PRIVACY POLICY

Torque Treasure (“Torque Treasure,” “we,” “us,” or “our”) respects your privacy and is committed to protecting your personal information.

This Privacy Policy explains how we collect, use, disclose, retain, and protect personal information when you visit or use our website, purchase products from us, create an account, contact customer service, interact with our advertisements or communications, or otherwise interact with our services (collectively, the “Services”).

For purposes of this Privacy Policy, “you” and “your” means any individual who visits or uses our Services or whose personal information we process in connection with the Services.

This Privacy Policy is intended to provide transparency regarding our privacy practices and to describe privacy rights that may be available to you under applicable law.

1. WHO WE ARE

Torque Treasure

Website: www.torque-treasure.com

Customer Service: care@torque-treasure.com

Returns: return@torque-treasure.com

Business Address: 7901 4TH ST N, ST PETERSBURG, FL 33702

For purposes of applicable privacy laws, Torque Treasure may act as the business, controller, or similar entity responsible for determining how and why certain personal information is processed.

2. INFORMATION WE COLLECT

The personal information we collect depends on how you interact with our Services.

We may collect the following categories of information.

2.1 Identifiers and Contact Information

This may include:

• Name;
• Email address;
• Telephone number;
• Billing address;
• Shipping address;
• Account username;
• Other contact information you provide.

2.2 Commercial and Transaction Information

This may include:

• Products purchased or considered;
• Order history;
• Order numbers;
• Returns and exchanges;
• Refund information;
• Shipping information;
• Customer service interactions;
• Warranty or product claims;
• Promotional or discount-code usage;
• Information concerning transactions with us.

2.3 Account Information

If you create an account, we may collect information necessary to establish and maintain that account, including:

• Login information;
• Account preferences;
• Account activity;
• Security-related information.

We do not intentionally collect passwords in plain text.

2.4 Payment Information

Payments may be processed by third-party payment providers.

Depending on the payment method used, payment processors may collect information such as:

• Payment-card information;
• Bank account information;
• Billing information;
• Payment authorization information;
• Transaction identifiers.

Where payment information is processed by a third-party payment provider, that provider may process the information under its own privacy policy and security practices.

We generally do not need to receive or retain complete payment-card information in order to process your order.

2.5 Customer Support and Communications

When you contact us, we may collect information contained in your communication, including:

• Emails;
• Chat messages;
• Telephone communications;
• Photos or videos you provide;
• Product information;
• Vehicle information;
• Order information;
• Shipping information;
• Other information you voluntarily provide.

We use this information to respond to your request, investigate issues, provide customer support, and maintain appropriate business records.

2.6 Device and Usage Information

When you visit our Website, certain information may be collected automatically.

This may include:

• IP address;
• Browser type;
• Device type;
• Operating system;
• Language preferences;
• General geographic information derived from IP address;
• Referring website;
• Pages viewed;
• Links clicked;
• Search activity on the Website;
• Date and time of visits;
• Session information;
• Other technical information concerning your interaction with our Website.

2.7 Cookies and Similar Technologies

We and our service providers may use cookies, pixels, tags, scripts, web beacons, local storage, and similar technologies.

These technologies may be used for:

• Essential Website functionality;
• Shopping-cart functionality;
• Checkout;
• Authentication;
• Security;
• Remembering preferences;
• Analytics;
• Measuring Website performance;
• Advertising;
• Marketing;
• Understanding how visitors interact with our Services.

The specific cookies and technologies used on our Website may change over time.

Because Torque Treasure uses Shopify to power the online store, Shopify may place certain cookies and technologies on the storefront as part of providing the platform and its services. Shopify publishes additional information about cookies used on merchant storefronts in its Cookie Policy.

3. HOW WE COLLECT PERSONAL INFORMATION

We may collect personal information from the following sources:

Directly from you

For example, when you:

• Place an order;
• Create an account;
• Subscribe to marketing communications;
• Contact customer service;
• Submit a return or warranty request;
• Submit a review or other content;
• Participate in a promotion;
• Otherwise provide information to us.

Automatically

For example, through:

• Cookies;
• Pixels;
• Web beacons;
• Server logs;
• Device information;
• Similar technologies.

From service providers

We may receive information from companies that provide services to us, such as:

• Shopify;
• Payment processors;
• Shipping and fulfillment providers;
• Fraud-prevention providers;
• Customer-service platforms;
• Analytics providers;
• Advertising and marketing providers.

From third parties

We may receive information from other third parties where permitted by law, including advertising, marketing, social-media, fraud-prevention, or business partners.

4. HOW WE USE PERSONAL INFORMATION

We may use personal information for the following purposes.

