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 10, Fourth Way, Wembley, HA9 0LH, 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. We will take all necessary steps to implement this policy. If you have any queries regarding this Policy, please contact us at info@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.

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, Viber, 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 use the interactive Live Chat service on the Website

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:

• 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, name, date of birth, user category and email, may be required on detail collection forms;
• 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.

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.

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. If you are a simple user, we collect your Data in order to:
• Sending you our Newsletters and personalised offers when you have subscribed to it;
• Enabling 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 and/or via the chat software;
• Enabling 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. Your Data may also be collected via cookies and tracers, with your consent when required, for:
• Improving your user experience, namely by:
- Enabling our Website to recognise your equipment, saving you from having to provide the same information several times to perform the same task,
- Recognising the user name and password you have provided so you do not have to enter them again for each page requiring it.
• Analysing Website traffic and data to measure the number of users and subsequently make the Website easier to use and ensure it is able to quickly respond to your requests.

The refusal to provide some Data could lead to the unavailability of certain services.

4. WHO PROCESSES MY DATA?


A. Your Data is processed by TORQEN employees tasked with:
- Managing the Website,
- Managing technical support to answer our customers questions,
- Managing the invoincing and payments for the orders
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. Managing communications between you and us:
• Communications between you and TORQEN are conducted with the chat software published by TawkTo – https://www.tawk.to
This software allows TORQEN to discuss directly with its users.

C. Managing payment:
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 WorldPay ;
• PayPal payment;
• Payment by bank transfer.
• Payment bank transfer from outside the UK via TransferWise.

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

D. Sending you our Newsletter:
Our emailing campaigns are run through the our internally developed software.

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.

E. 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.

F. 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.
If you subscribe to the Newsletter, your email will be stored until you unsubscribe. When you contact us through the contact forms, when you communicate with us by phone or by chat, your Data will be stored up to six (6) years from the date of the last contact.

In regards to your user account, your invoicing information will be stored for ten (10) years starting from the day of purchase. The remaining Data will be stored for five (5) years starting from the day of your account deactivation.

Your bank details will be stored for thirteeen (13) months starting from the debit date, in order to prevail a potential litigation.
When you ask for, your user account will be deactivated and erased at the end of the aforementioned durations starting from your deactivation request.
Lastly, Data collected using cookies/tracers will be stored for up to six (6) months for cookies measuring our Website’s audience and up to thirteen (13) months for others.
Beyond the aforementioned durations, your Data will be anonymised in order to be stored for statistic purpoposes.

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.
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 party. 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 the Live Chat. In this case, be aware that we will not be able to write to you and cannot therefore contact you with a reply.
In any events, you can access to your user account, at all time, in order to consult or correct your Data or unsubscribe from our Newsletter.

In accordance with the provisions of the applicable regulations regarding Data protection, namely the European General Data Protection Regulation 2016/679 (GDPR) and the UK Data Protection Act 1998 and its amendments, you have the right to access and correct your Data. You also have the right to stipulate directives relating to the fate of your Data in the event of your death.

Furthermore, subject to the conditions of the aforementioned regulation for exercising your rights, you have:
- The right to erasure of your Data.
- The right to limit processing of your Data.
- The right to object to the processing of your Data on legitimate grounds, in accordance with article 21 of the GDPR.
- The right to portability for the Data you have provided.
- The right to withdraw consent, when it has been asked.
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.

However, in accordance with Article 12.6 of the 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 10, Fourth Way, Wembley, HA9 0LH, 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 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. By using the Website, you agree to your Data being transferred to those servers.


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