Privacy Policy

Legal Privacy Policy

Date of Last Revision: November 1, 2020

This Privacy Policy (“Privacy Policy”) applies to the website accessible at https://sunshinetorczon.com/ (“Website”), and the mobile applications (and together with the Website, collectively, the “Site”), all owned and operated by Torczon Holdings, LLC, an Arizona limited liability company (“Torczon Holdings”, “THLLC”, “we”, or “us”). This Privacy Policy describes how Torczon Holdings collects and uses personal information collected through the Site. It also describes the choices available to you regarding the use of, your access to, and how to update and correct your personal information.

How we use the information we collect

THLLC will not sell or rent to any third party any of the personal information or data that you provide to us. THLLC uses the Personal Data you provide in a manner that is consistent with this Privacy Policy. If you provide Personal Data for a certain reason, we may use the Personal Data in connection with the reason for which it was provided. For instance, if you contact us by email, we will use the Personal Data you provide to answer your question or resolve your problem. Also, if you provide Personal Data in order to obtain access to the THLLC Services, we will use your Personal Data to provide you with access to such services and to monitor your use of such services. THLLC and its subsidiaries and affiliates (the “THLLC Related Companies”) may also use your Personal Data and other personally non-identifiable information collected through the Services to help us improve the content and functionality of the Services, to better understand our users and to improve the THLLC Services. THLLC and its affiliates may use this information to contact you in the future to tell you about services we believe will be of interest to you. If we do so, each communication we send you will contain instructions permitting you to “opt-out” of receiving future communications. In addition, if at any time you wish not to receive any future communications or you wish to have your name deleted from our mailing lists, please contact us as indicated below.

If THLLC intends on using any Personal Data in any manner that is not consistent with this Privacy Policy, you will be informed of such anticipated use prior to or at the time at which the Personal Data is collected.

Where we store your information

The data that we collect from you is transferred to, and stored at, a destination in the United States. THLLC participates in and has certified its compliance with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework. For more information on THLLC’ participation in EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework, please see below.

Information We Collect

When you interact with us through the Services, we may collect Personal Data and other information from you, as further described below:

Personal Data That You Provide Through the Services: We collect Personal Data from you when you voluntarily provide such information, such as when you contact us with inquiries, respond to one of our surveys, register for access to the THLLC Services or use certain THLLC Services. Wherever THLLC collects Personal Data we make an effort to provide a link to this Privacy Policy. You can choose at any time to opt out by contacting support through the Site, you can also contact us to opt out of your information being used for purposes other than it was originally collected.

By voluntarily providing us with Personal Data, you are consenting to our use of it in accordance with this Privacy Policy. If you provide Personal Data to the Services, you acknowledge and agree that such Personal Data may be transferred from your current location to the offices and servers of THLLC and the authorized third parties referred to herein located in the United States. The Personal Information that you provide can be accessed at any time through your account or you can contact our customer support through the Site if you need help accessing your account.

Cookies: In operating the Services, we may use a technology called “cookies.” A cookie is a piece of information that the computer that hosts our Services gives to your browser when you access the Services. Our cookies help provide additional functionality to the Services and help us analyze Services usage more accurately. For instance, our Services may set a cookie on your browser that allows you to access the Services without needing to remember and then enter a password more than once during a visit to the Services. In all cases in which we use cookies, we will not collect Personal Data except with your permission. On most web browsers, you will find a “help” section on the toolbar. Please refer to this section for information on how to receive notification when you are receiving a new cookie and how to turn cookies off. We recommend that you leave cookies turned on because they allow you to take advantage of some of the Services’s features. Aggregated Personal Data: In an ongoing effort to better understand and serve the users of the THLLC Services, THLLC often conducts research on its customer demographics, interests and behavior based on the Personal Data and other information provided to us. This research may be compiled and analyzed on an aggregate basis, and THLLC may share this aggregate data with its affiliates, agents and business partners. This aggregate information does not identify you personally. THLLC may also disclose aggregated user statistics in order to describe our services to current and prospective business partners, and to other third parties for other lawful purposes.

We will keep any information that you provide to us until such time as you delete your account with the THLLC Service.

