At Torque Squad (the “Platform”, “we” or “us”) we respect personal data and are committed to full implementation and compliance with the data protection principles and all relevant provisions of the Personal Data (Privacy) Ordinance, Cap. 486 ("the Ordinance").
This Policy is applicable to all visitors and users who use or access the Platform, as well as any other persons whose Personal Data is collected, by whatever means, used and held by us.
2. Kinds of Personal Data Collected, Used and Held
2.1 When registering an user account on the Platform or for the purposes token purchase, the personal data we collect may include:-
λ Government issued ID number;
λ Copy of government issued ID with photograph;
λ Expiration Date of government issued ID;
λ Physical address;
λ Date of Birth (DOB);
λ Credit Card Authorizations;
λ Data collected by the cookies specified below.
When submitting a purchase order, the following personal data will also be collected:
λ Wallet ID where tokens are to be sent to;
λ Amount sent in USDC/USDT;
λ Official timestamp of transaction;
λ Transaction hash;
In case you choose not to share certain personal data with us, we may not be able to offer or perform some or all our services insofar as these personal data are obligatory and/ or necessary by the law or for the performance of our services (for example, applicable anti-money laundering laws and regulations).
2.2 When you use our services on your mobile device, or features such as two-factor authentication, we may also collect your phone number. We may associate that phone number to your mobile device identification information.
2.3 Personal Data shall be provided by you to us at your own will. The information set out in Clause 2.1 are mandatory for our purpose of creating your user account and providing our services to you. Notwithstanding the foregoing, we reserve the right to refuse your account registration.
3. Public Profile
3.1 We collect artist’s registered name and links to his/her social media accounts which will/ may be displayed in the artist’s public profile, which are available and accessible to those who access the Platform.
4. Purpose of Personal Data to be Collected
4.1 Personal Data and information collected from you will be used by the Company for the following purpose: -
(a) Signing Up, Registration and Identification:
(i) To create, sign in and register a user account on the Platform;
(ii) To verify and ascertain your identity as a user in the Platform; and
(iii) To allow you to participate in interactive features of our services, when you opt to do so.
(b) Providing Services: To provide services to you on the Platform, including sending you notifications (e.g., notifications of offers on your digital assets or changes to our services), responding to your inquiries, comments and other requests;
(c) Business, Marketing and Statistics: to carry out statistics and data analysis to improve and enhance our services and develop our marketing strategies. We may conduct research on our customer demographics, interests and behavior based on the information collected;
(d) Profiling: To build up the Artist’s public profile;
(e) Compliance: To monitor compliance with our Terms & Conditions, our AML Policy and applicable KYC/AML laws and regulations, to prevent fraud and other prohibited or illegal activities as well as to protect the rights and safety of the Company, our Affiliates and third parties;
(f) Administration: to administer the Platform for internal operations, including troubleshooting, data analysis, testing, research and survey purposes, and as part of our efforts to keep the Platform safe and secure; and
(g) Direct Promotion and Marketing: Upon obtaining your consent, we may use your Personal Data for marketing or contact you from time to time to share promotional or marketing information in respect of the Platform.
5. Transfer of Personal Data
5.1 We use the information we collect to set up our services. We may also use the information to contact Users and prospects to further discuss their interest in our company, the services we provide, ways we can improve our services, and send information such as announcements of promotions and events regarding Torque Squad, our group companies or our business partners. We may disclose and share your Personal Data to third parties for the following purposes:
5.1.2 We may share Personal Data, as necessary, with counterparties involved in your trading activities on the Platform in order to execute those transactions, or otherwise for the purposes of enforcing or applying our Terms & Conditions, our AML Policy or other relevant agreements or Company’s policies.
5.1.3 We may share Personal Data with our agents, third party service providers and our business partners assisting our provision of the services to you.
5.1.4 We may disclose Personal Data where we are required by law to do so, or to protect the rights, property, or safety of our Company, our Affiliates, our users or customers or other third parties, which includes but not limited to exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
5.2 Save for Clause 5.1 above, all other transfers of your Personal Data to third parties will be subject to your prior consent in writing, unless we are required by law, or if we must disclose the data to enforce our claims to third parties, who are obligated to maintain secrecy.
6. Data Collected Automatically
6.1 Commercial activities, such as trading activity, order activity, deposits, withdrawals, account balances will be automatically stored and collected by the Platform.
