Introduction

This personal data protection policy (the "Policy") has been created to help you understand the practices and conditions in which TORQEN LTD (a public limited company registered in England and Wales under company number 09367435, having its offices at Unit 3 Quarry Court, Quarry Road, Pitstone Green Business Park, Pitstone, LU7 9GW, United Kingdom) ("TORQEN") gathers, uses and stores your personal data (the "Data").

TORQEN will take all necessary steps to respect your privacy and to ensure that personal data which we hold about our customers, suppliers and all other individuals is processed fairly and lawfully. We are committed to respecting your privacy and to complying with applicable data protection and privacy laws, including the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018. We will take all necessary steps to implement this policy.

If you have any queries regarding this Policy, please contact us at privacy@torqen.uk.

In this document you will find the various Data that we may collect or that you may provide to us when you access and/or use the website https://www.torqen.uk (the "Website") on which the OEM or performance car parts are sold, identified as such on the Website.

Given that laws and regulations on technology and personal data protection are constantly evolving, this Policy will likely be updated. If you are a user of the Website, you will be notified of any changes by email and the updated policy will be posted on our Website.

This Policy applies to Data collected:
- On the Website
- From your communication with TORQEN via email or other type of electronic messaging service like WhatsApp, Facebook Messenger, iMessage and other similar services
- When you create a user account on the Website
- When you subscribe to the Website newsletter (the "Newsletter")
- When you communicate with us via social media platforms (WhatsApp, Facebook Messenger, Instagram)
- During recorded telephone conversations
- During fraud prevention and security verification processes

It does not apply to information collected by any third party or through websites managed by the latter, including via applications and content (including advertisements) redirecting users to the Websites.

Please read the Policy carefully to clearly understand our practices regarding the processing of your Data. Please be aware that you must agree to this Policy in order to view and/or use our Websites.

If any of the clauses in this Policy should be declared null and void or contrary to regulations, that clause will be deemed nugatory, however this will not result in any other clauses in this Policy becoming null and void.

If you do not agree, please do not use our Websites.

You are responsible for ensuring any Data provided to TORQEN is complete, correct and up to date.

1. WHAT DATA DOES TORQEN COLLECT?

Depending on the nature and purpose of your interaction with TORQEN (creating a user account and/or communicating with us through the chat software, subscribing to the Newsletter and/or completing contact forms and/or speaking with us by phone), we may collect the following Data:

Standard Data Collection:
• Your email must be provided if you wish to create a user account, communicate with TORQEN via the contact forms and/or receive our Newsletter
• Data relating to your identity, such as your firstname, surname, date of birth, user category and email, may be required on detail collection forms
• Telephone recordings: calls made to and from our business landline are recorded for training, quality assurance, and order verification purposes
• Data relating to browsing, including: IP address, browser used, browsing duration, search history, operating system used, language and pages viewed
• Data about your visits to our Website, including traffic data, logfiles and other data or communication resources used by you when accessing our Website
• Orders Data: your mailing address is required to generate the invoices. Your bank or PayPal details have to be provided to pay your order
• Data about social network use when you use those features

Fraud Prevention and Security Verification Data:
In certain circumstances, to prevent fraud and protect both TORQEN and our customers, we may collect additional verification data including:
• Identity verification documents (driving licence, passport, utility bills)
• National Insurance numbers (only in exceptional circumstances where standard verification methods are insufficient)
• Bank account verification details
• Address confirmation documentation
• Information obtained from third-party verification services or databases

Important Note: Collection of sensitive identifiers such as National Insurance numbers will only occur in exceptional circumstances where there are clear indicators of potential fraud risk and standard verification methods have proven insufficient. We will always inform you of the specific reasons for such requests and obtain your explicit consent.

2. HOW IS MY DATA COLLECTED?

The Data collected and how it is collected depend on your use of the Website.

TORQEN directly collects Data that you enter into contact and user creation account forms and subscribing to our Newsletter available on the Website, and/or communicated when you contact us by phone, WhatsApp, Facebook Messenger, Instagram, or other electronic messaging services. All telephone calls to and from our business landline are recorded.

