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PRIVACY POLICY

EFFECTIVE DATE: MARCH 7, 2024

Introduction‍

Welcome to the TORBU Privacy Policy. This Privacy Policy applies to the torbu.com and our TORBU mobile app (collectively, the “Platform” or “TORBU Platform”). The TORBU Platform is owned and operated by TORBU LLC, a Delaware limited liability company (“TORBU”, “we”, “our”, or “us”).  We have created this Privacy Policy to tell you what information is collected through the Platform and how we collect, use, disclose, and protect that personal information. This Privacy Policy does not address the privacy practices of any third parties that we do not own, control, or operate. TORBU supports the most critical processes of organizational collaboration, and we are committed to the protection for personal information. By visiting and/or using the Platform, you agree to the terms of this Privacy Policy and the accompanying Terms of Service. By visiting and/or using the Platform you are also expressly acknowledging that your information will be processed in the United States of America in accordance with this Privacy Policy. We encourage you to read the Privacy Policy, and to use the information it contains to help you make informed decisions.

This Privacy Policy governs all the manners in which TORBU collects personal information from or about you as an individual through the Platform, whether you are a visitor to our website, request a trial of the Platform, or are a user of our mobile app. How the information is collected and used may differ based on our relationship with you. We have identified below the different relationships we may have with you, and our respective use of information we collect.

For purposes of this Privacy Policy, “End-User” refers to any user who has registered an account (“Account” or “TORBU Account”) on the TORBU Platform as an agent, employee or other end user of our Customer. “Customer” refers to any organization with a TORBU Account.

‍When a Customer’s privacy policy governs: If you are an End-User of our Customer and you are using the Platform through our Customer , we are collecting and processing your personal information to provide the TORBU Platform services on our Customer’s behalf and are considered a “data processor.” In these cases, your organization’s privacy policy or privacy notice governs the use of any personal information. Our Privacy Policy does not supersede the terms of any agreements between us and your organization, nor does it affect the terms of any agreement between the End-User and the End-User’s organization.

HEALTH INFORMATION

TORBU is not subject to the health insurance portability and accountability act of 1996, as amended, (“HIPAA”). This means that TORBU is not bound by HIPAA to protect health information that you provide to us in the same manner that your doctor is required to protect information you may provide to him or her.

‍What Information We Collect and How We Use It‍

The nature of the personal information we collect and how we use it depends on the context in which we collect that personal information. Please see the section below that applies to you.

The Platform is not intended for the collection, storage or maintenance of Social Security Numbers or other sensitive personal information. Customers should not request, and End-Users should not provide Social Security Numbers or other sensitive personal information via the Platform. TORBU disclaims all responsibility for the listing of any Social Security Numbers on the Platform.

‍WEBSITE USERS

‍You may visit the TORBU website without having to log in or provide any personal information. However, if you are on the TORBU website to access a service or product, you may need to log in to make use of the functionality of the particular product.

‍Information We Collect

‍Directly from you. We collect information, including personal information, from or about you when you directly submit that information to us. For example, you may provide information when you register or log in to your Account through the TORBU website , when you complete and submit a form (e.g., to “contact,” “request,” or “apply”) on the TORBU website, or when you email us. This information may include your full name, email address, position or organization affiliation, telephone number, professional or employment-related information (e.g., information from your resume), and any other information you choose to provide to us.

Indirectly from you. We may use cookies, tracking technologies, and other third-party analytics tools to collect information about the pages you visit and how you access and use the TORBU Platform. This information will be collected on servers which may be hosted by a third-party service provider. This information may include information about the devices you use to access the TORBU Platform, including unique device identifiers, IP address, operating system, browser type, access time and date, and other user actions. Depending on your device settings, we may also collect information about your approximate geographical location. We use this information to better understand our Customers and users and to develop and improve the Platform. You can learn about our use of cookies and how to set your preferences in our “Cookie Statement” in this Privacy Policy.

‍How We Use This Information

‍We use the information collected to provide and improve the Platform and to analyze usage information for sales and marketing purposes. This analysis is necessary to understand our users and their interactions with us and the Platform so that we can best iterate and improve on our website and communications, including marketing purposes.

We also use the information collected to respond to your requests, to communicate with you in any manner that you have requested, or to perform activities for other purposes described to you at the point of collection. For example, if you submit a job application for a TORBU position through the Platform, we may use information you submitted to evaluate and respond to your application.

‍How We Share This Information

‍We use third-party service providers to help provide our website. For example, we use a third party hosting provider to host the website. We also use third party analytics tools to help us understand how the TORBU Platform is used. We may share your information with these parties so that they can perform the services for which we have engaged them. Learn more about our use of cookies in our “Cookie Statement” in this Privacy Policy.

