Privacy Policy

Torro, LLC ("Torro," "we," "us," or "our") respects your privacy and is committed to handling personal information responsibly, transparently, and securely.

This Privacy Policy explains how Torro collects, uses, processes, stores, discloses, and protects information when you interact with Torro, our websites, applications, digital tools, software, client portals, forms, assessments, graders, calculators, artificial intelligence features, communications, marketing services, or other digital products and services that link to or reference this Privacy Policy (collectively, the "Services").

This Privacy Policy also explains the choices and rights that may be available to you regarding your personal information.

Torro, LLC is located at:

Torro, LLC
458 Main Street
Wilmington, Massachusetts 01887
United States
Email: privacy@torro.io

1. Scope of This Privacy Policy

This Privacy Policy applies to personal information collected through Torro's websites and digital properties, as well as information collected in connection with our business relationships, marketing activities, client services, applications, software tools, communications, meetings, and other Services.

Our Services may include, without limitation:

• Websites and landing pages;
• Contact forms and lead-generation forms;
• Website graders, SEO graders, marketing assessments, audits, and reporting tools;
• Calculators, quizzes, questionnaires, and interactive tools;
• Artificial intelligence and machine-learning features;
• Chatbots and conversational interfaces;
• Client portals and project-management systems;
• User accounts and authenticated applications;
• File, image, document, spreadsheet, text, URL, or data uploads;
• Email and SMS communications;
• Analytics and reporting systems;
• Marketing, advertising, SEO, AEO, social media, and communications services;
• Call, meeting, and communication transcription tools;
• Public or private sharing features;
• Applications and tools developed or operated by Torro; and
• Future digital products and services that reference this Privacy Policy.

Certain Torro products or services may provide additional privacy disclosures that supplement this Privacy Policy. If a product-specific notice conflicts with this Privacy Policy, the product-specific notice will control with respect to that particular product or service.

2. Information We Collect

The information we collect depends on how you interact with Torro and which Services you use.

Information You Provide Directly

We may collect information that you voluntarily provide, including:

• Name;
• Business name;
• Job title;
• Email address;
• Telephone number;
• Mailing or business address;
• Website URL;
• Social media information;
• Company information;
• Marketing information;
• Account credentials;
• Project information;
• Support requests;
• Survey and questionnaire responses;
• Messages and correspondence;
• Information submitted through forms, applications, calculators, graders, or assessments;
• Information submitted through chatbots or AI-powered tools;
• Files, images, videos, PDFs, spreadsheets, documents, URLs, text, or other content you upload;
• Comments, reviews, shared content, or other user-generated content;
• Meeting, call, or communication information where recording or transcription is used with appropriate notice or consent; and
• Any other information you choose to provide to us.

Information Collected Automatically

When you access or use our Services, we and our service providers may automatically collect certain technical and usage information, including:

• IP address;
• Browser type and version;
• Operating system;
• Device type;
• Device identifiers;
• Approximate geographic location derived from an IP address;
• Referring and exit pages;
• Pages viewed;
• Links clicked;
• Dates and times of access;
• Session duration;
• Interactions with our websites and tools;
• Advertising attribution information;
• Cookie and tracking identifiers;
• Error logs and diagnostic information;
• Performance information; and
• Other information about how you interact with the Services.

Information From Other Sources

We may receive information from other sources, including clients, business partners, advertising platforms, analytics providers, social networks, publicly available sources, referral partners, CRM systems, integrations, and service providers.

3. Information Submitted to Torro Tools

Certain Torro tools are designed to analyze information that a user intentionally provides in order to return useful information, recommendations, reports, scores, estimates, or other requested results.

For example, a Torro tool may ask you to submit a website address, business information, marketing information, advertising data, search-performance information, files, documents, images, text, prompts, or other content.

We may process this information to provide the requested functionality, perform analysis, generate reports, improve the user experience, troubleshoot the Service, prevent abuse, communicate with you, and improve our products and services.

You should only submit information that you have the right and authority to provide to Torro.

4. Artificial Intelligence and Automated Technologies

Torro uses artificial intelligence, machine learning, automation, and related technologies as part of our day-to-day operations and in certain Services. We use these technologies to improve efficiency, provide insights, analyze information, assist with research, create and improve content, provide customer support, perform marketing analysis, generate requested outputs, assist our team, and deliver better results to our clients and partners.

Certain Torro tools may send information you provide to third-party AI, machine-learning, transcription, cloud-computing, or technology providers for processing in order to deliver the requested functionality.

Depending on the Service and configuration, these providers may include companies that provide large language models, machine-learning systems, transcription technologies, cloud infrastructure, analytics systems, or similar technology services.

