Redfish Labs, Inc. dba Torch Leadership Labs
Redfish Labs, Inc. dba Everwise
Privacy Policy
Last Reviewed on September 9, 2024
Welcome to Torch! The privacy and security of your personal information is important to us. If you have any questions at all about this Privacy Policy, please do not hesitate to contact us at privacy@torch.io.
TABLE OF CONTENTS
- Applicability of this Privacy Policy
- What Information Do We Collect?
- How Do We Use the Information We Collect?
- Do We Share Your Personal Information?
- Cookie Policy – What are Tracking Technologies, such as Cookies and Web Beacons, and How Do We Use Them?
- How Do We Secure Your Personal Information?
- Your Choices Regarding Information
- Links to Third-Party Websites
- How We Respond to Do Not Track signals
- Children Under 16
- DMCA Notice
- Your California Privacy Rights
- Users Outside of the United States
- Contact Us
Applicability of this Privacy Policy
This Privacy Policy (“Privacy Policy“) applies to the Torch Software-as-a-Service platform, our website (available at https://www.torch.io, “Website”), and the related applications provided by Torch (https://app.torch.io, the “Service“) and explains how Redfish Labs, Inc. dba Torch Leadership Labs (“Torch,” “we,” “us,” or “our“) collects, uses, shares and otherwise processes “Personal Information.” Personal Information means any information that identifies or relates to a particular individual and also includes information referred to as “personally identifiable information” or “Personal Data” under applicable data privacy laws, rules or regulations. This Privacy Policy is incorporated by reference into the Torch Master Services Agreement (the “Agreement“). All capitalized terms not defined in this Privacy Policy have the meaning set forth in the Agreement. This Privacy Policy applies to all users of the Website and users of the Torch Service subject to the Agreement (“user”, “you”, “your”), and your use of Torch indicates your consent to this policy and our data processing practices.
If Torch processes Personal Information in the role of Data Processor under the terms of a commercial agreement, and you wish to exercise any of your rights with respect to your Personal Information for which we are a Data Processor, please contact your employer (the Customer) directly. Additional information on data subject rights for cases where Torch is the Data Controller is included below.
We will update this Privacy Policy to reflect changes in our data processing. Our current policy is available at https://torch.io/privacy.
How We Collect Information
- Information you provide. The information you provide in order to access or use our Service or Website, including registration information, account information, profile details, inquiries information, and customer support requests.
- Automatic Information. We may collect information about how you use our Service or Website, such as the types of content you view or engage with, and the frequency and duration of your activities, or where you are inquiring information from. You have options to control or limit how we or our partners use cookies and similar technologies. For more information, please see www.allaboutcookies.org/cookies. If you do not wish to receive cookies, you may set your browser to reject cookies or to alert you when a cookie is placed on your computer. If you limit or disable the use of cookies when you visit our Websites and Service, you may be unable to use their full functionality.
- Information from third parties. We may collect information about you from third parties, including through sponsored events, job applications or features through our Service or Websites. We may also collect information about you from our service providers, and information from third parties such as advertising networks, analytics providers, and search information providers.
- Events. We may collect your information through audio or video recording at any Torch event.
- Contests and Surveys. We may collect information about you if you opt-in to conducting a survey or a contest conducted on our behalf.
How Do We Use The Information We Collect?
We use the information we collect in order to:
- Administer and provide the Torch Service
- Identify and resolve issues with the Service
- Communicate with you, including for customer support
- Prevent and, if necessary, investigate unauthorized activity
- Comply with Legal Process
- Market and advertise Torch
- As Part of a Merger or Sale of Business
| Category of Personal Information | Personal Data We Collect |
| Profile Data | Mandatory:
Optional:
|
| Commercial Data |
|
| Telemetry Data |
|
| Web Analytics |
|
| Other Identifying Information that You Voluntarily Choose to Provide |
|
Use of AI Services
As of August 2024, Torch uses AI services to enhance the coaching experience. We do not use your data to train AI models, and we filter all inputs to remove personal and sensitive information. The AI services used are provided by our cloud infrastructure provider and data is not shared or transmitted elsewhere. We maintain strict controls for our AI summarization, do not share this information with other third parties, and users may opt out by contacting customer support.
How Do We Share Your Personal Information?