‍CUSTOMER PERSONNEL

‍If you are an agent or employee of a TORBU Customer that has granted you access to the TORBU Platform, we may collect personal information from you as you use the TORBU Platform.  We are providing the Platform directly to your organization. Your organization through which you interact with the Platform is the “data controller” for purposes of the personal information collected in connection with the Customer Account(s).

‍Information We Collect

‍Directly from you. We collect information necessary to provide the Platform. The information collected from you depends on each Customer’s specific requests and what is needed to integrate with your systems and to set up and maintain Accounts. This includes information in the following data categories:‍

Account information: The exact elements will depend on what specific information you as a Customer provide us, including records of users, such as names and email addresses.‍

Customer Information: We also collect user account information, including usernames and passwords, email addresses, mailing addresses, telephone numbers, websites, and titles to initially set up the Platform for you.If you choose to use the communication feature on the Platform to communicate with your fellow end-users, including to send images or media files, we will also collect, store, and archive your communication logs.

Supervisor Accounts may monitor and review accounts.If you choose to connect an account from a third-party website, such as a Google+ account, through the Platform, we may collect any information you have authorized that third party to share with us in accordance with the third party’s privacy practices. Please review the “Links to Other Sites” section of this Privacy Policy for more information about third-party websites.

Indirectly from you. We may collect device and usage information when you access and use the Platform, including information that your browser or mobile app sends when you are using it. This information may include your unique device identifier, IP address, your browser type and configuration, the date and time of your use of the Platform, and other user actions. We use cookies and other automated data collection tools to collect this information. Learn more about our use of cookies in our “Cookie Statement” in this Privacy Policy.

‍How We Use This Information

‍We use your information to provide you the features and functionality of the TORBU Platform, as well as to communicate directly with you and allow you to communicate with other TORBU users. It is necessary for us to use your information in this manner in order to provide you with the services your organization  has requested pursuant to its agreement with TORBU. We will use your information to provide you with news and information about Platform updates, including to send you notices or disclosures. We may also use de-identified and aggregated information for any purpose, including to understand and improve our Platform. We do not provide any user data or personally identifiable information to any third parties for those third parties’ marketing purposes.

‍How We Share This Information

‍We share information to provide the TORBU Platform to you and further improve it. Within TORBU, your information will be accessed only by those who have a need to provide the TORBU Platform. We use vendors to help us provide the TORBU Platform to your organization. For example, we use a third party provider of cloud hosting facilities. Third-party analytics tools may also have access to your personal information to help us understand how the TORBU Platform is being used. Learn more about our use of cookies and analytic tools in our “Cookie Statement” in this Privacy Policy.

‍Customer Personal Information

‍TORBU is a “data processor” with respect to personal information and the TORBU Customer is the “data controller.” Where a TORBU Customer enters into an agreement with TORBU to access and use the Platform, that TORBU Customer acknowledges that TORBU is a data processor with respect to personal information received from that TORBU Customer, including personal information received from or about an athlete connected to that Customer’s Account.

Personal Information Ownership: All personal information remains the property of and is solely owned and controlled by our TORBU Customers. TORBU will only use personal information for the purposes of providing the Platform that our Customers have contracted with us to provide and we will process personal information according to instructions and the terms of our contract with our Customers. We may aggregate and de-identify personal information and use such aggregate and de-identified information for any purpose, including to understand and improve our Platform. Personal information will not be used for targeted advertising by TORBU or any of its third-party service providers. If you access or use the Platform on behalf of another person or entity and you submit information about that person or entity, you represent that you have the legal authority to disclose that information to us.

‍OTHER END USERS

‍The Customer decides how your personal information is used. TORBU provides productivity and performance management services to End-Users as a “data processor.” The main responsibility of what is known as a “data controller” lies with the organization. This also means that the Customer’s own privacy policy governs the use of such personal information. TORBU’s Customers determine what information we collect through the TORBU Platform and how it is used, and we process that information according to our Customer’s instructions and the terms of our contract with our Customer.

If our Customer is a school, school district, college, or university, we will manage End-User information in accordance with the Family Educational Rights and Privacy Act of 1974 (including its implementing regulations, “FERPA”) that govern the confidentiality of, and access to, educational records. TORBU is committed to abide by state and federal laws protecting personal data.How information is used depends on the organization, so please consult your institution’s privacy policy.

‍Information We Collect

‍Directly from the Customer or another End-User. This information includes but is not limited to name and email address, and additional records as provided by the organization. Managers may also provide additional information about a member, such as learning and performance assessments. TORBU will receive regular updated information to keep account information Accurate and up to date.