Examples of providers that Torro may use may include OpenAI, Anthropic, Google, Microsoft, and other comparable technology providers. The specific providers used may change over time as technology and our business needs evolve.

Information processed through third-party AI systems may be subject to the security, retention, and data-processing terms applicable to Torro's relationship with those providers.

We do not sell personal information submitted to Torro's AI tools.

AI-generated results may contain errors or inaccuracies and should not be treated as professional legal, medical, financial, or other regulated advice unless expressly stated otherwise.

5. Meeting, Call, and Communication Transcription

Torro may use artificial intelligence or other technologies to record, transcribe, summarize, or analyze meetings, telephone calls, video conferences, or other communications for legitimate business purposes.

These purposes may include improving client service, documenting requested work, creating meeting summaries, identifying action items, maintaining accurate project records, quality assurance, training, and providing better support to our clients and partners.

Where required by applicable law, Torro will provide notice and/or obtain appropriate consent before recording or transcribing a communication.

Participants who do not wish to participate in a recorded or transcribed communication should notify Torro or the meeting organizer.

6. Payment Information

Torro may accept payments for our products and services through secure third-party payment and invoicing providers, including FreshBooks and other payment-processing providers.

Torro does not intentionally store full credit-card numbers, card security codes, banking credentials, or similar sensitive payment credentials in our ordinary internal documents, websites, or client portals.

Payment information is generally submitted directly to and processed by the applicable payment provider. Those providers process payment information according to their own privacy policies, security practices, and contractual obligations.

Torro may receive limited transaction-related information such as payment status, invoice amount, transaction identifier, billing contact information, or the last digits of a payment method as necessary for accounting, reconciliation, customer service, and recordkeeping.

7. How We Use Personal Information

We may use personal information for purposes including:

• Providing, operating, maintaining, and improving our Services;
• Responding to inquiries and requests;
• Providing requested reports, assessments, recommendations, scores, analyses, or information;
• Creating and managing accounts;
• Managing client projects and relationships;
• Providing marketing, advertising, SEO, AEO, website, content, social media, video, and related services;
• Personalizing the user experience;
• Processing transactions and invoices;
• Providing customer and technical support;
• Sending administrative and service-related communications;
• Sending marketing communications where permitted by law;
• Sending SMS or text communications where appropriate consent has been obtained;
• Conducting analytics and measuring performance;
• Understanding website and application usage;
• Improving our websites, products, services, and business operations;
• Operating AI and automated features;
• Transcribing and summarizing communications where appropriate;
• Detecting and preventing fraud, abuse, security incidents, and unauthorized activity;
• Debugging and troubleshooting;
• Protecting Torro, our clients, our users, and others;
• Enforcing our agreements and policies;
• Establishing, exercising, or defending legal claims;
• Complying with applicable law, regulations, legal processes, and government requests; and
• Carrying out other purposes disclosed to you at the time information is collected.

8. Cookies, Analytics, Pixels, and Similar Technologies

Torro and our service providers may use cookies, pixels, tags, local storage, scripts, software development kits, analytics technologies, and similar technologies.

These technologies may be used to:

• Keep Services functioning properly;
• Remember preferences;
• Maintain sessions;
• Understand website usage;
• Measure traffic and engagement;
• Improve user experiences;
• Measure marketing effectiveness;
• Attribute leads and conversions;
• Detect security threats or fraud; and
• Deliver or measure advertising.

Depending on the website or Service, technologies we use may be provided by companies such as Google, Meta, LinkedIn, HubSpot, advertising networks, analytics companies, CRM providers, and similar service providers.

The technologies used on a particular Torro property may change over time.

You may be able to control certain cookies through your browser settings, cookie preference tools, or other privacy controls available on the applicable website.

9. Advertising and Marketing Technologies

We may use advertising and marketing platforms to advertise Torro's services, understand the effectiveness of our campaigns, identify how users reach our websites, create audiences, measure conversions, and improve our marketing.

These platforms may receive information such as cookie identifiers, advertising identifiers, IP addresses, device information, browser information, website interactions, conversion events, and similar data.

Depending on applicable law, some disclosures involving advertising or cross-context behavioral advertising may be considered "sharing" of personal information even when no money is exchanged.

Torro does not sell personal information in exchange for monetary compensation.

10. How We Disclose Personal Information

We may disclose information to third parties when reasonably necessary to operate our business and provide our Services.

