Torsh Privacy Policy

Effective Date: March 23, 2026

This Privacy Policy sets forth the practices in effect at our websites located at www.torshtalent.com, www.torshtalenths.com and hs.torshtalent.com (each a “Site” and collectively the “Sites”), which are owned by Torsh Inc. (“TORSH”).This page explains how we collect, use your personal information and the limited conditions under which we may disclose it to others in relation to the Sites and the related applications, services and products offered by TORSH (collectively, the “Services”). By using the Sites you agree that your use is subject to the terms of this Privacy Policy and you consent to the collection, use and storage of your information in accordance with this Privacy Policy. The Sites are used in connection with the delivery of professional learning, data management and coaching services to educational institutions. As such, from time to time, content stored or transmitted on the Sites may contain student personally identifiable information. We will not make material changes to any policies or practices governing the use of a student’s personal information that are inconsistent with our contractual obligations. The Sites are not intended for children and we do not knowingly collect data from children. Depending on how the Services are used, TORSH may act as a service provider or data processor on behalf of a school, educational institution or other entity, or as an independent data controller for individual users. Educational institutions are responsible for determining whether their use of the Services complies with applicable student data privacy laws, including FERPA, and for providing any required notices and obtaining any required consents.

  1. Information Collection and Use

We collect information to provide better Services to all of our users. We collect information in the following ways and for the following purposes ( “Data”). As used herein, Data includes Personal Data as further defined below.

  • Information we Collect

    • Information you give us when you use the Sites, including, but not limited to, personally identifiable information (“Personal Data”) such as name, title, phone number, email address, mailing address, and billing information, such as billing name and address when purchasing Services or registering for an event.
    • Log data including device-specific information (such as your hardware model, operating system version, unique device identifiers, and mobile network information including phone number), device event information such as crashes, system activity, hardware settings, browser type, browser language, the date and time of your request and referral URL, your computer's Internet Protocol ("IP") address.
    • Information about your actual location using your IP address because it helps us to improve performance.
    • We use various technologies to collect and store information when you use the Services and this may include using cookies or other tracking technologies (including web beacons, email pixels and script-based trackers) to identify your browser or device. This information allows web applications to respond to you as an individual. Overall, cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us. You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of our Services.

  • How We Use Your Information

    • Manage user registrations. If you have registered for an account with us, TORSH processes your Data by managing your user account for the purpose of performing our contract with you according to applicable terms of service.
    • Promote the security of our Site and Services. TORSH processes your Data by tracking use of its Sites and Services, creating aggregated, non-personal data, verifying accounts and activity, investigating suspicious activity and enforcing our terms and conditions to promote the safety and security of our Services, systems and applications and to protect our rights and the rights of others.
    • Develop and improve our Site and Services. TORSH processes your Data to analyze trends and to track your usage of and interactions with our Sites and Services to develop and improve our Sites and Services and provide our users with more relevant content and service offerings.
    • Handle contact and user support requests. If you fill out one of our web forms or request user support, or if you contact us by other means including via a phone call, TORSH processes your Data to perform our contract with you, fulfill your requests and communicate with you.
    • Review compliance with applicable usage terms. TORSH processes your Data to review compliance with the applicable usage terms in our customer contracts and to ensure adherence to the relevant terms.
    • Assess and improve user experience. TORSH processes device and usage data which in some cases may be associated with your Data, in order to analyze trends, assess and improve the overall user experience and Service offering. In addition, we use website navigational information to operate and improve the Site.
    • Assess capacity requirements. TORSH processes your Data to assess and ensure that it is meeting the capacity requirements of its Services.
    • Identify customer opportunities. TORSH processes your Data to assess potential new opportunities with customers to ensure that it is meeting the demands of its customers and their users’ experiences.
    • Send marketing communications. TORSH processes your Data to send you marketing information, product recommendations and other non-transactional communications (e.g., marketing newsletters, telemarketing calls, SMS, or push notifications) about us and our partners, including information about our products, promotions, or events. To the extent your consent is required, and you have provided your prior consent, such consent can be withdrawn by you at any time without having to provide any specific reason for such withdrawal.
    • Comply with legal obligations. TORSH processes your Data when cooperating with public and government authorities, courts or regulators in accordance with our legal obligations under applicable laws to the extent this requires the processing or disclosure of Data or is necessary to protect against misuse or abuse of our websites or to respond to lawful requests.
  1. Use of Data for AI and Product Improvement

TORSH may use Data, including inputs, outputs, and interactions with the Services, to develop, train, test, and improve its products and services, including machine learning and artificial intelligence models. Where feasible, TORSH uses de-identified or aggregated data for these purposes. By using the Services, you acknowledge and agree that your Data may be used for these purposes. If you do not want your Data used to improve the Services, you may request to opt out by contacting us at legal@torsh.co. Please note that opting out may limit certain functionality of the Services.

