This Privacy Policy (“Privacy Policy”) applies to the websites (Sites) hosting Torch Solutions Group content and services, including but not limited to torchsolutionsgroup.com, meaningfulcompetence.com, and careerenhancementacademy.com.

Privacy Policy

Torch Solutions Group values privacy—ours and yours. We work with hosts that value privacy, and have developed and live with our own privacy policy.

Our Collection and Use of Information

Torch Solutions Group collects information from users who provide information to download or access information and those who purchase goods and services.

Personal Information is information and data that can be used to specifically identify or contact a single person. Torch Solutions Group may share your personal information internally in accordance with this Privacy Policy.

Personal Information We Collect

Examples of some types of personal information Torch Solutions Group may collect and how we use it may include the following:

• When you download a document or schedule an event with us, we’ll ask for your name and email address. We may also request your telephone number and location. These will be used to share additional information with you and advertise products and services.
• When you purchase a product, we will request your name, email address, telephone number and location so that we may better serve you and your needs. We may also request financial information, but we do not retain that information. Financial information is routed directly through our Kartra.com vendor. (See Kartra privacy policy.)

How We Use Your Personal Information

• Optional Communications: The personal information we collect allows us to provide you with the latest product announcements, helpful information, special offers, and upcoming events. If you don’t want to receive these communications, or do not wish to be on our mailing list, you can opt out of receiving them. Each communication will provide opt-out directions.
• Improvement: We also use personal information to help us develop, deliver, improve, and customize our products, services, content, and advertising to provide a better user experience for every user and subscriber.
• Important Communications: We may use your personal information to send important communications about your purchases and access to our products or services.
• If you enter into a promotion such as a contest, a giveaway, a one-time or special offer, or similar promotion, we may use the information you provide to administer those programs.
• If we become involved in a legal process as a result of your actions in connection with any products, or services we offer, we may be required to disclose your PII or PIFI to a government authority, or a third party who e.g., issues a subpoena that require us to provide it. Our response(s) to any such legal process will be handled on a case-by-case basis following the advice of our attorneys.

GDPR

Torch Solutions Group will continue to respect and value privacy in the age of GDPR regulations. To the extent commercially practicable, and in accordance with legal or regulatory requirements we obtain your clear, informed consent before collecting your personal data. We will also always work to balance obtaining clear consent with providing useful and powerful platforms and convenient and graceful user interfaces.

Collection of Non-Personal Information

Information of a type or in a form that does not permit direct identification of or association with any specific individual is ‘non-personal information.’ Combinations of personal and non-personal information are considered personal information if the combined information can be used to identify or contact any specific individual(s). Aggregated data is considered non-personal information for the purposes of this Privacy Policy as long as it cannot be used to identify or contact any specific individual. Internet Protocol (IP) addresses and certain other identifiers may be considered personal information under various local laws; we endeavor to comply with the laws and regulations that are applicable to us.

How we collect and use your non-personal information

 We may collect, use, transfer, and disclose non-personal information for any purpose. The following are some examples of non-personal information that we collect and how we may use it:

• We may collect non-personal information (e.g. demographic information) regarding our customers collectively including information such as age, gender, occupation, preferred language, zip code, area code, geographic location, or the time zone from which customers access the Sites, products, or services. Such non-personal information is used so that we can better understand who our customers are, and their behavior generally with regards the Sites, and to improve our products, services, communications, support, help, user experiences, and advertising for our customers.
• We also may collect non-personal information regarding customer activities on the Sites. This information is aggregated and used to help us provide more useful information to our customers and to understand which parts of the Sites, or our products and services are of most interest or which can be improved. Non-personal support or help request data may be used to improve our Sites, communications, and programs, or to allow us to provide additional product or service offerings to our present or future customers.
• We may collect non-personal information regarding the digital footprints of our customers with respect to accessing the Sites, or any related products or services including mobile and non-mobile access, specific types of devices being used, unique device IDs, type of browser(s) being used, networks that our customers use, and other non-personal information. This information may be used to improve the Sites, software, products, or services including but not limited to their performance, functionality, design, or responsiveness.

