Privacy Policy for TorchFi Sync

Effective Date: June 10th 2021

This “Privacy Policy” explains how TorchFi, Inc. (“Company” or “we”) collects, uses, discloses, and otherwise processes personal data on behalf of our customers – typically, merchants (any, a “Merchant”) – in connection with our application, TorchFi Sync, which runs on the Clover Point of Sale system (“Clover POS”). This Privacy Policy does not apply to Company’s privacy practices in any other context.

Company’s processing of personal data in connection with our application is governed by this Privacy Policy and our agreements with Merchants. In the event of any conflict between this Privacy Policy and a customer agreement, the customer agreement will control to the extent permitted by applicable law.

This Privacy Policy is not a substitute for any privacy policy that a Merchant may be required to provide to their customers, personnel, or other individuals.

Information We Collect

We may collect personal data from or on behalf of Merchants. Merchants determine the scope of the personal data transferred to us or that we collect, and the information we receive may vary by Merchant. Typically, the information we collect on behalf of Merchants includes:

Information that we collect when the Merchant installs our app

When Merchant installs the TorchFi Sync app, it reads the order type data and payment data configurations on the merchant’s Clover POS account. It also creates a new order type and payment tender type named TorchFi. The Company doesn’t read/ write or store any other data from Clover POS Merchant account.

Information that we collect when the Merchant imports inventory data into TorchFi platform

When the Merchant imports the inventory data into TorchFi platform, the entire inventory information along with business hours and tax information is ready by TorchFi. This data is then transferred and stored on TorchFi platform.

Information that we collect when the Merchant’s customer places an order on Company’s platform

When a customer makes a payment and places an order with the Merchant on Company’s platform, the order data along with customer information is stored by the Company. The data includes but is not limited to the list of items purchased, date and time of order, date and time of delivery, table number, transaction amount, customer name, mobile number, email address, delivery address and any additional instructions included by the customer. This data is stored on both the Company’s platform as well as Clover POS.

How We Use the Information We Collect

We use the personal data we collect for or on behalf of Merchants, to provide our services and the functionality of our application:

We may also use personal data for related internal purposes, including:

In addition, Company may use personal data as we believe necessary or appropriate to (a) comply with applicable laws and lawful requests and legal processes, such as to respond to subpoenas or requests from government authorities; (b) enforce the terms and conditions that govern our application; (d) protect our rights, privacy, safety or property, and/or that of you or others; and (e) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity.

How We Share Information

We may share personal data that we collect with:

Company may disclose personal data to government or law enforcement officials or private parties as required by law, and disclose and use such information as we believe necessary or appropriate to (a) comply with applicable laws and lawful requests and legal processes, such as to respond to subpoenas or requests from government authorities; (b) enforce the terms and conditions that govern our application; (d) protect our rights, privacy, safety or property, and/or that of you or others; and (e) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity.

Company may sell or transfer some or all of its business or assets, including your personal data, in connection with a business transaction (or potential business transaction) such as a merger, consolidation, acquisition, reorganization or sale of assets or in the event of bankruptcy, in which case we will make reasonable efforts to require the recipient to honor this Privacy Policy.

Your Rights and Choices

Data Subject Rights

To the extent that applicable law provides individuals with rights pertaining to their personal information, such as to review and request changes to their personal information, individuals should contact the Merchant with any requests pertaining to the Merchant’s use of our application. To the extent that Clover is responsible for responding to data subject rights requests under applicable law, individuals may contact Clover with applicable requests as explained in Clover’s Privacy Notice,https://www.clover.com/privacy-policy. Company will assist a Merchant, or Clover, as applicable, in responding to such requests subject to our contract with a Merchant or Clover.

Complaints

If you have a complaint about our handling of personal data, you may contact us via the contact information provided below.

Updates

We reserve the right to modify this Privacy Policy at any time. We will notify you of updates by updating the date of this Privacy Policy.

Contact Us

You may contact us with any questions, comments, or complaints, about this Privacy Policy or our privacy practices via: email to support@torchfi.com