Providing and fulfilling orders

We may use information to:

• Process orders;
• Process payments;
• Verify transactions;
• Fulfill purchases;
• Arrange shipping;
• Provide tracking information;
• Process returns and refunds;
• Provide warranty or product assistance;
• Communicate about transactions.

Customer service

We may use information to:

• Respond to inquiries;
• Investigate complaints;
• Resolve shipping or product issues;
• Communicate with customers;
• Maintain customer-service records.

Account administration

We may use information to:

• Create and manage accounts;
• Authenticate users;
• Maintain account preferences;
• Provide account-related services.

Security and fraud prevention

We may use information to:

• Detect fraud;
• Investigate suspicious transactions;
• Prevent abuse;
• Protect our Website;
• Protect customers and employees;
• Maintain system security;
• Investigate potentially unlawful activity.

Marketing and advertising

Where permitted by law and consistent with your privacy choices, we may use personal information to:

• Send promotional communications;
• Provide offers;
• Advertise our products;
• Measure advertising effectiveness;
• Personalize marketing;
• Understand customer interests;
• Conduct marketing analytics.

You may unsubscribe from promotional email communications at any time using the unsubscribe mechanism included in the communication.

Unsubscribing from marketing communications does not prevent us from sending transactional or service-related communications, such as order confirmations, shipping notifications, refund communications, or customer-service messages.

Analytics and service improvement

We may use information to:

• Understand Website usage;
• Analyze traffic;
• Improve our Website;
• Improve products and services;
• Diagnose technical problems;
• Measure performance;
• Develop new features.

Legal and compliance purposes

We may process information when reasonably necessary to:

• Comply with applicable laws;
• Respond to lawful legal requests;
• Establish, exercise, or defend legal claims;
• Enforce our Terms of Service;
• Protect our rights;
• Protect customers or others;
• Prevent fraud or unlawful conduct.

5. LEGAL BASES FOR PROCESSING

Depending on where you live and the law that applies, we may process personal information based on one or more of the following legal grounds:

• Performance of a contract;
• Taking steps at your request before entering into a contract;
• Compliance with legal obligations;
• Legitimate business interests;
• Your consent;
• Protection of rights and safety;
• Other lawful grounds permitted by applicable law.

Where consent is required, we will seek consent in accordance with applicable law.

Where we rely on consent, you may withdraw consent where applicable.

6. HOW WE DISCLOSE PERSONAL INFORMATION

We may disclose personal information to categories of recipients that help us operate our business and provide the Services.

These may include:

Shopify

Shopify provides the ecommerce platform that powers our online store and processes customer information on our behalf in connection with applicable Shopify services.

Shopify may process information as a service provider/processor for merchant services and may separately process information in connection with Shopify's own services, such as Shop or Shop Pay, subject to Shopify's applicable privacy policies.

Payment processors

We may disclose information to payment processors and financial-service providers to process payments, prevent fraud, and complete transactions.

Shipping and fulfillment providers

We may disclose information necessary to:

• Fulfill orders;
• Print shipping labels;
• Ship products;
• Provide tracking;
• Handle returns;
• Investigate delivery issues.

This may include your name, shipping address, telephone number, email address, order information, and tracking information.

Technology and service providers

We may disclose information to providers that help us operate our business, including:

• Hosting providers;
• Cloud storage providers;
• Customer-support platforms;
• IT providers;
• Security providers;
• Analytics providers;
• Communication providers.

Marketing and advertising providers

Where permitted by law, we may disclose or make available certain information to marketing, advertising, and analytics providers to:

• Deliver advertisements;
• Measure advertising performance;
• Understand customer interactions;
• Provide targeted or personalized advertising.

The specific providers used may change over time.

Professional advisors

We may disclose information to:

• Lawyers;
• Accountants;
• Auditors;
• Insurers;
• Financial advisors;
• Other professional advisors.

Government authorities and legal requests

We may disclose information when reasonably necessary to:

• Comply with applicable law;
• Respond to subpoenas or court orders;
• Respond to lawful government requests;
• Protect our rights;
• Investigate fraud;
• Protect the safety of our customers or others.

Business transactions

If Torque Treasure is involved in a merger, acquisition, financing, restructuring, sale of assets, bankruptcy, or similar transaction, personal information may be transferred as part of that transaction, subject to applicable law.