Directly from a individual. This information includes but is not limited to additional records as requested by the organization. An individual may also choose to submit information such as responses to TORBU surveys or personal goals and progress updates. TORBU will receive regular updated information to keep Account information accurate and up to date.

If you choose to use the communication feature on the Platform to communicate with your coach, including to send images or media files, we will also collect, store, and archive your chat logs. Supervisor Accounts may not participate in communication, but the chat logs may also be monitored and reviewed by these Accounts.

If you choose to connect an account from a third-party website, such as a Google+ account, through the Platform, we may collect any information you have authorized that third party to share with us in accordance with the third party’s privacy practices. Please review the “Links to Other Sites” section of this Privacy Policy for more information about third-party websites.

Indirectly from a individual. We collect device and usage information when you access and use TORBU Platform, including information that your browser or mobile app sends when you are using it. This data may include your IP address, your browser type, the date and time of your use of the Platform, and other user action data. We use cookies and other automated data collection tools to collect this information.  Learn more about our use of cookies in our “Cookie Statement” in the Privacy Policy.

‍How We Use This Information

‍We use your information on behalf of the organization which is the data controller. We use the information in accordance with our agreement with the Customer to operate, maintain, and provide the features and functionality of the TORBU Platform.

‍How We Share This Information

‍We share information in accordance with our agreement with the Customer. Within TORBU, your information will be accessed only by those who have a need to provide the TORBU Platform. We use vendors to help us provide the TORBU Platform to your organization. For example, we use a third party provider of cloud hosting facilities. Third-party analytics tools may also have access to your personal information to help us understand how the TORBU Platform is being used. Learn more about our use of cookies and analytic tools in our “Cookie Statement” in this Privacy Policy.‍

Other Disclosures‍

We may also share your information under the following circumstances:

We may disclose your information in the course of a corporate transaction such as a merger, acquisition, sale of assets, financing, or other change of ownership or control, or pursuant to a bankruptcy, dissolution proceeding, or reorganization (in each case whether in whole or in part).

We may disclose your information as we deem necessary to comply with legal or regulatory requirements and to respond to lawful requests, court orders, and legal or governmental processes, or as needed to support external auditing, compliance, and corporate governance functions. Where such disclosures relate to personal information we hold as a data processor on behalf of our Customers, we will refer such requests to our Customers where permissible.

Whenever we believe that disclosing your information is necessary or advisable to protect and defend the rights, property, or safety of TORBU, our Customers, or third parties, including enforcing contracts or policies, or in connection with investigating and preventing fraud or other misuse of our systems.

We may utilize and disclose aggregated or de-identified (anonymized) information that is no longer associated with a person for any lawful purpose, including to enhance and promote the TORBU Platform. TORBU does not rent, sell, or otherwise provide access to athlete personally identifiable information to third parties for marketing or advertising purposes.

We may engage third-party companies and individuals to perform functions on our behalf. Examples may include providing technical assistance, Customer service, marketing assistance, and administration of promotional programs. These third-party service providers will have access to the information only as necessary to perform the functions for which we engage them and to the extent permitted by law.We may share information with other third parties when you consent or direct us to do so.‍

Marketing‍

We conduct marketing to promote the TORBU Platform, but do not use or disclose information (whether personal information or otherwise) about individuals that we collect through the provision of the TORBU Platform for marketing purposes.‍

Google Analytics and Advertising‍

We use Google Analytics and other third-party cookies to collect certain information about your visits to the TORBU Platform.  You can opt-out of third-party cookies from Google Analytics using the Google Analytics opt-out browser setting add-on or other ad management tools.  You can learn more about our use of cookies in our “Cookie Statement” in this Privacy Policy, and you can learn about managing your preferences.

‍Security

‍We use reasonable organizational and technical measures to protect the information provided to us or collected by us.

End-User data will be managed by TORBU in accordance with the Family Educational Rights and Privacy Act of 1974 (including its implementing regulations, “FERPA”) that govern the confidentiality of, and access to, educational records. TORBU is committed to abide by state and federal laws protecting personal data.

Although we do take what we consider appropriate steps to protect your data, protection of information available over the internet is subject to attack from third parties, and accordingly we cannot guarantee that third parties cannot illegally gain access to Content.‍

Cookie Statement‍

Like many companies, we use “cookies” to help make sure the Platform is meeting the needs of its users and to help us make improvements. A cookie is a piece of data stored on the user’s hard drive containing information about the user. Usage of a cookie will in no way be linked to any personally identifiable information while using the Platform. Once the user closes their browser, the cookie simply terminates. If a user rejects the use of cookies, they may still use the Platform, but certain parts or features of the Platform may be limited.