Our Disclosure of Your Personal Data and Other Information

You can visit the Website without providing any Personal Data. If you choose not to provide any Personal Data, you may not be able to use certain THLLC Services.

THLLC is not in the business of selling your information. We consider this information to be a vital part of our relationship with you. There are, however, certain circumstances in which we may share your Personal Data with certain third parties without further notice to you, as set forth below:

Business Transfers: As we develop our business, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, dissolution or similar event, Personal Data may be part of the transferred assets. In cases of onward transfer of personal information to third parties of data of EU and Swiss individuals received pursuant to the EU-U.S. and Swiss-U.S. Privacy Shield, THLLC remains liable. Related Companies: We may also share your Personal Data with our Related Companies for purposes consistent with this Privacy Policy. Agents, Consultants and Related Third Parties: THLLC, like many businesses, sometimes hires other companies to perform certain business-related functions. Examples of such functions include mailing information, maintaining databases and processing payments. When we employ another company to perform a function of this nature, we only provide them with the information that they need to perform their specific function. Legal Requirements: THLLC may disclose your Personal Data if required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation, (ii) protect and defend the rights or property of THLLC, (iii) act in urgent circumstances to protect the personal safety of users of the Services or the public, or (iv) protect against legal liability.

Third-Party Payment Processor

We use a third party payment processor to process payments made to us. In connection with the processing of such payments, we do not retain any personally identifiable information or any financial information such as credit card numbers. Rather, all such information is provided directly to our third party processor, Stripe.com, whose use of your personal information is governed by their privacy policy, which may be viewed at https://www.stripe.com/privacy/.

Security

THLLC takes reasonable steps to protect the Personal Data provided via the Services from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. However, no Internet or email transmission is ever fully secure or error free. In particular, email sent to or from the Services may not be secure. Therefore, you should take special care in deciding what information you send to us via email. Please keep this in mind when disclosing any Personal Data to THLLC via the Internet.

Exclusions

This Privacy Policy does not apply to any Personal Data collected by THLLC other than Personal Data collected through the Services. This Privacy Policy shall not apply to any unsolicited information you provide to THLLC through the Services or through any other means. This includes, but is not limited to, information posted to any public areas of the Services, such as bulletin boards (collectively, “Public Areas”), any ideas for new products or modifications to existing products, and other unsolicited submissions (collectively, “Unsolicited Information”). All Unsolicited Information shall be deemed to be non-confidential and THLLC shall be free to reproduce, use, disclose, and distribute such Unsolicited Information to others without limitation or attribution.

Users under age of 13

THLLC does not knowingly collect Personal Data from children under the age of 13. If you are under the age of 13, please do not submit any Personal Data through the Services. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce our Privacy Policy by instructing their children never to provide Personal Data on the Services without their permission. If you have reason to believe that a child under the age of 13 has provided Personal Data to THLLC through the Services, please contact us, and we will endeavor to delete that information from our databases.

Links to Other Web Sites

This Privacy Policy applies only to the Services. The Services may contain links to other web sites not operated or controlled by THLLC (the “Third-Party Sites”). The policies and procedures we described here do not apply to the Third-Party Sites. The links from the Services do not imply that THLLC endorses or has reviewed the Third-Party Sites. We suggest contacting those sites directly for information on their privacy policies.

Changes to this Privacy Policy

As our Site evolves, this Privacy Policy will need to evolve as well to cover new situations. To ensure that you are kept informed of changes, check this Privacy Policy periodically as we will update the date at the top of the document any time we make a change. If we make material changes to this Privacy Policy, we will post the revised policy on this page and will send a notice via email or our Site to all registered users of the Platform. Your continued use of our Site after any such changes constitutes your acceptance of the new Privacy Policy. If you do not agree to abide by these or any future version of the Privacy Policy, you do not have permission to use or access (or continue to use or access) our Site.

Other Terms

Your access to and use of the Services is subject to the Terms of Service at www.sunshinetorczon.com/terms-of-service/

Contacting Us

Questions or comments regarding this Privacy Policy should be submitted to THLLC by e-mail as follows:

Email: [email protected]