Privacy Policy

This “Privacy Policy” describes how Crowdpulse LLC d/b/a “Torchlight AI” (“we”, “us”, or “our”) collects, uses, discloses, and otherwise processes personal information in connection with our website, located at torchlight.ai (“Site”), certain features, functionality and services, and any and all related applications (collectively, the “Service(s)”). Any undefined terms in this Privacy Policy have the definition specified in our Terms of Service (“Terms”).

By accessing and/or using the Service, you agree that you have read, understood and agree to our collection, storage, use and disclosure of your personal information as described in this Privacy Policy and our Terms.

Our Service may include links to third-party websites, plug-ins and applications. Except where we post, link to, or expressly adopt or refer to this Privacy Policy, this Privacy Policy does not apply to, and we are not responsible for, any personal information practices of third-party websites, online services, or the practices of other third parties. To learn about the personal information practices of third parties, please visit their respective privacy notices.

1. Personal Information We Collect.

• Provided Directly By You.

• Service Information. When you communicate or interact with us on the Service, we may collect information from you, such as your name, phone number, e-mail address and other personal identifiers. We use this information to: (i) communicate with you directly about the Service as well as about any questions, issues or concerns you or other users may have, and (ii) send you marketing communications, newsletters or other information in accordance with your preferences.

• Communications. We use our communications with you to address your questions, issues and concerns and to improve our Services. We maintain your communications with others via our Site for your ease of use and for other business related purposes in connection with the Services and the use thereof.

• Generated and/or Automatically Collected During Your Use of the Service.

• Device Information. To access and use the Site, the Services may be integrated with your personal computer, mobile handsets, tablets, wearable devices, speakers, and other devices by which you access the Services. Information about such devices and its software includes, without limitation, your IP address, browser type, internet service provider, device type/model/manufacturer, operating system, date and time stamp, and a unique ID that allows us to identify your browser, mobile device, and other similar information. We use this device and software information to diagnose and fix technology problems, personalize your experience, perform analytics/identify usage trends, and improve our Services.
• Manner of Access and Use. We collect information about the way you access and use the Services, including tracking the pages you visit on the Site, the links you click, and the actions you take on the Site, such as whether you open emails or click the links contained in emails that we send, other actions you take on the Site and through the use of our Services, and whether you access the Service from multiple devices. We may use this information to determine products and services that may be of interest to you, to improve our Services, to send you marketing communications, or for other business related purposes in connection with the Services and the use thereof.
• Analytics Information. We may collect analytic data or use third-party analytics tools such as Google Analytics to help us measure traffic and usage trends and the demographics of our users in order to improve the Services. You can learn more about Google’s practices at http://www.google.com/policies/privacy/partners.

• Other Collection and Uses.

• We typically collect the foregoing information through a variety of tracking technologies, which may include, without limitation:
• “Cookies”, which are data files that are placed on your device or computer and often include an anonymous unique identifier – For more information about cookies see Torchligh AI’s Cookies Policy at and for information on how to disable cookies, visit http://www.allaboutcookies.org;
• “Log files” track actions occurring on the Services, and collect data including our IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps; and
• “Web beacons,” “tags,” and “pixels” are electronic files used to record information about how you browse the Services.

• We may use third-party partners or services to assist with this effort. Information we collect automatically about you or your device may be combined with other personal information we collect directly. We, or the third-party partners we use, may use the data collected automatically through tracking technologies to: (i) remember information so that you will not have to re-enter it during your visit or the next time you visit the Services; (ii) provide custom, personalized content and information; (iii) identify and contact you across multiple devices; (iv) provide and monitor the effectiveness of the Services; (v) perform analytics and detect usage patterns on our Services; (vi) diagnose or fix technology problems; (vii) detect or prevent fraud or other harmful activities; and (viii) otherwise plan for and enhance our Services and for other internal purposes.

• If you would like to opt-out of the tracking technologies we employ on the Services, you may do so by blocking, deleting or disabling them as your browser or device permits. Please note that blocking, deleting, or disabling these technologies will affect the functionality of our Services, and may prevent you from being able to access certain features. Please note that we do not alter its data collection or use practices when a user enables a ‘Do Not Track’ signal from their browser.

• Our Service may contain social media buttons and email integrations such as Facebook, LinkedIn, Twitter, Instagram, Gmail, and others. These features may collect your IP address, which pages you are visiting on our Site and through the Service, and may set a Cookie to enable the feature to function properly. Your interactions with these third-party platforms are governed by the privacy policy of the companies providing them.

2. How We Use Your Personal Information. In addition to the uses described above, we may collect and use personal information to:

• Provide, Maintain, Improve and Develop the Service. We may use the personal information to provide, maintain, improve and develop the Services. For example, we may: (i) fulfill your requests in connection with our Services, (ii) perform analytics, detect activity patterns on our Services and otherwise research usage, and (iii) test and develop new features and functionality and otherwise enhance the Services.