7. CATEGORIES OF PERSONAL INFORMATION DISCLOSED

Depending on how you interact with us, we may disclose the following categories of personal information to the categories of recipients described above:

Category	Examples	Potential Recipients
Identifiers	Name, email, phone number	Shopify, service providers, shipping providers, customer support providers
Customer records	Address, contact details	Shopify, payment providers, shipping providers
Commercial information	Orders, purchases, returns	Shopify, payment processors, fulfillment providers
Internet/network information	IP address, browser/device information	Shopify, analytics, security and advertising providers
Geolocation information	Approximate location derived from IP address	Shopify, analytics and security providers
Account information	Login and account information	Shopify and technology providers
Customer-support information	Communications and information you submit	Customer-support and technology providers
Transaction information	Payment confirmation and transaction identifiers	Payment processors and Shopify
User-generated content	Reviews, photos, messages	Platforms and service providers as necessary to provide the requested service

We do not disclose every category to every recipient.

The categories of information and recipients may vary depending on the Services you use and the requirements of applicable law.

8. SALE, SHARING, AND TARGETED ADVERTISING

Certain privacy laws define “sale” and “sharing” broadly.

If Torque Treasure uses advertising, analytics, or similar technologies that qualify as a “sale,” “sharing,” or targeted advertising under an applicable privacy law, you may have the right to opt out.

We do not sell personal information for money in the ordinary meaning of the term.

However, certain disclosures or transfers to advertising, analytics, or marketing partners may be considered a “sale” or “sharing” under certain privacy laws even when no money is directly exchanged for the personal information.

Where applicable law gives you the right to opt out, we will provide an appropriate method for exercising that right.

Where supported by our Shopify configuration and required by applicable law, we may recognize Global Privacy Control (“GPC”) or another recognized universal opt-out preference signal as a request to opt out of applicable sale, sharing, or targeted advertising.

You can learn more about GPC at:

https://globalprivacycontrol.org/

Important: The actual operation of opt-out signals depends on the privacy and consent tools configured on our Shopify store. We do not represent that every browser signal is recognized for every purpose.

9. SENSITIVE PERSONAL INFORMATION

Depending on how you interact with us, we may process certain information that could qualify as “sensitive personal information” or “sensitive data” under applicable law.

Examples may include information necessary for account security, precise geolocation where collected, or other categories defined as sensitive under applicable law.

We do not intentionally request sensitive personal information unless reasonably necessary for a specific business, legal, security, or service-related purpose.

We do not use sensitive personal information for purposes prohibited by applicable law.

Where applicable law requires consent or provides a right to limit certain uses of sensitive personal information, we will provide the applicable mechanism.

10. DATA RETENTION

We retain personal information only for as long as reasonably necessary for the purposes described in this Privacy Policy, including to:

• Complete transactions;
• Provide Services;
• Maintain business and transaction records;
• Provide customer support;
• Resolve disputes;
• Prevent fraud;
• Comply with legal obligations;
• Enforce agreements;
• Protect our rights.

Retention periods vary depending on the type of information, the purpose for which it was collected, legal requirements, and legitimate business needs.

When personal information is no longer reasonably required, we may delete, anonymize, aggregate, or otherwise dispose of it in accordance with applicable law and our retention practices.

11. DATA SECURITY

We use reasonable administrative, technical, and organizational safeguards designed to protect personal information against unauthorized access, loss, misuse, alteration, or disclosure.

These measures may include access controls, authentication, service-provider security controls, and other safeguards appropriate to the nature of the information.

However, no method of transmission over the Internet or electronic storage is completely secure.

We therefore cannot guarantee absolute security.

If we become aware of a data security incident that triggers notification obligations under applicable law, we will provide notices as required by law.

12. YOUR PRIVACY RIGHTS

Depending on where you live and which laws apply, you may have some or all of the following rights.

Right to Know or Access

You may have the right to request information about:

• Whether we process your personal information;
• The categories of information we collect;
• The purposes for which we use it;
• The categories of recipients to whom we disclose it;
• Certain specific pieces of personal information we maintain about you.

Right to Correct

You may have the right to request correction of inaccurate personal information.

Right to Delete

You may have the right to request deletion of personal information we maintain about you, subject to legal exceptions.

For example, we may need to retain certain information to complete a transaction, comply with law, prevent fraud, resolve disputes, or exercise legal rights.

Right to Data Portability

Where applicable, you may have the right to receive certain personal information in a portable format.

Right to Opt Out

Depending on applicable law, you may have the right to opt out of:

• Sale of personal information;
• Sharing of personal information;
• Targeted advertising;
• Certain profiling activities;
• Other processing activities identified by applicable law.

Right to Limit Certain Uses of Sensitive Personal Information

California consumers may have a right to limit certain uses and disclosures of sensitive personal information where provided by the CCPA.

Right to Withdraw Consent

Where processing is based on consent, you may withdraw consent where permitted by law.

