Privacy Policy

This Privacy Policy applies to information collected by Torazzo from users of the website https://www.torazzo.com (“Website”) and the services available or offered thereon (the “Services”) or from such users with whom we communicate through email or other means. For the purposes of this Privacy Policy Torazzo means Madzuma LLC, registered at 5737 Kanan Rd, Ste 358, Agoura Hills, CA 91301-1601, and any of its related entities and affiliates powered by Madzuma (the “Torazzo”, “we”, “our”, “us”).

We are providing you with this Privacy Policy to help you make an informed decision as to whether to use or continue using the Website. By visiting the Website, you agree to the collection and use of your personal and non-personal data as outlined below. Torazzo reserves the right to update the policy periodically, and these updates are effective upon posting.

COLLECTION OF INFORMATION

We collect from you only limited amount of information necessary to use the Website and our Services. Torazzo does not collect any personal information by illegal means.

INFORMATION YOU PROVIDE

Registration Information.

When you sign up for a Torazzo account, we may ask you to provide information by which you may be personally identified, such as your name, email address, postal address, telephone number, demographic information, and name of the company you represent or account name, where applicable, or any other personal or personally identifiable information under applicable law (“personal information”).

Communications.

If you contact us directly, we may receive additional information you provide, such as your name, email address, Teams, Telegram or other messenger login or phone number, and the contents of a message or attachments that you may send to us. You may also provide us with information if you subscribe to marketing communications from us or to obtain content such as product information, documents and reports.

Other Contact Information.

Torazzo will also collect the phone number, email address, and any other contact information you provide during the use of our Services.

Payment.

When you add a payment method to your account, we will collect your payment information and billing address.

Shipping Information.

If you are available to get a gift from Torazzo, we will also collect your shipping information.

Information You Provide About Others.

We also collect the personal information of other people, for example, if you provide email addresses of friends for referrals.

BY PROVIDING PERSONAL INFORMATION TO TORAZZO, YOU VOLUNTARILY CONSENT TO THE COLLECTION, USE AND DISCLOSURE OF SUCH PERSONAL INFORMATION AS SPECIFIED IN THIS PRIVACY POLICY.

INFORMATION WE COLLECT AUTOMATICALLY THROUGH OUR SERVICES

Device Information.

When you visit the Website or log in to access your account, our servers may automatically record and archive certain information that web-browsers send whenever visiting the Website. We may receive information about the browser and devices you use to access the Internet, including our services, such as device types and models, unique identifiers, IP address, operating system type and version, browser type and language, Wi-Fi network name and connection data, and information about other devices connected to the same network, referring pages, exit pages and visited URLs, platform type, click counts, pages viewed and in what order, time spent, date and time of the request, and other important data is necessary to validate and authorize your entry and activity on the Website.

Information from Cookies and Similar Technologies.

We collect information on the Website and in our emails using cookies, pixel tags, or similar technologies. A cookie is a small amount of data stored on the hard drive of your computer that allows us to identify you with your corresponding data that resides in our database. Cookies do not reveal personal information. The only personal information a cookie can be linked to is information you supply yourself such as email address, or information on your actions and behavioral data while using our website. Cookies cannot read data from your hard drive. If you want to delete cookies from your computer, please go to your browser settings and do it manually.

You may get additional and specified information from Cookie Declaration available in the checkbox when you entering the Website. In the checkbox you may also choose your preferences regarding Cookies that we collect.

Activity and Usage Information on our Website.

We receive information about your interactions with our Website and Services, such as length of your visit, the date and time of your visit, how you navigate the Website, how you customize your account settings, numbers of offers viewed by user, numbers of offers selected and/or changed by user, all user interactions with a referral link (if any) and the types of analytics or algorithms a user applies, interactions with content and ads, and settings and preferences.

Activity, Location, and Usage Information Through Our Advertising Services.

We may receive information about your activities on other websites, apps, and connected devices to which Torazzo provides advertising or measurement and analytics services, including the content you view, the date and time of your visits, how you interact with these websites, apps and devices, and how you interact and respond to ads. We may also receive your precise geolocation information.

