account and other third-party websites and services that are not owned or controlled by us (each a “Third Party Service”). We are not responsible for the privacy practices or the content of such Third Party Services. Please be aware that Third-Party Services may collect Personal Information from you. Accordingly, we encourage you to read the terms and conditions and privacy policy of each Third Party Service that you choose to use or interact with.

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 support@torto.ai. 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 contact@torto.ai.

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.

We are committed to protecting your privacy. Protecting your privacy online is an evolving area, and we are constantly evolving our Website to meet these demands. If you have any comments or questions regarding our Privacy Policy or your Personal Information that we may be storing and using, please contact us at support@torto.ai.