Privacy Policy

1. The Scope

1.1 This policy describes the types of Personal Data the Company collects from natural persons and how it processes, shares with third parties, and secures that data.

1.2 This Policy concerns information relating to an identified or identifiable natural person. An identifiable natural person is one who can be identified directly, or indirectly through additional information we hold or are able to access.

1.3 Under this Policy, "processing" means any operation that uses or collects Personal Data, including its management, organization, and storage.

1.4 Our services are intended for general audiences and are not designed for anyone under the age of 18. We do not knowingly seek or collect information from anyone under 18, nor do we knowingly allow such individuals to use our services. If we learn that we hold any information about a child, we will erase it as quickly as possible.

2. What Personal Data Do We Have on You

2.1 We collect Personal Data when you access the service and channels or visit our website. In certain cases, we may request your Personal Data.

2.2 In other cases, we collect your Personal Data by analyzing how you use our Services or service channels, or by receiving information from our third-party partners.

3. No Requirement to Disclose Personal Information

3.1 You are not obliged to provide Us with any Personal Data. In certain cases, however, withholding such data may prevent Us from delivering the Services or granting you access to the website.

4. What Personal Data We Collect

4.2 The information we collect is not personal data and cannot be used to identify you.

4.3 Personal Data we receive from you: any personal data you choose to provide to Us when you connect with a third party's online trading platform through Us.

4.4 Personal information you provide directly to third-party platforms to facilitate trade: this includes your full name, address, phone number, and email address.

5. Legal Basis and Reasons for Processing of Personal Data

5.1 The company processes your Personal Data for the purposes described in this section and in accordance with the applicable legal basis.

5.3 Contact us by email for more details on the processing necessary to safeguard our legitimate interests.

5.4 We may use the information you provide for the following reasons and on the following legal grounds:

6. Transfer of Personal Data to Third Party

6.1 The Company may also share Personal Data with third-party providers who deliver services to us, such as hosting and storage providers, including IP address information and analysis of user experiences.

6.2 You can also request that we share specific Personal Data about you with third-party trading platforms. In these cases, we will provide the Personal Data you have given us to those third-party trading platforms. Their use of your Personal Data is governed by their own privacy policies. Your Personal Data may be shared with multiple trading platforms.

6.3 The Company may share Personal Data with related entities or business partners. This gives the Company access to the resources needed to enhance and improve the products and services it provides to its customers.

6.4 The Company may disclose Personal Data to regulatory, local, or other official authorities where necessary to protect the rights or assets of third parties.

6.5 We may also share your Personal Data with potential investors or buyers, or with lenders to the Company or any other company within the group, in connection with such a transaction (including the transfer or sale of assets belonging to the Company or any other company within the group) or as part of any merger, restructuring, consolidation, or bankruptcy of the Company or any other business within the group.

7. Cookies and Services from Third Parties

7.1 We may use third-party services, such as advertising providers or analytics companies. These companies may also use cookies or similar technology.

7.2 Cookies are small text files placed on your device each time you visit or access the website. They collect information about your preferences and browsing habits to improve your experience, remember your settings, and tailor the products and services you may enjoy. Cookies are also used for statistics and analytics.

7.3 Some of the cookies we use are session cookies. These are temporarily downloaded to your device and remain only until you close your browser. Others are persistent cookies, which stay on your device for a set period after you close your browser. Persistent cookies help the Website recognize you as a returning user and make it easier to return to the site.

7.5 Please note that some or all of the Website's functions and features may not work as expected if this occurs.

Online Tracking Notice: This service does not currently respond to do-not-track signals.

8. Retention of Personal Data

8.1 The Company will retain your Personal Data for as long as necessary to fulfill the purposes of processing described in this Policy, or for longer periods where permitted by applicable laws, regulations, policies, and orders.

8.2 We will share your personal data with third-party trading platforms for a period of 12 months. If you consent, we will continue to share your data for a further 12 months.

8.3 We regularly review the Personal Data we hold to confirm it is still needed.

9. International Transfers

9.1 Your personal data may be transferred to other countries, including to a third country or to international organizations. The Company takes all necessary steps to safeguard the personal data you provide and to ensure that data users can assert their rights and access effective legal recourse.

9.3 Upon request, the Company can provide details about the security measures it uses to protect your Personal Data transferred to third-party countries or international organisations. Send an email to: support@torch-vermoss.com

10. Security of Personal Data

10.1 We have implemented appropriate organizational and technical measures to protect Personal Data, including safeguards against the accidental or unlawful destruction, loss, or modification of Personal Data.

10.2 We cannot guarantee that the security of your Personal Data will be maintained without error. We are also not liable for any intangible, incidental, or consequential damages arising from the use or disclosure of Personal Data. This includes, but is not limited to, any Personal Data disclosed due to transmission errors, unauthorised access by a third party, or any other cause beyond our control.