• Maintain Safety, Stability and Security of the Service. We may use the personal information to maintain the safety and security of the Services. For example, we may: (i) attempt to detect or prevent fraud, abuse or other harmful activities, (ii) diagnose or fix technology problems, (iii) conduct security investigations and risk assessments, and (iv) improve and enforce our security measures.

• User Communication and Support. We may use personal information to communicate important messages to you and/or to provide you with support or send you information you have requested such as our newsletter or responses to our Q&A forum.

• Provide, Personalize, Measure and Improve Advertising and Marketing. We may use personal information to provide, personalize, measure and improve our advertising and marketing. For example, we may inform you of our Torchlight products (including informational products such as newsletters), programs, services, and promotions that we believe may be of interest to you, including, without limitation, through emails.

• Legal and Regulatory Requirements and Proceedings. We may use the personal information in connection with legal and regulatory proceedings and requirements, such as to comply with applicable laws and regulations.

• Enforce our Rights. When you access or use the Service, you are bound by this Privacy Policy and the Terms, and you may be subject to additional terms and conditions presented by us, which are thereby incorporated by reference into the Terms. To ensure you comply with the foregoing, we may use your personal information to monitor, investigate, prevent and/or mitigate violations of our Terms as well as for other enforcement related purposes in connection with the Services and your use thereof, including, without limitation, to enforce our agreements with third parties and business partners.

3. Sharing Your Personal Information. We share your personal information with third parties in the following circumstances:

• Third Parties Necessary to Enable Your Use of the Service. We disclose personal information to other third parties as needed to fulfill your requests and to provide the Service.

• Service Providers. We disclose personal information to third parties that provide services for us or on our behalf, such as, payment processing, website hosting, data analysis, infrastructure provisioning, IT services, customer service, email delivery services, fraud detection, security monitoring, advertising and marketing, and other similar services. For example we use: WP Engine for web hosting and infrastructure of our Site ai, and Gmail for email communications. We periodically review these third-party privacy policies to determine and confirm they are consistent with our own Privacy Policy.

• Analytics Providers. As mentioned above, we share personal information with third-party analytics providers to better understand the demographics of our users and visitors, and to personalize, enhance and improve the Service.

• Business Transaction. If another company acquires our company, business, or our assets, that company may then possess the personal information collected and stored by us, however, such company will assume the rights and obligations regarding your personal information as described in this Privacy Policy.

• Legal Obligations. We may also share your personal information to: (i) comply with applicable laws and regulations, to respond to a subpoena, search warrant or other lawful request for information we receive, or to otherwise protect our rights, (ii) enforce the Terms or to protect the security or integrity of the Services; (iii) detect, suppress or prevent fraud or reduce credit risk and collect debts owed to us; and/or (iv) exercise or protect the rights, property, or personal safety of our company, our uses, Site visitors, or other third parties.

• Consent. We may disclose your personal information to other third parties with your consent.

4. Consent to Processing.

• Our Service is operated in the United States of America. If you are located in the European Union, Canada or elsewhere outside of the United States, please be aware that personal information we collect will be transferred to and processed in the United States. By using the Service, or providing us with any personal information, you fully understand and unambiguously consent to this 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/or are a citizen.

• If you are an individual in the European Economic Area (EEA), we collect and process personal information about you only where we have legal basis for doing so under applicable EU laws.  The legal basis depends on the manner in which you use the Services. This means we collect and use your personal information only where: (i) we need it to provide you access and use of the Service, including to operate the Services, provide customer support and personalized features, and to protect the safety and security of the Services and its users; (ii) it satisfies a legitimate interest (which is not overridden by your data protection interests), such as for research and development, to market and promote the Service and to protect our legal rights and interests; (iii) you give us consent to do so for a specific purpose; or (iv) we need to process your personal information to comply with a legal obligation.

• If you have consented to our use of personal information for a specific purpose, you have the right to change your mind at any time, but this will not affect any processing that has already taken place.  Where we are using your personal information because we or a third party have a legitimate interest to do so, you have the right to object to that use, though, in some cases, this may mean no longer using the Services. 

• By using the Service you understand that your personal information may be transferred to countries outside of your country of residence, including the United States, which may have data protection rules that are different from those of your country.  In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your personal information.

• You are the controller of any information that is entered during and as part of your use of the Services and we are the processor of that information on your behalf. We will process the information according to your instructions, which you give us in the process of using the Services.

• If you reside in the EEA and we do not seek your explicit consent to process your personal information, we are relying on the legitimate commercial interest of our company in providing the Service to you and other customers and the need to process your personal information, as previously described, in order to accomplish that legitimate interest. Where data processing is occurring based on the basis of your consent, you also have the right to withdraw consent and request that we halt processing at any time. This withdrawal of consent does not invalidate the consent-based processing that occurred prior to withdrawal.