For fraud prevention purposes, we may also collect data through:
• Third-party verification services (where legally permitted)
• Government databases for identity verification (such as DVLA for driving licence verification, used only when you provide explicit consent and documentation)
• Credit reference agencies for identity confirmation

TORQEN also indirectly collects your Data through cookies and tracers.

Please read our Cookies Policy which has been created to help you better understand this technology and how we use it on our Website and for our services, applications and tools.

3. WHY IS MY DATA COLLECTED?

Your Data is collected by TORQEN for the following purposes:

A. Standard Website and Service Operations:
If you are a user, we collect your Data in order to:
• Send you our Newsletters and personalised offers when you have subscribed to it
• Enable you to use interactive features of the Website, place orders on the Website
• Manage the orders and fulfil the contract
• Ensure the security and traceability of your purchases
• Transmit you information regarding your user account (invoices, orders history)
• Manage your requests communicated via the Contact us section, social media platforms (WhatsApp, Facebook Messenger, Instagram), and telephone calls
• Record telephone conversations for training, quality assurance, fraud prevention, and dispute resolution purposes
• Enable you to leave a comment or review on products and orders
• Notify the changes on our Website or in our offering of products and services
• Respect our rights and obligations stipulated in the agreements concluded with the users and for any other lawful purposes

B. Fraud Prevention and Security:
We may collect and process additional personal data for fraud prevention purposes based on our legitimate interests, including:
• Preventing fraudulent transactions and protecting our business
• Verifying customer identity when there are indicators of potential fraud
• Protecting customers from identity theft and unauthorised use of payment methods
• Complying with anti-money laundering regulations
• Maintaining the security and integrity of our payment systems

Lawful Basis for Fraud Prevention**: We rely on legitimate interests as our lawful basis for processing personal data for fraud prevention. We have conducted a balancing test which demonstrates that our legitimate interests in preventing fraud do not override your fundamental rights and freedoms. However, sensitive identifiers such as National Insurance numbers will only be processed with your explicit consent and only when standard verification methods are insufficient.

C. Cookies and Tracers:
Your Data may also be collected via cookies and tracers, with your consent when required, for:
• Improving your user experience
• Analysing Website traffic and data to measure the number of users and subsequently make the Website easier to use

The refusal to provide some Data could lead to the unavailability of certain services. For fraud prevention data, refusal may result in us declining to process high-risk transactions.

4. WHO PROCESSES MY DATA?

A. Internal Processing:
Your Data is processed by TORQEN employees tasked with:
- Managing the Website
- Managing technical support to answer our customers questions
- Managing the invoicing and payments for the orders
- Fraud prevention and security verification

In addition to our TORQEN teams, your Data may be sent to DNS Accountants, whose offices are located at 382 Kenton Rd, Harrow, HA3 8DP, United Kingdom, within the scope of our business and for accountancy services and auditing. In any case TORQEN will be responsible on how your Data is stored and used by people accessing it.

B. Third-Party Service Providers:
We may share your personal data with the following categories of third parties:

Social Media Communications:
• Communications between you and TORQEN are conducted through various social media platforms including WhatsApp Business, Facebook Messenger, and Instagram Direct Messages
• These platforms have their own privacy policies which govern how your data is processed by them
• We retain copies of communications for customer service and order management purposes

Payment Processing:
In order to facilitate the users experience, TORQEN offers the following payment methods to purchase on the Website:
• Online payment by credit card (Visa, Mastercard, American Express) via PayPal as our merchant provider.
• PayPal payment
• Payment by bank transfer
• Payment bank transfer from outside the UK via Wise

TORQEN does not have any access to your banking credentials and debit/credit card numbers. All the transactions are secured by SSL encryption.

Fraud Prevention Services:
• Identity verification service providers
• Credit reference agencies (for identity verification only)
• Anti-fraud databases and services
• Government verification services (such as DVLA, used only with your explicit consent)

Newsletter Management:
Our emailing campaigns are run through our internally developed software.