Service Providers

We may provide information to vendors and service providers that perform services on our behalf, including:

• Website and application hosting providers;
• Cloud infrastructure providers;
• Database providers;
• Email providers;
• CRM providers;
• Project-management systems;
• Analytics companies;
• Advertising platforms;
• AI and machine-learning providers;
• Transcription services;
• Communications providers;
• SMS providers;
• Payment processors;
• Accounting and invoicing providers;
• Cybersecurity providers;
• Customer-support providers;
• Data-storage providers; and
• Professional advisors and consultants.

Examples may include FreshBooks, RingCentral, Google, Meta, LinkedIn, HubSpot, OpenAI, Anthropic, Microsoft, and other technology providers depending on which Services Torro uses at a particular time.

Clients

Where you interact with a website, application, form, campaign, or other digital experience operated by Torro on behalf of a client, information collected through that experience may be provided to or controlled by that client.

Legal and Safety Reasons

We may disclose information if we reasonably believe disclosure is necessary to:

• Comply with applicable law or legal process;
• Respond to lawful government requests;
• Protect the rights, property, security, or safety of Torro or others;
• Investigate fraud, abuse, or security incidents;
• Enforce agreements or policies; or
• Establish, exercise, or defend legal claims.

Business Transactions

Information may be disclosed or transferred as part of an actual or proposed merger, acquisition, financing, investment, reorganization, bankruptcy, sale of assets, or similar business transaction.

11. Torro Acting on Behalf of Clients

Torro frequently provides website development, hosting, marketing, advertising, analytics, SEO, AEO, CRM, lead-generation, content, and related services to business clients.

In some situations, Torro processes personal information on behalf of a client rather than determining the purposes for which that information is collected.

In these circumstances, the applicable client may be the business, controller, or organization primarily responsible for determining how the information is used, and Torro may act as a service provider, contractor, or processor.

If you submit personal information directly to one of our clients through a website or service Torro manages on that client's behalf, you should review that client's privacy policy for additional information about its privacy practices.

Requests relating to information controlled by a Torro client may need to be directed to that client. Torro will reasonably assist its clients in responding to valid privacy requests where required by applicable law or contract.

12. SMS and Text Messaging

Torro and certain Torro-operated Services may offer communications through SMS, MMS, or other text-messaging technologies. These communications may include responses to inquiries, requested information, project communications, account updates, service notifications, reminders, support communications, scheduling communications, alerts, and marketing or promotional messages where permitted by applicable law and the recipient has provided the required consent.

Torro only sends SMS or text messages where we have an appropriate basis to do so, including when an individual has provided a mobile telephone number and affirmatively opted in to receive text messages, initiated a text-message conversation with Torro, or otherwise provided consent in a manner permitted by applicable law.

When SMS consent is collected through a Torro website or digital form, the consent request will be presented separately and will not be pre-selected. Where required by applicable law, consent to receive marketing text messages is not a condition of purchasing goods or services from Torro.

Message frequency may vary depending on your relationship and interactions with Torro. Message and data rates may apply depending on your mobile carrier and service plan.

You may opt out of SMS communications at any time by replying STOP to a message. Where supported, you may reply HELP for assistance. You may also contact Torro at privacy@torro.io for assistance with your messaging preferences.

Torro will honor valid requests to revoke SMS consent as required by applicable law. After opting out, you may receive a final confirmation message confirming that your opt-out request has been processed. Certain communications may still be sent where independently authorized or required by law.

Torro may use third-party telecommunications, communications, and technology providers, including RingCentral and similar service providers, to facilitate and deliver SMS communications. These providers may process mobile telephone numbers, message content, delivery information, and related technical data solely as reasonably necessary to provide communications services to Torro or as otherwise permitted or required by law.

Torro does not sell, rent, or share SMS opt-in information, mobile phone numbers, or SMS consent information with third parties or affiliates for their own marketing or promotional purposes. SMS opt-in data and consent will only be used by Torro and service providers acting on our behalf as reasonably necessary to provide messaging services, support our communications, or as otherwise required by law.

SMS consent is specific to the communications described when consent is obtained and does not constitute consent for unrelated third parties to send marketing or promotional text messages.

13. Email Communications

We may use your email address to provide requested information, communicate regarding projects or accounts, provide customer service, send administrative messages, and send marketing communications where permitted by applicable law.

You may unsubscribe from promotional emails using the unsubscribe link included in those emails.

Even after unsubscribing from promotional messages, we may continue sending transactional or administrative communications relating to an existing relationship, account, project, transaction, legal matter, or requested service.

14. User-Generated and Public Content

Some Torro Services may allow users to publish, share, or make information available to other users or to the public.

This may include profiles, projects, comments, reviews, shared documents, shared links, public pages, user submissions, community content, or similar functionality.