Cookies and Other Technologies

To help Torch Solutions Group serve you better, we use technological means to better understand and adapt to user behavior. To accomplish this, the Sites, as well as our online services, email messages, and advertisements may use cookies or related technology such as pixel tags, clear gifs, and web beacons. These technologies help us to know which parts of the Sites people have visited, and provide data to aid us in understanding the effectiveness of the services, our advertisements, and web searches. These data are used to improve our products, services, communications, and advertisements. We generally consider such information collected through the use of cookies and other technologies as non-personal information, and treat it accordingly.

 We also use cookies and other technologies to remember personal information when you use the Sites, products, or services. These uses are intended to improve your personal experience. For example, we can provide better and more personal results if we ‘remember’ your preferred settings, your name, and such.

Torch Solutions Group may use cookies or other technologies in connection with certain advertising services to determine your experience with our content including whether an ad is likely to be of interest to you, whether or not you are served a particular ad, and the number of times you are served a particular ad. These technologies allow us to measure the effectiveness of our ad campaigns. You may have options for opting out of such targeted ads. You should contact your service provider or your mobile provider to inquire about how to do so.

 Torch Solutions Group also uses specific technologies in connection with certain communications such as emails that may be used to track actions by recipients. For example, these communications may include one or more clickable text or graphics that include URLs that link to content on the Sites. However, these URLs, may pass through a web server that tracks the click before arriving at the linked content on the Sites. The tracked data can help Torch Solutions Group determine the effectiveness of our communications to users and customers, or to gage interest in specific topics. If you prefer not to have your responses to such communications tracked in this manner, do not click links in the email messages. Such communications may also include pixel tags that can tell us whether e.g. an email has been opened. We may use this information to throttle the number of messages sent to users or customers, or to remove people who do not read or interact with our communications from one or more lists.

 We also use cookies to track certain behaviors of unknown visitors on our site. E.g. if you visit our site by following a link in an email from a third party or in an advertisement from such a party, we may track that behavior. In such cases, we may not have any personally identifying information about you at that time; however, if you later sign up for a product or service, or make a purchase, we may be able to associate your past behaviors on our sites with you thereafter.

 Cookies and other technologies can generally be controlled on your devices. If you want to disable cookies and you should review your privacy or security settings. Please note that certain features of the Sites or related software, products, or services may not be available if you have cookies disabled on your device. We will typically try to warn you that a page or feature you are trying to reach will not function without cookies enabled. If you have your cookies on your device or browser disabled and are having difficulties you may wish to enable them to see if the problem is resolved.

Finally, it's worth mentioning that some of these cookies are essential to the operational functioning of the platform, such as for example those related to the transactional checkout process. Some others, while improving the user experience and feature scope of the platform, are not strictly required to utilize our services such as for example certain tracking cookies.

Social Media

 Torch Solutions Group may collect certain information from you if you interact with us via social media such as Facebook, Twitter, LinkedIn, Google+, Pinterest, Snapchat, Instagram, and other such services. For example, you may be given the option to register for webinars, take advantage of special offers, receive mailings, newsletters or the like, via your social media account. The information we receive or collect from such social media, and our ability to collect it, may depend on the social media site, its policies, and its requirements or its technology. We may collect the information you provide from these social media interactions and may use it for various purposes to improve our services or your experience, or to contact you regarding the reason you connected with us or with additional offers in the future. Of course, you have the opportunity to opt-out at any time provided we do not require a means of contacting you to fulfill your request.

Children

Protecting children's privacy is important to Torch Solutions Group. It is our policy to comply with the Children's Online Privacy Protection Act of 1998 and all other applicable laws. Therefore we restrict our website use to persons eighteen years or older. Therefore, we do not knowingly collect personal information from children under 18. If we learn that Torch Solutions Group has inadvertently collected or received the personal information of a child under 18 we will take steps to delete the information.

[PLEASE NOTE: You must be 18 or older to use the Sites, and to purchase the software, products, or services offered via the Sites without an adult (parent or guardian).]

DUE TO THE AGE RESTRICTIONS FOR USE OF THIS WEBSITE, NO INFORMATION OBTAINED VIA THIS WEBSITE FALLS WITHIN THE CHILDREN'S ONLINE PRIVACY PROTECTION ACT (COPPA) AND IT IS NOT MONITORED AS DOING SO.

