Privacy Policy

1. Introduction

TorlyAI ("we", "our", or "us") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website torly.ai and use our AI-powered UK Innovator Visa assessment services.

2. Information We Collect

2.1 Personal Information

We collect information that you voluntarily provide to us when you:

• Register for an account
• Use our visa assessment tool
• Contact us via email or contact forms
• Subscribe to our newsletter
• Participate in surveys or promotions

This information may include:

• Contact details: Name, email address, phone number
• Business information: Company name, business description, industry sector
• Visa assessment data: Innovation factors, business plan details, growth projections
• Communication data: Messages, feedback, and correspondence

2.2 Automatically Collected Information

When you access our website, we automatically collect certain information:

• Log data: IP address, browser type, operating system
• Usage data: Pages viewed, time spent on pages, click patterns
• Device information: Device type, unique device identifiers
• Cookies: See our Cookie Policy for details

3. How We Use Your Information

We use the information we collect for the following purposes:

• Provide Services: Process visa assessments, calculate eligibility scores, generate recommendations
• Communication: Send you updates, newsletters, marketing materials (with your consent)
• Improvement: Analyze usage patterns to improve our AI algorithms and user experience
• Legal Compliance: Comply with legal obligations and prevent fraud
• Customer Support: Respond to inquiries and provide technical assistance

4. Legal Basis for Processing (GDPR)

Under the UK GDPR and Data Protection Act 2018, we process your personal data based on:

• Consent: You have given clear consent for processing (e.g., newsletter subscriptions)
• Contract: Processing is necessary to fulfill our service contract with you
• Legitimate Interests: We have a legitimate interest in improving our services and preventing fraud
• Legal Obligation: We must process data to comply with UK law

5. Data Sharing and Disclosure

We do not sell your personal information. We may share your data with:

5.1 Service Providers

• Cloud hosting providers (e.g., Oracle Cloud)
• Email service providers (e.g., Lark Suite)
• Analytics providers (e.g., Google Analytics)
• Payment processors (if applicable)

5.2 Legal Requirements

We may disclose your information if required by law or in response to:

• Court orders or legal processes
• Government or regulatory requests
• Protection of our rights, property, or safety
• Investigation of fraud or security issues

6. Data Retention

We retain your personal information only as long as necessary for the purposes set out in this Privacy Policy:

• Assessment data: Stored for up to 7 years for legal compliance
• Account information: Retained until account deletion requested
• Marketing data: Until you unsubscribe or withdraw consent
• Log data: Typically retained for 90 days

7. Your Data Protection Rights (UK GDPR)

Under UK data protection law, you have the following rights:

• Right to Access: Request copies of your personal data
• Right to Rectification: Request correction of inaccurate data
• Right to Erasure: Request deletion of your personal data
• Right to Restrict Processing: Request limitation of processing
• Right to Data Portability: Receive your data in a structured format
• Right to Object: Object to processing based on legitimate interests
• Right to Withdraw Consent: Withdraw consent at any time

To exercise these rights, contact us at: privacy@torly.ai

8. Data Security

We implement appropriate technical and organizational measures to protect your data:

• SSL/TLS encryption for data in transit
• Encrypted database storage
• Access controls and authentication
• Regular security audits and updates
• Secure backup systems

9. Cookies and Tracking Technologies

We use cookies and similar technologies to:

• Remember your preferences and settings
• Analyze website traffic and usage patterns
• Improve user experience and functionality
• Deliver personalized content

For detailed information, please see our Cookie Policy.

10. Third-Party Links

Our website may contain links to third-party websites. We are not responsible for the privacy practices of these external sites. We encourage you to review their privacy policies.

11. International Data Transfers

Your data may be transferred to and processed in countries outside the UK. We ensure appropriate safeguards are in place:

• Standard Contractual Clauses (SCCs) approved by the ICO
• Adequacy decisions by the UK government
• Binding Corporate Rules where applicable

12. Children's Privacy

Our services are not directed to individuals under 18. We do not knowingly collect personal information from children. If we discover we have collected data from a child, we will delete it promptly.

13. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of significant changes by:

• Posting the new policy on this page with an updated "Last Updated" date
• Sending an email notification (for material changes)
• Displaying a prominent notice on our website

14. Contact Us

If you have questions about this Privacy Policy or wish to exercise your data protection rights, please contact us:

15. Supervisory Authority

You have the right to lodge a complaint with the UK's supervisory authority:

Information Commissioner's Office (ICO)
Website: ico.org.uk
Telephone: 0303 123 1113