PRIVACY POLICY

We, at Aztec Media inc (“Aztec Media”) are committed to respecting our customers’ privacy, protecting their personal information and making sure it is used properly by us.

This Privacy Policy explains our privacy practices for processing personal information on our services and products. We process your personal information subject to the terms of this Policy.

You can access our full Privacy Policy below to help you understand better how we use your personal information. In it, we explain in more detail the types of personal information we collect, how we collect it, what is legal basis of collection, what we may use it for, who we may share it with, what our retention periods and are and what are your rights in relation to the Personal Information we collect.

Within the Privacy Policy you will find some specific examples of why and how we use your personal information. If you have further questions please contact privacy@aztec-media.com

This Privacy Policy is an integral part of our General Terms of Service governing your use of our Services (the “Terms of Service”).

FULL PRIVACY POLICY

Aztec Media (“Aztec Media”, “we”, “our” or “us”) provides this Privacy Policy, as will be updated from time to time (our “Policy” or “Privacy Policy”) to inform you (“you”) of our policies and procedures regarding the collection, use and disclosure of information we receive when using the Services.

The use of the Services constitutes consent to be bound by the terms of this Policy and you hereby agree and confirm that you will not have any claims or demands with respect to the Policy.

1. Definitions:

Personal Information” means details which identify you or could be used to identify you, such as IP address etc.

Non Personal Information” means information that does not personally identify you or your representative and does not reveal your specific identity as an individual and/or cannot be attributed to you, such as operation system name and version, browser name and version, device name and version, referring site, searched terms.

GDPR” means the General Data Protection Regulation (EU) 2016/679, as amended from time to time.

Services” means use of our products or services.

This Policy was originally written in English. If you are reading a translation and it conflicts with the English version, please note that the English version prevails.

2. WHEN DOES THIS PRIVACY POLICY APPLY

This Privacy Policy applies to Personal Data about you that we collect, use or otherwise process regarding your use of our products or services

This Privacy Policy does not apply to services that may have separate privacy policies that do not incorporate this Policy.

3. THE PERSONAL INFORMATION THAT WE COLLECT

If you use our Services, we may collect Personal Information. This includes (by way of a non-exhaustive list) your computer’s Internet Protocol address through the use of “cookies”. A cookie is a small data file that we transfer to your computer’s hard disk for record-keeping purposes. We use cookies to enable certain features of our websites, to better understand how you interact with our websites and to monitor web traffic routing and aggregate usage of our websites. You can instruct your browser, by changing its options, to stop accepting cookies or to prompt you before accepting a cookie from the website you visit. If you do not accept cookies, however, you may not be able to use all portions or all functionality of the Website.

4. NON PERSONAL INFORMATION

We may collect Non-Personal Information in the following ways:

By using the Services and when you provide us with Non Personal Information, you hereby agree and consent that Non Personal Information will be considered as non-confidential, non-proprietary, and unprotected.

5. HOW WE USE PERSONAL INFORMATION

Personal Information is used for the following primary purposes (as may be updated from time to time): to (i) provide the Services; (ii) monitor and analyze use of the Services and study and analyze the functionality of the Services; (iii) for the technical administration and troubleshooting of the Services and to provide support and maintain the Services, (iv) to search for fraudulent traffic sources; (v) provide service announcements and market the Services; (vi) enforce our Terms of Service, policies and other contractual arrangements, to comply with court orders and warrants, and prevent misuse of the Services, and to take any action in any legal dispute and proceeding.; (vii) better understand your needs both on an aggregated and individualized basis in order to improve and continue developing our Services; (viii) communicate with you and contact you to obtain feedback from you regarding the Services; (ix) disclose to third party vendors, service providers, contractors or agents who perform functions on our behalf with respect to the Services; (x) enable the Service’s tools and features, and (xi) as otherwise authorized by you.

6. HOW WE USE NON PERSONAL INFORMATION

We may use information that is Non Personal Information for the same purposes we use Personal Information (where applicable) and in addition in order to (i) compile anonymous or aggregate information, (ii) disclose to third party vendors, service providers, contractors or agents who perform tasks on our behalf in connection with the Services, (iii) monitor and analyze use of the Services and for the technical administration and troubleshooting of the Services, and (iv) provide us with statistical data.

We use anonymous, statistical or aggregated information, which may be based on extracts of your Personal Information, for legitimate business purposes including for testing, development, improvement, control and operation of the Services. We may share such information with third parties on our behalf. It has no effect on your privacy, because there is no reasonable way to extract data from the aggregated information that can be associated with you. We will share your Personal Information only subject to the terms of this Policy, or subject to your prior informed consent.