C. Legal Disclosures:
Your Data may also be sent to any buyer or successor in the event of the merger, transfer, restructuring, reorganisation, dissolution or other sale or transfer of some or all of TORQEN's assets due to uncertainties, bankruptcy, liquidation or other processes in which the personal data of TORQEN Website users are listed among the transferred assets.

We may also disclose your personal Data:
- To comply with legal mandates, laws and legal procedures, including governmental and regulatory requests
- If we deem that disclosure is required or appropriate within the scope of protecting the rights, ownership or security of TORQEN, our users and other stakeholders
- This disclosure includes exchanging information with other companies and organisations for the purpose of protecting against fraud and counterfeiting

D. Links to Third Party Websites:
The Websites may contain links to various websites and social network platforms managed on third party servers by people and organisations over which TORQEN has no control. As such, we cannot under any circumstances be held liable for the way in which your Data is stored or used on those third party servers.

We recommend that you read the applicable policy regarding personal data protection for each third party website you access via our Website in order to understand how your Data will be used.

5. HOW LONG IS MY DATA STORED FOR?

TORQEN only stores your Data for the period necessary for the purposes explained in Article 3. This storage period varies according to the Data in question, as it may be affected by the nature and purpose of the collection. Similarly, certain legal obligations stipulate a specific storage period.

Standard Data Retention:
• Newsletter subscriptions: stored until you unsubscribe
• Contact form communications, phone calls, chat, and social media communications: stored for six (6) years from the date of the last contact
• Telephone recordings: stored for six (6) years from the date of the call for training, quality assurance, and dispute resolution purposes
• User account invoicing information: stored for ten (10) years starting from the day of purchase
• Other user account data: stored for five (5) years starting from the day of your account deactivation
• Bank details: stored for thirteen (13) months starting from the debit date, in order to address potential litigation
• Cookies/tracers data: stored for up to six (6) months for cookies measuring our Website's audience and up to thirteen (13) months for others

Fraud Prevention Data Retention:
• Identity verification documents: deleted within 90 days of successful verification or immediately upon transaction decline
• National Insurance numbers: deleted within 30 days of verification completion and never stored in our standard customer database
• Fraud prevention records: retained for up to seven (7) years to maintain fraud detection effectiveness and comply with financial regulations
• Government database query records: logs maintained for 12 months for audit purposes only

When you request account deactivation, your user account will be deactivated and erased at the end of the aforementioned durations starting from your deactivation request.

Beyond the aforementioned durations, your Data will be anonymised in order to be stored for statistical purposes.

6. HOW IS MY DATA PROTECTED?

Your Data is stored on secure servers protected by firewalls and antivirus software. We have implemented technical and organisational measures intended to protect the security and confidentiality of your Data against any accidental loss and any unauthorised access, use, modification or disclosure.

Additional Security Measures for Sensitive Data:

• National Insurance numbers and other sensitive identifiers are encrypted using AES-256 encryption during the verification process
• National Insurance numbers are deleted immediately upon completion of verification checks
• Access to fraud prevention data is restricted to authorised personnel only
• All data transfers to third-party verification services use secure, encrypted connections
• Regular security audits are conducted on systems processing sensitive personal data

Given the inherent characteristics of the Internet, we cannot guarantee the optimal security of information exchanged over this network.

We strive to protect your Data but cannot guarantee the absolute security of information sent to our Website. You agree that you provide your Data at your own risk.
We cannot be held liable for any failure to comply with privacy settings and security measures implemented on our Website.

As such, you agree that the security of your information is equally your responsibility. For example, it is your duty to keep secret your password enabling you to log in to your user account. Do not disclose it to third parties. Be careful when you disclose information on public sections of the Website. They can be consulted by any user of the Website.

7. WHAT ARE MY RIGHTS?

You can choose how the Data you provide is used:
• You can browse the Website without providing Data. This means you will be unable to use certain Website features and, in particular, purchase on the Website
• You can decide not to provide your email in the Contact Us section or via social media communications. In this case, be aware that we will not be able to write to you and cannot therefore contact you with a reply
• You can refuse to provide fraud prevention data, though this may result in us declining to process your transaction
• Please note that all telephone calls to our business landline are recorded - by calling us, you consent to this recording

In any events, you can access your user account, at all times, in order to consult or correct your Data or unsubscribe from our Newsletter.