Notwithstanding the foregoing, if we discover or form a reasonable belief that we have received any information from a child under 18 in violation of this policy, we will delete that information. If you believe Torch Solutions Group has any information from a child under age 18, please contact us at the following address:

• Mail: Torch Solutions Group, 6311 Bolsa Chica Ln, Houston TX 77041, USA
• Email: inf@torchsolutionsgroup.com

Disclosure to Third Parties

At times Torch Solutions Group may make certain personal information available to strategic partners that work with us to provide software, products and services, or that help us service our customers. Personal information will only be shared by Torch Solutions Group to provide or improve the Sites, and our products, services, and advertising.

 Service Providers

To provide its various products or services, Torch Solutions Group works with third party providers. Such companies provide services to Torch Solutions Group. Examples may include information processing, emailing services, server hosting, transaction processing and banking services, video hosting, product/service delivery, communications, managing and enhancing customer data, providing technical support and/or customer service, and conducting customer research or satisfaction surveys. At any given time, Torch Solutions Group may work with one or more such provider. We will only provide personal information to these companies where required for them to provide their services, or to improve our products or services for our customers. These companies are contractually obligated to protect your information.

Others

Torch Solutions Group will not share PII with third parties for their marketing purposes. In some cases, Torch Solutions Group may be required by legal process to disclose your personal information. Such disclosure may be compelled by applicable law, regulation, judicial order, and/or lawful requests from local authorities. Torch Solutions Group may also disclose information about you if we determine, in our sole discretion, that disclosure is necessary or appropriate to ensure the safety of any individual(s), or for purposes of national security, law enforcement, or other issues of public importance.

If the Sites and/or products, or services, or Torch Solutions Group LLC becomes the subject of a reorganization under the bankruptcy law, a merger, a sale, or other change in control, any and all personal information in Torch Solutions Group’s control will be transferred to the trustee, debtor in possession, successor, acquirer, or such other third party as will control Torch Solutions Group, the Sites, and/or software, products, or services thereafter.

We reserve the right to disclose personal information if we reasonably believe that disclosure is necessary to protect our users, customers, or the public, prevent fraud or financial wrongdoing, or in any action to enforce our End User License Agreement, Terms and Conditions, or other policies regarding Torch Solutions Group.

GDPR Perspective

 DISCLOSURE and USE: Torch Solutions Group will let users know to whom we are disclosing personal information, and how it is being used. Of course, you should already know that we only use personal information to provide the products and services that you want.

Personal Information Protection

Torch Solutions Group uses commercially reasonable security measures to protect against unauthorized access to or unauthorized alteration, disclosure or destruction of data. We restrict access of personal information to our employees, contractors, and/or agents who need to know that information in order to process it on our behalf. These individuals are bound by confidentiality obligations and may be subject to discipline, including termination and criminal prosecution, if they fail to meet these obligations. Torch Solutions Group uses third party providers that use Secure Sockets Layer (SSL) encryption on all web pages where personal information, including financial information is transmitted.

You are solely responsible for any personal information you choose to submit on non-secure sites including but not limited any discussion forums or public comment threads on the Sites, or any social media sites, groups, or threads related to the Sites or the related software, products, or services.

Access to Your Personal Information

Torch Solutions Group customers should periodically log in to review your name, contact information and other readily available personal information, and to ensure they are accurate, complete, and up to date. You can make changes to your information. Changes to your personal details and particulars should be made through the software.

You can request access to any personal information we have for you. We will make a good faith effort to provide you with access to reasonably accessible information. You can request that we correct the data if it is inaccurate or delete your personal data. Torch Solutions Group will comply with such requests if they are reasonable and we will delete your data if Torch Solutions Group is not required to retain it by law, and does not require it for legitimate business purposes. We may reserve the right to refuse deletion requests that we believe require undue time, or technical effort, or where not provided by local law. We also reserve the right to deny or delay requests where the personal information is scheduled to be deleted as part of any upcoming purge of data that is not being retained. Requests for access, correction, or deletion can be submitted to info@torchsolutionsgroup.com.

GDPR Perspective

 The RIGHT to KNOW and the RIGHT to BE FORGOTTEN: The GDPR gives you these rights and Torch Solutions Group uses third-party companies that enable every user to know what we know, and to ask us to ‘forget’ them.

Links to Third-Party Sites

The Sites, software, products, services, and communications may contain links to third-party websites, products, or services. Information collected by third parties is governed by their privacy practices, not this Privacy Policy. Please be aware when you leave the Sites and understand that you are subject to a third party’s privacy policy except when you are on the Sites, or using Torch Solutions Group’s related products, or services.