We do not sell, or share your Personal Information except with your prior consent and we do not share Personal Information with third parties for their own use. To help us provide the Torch Service, we do share Personal Information with sub-processors, companies which provide specialized services we use within the Torch platform. A current list of sub-processors is available at:
https://torch.io/security/torch-subprocessors/
All sub-processors are evaluated to ensure their data security practices are robust, and Torch has contractual agreements governing the transfer and protection of Personal Information.
How We Secure Your Data
We take the security of your Personal Information seriously. Torch employs industry-standard security measures to protect your Personal Information from unauthorized access, disclosure, alteration, and destruction. We use secure cloud infrastructure with encryption for data in transit and at rest and access to Personal Information is restricted to authorized personnel. While no method of data transmission or storage is 100% secure, we regularly update our security practices to match industry best-practices.
How We Retain Your Data
We retain Personal Information only for as long as necessary to fulfill the purposes for which it was collected including contractual, legal, accounting, or reporting requirements. Telemetry data is stored for no more than 90 days unless a longer retention period is required by law or regulatory obligations. See below for additional information on your rights regarding personal data we have collected or otherwise processed.
Cookie Policy
The Service use cookies and similar technologies such as pixel tags and web beacons (collectively, “Cookies”) to enable our servers to recognize your web browser, tell us how and when you visit and use our Service, analyze trends, learn about our user base and operate and improve our Service. Cookies are small pieces of data placed on your computer, tablet, phone or other device when you use that device to access our Service. We may also supplement the information we collect from you with information received from third parties, including third parties that have placed their own Cookies on your device(s). Please note that because of our use of Cookies, the Service do not support “Do Not Track” requests sent from a browser at this time.
We, or contracted third party sub-processors, may automatically collect log files and other information about your usage of the Torch Service. For example, we use technologies like cookies, session replay tools, and similar technologies to help us analyze performance, customize our Service, serve content, measure promotional effectiveness and promote trust and safety. You may delete and block all cookies via your browser, but parts of the Service will not perform as expected.
As outlined above, information on your connection and browser is automatically collected. This information will be collected every time you access the Service and it will be used for the purposes outlined in this Privacy Policy.
Children Under 18
The Service is not directed to individuals who are under the age of eighteen (18) and we do not solicit nor knowingly collect Personal Information on these data subjects. If you believe that we have unknowingly collected any Personal Information from someone under the age of sixteen (16), please contact us immediately at privacy@torch.io and the information will be deleted.
Data Subject Access Requests
At Torch we respect your right to access and control your Personal Information. You may submit a data subject access request (DSAR) to exercise your rights regarding the limited Personal Information we collect about you. To submit a DSAR, please contact us at privacy@torch.io and we will respond to your request within 30 days. To protect your privacy, we may need to verify your identity before processing your request. We do not charge a fee for handling DSARs unless they are excessive or unfounded.
Right to Corrections. We rely on you to update and correct the Personal Information contained on your Account. However, if you are unable to do so, or you wish to have your personal information corrected, please follow the DSAR method below.
Access to Your Personal Information. You may request access to your Personal Information by contacting us as through the DSAR method below. We will grant you reasonable access to the personal information that we have about you as required by law.
Right to Deletion. You may request that we delete your Personal Information by contacting us through the DSAR method below. We will grant a request to delete personal information as required by law, but you should note that in many situations we must keep certain Personal Information to comply with our legal obligations, resolve disputes, enforce our agreements, or for other required business or legal purposes. Except as provided above, we will delete, aggregate, or de-identify all your personal information upon request, within the timeframes required by law.
Opting Out of Advertising. If you wish to limit third parties’ collection of information about your use of our Services, you can opt-out of such marketing through the Digital Advertising Alliance or Network Advertising Initiative. Please note that opting out of behavioral advertising does not mean that you will not receive advertisements while using our Services. It will, however, exclude you from interest-based advertising conducted through participating networks, as provided by their policies and choice mechanisms.
We may also utilize certain forms of display advertising and other advanced features through third-parties such as Google Analytics, (Remarketing with Google Analytics, Google Display Network Impression Reporting, and Google Analytics Demographics and Interest Reporting). You may control your advertising preferences or opt-out of certain Google advertising products by visiting the Google Ads Preferences Manager, currently available here, or by visiting NAI’s online resources on their website.
Opting Out of Marketing. You may opt-out of future marketing emails by following the unsubscribe instructions provided to you. Please note that if you access and use our Service, or if you opt-in to Service updates, we reserve the right to send you certain communications related to our Service, your account or your use of the Service, and these transactional messages may be unaffected if you choose to opt-out of marketing communications.