We use third-party cookies set by our service provider, Google Analytics, to collect and analyze information about how users interact with the Platform and to enhance your experience with TORBU. You can visit Google Analytics to learn more about Google Analytics’ use of cookies. You can visit Google Analytics for information on how to opt out of Google Analytics cookies.‍

“Do Not Track” Signals‍

TORBU does not currently take any action when we receive a “Do Not Track” request. Do Not Track is a privacy preference that you can set in certain web browsers to indicate that you do not want certain information about your webpage visits collected across websites when you have not interacted with that service on the page. For details, including how to turn on Do Not Track, visit www.donottrack.us.‍

Links to Other Sites‍

The TORBU platform may provide links to third-party websites or resources, such as YouTube links to resources displayed on the “Articles On Video” page of the Platform. The information practices of those third-party websites are not covered by this Privacy Policy or any other policies or terms applicable to the TORBU Platform. We have no control over the privacy practices or the content of those websites and accordingly are not responsible for the content or the privacy policies of those third-party websites. We recommend that you review any terms of use and privacy policy of any linked third-party website before providing any information.‍

Children‍

In general, the TORBU Platform is not directed to children under the age of 13 (“child” or “children”). TORBU does not knowingly collect personal information from any child under the age of 13 except in the limited circumstances described below when the TORBU Platform is being used by a Customer that is a school or school district (“School Customers”). Except as expressly permitted under a contract with one of our School Customers, we ask that minors (under the age of 13) not use the TORBU platform. If a child under the age of 13 has provided us with Personal Information, a parent or guardian of that child may contact us and request that such information be deleted from our records.

‍SCHOOL CUSTOMERS

‍TORBU may contract with School Customers who use the TORBU Platform for the benefits of their students, school or school system. Some School Customers desire to provide students who are under the age of 13 with direct access to the TORBU Platform as users. In these cases, we collect information from those child users and our School Customers act as the agent of parents and provide consent to the collection of children’s information on the parents’ behalf. TORBU uses children’s data only to provide the TORBU Platform for the use and benefit of the school and for no other commercial purpose. The notice in the following section applies to TORBU’s collection of children’s information in these circumstances.

‍CHILDREN’S PRIVACY NOTICE

‍If a School Customer has registered a student athlete or other student as a user of the TORBU Platform, TORBU may collect the following types of from that child when the child users the TORBU Platform:

  • Name
  • Email address
  • Username and password (if an Account is created)
  • Information submitted relating to surveys or personal goals
  • Content of messages sent through the Platform (e.g., through Team Chat, journal entries, goal tracking, or other features)
  • Device and usage information such as IP address, browser type, and the date and time the user uses the TORBU Platform

The TORBU Platform provides functionality to share information with other TORBU Platform users, for example by chatting with other members of the user’s team or class that also use the TORBU Platform. TORBU does not enable children to make their personal information publicly available.

TORBU uses the children’s information it collects to operate, maintain, and provide the features and functionality of the TORBU Platform on behalf of its School Customers.We may share children’s information with the following third parties:

  • Our third-party service providers to perform the functions for which we engage them, including but not limited to assisting us in providing functionality on the Platform;
  • To a successor in interest in the event of any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceeding);
  • To law enforcement or other third parties to comply with or respond to any legal obligation or process such as a subpoena, warrant, or court order; and
  • To law enforcement or other third parties to protect the rights, property, or safety of TORBU or any affiliate, our Customers, or others, or to enforce our legal rights.

Our School Customers may review the information we collect about their own students, including students under the age of 13 by contacting us at support@torbu.com.

‍California “Shine the Light” Law‍

California's "Shine the Light" law (Civil Code Section § 1798.83) permits users of the Platform that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to support@torbu.com.

‍Changes to This Privacy Policy‍

This Privacy Policy is effective as of the date stated at the top of this Privacy Policy. We reserve the right to modify the provisions of this Privacy Policy from time to time. By using the Platform after we make any such changes, you are deemed to have accepted such changes and consented to this Privacy Policy at the time of such use. We recommend that you check this Privacy Policy periodically for any changes. TORBU will provide notice on the Platform prior to any material changes to this Privacy Policy.

‍Contact Us‍

If you would like to exercise your right to view, correct, complete or remove your personal information, please contact us at support@torbu.com. Upon verification of your identity, we will use commercially reasonable efforts to process your request in a timely manner and will attempt to quickly fulfill your request, provided we will not act contrary to applicable legislation by fulfilling your request. You should be aware, however, that it is not always possible to completely remove or modify information in our databases. You cannot opt out of receiving transactional e-mails related to the platform (e.g., requests for support). Also, we may deliver notifications or verification requests to your mobile device (e.g., push notifications). You can disable these notifications by deleting the relevant service or by changing the settings on your mobile device.