EUROPEAN UNION Users: The GDPR

Torch Solutions Group uses third-party vendors that are compliant as a Processor of Personal Data under the GDPR.

Changes to this Privacy Policy and Privacy Questions

If you have any questions or concerns about this Privacy Policy please email us at info@torchsolutionsgroup.com.

This Privacy Policy is subject to change from time to time at Torch Solutions Group’s sole discretion. Please check this page periodically for changes. Any such changes to the Privacy Policy will be available on this page. If the policy has been changed in a material way, a notice will be posted on our website along with a link to the updated Privacy Policy. Your continued use of our site following the posting of changes to these terms will mean you accept the changes. Information collected prior to the time any change is posted will be used according to the rules and laws that applied at the time the information was collected.

Notice of Compliance to California Residents

Your California Privacy Rights Under The California Online Privacy Protection Act and the California Business and Professions Code

This privacy policy identifies the categories of personally identifiable information that our company collects through our website or online services about individual consumers who use or visit Torch Solutions Group's commercial websites or online services in connection with Torch Solutions Group (including but not limited to torchsolutionsgroup.com and careerenhancementacademy.com) (collectively “the Sites”) and the categories of third-party persons or entities with whom our company may share that personally identifiable information.

Torch Solutions Group does not maintain an online process for an individual consumer who uses or visits our commercial website or online products and services to review and request changes to any of his or her personally identifiable information that is collected through our website or online service.

See the section above titled "Changes To This Privacy Policy" for a description of the process by which our company notifies consumers who use or visit our commercial website or online service of material changes to our company's privacy policy for this website or online service.

The effective date of this Privacy Policy is listed at the end of this privacy policy under the heading, "Last Updated."

For the purposes of this policy and California compliance the following definitions apply:

Depending on your activity on our website or online service, the following "personally identifiable information" may be collected, in addition to what is in prior sections of this document.

The term "personally identifiable information" means individually identifiable information about an individual consumer collected online via the Sites from an individual and maintained by us in an accessible form and may include any of the following:

• A first and last name;
• A home or other physical address, including street name and name of a city or town;
• An e-mail address;
• A telephone number;
• Any other identifier that permits the physical or online contacting of a specific individual; and
• Information concerning a user that the Sites collect online, from the user, and which is maintained in personally identifiable form, in combination with an identifier described within this Privacy Policy.

Under California Law SB 27, California residents have the right to receive, once a year, information about third parties with whom we have shared information about you or your family for their marketing purposes during the previous calendar year, and a description of the categories of personal information shared. To make such a request, please send an email to info@torchsolutionsgroup.com and please include the phrase "California Privacy Request" in the subject line, the domain name of the website you are inquiring about, along with your name, address and e-mail address. We will respond to you within thirty (30) days of receiving such a request.

"Cookies" and How We Use Them

 A "cookie" is a small data file that can be placed on your hard drive when you visit certain websites. The Sites may use cookies to collect, store, and sometimes track information for purposes stated earlier as well as for statistical purposes to improve the products and services we. We may also use cookies for purposes of personalizing your experience on the Sites, or for providing online behavioral advertising such a retargeting or remarketing. These uses provide you with additional opportunities to take advantage of our services or products, and provide us with additional opportunities to reach you with personalized offers more tailored to your interests. Advertisers and partners may also use their own cookies (e.g. on their own sites). Torch Solutions Group does not control any third party’s use of such cookies and we expressly disclaim responsibility for information collected by or through them.

Public Areas & Social Media

Any information you disclose in any public areas of our website or the Internet, including via social media becomes public information. You should exercise caution when deciding to disclose personal information in these public areas.

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This Privacy Policy does not create any contractual or other legal rights in or on behalf of Torch Solutions Group or any other party and is not intended to create any such rights.

 Questions about this Privacy Policy may be directed to us in writing at:

• Mail: Torch Solutions Group, 6311 Bolsa Chica Ln, Houston TX 77041, USA
• Email: inf@torchsolutionsgroup.com

LAST UPDATED: March 7, 2022

Torch Solutions Group, LLC
6311 Bolsa Chica Lane
Houston, TX 77041
+1 (281) 942-4567