Right to Appeal

Where applicable law provides a right to appeal our decision regarding a privacy request, you may appeal by contacting us using the information below.

Right to Non-Discrimination

Where applicable law provides this right, we will not discriminate against you for exercising your privacy rights.

13. HOW TO SUBMIT A PRIVACY REQUEST

To submit a privacy request, please contact us at:

care@torque-treasure.com

Subject line:

Privacy Request

Please identify the right you are seeking to exercise and provide enough information for us to reasonably understand and process your request.

Depending on the request and applicable law, we may need to verify your identity before providing information or completing certain requests.

We will only request information reasonably necessary to verify the identity or authority of the person making the request.

You generally do not need to create an account solely to submit a privacy request where applicable law prohibits us from requiring one.

We will respond within the timeframe required by applicable law.

14. AUTHORIZED AGENTS

Where permitted by applicable law, you may authorize another person to submit a privacy request on your behalf.

We may require:

• Proof of authorization;
• Verification of the authorized agent's identity;
• Verification of your identity;
• Other information reasonably necessary to protect against unauthorized requests.

15. CALIFORNIA PRIVACY RIGHTS

This section applies to California residents to the extent the California Consumer Privacy Act, as amended (“CCPA”), applies to Torque Treasure and their personal information.

California residents may have rights including:

• Right to Know;
• Right to Delete;
• Right to Correct;
• Right to Opt Out of Sale or Sharing;
• Right to Opt Out of Certain Targeted Advertising;
• Right to Limit Certain Uses and Disclosures of Sensitive Personal Information;
• Right to Non-Discrimination.

California consumers may submit requests using the privacy contact information above.

Where Torque Treasure is required to provide a “Notice at Collection,” we may provide that notice at or before the point at which personal information is collected, including through checkout, forms, cookie banners, or other applicable interfaces.

The CCPA requires certain businesses to provide a comprehensive privacy policy describing their practices and consumer rights.

Where applicable, we will maintain and provide the required disclosures regarding categories of personal information collected, purposes of use, categories of recipients, retention information, and applicable consumer rights.

16. NEW JERSEY PRIVACY RIGHTS

This section applies to New Jersey residents to the extent the New Jersey Data Privacy Act (“NJDPA”) applies to Torque Treasure.

New Jersey consumers may have rights to:

• Confirm whether personal data is being processed;
• Access personal data;
• Correct inaccuracies;
• Delete personal data;
• Obtain a portable copy of personal data;
• Opt out of targeted advertising;
• Opt out of the sale of personal data;
• Opt out of certain profiling activities that produce legal or similarly significant effects.

The NJDPA also requires applicable controllers to provide a reasonably accessible privacy notice describing categories of personal data processed, purposes, categories of third parties, categories of personal data disclosed, consumer rights, and how consumers can exercise those rights.

Torque Treasure does not use consumer personal information to make decisions concerning employment, housing, credit, insurance, or other similarly significant matters.

17. OTHER U.S. STATE PRIVACY RIGHTS

Other U.S. states may provide privacy rights to their residents.

Depending on the state in which you live, you may have rights relating to:

• Access;
• Correction;
• Deletion;
• Portability;
• Opting out of targeted advertising;
• Opting out of sale of personal information;
• Opting out of profiling;
• Limiting certain processing of sensitive information;
• Appeals.

Where a state privacy law applies to Torque Treasure, we will provide the rights and mechanisms required by that law.

Because state privacy laws and applicability thresholds can change, the rights available to you may depend on your location, the nature of your relationship with us, and the law applicable to the processing.

18. CHILDREN'S PRIVACY

Our Services are not directed to children under 13.

We do not knowingly collect personal information from children under 13.

If you believe that a child under 13 has provided personal information to us, please contact us so that we can investigate and take appropriate action.

Where applicable law provides additional protections for minors, we will comply with those requirements.

We do not knowingly sell or share personal information of children under 16 for purposes prohibited by applicable law.

19. THIRD-PARTY WEBSITES AND SERVICES

Our Website may contain links, integrations, applications, payment options, social-media features, advertisements, or other services operated by third parties.

Third-party services may collect information directly from you and may have their own privacy policies.

Examples may include:

• Shopify;
• Payment providers;
• Shipping providers;
• Google services;
• Meta services;
• Social-media platforms;
• Analytics providers;
• Advertising platforms;
• Review platforms.

We encourage you to review the privacy policies of third parties before providing them with personal information.

We are not responsible for the independent privacy practices of third parties except where applicable law provides otherwise.

20. SHOPIFY

Our online store is powered by Shopify.

Shopify may process customer information on our behalf as a service provider or processor in connection with operating the store.