Information that you intentionally designate as public or share with other users may be viewed, copied, redistributed, indexed, saved, or otherwise used by people outside Torro's control.

You should not make information public that you wish to remain confidential.

15. File Uploads and Stored Content

Certain Services may allow users to upload or store files, images, documents, spreadsheets, videos, URLs, text, data, or other content.

Torro may process and store uploaded content as reasonably necessary to provide the Service, complete requested work, maintain functionality, prevent fraud or abuse, troubleshoot technical problems, comply with law, and protect the security of the Services.

Uploaded content may be processed or stored using third-party cloud, hosting, storage, AI, or infrastructure providers.

You are responsible for ensuring that you have sufficient rights, permissions, and legal authority to upload and provide any information or content submitted to Torro.

16. Data Retention

Torro retains personal information only for as long as reasonably necessary for the purposes for which it was collected or processed, including providing Services, maintaining business and financial records, managing client relationships, resolving disputes, enforcing agreements, preventing fraud, maintaining security, satisfying contractual requirements, and complying with legal obligations.

The specific retention period may depend on factors including:

• The type of information;
• The reason it was collected;
• The nature of our relationship with you;
• Contractual requirements;
• Legal and regulatory obligations;
• Security considerations;
• Backup and disaster-recovery practices; and
• Potential or actual disputes or legal claims.

When information is no longer reasonably necessary, Torro may delete, destroy, aggregate, or de-identify it in accordance with our data-retention practices.

Information that has been deleted from an active system may remain temporarily in backups, archives, logs, disaster-recovery systems, or other systems until those systems are overwritten, rotated, or otherwise processed in accordance with applicable retention procedures.

17. Data Security

Torro uses reasonable administrative, technical, and physical safeguards designed to protect personal information against unauthorized access, acquisition, loss, misuse, alteration, disclosure, or destruction.

Depending on the nature of the information and Service, safeguards may include access controls, authentication measures, encryption, secure third-party infrastructure, employee access restrictions, monitoring, software updates, security procedures, and vendor-management practices.

Torro also uses reputable third-party platforms and service providers for functions involving sensitive or specialized information, such as payment processing, communications, cloud hosting, and other infrastructure.

No website, network, storage system, transmission method, or electronic system can be guaranteed to be completely secure. Accordingly, Torro cannot guarantee absolute security.

If we become aware of a security incident involving personal information, we will investigate and take appropriate action consistent with applicable law.

18. Your Privacy Choices

Depending on your location and applicable law, you may have rights relating to your personal information.

These rights may include the ability to:

• Request access to personal information;
• Request information about how personal information is used;
• Request correction of inaccurate information;
• Request deletion of certain personal information;
• Request a portable copy of certain information;
• Object to or restrict certain processing;
• Withdraw consent where processing is based on consent;
• Opt out of certain marketing communications;
• Opt out of certain targeted or cross-context behavioral advertising where required by law;
• Limit certain uses of sensitive personal information where applicable; and
• Appeal certain decisions regarding privacy requests where required by law.

Privacy requests may be submitted by emailing: privacy@torro.io.

We may need to verify your identity before processing certain requests. The verification information we request will depend on the nature of the request and the information involved.

We will not unlawfully discriminate against you for exercising applicable privacy rights.

19. United States State Privacy Rights

Residents of certain U.S. states may have additional privacy rights under state law.

Where applicable, Torro will process valid privacy requests in accordance with the requirements and exceptions of the applicable law.

State privacy laws may define terms such as "personal data," "personal information," "sale," "sharing," "targeted advertising," "controller," "processor," "business," and "service provider" differently.

Nothing in this Privacy Policy is intended to limit rights available to individuals under applicable law.

20. California Privacy Information

If the California Consumer Privacy Act, as amended ("CCPA"), applies to Torro's processing of your personal information, California residents may have certain rights including the right to know, access, correct, delete, and obtain information about the collection, use, disclosure, sale, or sharing of personal information, subject to applicable exceptions.

California residents may also have the right to opt out of the sale or sharing of personal information and to limit certain uses and disclosures of sensitive personal information where applicable.

Torro does not sell personal information for monetary compensation.

Certain advertising or analytics activities involving cookies, pixels, advertising identifiers, or similar technologies may constitute "sharing" for cross-context behavioral advertising under California law even when no monetary payment is involved.

Where legally required, Torro will provide appropriate mechanisms for California residents to opt out of such processing and will recognize legally required browser-based opt-out preference signals, including Global Privacy Control, to the extent required by applicable law and technically applicable to the relevant Service.

California privacy requests may be submitted to privacy@torro.io.

An authorized agent may submit a request on behalf of a California resident where permitted by law. We may request information necessary to verify the agent's authority and/or the identity of the individual involved.