10.3 Legal obligations or other circumstances beyond our control may require us to disclose your Personal Data to third parties, such as public authorities. In such cases, we cannot control the security measures those third parties apply to your Personal Data.

10.4 No method of transmitting Personal Data over the internet is completely secure. The Company cannot guarantee the security of any Personal Data you transmit to Us online.

11. Hyperlinks to Third Party Websites

11.1 The website contains links to third-party sites and applications. These sites and applications are not under the Company's control. We are not responsible for the collection or processing of Personal Data by them. This Policy does not apply to any actions taken through such sites or applications.

11.2 When you visit any third-party websites or apps, we recommend reading their privacy policies before deciding to access or use them, and before providing any Personal Data to them.

12. Modifications to This Policy

12.1 We may update this Policy at any time. Any changes will take effect once the updated Policy is posted on our website.

12.2 We will also notify you of any significant changes to this Policy through methods we consider appropriate and will post an announcement on our website.

12.3 Unless otherwise stated, any amendments take effect upon publication of the revised Policy.

13. Your Rights

13.1 You have the right to ask us to verify the accuracy of the Personal Data we collect about you, to correct any errors, and to delete any Personal Data we do not require. You may also restrict the scope and types of processing applied to your personal information.

13.2 If you reside in the EEA, please refer to this page. These rights apply to the information you provide regarding your Personal Data. To exercise your rights, send an email to the address below.

13.3 Access rights The Company can confirm whether your Personal Data is being processed. Where it is, you may access that Personal Data. The Company will provide an electronic copy of the Personal Data currently being processed and may charge a reasonable fee for any additional copies. If you request it, the data will be made available electronically. The right to access Personal Data must not conflict with the rights and freedoms of others. Where a request would harm the rights and freedoms of another, the Company may refuse to comply or limit its ability to fulfill it.

13.4 Right to rectification The Company may correct inaccurate Personal Data. You have the right to request that incomplete Personal Data concerning you be rectified, taking into account the purpose of processing.

13.5 Right to Erasure The following grounds apply: (a) Personal Data are no longer required for the purpose for which they were collected or processed; (b) you withdraw consent and there is no legal basis to continue processing; (c) you object, on grounds relating to your particular situation, to the processing of Personal Data about yourself that is based on legitimate interests pursued by Us or by a third party; (e) Personal Data are unlawfully processed; or (f) Personal Data must be erased to comply with a legal obligation of the company. This right does not apply where processing is necessary (a) to fulfill a legal obligation required under European Union law or Member State law; or (b) to establish, exercise, or defend legal rights.

13.6 Restriction of processing If you have concerns about the accuracy of your Personal Data, you may ask the Company to restrict its processing. Where you request such a restriction, Personal Data may only be retained with your consent, to establish, exercise, or defend legal claims, to protect the rights of another natural person, or for reasons of significant public interest within the European Union or a Member State.

13.7 Right to data portability Where processing is carried out by automated means and is based on your consent or on a contract to which you are a party, you have the right to receive the Personal Data you have provided to the Company. You may request that your Personal Data be transferred directly from the Company to another controller, where technically feasible. Exercising your right to data portability does not affect your right to erasure. The right to data portability must not adversely affect the rights and freedoms of others.

13.8 Right to object You may object at any time to any processing of Personal Data concerning you that is based on legitimate interests pursued by the Company or a third party, including profiling based on those legitimate interests. Where we can demonstrate compelling legitimate grounds for the processing, we may continue unless you can show that your rights, freedoms, or interests outweigh those grounds, or unless the processing is necessary for the exercise, establishment, or defense of legal claims. You also have the right to object at any time to the processing of Personal Data concerning you for direct marketing purposes.

13.9 Right to withdraw consent You may withdraw your consent for Us to process Personal Data about you at any time. This does not affect the lawfulness of any processing carried out under your consent before its withdrawal. You have the right to lodge a complaint with your supervisory authority. You may submit a complaint to a supervisory authority established by a member state to protect the fundamental rights of individuals in relation to the processing of Personal Data within the European Union. The laws of the European Union and Member States may limit your rights regarding Personal Data concerning you, as set out in this section 13.

13.10 We will provide the information you request under your rights in section 13 of this agreement within one month of receiving your request. This period may be extended by up to two months where necessary, depending on the nature and number of requests. We will notify you of any extension and the reasons for it within one month of receiving your request.

13.11 Provided it does not conflict with the provisions of section 13 of the law, the information you request under your section 13 rights will be made available free of charge. Where a request is unfounded or excessive, in particular where it is repetitive, we may charge a reasonable fee to cover the administrative costs of providing the information or taking the requested action. We may also decline to act.

13.12 If we have doubts about the identity of the person who submitted your request, we may ask that person to provide reasonable means of identification.