• Our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it. However, we will normally collect or process personal information from you only where we have your consent to do so, where we need the personal information to perform a contract with you, or where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. In some cases, we may also have a legal obligation to collect personal information from you or may otherwise need the personal information to protect your vital interests or those of another person.

5. Security. The security of your personal information is important to us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security. We store and process your personal information using third-party servers located in data centers in the United States. Our third-party service providers employ administrative, physical, and technical safeguards, including firewalls and data encryption for sensitive information such as credit card numbers, designed to protect your information from unauthorized access. Your personal information will be kept on our servers or on those of our service providers and only those employees that require it for the purposes of their duties will have access to your personal information. If we learn of a systems security breach, we may attempt to notify you electronically if you have provided us with your contact information so that you can take appropriate protective steps. By using the Services, you agree that we may communicate with you electronically. We will also post a notice on the Site or through the Services if a security breach occurs.

8. Control of Your Personal Information. We will maintain your personal information for as long as needed in order to perform the purposes for which such personal information was collected. You will be able to access, update and/or delete your personal information as set forth herein.  You may also request at any time to access or update your personal information, or that we delete any of your personal information stored by us, by contacting us as provided below. Following any such request, we will take all reasonable steps to provide, modify and/or delete your personal information as soon as is practicable, but some information may remain in archived/backup copies for our records or as otherwise required by law. Where you have consented to our use of your personal information, you may withdraw that consent at any time and opt-out to further use by contacting as provided through one of the mediums as provided below.
   
   
9. Children. We are concerned about the safety and privacy of children who use the Internet.  We encourage the viewing of our Site by minors and/or children to be done with parental supervision.  Consistent with the Children’s Online Privacy Protection Act of 1998 (“COPPA”), we will never knowingly request personal information from anyone under the age of 13 without prior verifiable parental consent.  If we become aware that a child under 13 years old has provided us with personal information without verifiable parental consent, we will use our best efforts to remove such information from our files.  If a parent or guardian becomes aware that his or her child has provided us with personal information without verifiable parental consent, he or she should contact us.
   
   
10. California Residents.

• California Civil Code. Under California Civil Code Sections 1798.83-1798.84, California residents are entitled to ask us for a notice describing what categories of personal customer information we share with third parties or corporate affiliates for those third parties or corporate affiliates’ direct marketing purposes. That notice will identify the categories of information shared and will include a list of the third parties and affiliates with which it was shared, along with their names and addresses. If you are a California resident and would like a copy of this notice, please submit a written request to the address referenced below, Attn: California Privacy Rights.

• Personal Information of California Residents. Consistent with the “Personal Information We Collect” section above, we collect certain categories and specific pieces of information about individuals that are considered “Personal Information” in California (“CA Personal Information”). As detailed above, we may collect this CA Personal Information from you and other third parties. We collect, share and disclose CA Personal Information for the business and commercial purposes described in the “How We Use Your Personal Information”, “Sharing Your Personal Information” sections above. Subject to certain exceptions, as a California resident, you have the right to: (i) access your CA Personal Information; (ii) obtain deletion of your CA Personal Information; (iii) receive information about the CA Personal Information about you that we have “sold” (as such term is defined under California law) to third parties within the past 12 months; and (iv) opt-out of the “sale” of your CA Personal Information.

• Do Not Sell My Information. In addition to the above, California residents have the right to opt-out of the “sale” of their personal information, as such term is defined under the California Consumer Privacy Act. We do not sell your personal information at this time.

• Exercising Other California Consumer Rights. Should you wish to request the exercise of your other rights as detailed above with regard to your personal information, we will not discriminate against you by offering you different pricing or products, or by providing you with a different level or quality of products, based solely upon this request. Please see the “Contact Information” section below if you have questions or would like to exercise such rights.

9. Links to Third-Party Platforms. The Service may contain links to (or allow you to link to) other third-party services or websites. We do not control the information collection of third-party services or websites that can be reached through such links. This Privacy Policy only covers our privacy practices for the Site and Services. It does not apply to the practices of third-party websites, services, or applications, even those who we have partnered or integrated with. We encourage you to be aware when you are linking to a third-party service or website and to read the privacy statements of any third-party service or website that collects personal information. Third-party services handle your information in accordance with their own practices and privacy policies. We are not responsible for their policies, practices, or handling of your personal information.

10. Modifications. We may update this Privacy Policy from time to time in order to reflect, for example, changes to our practices or for other operational, legal or regulatory reasons. As such, we encourage you to periodically review this page for the latest information on our privacy practices as well as the Terms for any modification thereof. However, we will not use your personal information in a way that is materially different from the uses described in this Privacy Policy without giving you an opportunity to opt-out. If we make a material change to the way in which we collect, use, and/or share your personal information, we will send an email to users who have provided an email address and/or change the “Effective as of” date at the top of this Privacy Policy.

12. Opt-Out. You can always choose whether or not to provide information on this Site.  If at any time you decide that you no longer want us to have your personal information, you may indicate this preference by emailing info@torchlight.ai.