21. Categories of Personal Information

Depending on how you interact with Torro, we may collect categories of information such as:

• Identifiers, such as name, email address, phone number, IP address, and account identifiers;
• Customer and business records;
• Commercial information, such as services requested or purchased;
• Internet or electronic network activity;
• Approximate geolocation information;
• Audio, electronic, visual, or similar information;
• Professional or employment-related information;
• User-generated content;
• Inferences derived from information provided to or generated through certain analytical tools; and
• Other information you voluntarily provide.

We collect and use these categories for the business and commercial purposes described throughout this Privacy Policy.

22. International Visitors and Users

Torro is based in the United States. If you access our Services from outside the United States, your information may be transferred to, stored in, or processed in the United States or other countries where Torro or our service providers operate.

Privacy and data-protection laws in those countries may differ from those in your country of residence.

23. European Economic Area, United Kingdom, and Similar Jurisdictions

Where applicable data-protection laws require a legal basis for processing, Torro may process personal information based on one or more of the following:

• Performance of a contract: where processing is necessary to provide products or services you requested or to take steps at your request before entering into a contract.
• Legitimate interests: where processing is reasonably necessary for legitimate business purposes and those interests are not overridden by your rights and interests.
• Consent: where you have provided consent for a particular processing activity.
• Legal obligations: where processing is necessary to comply with applicable law.
• Legal claims and protection: where processing is necessary to establish, exercise, or defend legal rights or protect individuals, Torro, or others.

Individuals in jurisdictions with applicable data-protection laws may have rights to access, correct, erase, restrict, object to processing, obtain data portability, withdraw consent, or file a complaint with an appropriate supervisory authority.

Requests may be submitted to privacy@torro.io.

24. Automated Processing

Certain Torro tools may automatically analyze information and generate recommendations, classifications, scores, reports, content, or other outputs.

Unless otherwise specifically disclosed, these tools are designed to provide information or assist human decision-making and are not intended to make legally binding or similarly significant decisions about individuals without appropriate human involvement.

25. Children's Privacy

Torro's general business, marketing, and professional Services are not directed to children under the age of 13, and Torro does not knowingly solicit personal information from children under 13 through those Services.

If we learn that we have collected personal information from a child under 13 through a Service not intended for children without appropriate parental authorization where required, we will take reasonable steps to delete the information in accordance with applicable law.

If you believe a child has provided personal information to Torro in circumstances that may violate applicable law, please contact privacy@torro.io.

A Torro-operated product specifically designed for children or families, if any, may be governed by additional or different privacy disclosures and consent procedures.

26. Sensitive Information

Unless a particular Service specifically requests it, please do not submit highly sensitive personal information through Torro websites, general contact forms, AI tools, chat interfaces, or other general-purpose Services.

This includes information such as Social Security numbers, government identification numbers, full financial-account credentials, payment-card security codes, medical records, biometric identifiers, passwords, or other highly sensitive information unless necessary for a specific authorized purpose and submitted through an appropriate secure system.

27. Third-Party Websites and Services

Our Services may contain links to or integrations with third-party websites, applications, services, or platforms that Torro does not control.

This Privacy Policy does not govern the independent privacy practices of those third parties.

We encourage you to review the privacy policies and terms of third-party services before providing information to them.

28. Social Media

Torro may maintain profiles and interact with users on social media platforms.

Information you provide through social media platforms may be processed by both Torro and the applicable social media provider according to that provider's own privacy practices.

29. De-Identified and Aggregated Information

Torro may create aggregated, statistical, or de-identified information from information collected through our Services.

We may use this information for analytics, research, benchmarking, product improvement, reporting, security, business intelligence, and other lawful business purposes.

Where information is treated as de-identified under applicable law, we will handle it in accordance with applicable legal requirements relating to de-identified information.

30. Changes to This Privacy Policy

Torro may update this Privacy Policy from time to time to reflect changes in our Services, technologies, business practices, legal requirements, or other circumstances.

When we make changes, we will update the "Last Updated" date at the top of this Privacy Policy.

If we make material changes to how we use personal information, we may provide additional notice or obtain consent where required by applicable law.

Changes to this Privacy Policy will apply prospectively as required by applicable law and will not be used to retroactively authorize materially different uses of personal information where additional notice or consent is legally required.

31. Contact Us

If you have questions about this Privacy Policy, Torro's privacy practices, or your personal information, or if you would like to submit a privacy request, please contact:

Torro, LLC
Attn: Privacy
458 Main Street
Wilmington, Massachusetts 01887
United States

Email: privacy@torro.io