USE OF INFORMATION

Torazzo will only use information provided by you and other individuals, who use the Website, for purposes that you have provided it for, including:

• Support, Maintenance and Fulfillment: We use your information to provide and maintain our Website and Service, and to process and fulfill your requests;
• Improvement of Products and Services: We use your information to understand and analyze user behavior, to improve and enhance our Services, to develop new products, services, features and functionality; to perform technical operations, such as updating software; to validate our users and ensure their qualifications to use our Services; and for other customer service and support purposes;
• Marketing and Promotions: We use your information for marketing purposes, including sending you emails and text messages about products, events, promotions and offers from Torazzo or its partners or advertisers, and understanding the effectiveness of our marketing; responding to your inquiries; and for other informational, marketing, or promotional purposes.
• Analytics and Performance: We use your information to measure performance and analyze key metrics relevant to our business; to analyze how you interact with our services; to monitor and analyze usage and activity trends; and for other research, analytical, and statistical purposes.
• Service Communication and Customer Care: We use your information to communicate with you, including sending you service information such as confirmations, notices, updates, security alerts, user surveys, and support and administrative messages (notifications on offer changes, your campaign updates, notes about your results, etc.); and to respond to your comments and questions and provide customer service. For avoidance of doubts, your email addresses will never be provided to any third party, without a written approval, or an electronic consent from you.
• Security and Fraud Prevention: We use your information to enforce our terms and conditions; and to protect, investigate, and deter against fraudulent, unauthorized, infringing or illegal activity, including click fraud.
• Legal Compliance: To comply with applicable legal or regulatory obligations, including as part of a judicial proceeding; to respond to a subpoena, warrant, court order, or other legal process; or as part of an investigation or request, whether formal or informal, from law enforcement or a governmental authority.

SHARING PERSONAL INFORMATION

Your personal information will not be shared, distributed, sold, traded, rented or otherwise transferred to outside parties, unless we have first given you notice that we might share your data, and you have authorized us to do so in accordance with applicable privacy laws, unless as follows:

Service Providers and Vendors.

We work with other businesses which may require access and use your information, in particular, we use other companies to communicate with you about our products or services, to send information to you, to process and collect payment via your credit card, to provide customer support, to receive additional data about you, and to perform analytics and other work that we may need to outsource.

Analytics Providers.

We use analytics services to collect and process certain analytics data for our Services. These analytics services may also collect information regarding your use of other companies’ websites, apps, online services, and devices. We also contract with third-party tracking technologies who use similar tracking tags on our Services via ad tags or SDK, to collect information about your use of our Services, for advertising, analytics, and measurement purposes (for example, Google Tag Manager, Facebook pixel). We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about a third party’s processing of your information, you should contact the responsible provider directly. You acknowledge and agree that your access and use of such third party’s tools may be subject to their respective terms of use and privacy policies.

Corporate Affiliates.

We may share your information with our current or future “affiliates” (which means a parent company, any subsidiaries, joint ventures, or other companies under common control), which will adhere to this Privacy Policy as strict as Torazzo.

Transferring of Assets and Rights.

We may also share your information with others in connection with or during negotiation of any merger, financing, acquisition, bankruptcy, dissolution, transaction or proceeding involving sale, transfer, divestiture or disclosure of all or a portion of our business or assets to another company.

Legal Disclosures.

We may also share your information (1) to comply with laws or to respond to lawful requests and legal process, (2) to protect the rights and property of Torazzo, our employees, agents, customers, and others, including to enforce our agreements, policies, and terms of use, (3) in an emergency to protect the personal safety of Torazzo, our employees or customers, or any person, or (4) to investigate, prevent, or take action regarding illegal or suspected illegal activities.

Anonymous or aggregated information.

Aggregated or de-identified information that does not identify you personally, like usage and metrics information, may be shared with others, including partners, developers, potential investors, marketers, and business partners for a variety of purposes, including for their own uses, for example, for improving their products and services for us and others, and to make ads more relevant to your interests. Anonymous information helps us understand trends and user needs so that we can better design new products and services and refine existing products and services to serve our customers better.

THIRD PARTY LINKS

The Website may contain links to other websites that are not operated by us. If you click on a third-party link, you will be directed to that third party’s website. We strongly advise you to review the privacy policy of every website you visit. We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party websites or services.