In accordance with the provisions of the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018, you have the following rights:

Your Data Protection Rights:
• Right of access: You can request copies of your personal data
• Right to rectification: You can request correction of inaccurate or incomplete data
• Right to erasure: You can request deletion of your personal data in certain circumstances
• Right to restrict processing: You can request limitation of how we process your data
• Right to object: You can object to processing based on legitimate interests (including fraud prevention processing)
• Right to data portability: You can request transfer of your data in a structured format
• Right to withdraw consent: Where processing is based on consent, you can withdraw it at any time

Special Rights for Fraud Prevention Data:
• You have the right to be informed of the specific reasons why additional verification is required
• You can request details of any third-party databases or services used to verify your information
• You can object to the use of your National Insurance number or other sensitive identifiers for verification
• You can request immediate deletion of verification data once the verification process is complete

Furthermore, subject to the conditions of the aforementioned regulation for exercising your rights, you also have the right to stipulate directives relating to the fate of your Data in the event of your death.

When processing of your Data has occurred based on your consent, you may withdraw that consent at any time. However, you acknowledge that any processing that occurred before your consent was withdrawn remains entirely valid.

You also have the right to object, without providing a reason, to TORQEN profiling you based on your Data, when content or communications are sent for commercial solicitation.

Exercising Your Rights:
However, in accordance with Article 12.6 of the UK GDPR, when you exercise these rights, TORQEN, as the controller, reserves the right to require proof of your identity. Please be aware that the data required to prove your identity will be deleted once we have responded to your request.

You can exercise your rights by sending an email in English to privacy@torqen.uk or writing to TORQEN, Unit 3 Quarry Court, Quarry Road, Pitstone Green Business Park, Pitstone, LU7 9GW, United Kingdom.

We are required to reply within one (1) month to all requests regarding the exercising of these rights. This timeframe may be extended to two (2) months for complex requests and large request volumes.

Lastly, you also have the right to lodge a complaint with the Information Commissioner's Office via their website here - https://ico.org.uk.

8. DOES TORQEN TRANSFER MY DATA OUTSIDE THE EUROPEAN UNION?

Data collected within the scope of Website use are hosted by OVH - https://www.ovh.co.uk/aboutus, whose servers are located in the European Union, Canada and the United States. As such, your Data may be transferred outside of the European Union, to the United States for hosting purposes.

Some fraud prevention services may involve data transfers outside the UK/EU. Where this occurs, we ensure appropriate safeguards are in place, including:
• Adequacy decisions by the UK government or European Commission
• Standard contractual clauses approved by relevant authorities
• Binding corporate rules where applicable

By using the Website, you agree to your Data being transferred to those servers and for fraud prevention purposes where appropriate safeguards are in place.

9. AUTOMATED DECISION MAKING AND PROFILING

We may use automated systems to assess fraud risk based on transaction patterns, device information and other indicators. These automated systems may flag transactions for manual review but do not make final decisions about transaction acceptance without human intervention.

You have the right not to be subject to decisions based solely on automated processing. If you believe an automated system has unfairly affected a decision about your transaction, you can request human review by contacting privacy@torqen.uk.

10. CONTACT INFORMATION

If you have any questions about this Privacy Policy, your personal data, or wish to exercise any of your rights, please contact us:

Email: privacy@torqen.uk
Post: TORQEN Ltd, Unit 3 Quarry Court, Quarry Road, Pitstone Green Business Park, Pitstone, LU7 9GW, United Kingdom
Phone: Available through our Website contact page

For fraud prevention inquiries specifically, please clearly mark your communication as "Fraud Prevention Data Inquiry" to ensure proper handling.

Last Updated: 30th May 2025

This policy is reviewed annually and updated as necessary to reflect changes in our practices and legal requirements.