International Users
If you are located in another jurisdiction, you should be aware that once your Personal Information is submitted through our Service, it will be transferred to our servers in the United States. By using our Service, or providing us with any Personal Information, you consent to the transfer, processing and storage of your Personal Information in the United States, a jurisdiction in which the privacy laws may not be as comprehensive as those in the country where you reside, and that the United States currently does not have uniform data protection laws in place.
Data Privacy Framework Program for EU, UK and Swiss Individuals
Torch complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce. Torch has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of Personal Information received from the European Union in reliance on the EU-U.S. DPF and from the United Kingdom (and Gibraltar) in reliance on the UK Extension to the EU-U.S. DPF. Torch has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the processing of Personal Information received from Switzerland in reliance on the Swiss-U.S. DPF. If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit https://www.dataprivacyframework.gov/.
Pursuant to the Data Privacy Framework Principles, EU, UK and Swiss data subjects have the right to obtain our confirmation of whether we maintain Personal Information in the United States. If so, we will provide data subjects with access to the Personal Information that we hold and also correct or amend incomplete or incorrect information, or delete relevant Personal Information. An individual who seeks access, or who seeks to correct, amend, or delete data transferred to the United States under a DPF, should direct their query to privacy@torch.io.
In certain situations, we may be required to disclose Personal Information in response to lawful requests by public authorities.
In compliance with the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF), Torch commits to resolve complaints about our collection or use of your Personal Information transferred to the U.S. pursuant to the EU-U.S. DPF, the UK extension to the EU-U.S. DPF, and the Swiss-U.S. DPF. EU, UK, and Swiss individuals with inquiries or complaints should first contact privacy@torch.io.
Torch has committed to refer unresolved DPF Principles-related complaints to a U.S.-based independent dispute resolution mechanism, BBB National Programs. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbbprograms.org/dpf-complaints for more information and to file a complaint. This Service is provided free of charge to you.
Torch commits to cooperate with EU data protection authorities (DPAs), the United Kingdom Information Commissioner’s Office (ICO) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) and comply with the advice given by such authorities with regard to human resources data transferred from the EU, the UK and Switzerland in the context of the employment relationship. EU, UK or Swiss individuals with HR complaints should not refer anything to BBB National Programs.
EU, UK or Swiss individuals wishing to contact their Data Protection office may find more information at the following links:
EU DPA’s: https://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm
UK ICO: https://ico.org.uk/make-a-complaint/uk-extension-to-the-eu-us-data-privacy-framework-complaints-tool/
Swiss FDPIC: https://www.edoeb.admin.ch/edoeb/en/home/the-fdpic/links/data-protection—switzerland.html
If your DPF complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See https://www.dataprivacyframework.gov/s/article/ANNEX-I-introduction-dpf
The Federal Trade Commission has jurisdiction with enforcement authority over Torch’s compliance with the Data Privacy Framework Principles.
Changes to our Privacy policy
We reserve the right to update this Privacy Policy at any time, without prior notice to you, and any changes will become effective immediately upon posting. If we make material changes to this Privacy Policy, we will notify you by email via the primary email address specified in your account or through a notice on the website home page. You are responsible for ensuring we have an up-to-date, active, and deliverable email address for you or if you do not have an account, for visiting our Website and this Privacy Policy to check for any changes. Your continued use of our Service following posting of any Privacy Policy changes constitutes your acceptance of such changes. The effective date of this Privacy Policy, and the last revised date is identified at the bottom of the page.
Contacting Torch
Please contact us at privacy@torch.io if you have concerns, questions or complaints regarding our processing of Personal Information. We are committed to working with you to resolve any complaint or concern you may have with respect to your privacy; however, if you believe we have been unable to assist you, you may also have the right to lodge a complaint with a supervisory authority in the relevant jurisdiction.
For individuals in the European Union, a list of Supervisory Authorities is available here:
https://edpb.europa.eu/about-edpb/board/members_en.
Individuals in the United Kingdom may find more information about the ICO here :
https://ico.org.uk/make-a-complaint/uk-extension-to-the-eu-us-data-privacy-framework-complaints-tool/
Swiss individuals may locate FDPIC information here:
https://ico.org.uk/make-a-complaint/uk-extension-to-the-eu-us-data-privacy-framework-complaints-tool/
However, we are committed to working with you to resolve any complaint or concern you may have with respect to your privacy.