CHILDREN'S PRIVACY

We adhere to the Children's Online Privacy Protection Act and similar legislation applicable in other jurisdictions. Our Services are not intended for anyone under age 18 without the involvement of a parent or guardian. We do not knowingly collect or distribute information from or about anyone under age 18. If we are made aware that we have received personally identifiable information from someone under 18, we will use reasonable efforts to remove that information from our records.

DATA STORAGE AND SECURITY

Security of your information is our utmost priority. We use industry-standard methods of securing electronic databases of personal information in order to protect our data from unauthorized access, unauthorized disclosure or destruction of data. Our data is only stored in centers that provide the highest quality security for your information. Only authorized employees have access to the information you provide us.

However, you should know that no company can fully eliminate security risks associated with personal information. To help protect yourself, please use a strong password, do not use the same password to access your account on the Website that you use with other accounts or services, and protect your usernames and passwords to help prevent others from accessing your accounts and services.

INFORMATION TRANSFER

Torazzo cannot guarantee or warrant the security of any information you transmit on or through our Services and you do so at your own risk. Information may be transferred to and maintained on servers or databases located outside your country or to a jurisdiction where the privacy laws may not be as protective as those in your location. While such information is outside of your country of residence, it is subject to the laws of the country in which it is held, and may be subject to disclosure to the governments, courts or law enforcement or regulatory agencies of such other country, pursuant to the laws of such country. We will protect all personal information we obtain in accordance with this Privacy Policy and take reasonable steps to ensure that it is treated lawfully.

MODIFICATIONS

We may amend this Privacy Policy at any time by posting the amended version on the Website or by providing such notice about or obtaining consent to changes as may be required by applicable law.

Additional Notice for European Economic Area (EEA) Residents

LEGAL BASIS FOR PROCESSING PERSONAL INFORMATION

If you reside in the EEA, we will normally collect personal information from you (1) where we need the personal information to enter into or perform a contract with you, (2) where we have your consent to do so, (3) where the personal information is needed to comply with a legal obligation or requirement, or (4) where the processing is in our legitimate interests or the legitimate interests of others, and not overridden by your rights. These legitimate interests may include the operation, maintenance and improvement of our products, platform and services, offering a more tailored, personalized and efficient service for our users, communication with you as necessary to provide our services to you, fraud prevention and network and information security and detecting or preventing illegal activities. We may have other legitimate interests, and if we believe it is appropriate, we will inform you of what they are.

DATA CONTROLLER

This Privacy Policy applies to personal data which is collected and/or used by Torazzo in its capacity as a data controller as that term is defined in the GDPR and similar privacy laws, for the purposes set out in Section “Use of Information” above.

PRIVACY RIGHTS

As a resident of the EEA, among other rights, you have the following data protection rights:

• The right to access, correct, update or request deletion of your personal information.
• The right to object to processing of your personal information; ask us to restrict processing of your personal information or request portability of your personal information.
• The right to opt-out of marketing communications we send you at any time.
• The right to withdraw your consent at any time if we have collected and processed your personal information with your consent.
• You have the right to complain to a data protection authority about our collection and use of your personal information.

You may also request additional information about: the purpose of the processing; the categories of personal data concerned; who else outside Torazzo might have received the data from Torazzo; what the source of the information was; and how long it will be stored.

If you wish to exercise any of these rights, please contact us here [email protected]. We may ask you to verify your identity, or ask for more information about your request.

Please note that while any changes you requested will be reflected in active user databases instantly or within a reasonable period of time. Torazzo will process your requests as soon as possible but not later than within 45 days from the day of the receipt. If necessary, we will also notify you and a relevant supervisory authority within 72 hours from a breach related to your personal information that we hold.

WARNING! Please exercise your rights wisely and note that abuse of rights may entail your liability.

DATA RETENTION

Torazzo does not keep personal data any longer than is necessary for the purposes for which it is being processed.

TRANSFER

For transfers of personal information to countries outside EU, we rely on the European Commission’s adequacy decisions https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/adequacy-decisions_en and their Standard Contractual Clauses, available here https://eur-lex.europa.eu/eli/dec_impl/2021/914/oj?uri=CELEX:32021D0914&locale=en

California-specific description of consumers’ privacy rights

LEGAL CAPACITY

Torazzo complies with the CCPA in its capacity as a “business”.

