Welcome to our Privacy Policy
Your privacy is critically important to us.
It is Torch Leadership and Training Consultancy Corp.’s (“Torch”) policy to respect your privacy as the user (“User” or “Data Subject”) regarding any information we may collect while you are operating our website (“Site”) or other tools (“Tools”) that are needed in order for the business to operate. This Privacy Policy applies to https://torchconsulting.com.ph (hereinafter, “us”, “we”, or “https://torchconsulting.com.ph”) and the platforms such as assessment tools or the surveys we conduct. We respect your privacy and are committed to protecting personally identifiable information you may provide us through the Site and/or Tools. We have adopted this privacy policy (“Privacy Policy”) to explain what information may be collected on our Site and/or Tools, how we process this information, and under what circumstances we may disclose the information to third-party entities.
This Privacy Policy, together with the Terms and conditions posted on our Site, set forth the general rules and policies governing your use of our Site and/or Tools. Depending on your activities when visiting our Site and/or Tools, you may be required to agree to additional terms and conditions. The Privacy Policy explains why Torch, by its Site and/or Tools, collect and process data. The User of the Site and/or Tools is advised to read carefully through the said policies. By using the Site and/or Tools, the Data Subject confirms that he or she is of legal age and that he or she accepts and consents to be bound by the provisions of this Privacy Statement as well as the processing of his or her Personal Information, which may include personal data and/or sensitive information as set out in this Privacy Statement and/or otherwise provided by the Data Subject or possessed by Torch for one or more of the purposes as described herein.
Website Visitors
Like most website operators, Torch collects statistics or analytics data about the behavior of the Users to its Site and/or Tools. The collected data are non-personally-identifying information and are generated by web browsers or servers such as browser type, language preference, referring site, and the date and time of each visitor request. Torch’s purpose in collecting this information is to better understand how Users use our Site and/or Tools. From time to time, Torch may release non-personally-identifying information in the aggregate such as publishing a report on trends in the usage of our Site and/or Tools. Rest assured, Torch does not disclose the User’s Personal Information.
Torch also collects potentially personally-identifying information like Internet Protocol (IP) addresses for logged in users and for users leaving comments on our Site’s blog posts, storing of Cookies that is limited only to storing data on the specific session of the User, and other similar technologies to collect and store information when its Site and/or Tool is used. Torch only discloses logged in user and commenter IP addresses under the same circumstances that it uses and discloses personally-identifying information as described below.
Gathering and Security of Personally-Identifying Information
To operate effectively and provide the Data Subject the best experience, Torch collects personal data from the Users through the Site and/or Tools and implements the rules and regulations found in the Data Privacy Act of 2012 of the Philippines. Certain Users of the Site and/or Tools choose to interact with Torch in ways that require them to input personally-identifying information. The amount and type of information depends on the nature of the interaction. For example, we ask visitors who sign up for a blog at https://torchconsulting.com.ph to provide a username and email address. Processing of User’s information includes, but is not limited to, the following:
- Collection of relevant information to provide proper analysis of reports
- Use/Sharing with relevant consultants for accurate processing
- Storage and data archiving for future analysis
- Client Prospecting, Forecasting, and Marketing processing
When the Data Subject makes use of our Site and/or Tools, we automatically collect and store certain information in our server logs. These include, but is not limited to, the following:
- Personal information (name, address, birthday, email address and contact information such as mobile number)
- Employment information (company and job position/role, company email address)
- Internet protocol address (IP Address)
- Cookies that may uniquely identify the browser and operating system of the User
To protect the personal information of the Data Subject, Torch takes appropriate organizational, physical, and technical measures intended to protect the data against any accidental or unlawful destruction, alteration, disclosure, as well as protection against human dangers such as unlawful access, fraudulent misuse, unlawful destruction, alteration and contamination. But remember, no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Information, we cannot guarantee its absolute security. In case of questions or requests on the submitted information, please contact Torch using the contact page found in the Site. Depending on the sensitivity of the information, Torch uses the following, but is not limited to, data storage mediums:
- Google G-Suite Accounts
- Local files storage (e.g. Thumb Drives or External Hard Drives)
- Local computers
- Electronic Mail (E-mail)
- Digital Files such as Excel Spreadsheets or Word Documents
- Filing cabinets
- Internal Torch administration system
- Platform(s) used for conducting surveys and/or assessments
Usage and Processing of Personal Information
Torch uses the Personal Information that it collects from the Data Subject through the Site and/or Tools to provide, maintain, protect, improve, and develop Torch’s services. Further, Torch may use the data provided by the Data Subject to create a profile in its system which will allow us to identify the Data Subject whenever Torch’s services are used. We may also use the Data Subject’s provided email address to inform him or her of its services such as product offers, changes, or improvements in the system.