6.2 When you use the Platform, we also receive and store certain information such as your IP address, device ID, and your activities within the Platform. We may store such information or such information may be included in databases owned and maintained by affiliates, agents or service providers. The Platform may use such information and pool it with other information to track, for example, the total number of visitors to the Platform, the number of messages users have sent, as well as the sites which refer visitors to Torque Squad.
6.3 This data we collect automatically may be compiled and analyzed anonymously, and we may share this anonymous data with our affiliates, agents and business partners. We may also disclose aggregated user statistics in order to describe our services to current and prospective business partners, and to other third parties for other lawful purposes.
7. Retention of Data and Information
7.1 We will retain all your Personal Data, transaction records and other account information so long as is necessary for the fulfilment of (i) the purposes for which they were collected and (ii) of the legal requirements, after which they will be removed and destroyed.
7.2 You hereby acknowledge that your information and data are stored and maintained in our electronic database, facilities, servers and back-up servers which may be located outside your country, where the legal protection and standard of security requirements may not be equivalent to the same provided by and legally required by the applicable laws and regulations of your country.
7.3 At any time, if you desire to erase any of your information or data from our electronic databases, facilities, servers and/or back-up servers, please contact us.
8. Accuracy and Change of Personal Data
In order to ensure the correctness and accuracy of your Personal Data, particularly your contact details retained by us, you may receive from time to time our request of confirmation, verification and/or update of your information and data. You can also from time to time request us to correct and/or change your Personal Data held by us.
9. Handling and Security Measures
9.1 Save as stated herein, Personal Data and information we collect about you will not be disclosed to any other party without your prior approval.
9.3 We have established in place security measures and monitoring procedures to prevent unauthorized or accidental access, processing, erasure, loss or use of the data. We shall at all times use our best endeavors to ensure that personnel with access to Personal Data will adhere to all necessary procedures for ensuring compliance with applicable legal requirements for data protection.
9.4 Our security measures are listed below:
(a) Controls on password complexity, any password must consist of at least 8 characters, re-tries or resets are implemented to prevent passwords from being compromised;
(b) Advanced encryption technology is used to protect the safety of Personal Data during transmission.;
(c) Only the personnel that have been trained with the strict privacy guidelines and procedures are authorized to access or handle your Personal Data. Such personnel are accountable for non-compliance with the related obligations; and
(d) The security system will be reviewed regularly.
10. Third-Party Platforms
10.5 We provide these third party platforms only as a convenience and does not review, approve, monitor, endorse, warrant, or make any representations with respect to third party platforms, or their products or services. You use all links in third party platforms at your own risk. For avoidance of doubt, we do not endorse the contents, the privacy policies or their security measures in respect of personal information and data collected by any third-party platforms.
We may use “Cookies” to improve our internet service and enhance your online experience. Cookies are small file that are automatically stored on your web browser in your computer that can be retrieved by the Platform. Cookies may be used to remember you and your preferences when you visit the Platform and enable us to tailor the Platform to your needs. The information collected by Cookies is anonymous visitor’s personalized settings information and contains no full name or address information or any information that will enable anyone to contact you via telephone, email or any other means. We will not collect any Personal Data from you when the cookies are being used. You can disable cookies by changing the settings of your web browser. Cookies cannot be used to run programs or deliver viruses to your computer and/or device.
12. Limitation of Liability
We have implemented reasonably practicable procedures, measures and steps to safeguard the security of your Personal Data. However, no method of transmission over the Internet, or method of electronic storage, is impenetrable and we cannot guarantee the absolute security of our systems. In the event any Personal Data is compromised as a result of a breach of security which is not a result of our act or omission, we will not be liable for your resulting losses and damages, whether direct or indirect, but will use our best endeavors to mitigate such losses in accordance with applicable laws.
13. Social Media Widgets
16. Access to Personal Data
You have the right to request for access to and copy of, and correction and updating of your information and data held by us. If you wish to exercise these rights, please contact us.
17. Contact Us
User Consent (for Direct Marketing)
λ Your name, phone number, and the email address collected by us will be used for providing you with information in relation to the promotion and direct marketing of our products and/or services.
λ We cannot use your Personal Data unless we have received your consent or indication of no objection.
λ If you do not wish to receive information on the above, please unsubscribe from our mailing list or Text STOP to opt-out from our SMS list.