LEGAL BASIS FOR PROCESSING PERSONAL INFORMATION

Torazzo collects a variety of personal information from you. “Personal Information” under CCPA means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. Personal information does not include deidentified or aggregated consumer information.

Torazzo collects personal information for business and commercial purposes outlined in the Section “Use of Information” above and any other purpose not prohibited by applicable laws or privacy regulations, including the CCPA.

Categories of personal information Torazzo collects

Torazzo has collected the following categories of personal information from users within the last twelve (12) months:

• A. Identifiers. A name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, driver's license number, passport number, or other similar identifiers. YES
• B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). A name, address, telephone number, passport number, driver's license or state identification card number, credit card number, debit card number, or any other financial information. Some personal information included in this category may overlap with other categories. YES
• C. Protected classification characteristics under California or federal law. Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information). NO
• D. Commercial information. Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. NO
• E. Biometric information. Physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data. NO
• F. Internet or other similar network activity. Browsing history and search history within our website; information on a consumer's interaction with a website and advertisement. NO
• G. Geolocation data. Physical location or movements. NO
• H. Sensory data. Audio, electronic, visual, thermal, olfactory, or similar information. NO
• I. Professional or employment-related information. Current or past job history or performance evaluations. YES
• J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. NO
• K. Inferences drawn from other personal information. Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. NO

INFORMATION TORAZZO SELLS

In the preceding twelve (12) months, or at any point in the past, Torazzo has not sold any Personal Information to third parties for a business or commercial purpose.

YOUR RIGHTS AND CHOICES

As a California resident you have certain rights with respect to the Personal Information collected by businesses:

• Right to Access. You have the right to receive information about the types of personal information that Torazzo collects, uses, discloses, and sells. Specifically, this right allows you to ask Torazzo for the following information: [a]the categories of personal information that Torazzo collects about you; [b] the categories of sources from which Torazzo has obtained personal information about you; [c] Torazzo’s business or commercial purpose for collecting or selling your personal information; [d] the categories of your personal information that Torazzo sells to third parties; [e] the categories of third parties that Torazzo sells your personal information to; and [f] the specific pieces of personal information that Torazzo has collected about you. Torazzo must disclose this information to you when you exercise your right to know, subject to proper verification of your request.
• Right to be Forgotten. You have the right to request that Torazzo delete any personal information it has collected or maintains about you, subject to certain exceptions for business purposes outlined in the applicable law. Once Torazzo receives and confirms your verifiable consumer request, Torazzo will delete your personal information from its records, unless an exception applies.
• Right to Non-Discrimination. You have the right to non-discrimination if you exercise any of your rights under the CCPA. If you exercise your rights under the CCPA, Torazzo, pertaining to its good and services, will not do any of the following: [a] deny you any goods or services; [b] charge you a different price or rate for goods or services, including through the use of discounts or other benefits or imposing penalties; [c] provide to you a different level or quality of goods or services; or [d] suggest to you that you will receive a different price or rate for goods or services or a different level or quality of goods or services.
• Right to Opt-Out. You have the right to direct Torazzo to not sell your personal information to third parties at any time. Torazzo only shares information as outlined herein. If you choose to opt-out of the sharing of your personal information, Torazzo will no longer send your personal information to third parties. You can choose, at any time, to opt back in to the sale of your personal information.

EXERCISING YOUR RIGHTS

To exercise your rights to know, access, and be forgotten described above, please submit a verifiable consumer request to Torazzo by either:

1. Emailing [email protected]

Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request to know or for access twice within a 12-month period. The verifiable consumer request must: (1) Provide sufficient information that allows Torazzo to reasonably verify you are [a] the person about whom Torazzo collected personal information or [b] such person’s authorized representative. (2) Describe your request with sufficient detail that allows Torazzo to properly understand, evaluate, and respond to it.

We may require additional information to verify your requests to exercise your rights or understand the scope of your request, although you will not be required to create any account on this Website to submit a request or have it fulfilled. Torazzo cannot respond to your request or provide you with personal information if Torazzo cannot verify your identity or authority to make the request and confirm the personal information relates to you. Torazzo will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request. We are permitted to reject your request if we reasonably determined that you are not a resident of the State of California.

RESPONSE TIMING AND FORMAT

We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your Personal Information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.