Privacy Notice

1. Who we are

Torch Bearer (the "Service") is provided by Torch Bearer Global LLC("we", "us", "our"). For the personal data described in this notice, Torch Bearer Global LLC is the data controller.

2. Data we collect

• Account data: name (if provided), email address, hashed password.
• Profile and progress data: learning track selections, quiz attempts, scores, and completion status.
• Support communications: any messages you send us.
• Usage and device data: log data, IP address, browser type, device identifiers, pages visited, and basic telemetry needed to operate and secure the Service.
• Order data: products purchased and entitlements. Payment card details are collected by Paddle, not by us.

3. How we use it

• To create and manage your account (contract performance);
• To deliver the learning content and track your progress (contract performance);
• To process orders and entitlements via Paddle (contract performance);
• To secure the Service, prevent fraud, and debug issues (legitimate interests);
• To improve content and the user experience (legitimate interests);
• To respond to support requests (contract performance);
• To comply with legal, accounting, and tax obligations (legal obligation);
• To send service-related emails (contract performance) and, only with your consent, marketing emails (consent — withdrawable at any time).

4. Who we share with

We share personal data only with:

• Paddle — our Merchant of Record — for sale of the product, subscription management, payments, tax compliance, and invoicing;
• Hosting and infrastructure providers that run the Service and store our database and files;
• Email and support tooling providers that help us deliver transactional emails and respond to inquiries;
• Analytics providers, where used, to understand aggregate usage;
• Professional advisers (legal, accounting) where strictly necessary;
• Authorities where required by law or to protect our rights.

We do not sell personal data.

5. International transfers

Our service providers may process data in countries outside your own, including the United States. Where required, we rely on appropriate safeguards (such as Standard Contractual Clauses or equivalent mechanisms).

6. Data retention

We keep account and progress data for as long as your account is active. When you delete your account or request erasure, we delete or anonymise personal data within a reasonable period, except where we must keep records for legal, tax, or fraud-prevention purposes (typically up to 7 years for order records).

7. Your rights

Depending on your location, you may have the right to access, correct, delete, restrict, or port your personal data, to object to processing, and to withdraw consent at any time. EU/UK residents also have the right to lodge a complaint with their local supervisory authority. We aim to respond within one month.

8. Security

We use appropriate technical and organisational measures, including encryption in transit, hashed passwords, access controls, and regular updates, to protect your data. No system is perfectly secure; we will notify affected users and authorities of qualifying incidents as required by law.

9. Cookies

We use a small number of essential cookies and similar storage to keep you signed in and to remember preferences such as language. We do not use marketing cookies. If we add analytics cookies in the future, we will update this notice and (where required) request your consent.

10. Children

The Service is not directed at children under 16. We do not knowingly collect personal data from children.

11. Changes

We may update this notice from time to time. Material changes will be communicated via the Service or by email.

12. Contact

To exercise your rights or ask a privacy question, contact Torch Bearer Global LLC through the support options inside your Torch Bearer account.