Shopify also operates separate consumer services, such as Shop and Shop Pay, that may have their own privacy practices.

For information about Shopify's handling of information in connection with merchant storefronts, customers may review Shopify's applicable privacy information.

Shopify states that when a consumer visits or purchases from a Shopify-powered merchant store, the merchant generally controls the consumer information processed for that merchant, while Shopify may act as a processor for merchant-directed processing.

21. COOKIES AND PRIVACY CONTROLS

We may use cookies and similar technologies necessary for the Website to function and, where permitted, for analytics, personalization, advertising, and marketing.

Depending on your location, we may provide a cookie banner, privacy settings, opt-out mechanism, or other privacy controls.

You may also be able to control cookies through your browser.

Blocking essential cookies may affect Website functionality.

Shopify provides merchants with privacy tools that can include cookie banners, opt-out pages, regional privacy settings, and privacy preference controls.

The availability and operation of these tools depends on the settings and applications configured on our store.

22. EMAIL AND MARKETING COMMUNICATIONS

We may send transactional and promotional communications.

Transactional communications may include:

• Order confirmations;
• Shipping notifications;
• Delivery updates;
• Return communications;
• Refund notices;
• Customer-service responses;
• Account notices;
• Security notices.

You may opt out of promotional communications by using the unsubscribe mechanism included in those communications.

Opting out of marketing communications does not prevent us from sending necessary transactional or service-related communications.

23. TEXT MESSAGE / SMS COMMUNICATIONS

If you separately consent to receive SMS or text messages from Torque Treasure, we may use your telephone number to send the communications for which you provided consent.

Message frequency may vary.

Message and data rates may apply depending on your mobile carrier.

You may opt out of marketing text messages by following the opt-out instructions contained in the applicable message.

Opting out of promotional SMS communications does not necessarily stop transactional or service-related communications that are permitted by law.

24. INTERNATIONAL DATA TRANSFERS

Torque Treasure and our service providers may process or store personal information in countries other than the country where you live.

These countries may have privacy laws that differ from those in your jurisdiction.

Where applicable law requires specific safeguards for international transfers, we will use appropriate legal mechanisms.

For individuals located in the European Economic Area, United Kingdom, or Switzerland, where applicable, we may rely on mechanisms recognized under applicable data-protection law, such as adequacy decisions or Standard Contractual Clauses.

25. EUROPEAN PRIVACY RIGHTS

If you are located in the European Economic Area, United Kingdom, or Switzerland and applicable data-protection law applies to our processing, you may have rights including:

• Access;
• Correction;
• Deletion;
• Restriction of processing;
• Data portability;
• Objection to certain processing;
• Withdrawal of consent;
• Complaint to an applicable supervisory authority.

Where we rely on legitimate interests as a legal basis, you may have the right to object to that processing in accordance with applicable law.

If you are located in one of these jurisdictions, additional disclosures may apply depending on the Services you use and our relationship with you.

26. DATA PROCESSING AND SERVICE PROVIDERS

We may use third-party service providers to process information on our behalf.

Depending on the Services used, these providers may include:

• Ecommerce platforms;
• Payment processors;
• Shipping providers;
• Fraud-prevention providers;
• Email providers;
• SMS providers;
• Customer-support platforms;
• Analytics providers;
• Advertising platforms;
• Cloud-storage providers;
• IT and security providers.

We seek to use providers appropriate to the services they perform and require appropriate contractual or technical protections where required by applicable law.

27. BUSINESS RECORDS AND LEGAL RETENTION

We may retain certain personal information longer than other information where reasonably necessary to:

• Meet tax obligations;
• Maintain accounting records;
• Document transactions;
• Defend against claims;
• Resolve disputes;
• Detect fraud;
• Enforce agreements;
• Comply with legal requirements.

Legal retention requirements may prevent immediate deletion of certain information even when a customer submits a deletion request.

28. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time to reflect:

• Changes to our business;
• Changes to our Services;
• Changes to technology;
• Changes to privacy practices;
• Changes to applicable laws;
• Regulatory developments.

When we make material changes, we will update the “Last Updated” date and provide any additional notice required by applicable law.

We encourage you to review this Privacy Policy periodically.

29. CONTACT US

If you have questions about this Privacy Policy, our privacy practices, or wish to exercise a privacy right, please contact us:

Torque Treasure

Customer Service: care@torque-treasure.com

Returns: return@torque-treasure.com

Website: www.torque-treasure.com

Business Address: 7901 4TH ST N, ST PETERSBURG, FL 33702

When submitting a privacy request, please use the subject line:

Privacy Request

We will process privacy requests in accordance with applicable law.