  1. Disclosure of Your Information

Except as noted in this Privacy Policy, TORSH will not sell or rent your personal information to third parties without your permission.

  • Disclosure to Affiliates. We may share some or all of your Data with other companies under our common control ("Affiliates"), in which case we will require our Affiliates to honor this Privacy Policy. If another company acquires us or our assets, that company will possess the Data collected by it and us and will assume the rights and obligations regarding your Data as described in this Privacy Policy. We may also disclose your Data to third parties in the event that we sell or buy any business or assets, in which case we may disclose your Data to the prospective seller or buyer of such business or assets.

  • Disclosure to Service Providers. We may share your Data with service providers to: (a) provide you with the Services (b) process payments; (c) conduct quality assurance testing; (d) facilitate creation and maintenance of accounts; (e) collect and analyze data; (f) provide technical support; or (g) provide specific business services, such as synchronization with other software applications and marketing services. These service providers process Data solely on TORSH’s behalf and under contractual obligations that require them to protect the confidentiality and security of the data and prohibit them from using it for any purpose other than providing services to TORSH. From time to time, we may share your information with the following third parties and to the extent possible, we encourage you to review their privacy policies and terms of use to see how they treat the information we share with them: Zendesk ( ZenDesk Privacy Policy) ; Google (Google Privacy Policy); Atlas (Atlas Privacy Policy); Zoom (Zoom Privacy Policy); Amazon (Amazon Privacy Policy).

  • Disclosure to Other Third Parties. From time to time we may disclose your Data to other third parties with your prior consent, which consent can be withdrawn at any time.

  • Other Disclosures. We may disclose your Data if we believe in good faith that such disclosure is necessary to (a) comply with relevant laws or to respond to subpoenas or warrants served on us; (b) protect or defend our rights or property or the rights or property of users of the Services; or (c) protect against fraud and reduce credit risk. We will NOT share your Data with your employer except with your consent. Any artifacts (e.g, videos, audio recordings, images, documents, etc.) that you upload in the use of the Services are private to you unless you share them with others. No other users of the Services will have access to your artifacts or other Data UNLESS you share it with them.

  • What We Do Not Do. TORSH does not:

    • Sell or share Personal Data to third parties as those terms are defined under applicable law
    • Use student Personal Data for targeted advertising
    • Build profiles of users unrelated to educational purposes
  1. Privacy Rights

Depending on your location and applicable law, you may have certain rights regarding your Data, including the right to access the Personal Data we hold about you, request correction of inaccurate or incomplete data, request deletion of your Personal Data, request restriction of or object to certain processing activities, or opt out of certain uses of your Personal Data. To exercise any of these rights, please contact us at legal@torsh.co. We will respond to your request in accordance with applicable law.

  1. Data Location and Transfers

Your Data may be stored and processed in the United States or other jurisdictions where TORSH or its service providers operate. By using the Services, you consent to the transfer of your Data to locations outside your state, province, or country, which may have different data protection laws.

  1. Security of your Data

Unfortunately, the transmission of information via the internet is not completely secure. Although we are committed to protecting your Data, we cannot guarantee the security of your information transmitted to the Sites; any transmission is at your own risk. Once we have received your information, we use a variety of industry-standard security technologies and procedures to help protect your Data from unauthorized access, use, or disclosure. We also require you to enter a password to access your account information. Please do not disclose your account password to unauthorized people. We have put in place procedures to deal with any suspected Data breach and will notify you and any applicable regulator of a breach where required to do so. TORSH implements administrative, technical, and physical safeguards designed to protect your Data, including encryption in transit, access controls, and monitoring of system activity. However, no method of transmission over the Internet or method of electronic storage is completely secure.

  1. Data Retention

We will only retain your Data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for Data, we consider the amount, nature, and sensitivity of the Data, the potential risk of harm from unauthorized use or disclosure of your Data, the purposes for which we process your Data and whether we can achieve those purposes through other means, and the applicable legal requirements. When you decide to delete certain information in your account, we will fulfill your request and update this information on our platform. We will also notify third parties that we have authorized to use that information of your request. TORSH has no obligation to store, maintain, or provide copies of Data except as required by applicable law. Please note that account data, when deleted, cannot be recovered.

  1. Legal Disputes

If you believe that we have not adhered to this Privacy Policy, please contact us by e-mail at legal@torsh.co. We will do our best to address your concerns. If you feel that your complaint has been addressed incompletely, we invite you to let us know for further investigation. If we are unable to reach a resolution to the dispute, we will settle the dispute exclusively under the rules of the American Arbitration Association.

  1. Changes to this Privacy Policy

We may change this Privacy Policy from time to time in our sole discretion without notice to you by updating this posting. You should periodically review this Privacy Policy carefully in order to inform you of the most current terms and conditions for the use of the Sites. By continuing to use the Sites, you agree to be bound by any such changes.