7. THE LEGAL BASIS FOR USE OF INFORMATION

We will only process your Personal Information where we have a legal basis to do so. The legal basis will depend on the reason or reasons we collected and need to use your Personal information. In almost all cases the legal basis will be:

More information on the basis of processing:

8. SHARING INFORMATION WITH OTHERS

Aztec Media does not rent, sell, or share any information about you with any third-parties.

However, Aztec Media may disclose your Personal Information if Aztec Media believes such action is necessary to:

9. TRANSFER OF DATA OUTSIDE YOUR TERRITORY

We may store, process or maintain information in various sites worldwide, including through cloud based service providers worldwide. Where the GDPR applies and we transfer Personal Data to another country outside the EEA, we will ensure that it is protected and transferred in a manner consistent with legal requirements. In relation to data being transferred outside of the EEA, for example, this may be done in one of the following ways:

You can obtain more details of the protection given to your Personal Data when it is transferred outside the EEA (including a copy of the standard data protection clauses which we have entered into with recipients of your Personal Data) by contacting us as described the Section “CONTACT US” below.

If you are located in a jurisdiction where transfer of your Personal Data to another jurisdiction requires your consent, then you provide us your express and unambiguous consent to such transfer or the storage, processing or maintenance of the information in other jurisdictions by using the service.

10. YOUR RIGHTS

In all of the above cases in which we collect, use or store your Personal Information, you may have the following rights and, in most cases, you can exercise them free of charge.

At any time, you may contact us at: privacy@aztec-media and request to know what Personal Data we keep about you. We will make good-faith efforts to locate the data that you request to access.

Under your right of access, you may obtain confirmation from us of whether we are processing Personal Data related to you, receive a copy of that data, so that you could verify its accuracy and the lawfulness of its processing, request the correction, amendment or deletion of the data if it is inaccurate, incomplete, outdated or processed in violation of applicable law.

However, we may retain certain information as deemed required by us in accordance with applicable laws, or for legitimate business reasons, for the duration as required under applicable laws.

In addition, we may delete any Personal Data pursuant to our policies, as in effect from time to time.

11. RESPONSE TO REQUESTS

When you ask us to exercise any of your rights under this Policy and the applicable law, we may need to ask you to provide us certain credentials to make sure that you are who you claim you are, to avoid disclosure to you of Personal Information related to others and to ask you questions to better understand the nature and scope of data that you request to access.

We may redact from the data which we will make available to you, any Personal Information related to others.

12. INFORMATION SECURITY

We take the safeguarding of the Personal and Non Personal Information very seriously, and use a variety of systems, applications and procedures to protect the information from loss, theft, damage or unauthorized use or access when it is in our possession or control, including reasonable physical, technical and organizational measures which restrict access to the information. These measures provide sound industry standard security. However, although we make efforts to protect your privacy, we cannot guarantee that the Services will be immune from any wrongdoings, malfunctions, unlawful interceptions or access, or other kinds of abuse and misuse.

You should take steps to protect against unauthorized access to Personal Information stored on your premises as well as defining limited access rights to such information on a need to know basis.

If you receive an e-mail asking you to update your information with respect to the Services, do not reply and please contact us at support@torchbrowser.com

13. DATA RETENTION

We retain different types of information for different periods, depending on the purposes for processing the information, our legitimate business purposes as well as pursuant to legal requirements under the applicable law. We may retain Personal Information for as long as necessary to support the collection and the use purposes of this Policy and for other legitimate business purposes, For example, for storing information for documentation, for managing internet security for legal proceeding and for text purposes. We may store non-personal aggregate information without time limit. In any event as long as you use the services, we will retain information about you and your users, unless we are legally required to delete it, or if you seek to exercise your rights to delete the information.

14. OUR POLICY TOWARD CHILDREN

Our Sites are intended for general audiences over the age of 16 years old. We do not knowingly collect information from children under the age of 16 years old. IF YOU ARE NOT AT LEAST 16 YEARS OLD, DO NOT USE THE SERVICES.

15. CHANGES TO THIS PRIVACY POLICY

From time to time, Aztec Media may revise this Policy. Aztec Media will post the revised Policy on the Site, so that users can always be aware of what information Aztec Media collects, how the information is used and under what circumstances such information may be disclosed. Your continued use of the Services following such notice shall constitute your consent to any changes made and a waiver of any claim or demand in relation to such changes. If you do not agree to the new or different terms, you should not use and are free to discontinue using the Services.

16. CONTACT US

For further information about this Policy, please contact us at:privacy@aztec-media.com

We work hard to handle your information responsibly. If you are unhappy about the way we do this, please contact us and we will make good-faith efforts to address your concerns.

Copyright © 2019, Aztec Media inc. . All rights reserved.

Last Updated: November 27, 2019