In particular, Torch uses the Personal Information it collects from the Data Subject through the Site and/or Tools for purposes such as, but is not limited to, the following:
- Operational processes
- Marketing research
- Database backups and uploading
- Reporting after analysis of data
- Program reviews
- Feasibility studies
- Database collecting for baseline studies across industries
Torch will keep the Personal Information of the Data Subject confidential. However, it may be necessary for Torch to transfer and disclose personal information for similar purposes to the following, but not limited to, categories of parties:
- Companies, organizations, and/or individuals such as auditors, consultants, accountants, lawyers or other financial or professional advisers that act as Torch’s contractors and/or service providers;
- Torch’s channel partners and affiliates for purposes that are related to the purpose for collecting and using the Data Subject’s personal information;
- Other parties in respect of whom the Data Subject has previously given his/her express consent;
Torch will only disclose personal information with the above mentioned entities for the purpose/s indicated only with the consent of the Data Subject or if required by an applicable law, judicial, or other governmental action. The Data Subject is deemed to have given such consent once he or she provides personal information details through Torch’s Site and/or Tools. See section on User Consent for more details.
Third-Party Privacy Policies and Statements
In general, the third-party providers used by Torch will only collect, use, and disclose User’s information to the extent necessary to allow them to perform the services that they are expected to provide to Torch. However, certain third-party service providers, such as payment gateways and other payment transaction processors, have their own privacy policies and statements with respect to the information that Torch is required to provide to them for user purchase-related transactions. We have no control over, and assume no responsibility for the content, privacy policies, or practices of any third party sites, products, or services. We strongly advise you to review the Privacy Policy and Terms and Conditions of every site you visit. For such providers, Torch recommends that the Data Subject should read their privacy policies and statements so that the Data Subject can understand the manner of how his or her personal information will be handled by these providers. In particular, the Data Subject is reminded that certain providers may be located in or have facilities that are located in different jurisdictions. Hence, if the Data Subject elects to proceed with a transaction that involves the services of a third-party service provider, then the information may become subject to the laws of the jurisdiction(s) in which such service provider or its facilities are located. As an example, if the Data Subject is located in the Philippines and the transaction is processed by a payment gateway located in the United States, then the personal information used in completing that transaction may be subject to disclosure under United States legislation, including the Patriot Act.
User Consent
Torch’s Site and/or Tools will provide an avenue for the Data Subject to give consent. An example of which is an Information Guide to be given during an assessment. The purpose of the information guide is to give the user an understanding of what the Tool is about, its purpose and objectives, and possible risks and benefits of undergoing Torch’s Tool. Before conducting the actual process of any Tool, a question asking for the Data Subject’s consent will be presented and depending on the medium of how the Tool is conducted, the Data Subject may tick and/or sign the specific sections indicating that they agreed and deemed to have given consent to the collection, use, and processing of his or her personal data in connection with the Site and/or Tools of Torch. In case of questions or requests on the submitted information, withdrawal of the User’s consent regarding usage or disclosure of his or her Personal Information, the Data Subject may contact Torch using the contact page found in the Site. Under the Data Privacy Act of 2012 of the Philippines, Torch shall need to comply with the request and undergo due process in checking the proper execution of the Data Subject’s request regarding his or her Personal Information making sure that in doing so, Torch does not violate any other law it is bound to comply to.
Rights of the Data Subject
Under and in accordance with the terms of the Data Privacy Act of 2012 of the Philippines, the Data Subject whose personal information will be processed has the following rights: the right to object to processing of data, the right to access data, the right to correct any inaccurate data, and the right to erasure or blocking of data, among others. For more information on these rights, and for requests to review the data, and/or to correct or update the data, the Data Subject may contact Torch using the contact page found in the Site.
Site and/or Tool Cookies and Advertisements
To enrich and perfect your experience on our different platforms, Torch uses “Cookies” and similar technologies and services provided by others to display personalized content, appropriate advertising, and store your preferences on your computer. A Cookie is a string of information that a website stores on a visitor’s computer, and that the visitor’s browser provides to the website each time the visitor returns. Torch uses Cookies to help us track Users, their usage of the Site and/or Tools, and their website access preferences. Torch Users who do not wish to have Cookies placed on their computers should set their browsers to refuse Cookies before using our Site and/or Tools, with the drawback that certain features of the Site and/or Tools may not function properly without the aid of Cookies. By continuing to navigate our Site and/or Tools without changing your cookie settings, you hereby acknowledge and give consent in the usage of Cookies.
Inline with this, Advertisements appearing on our Site and/or Tools may be delivered to users by advertising partners, who may set Cookies. These Cookies allow the ad server to recognize your computer each time they send you an online advertisement to compile information about you or others who use your computer. This information allows ad networks to, among other things, deliver curated and targeted advertisements that they believe will be of most interest to you. This Privacy Policy covers the use of Cookies by Torch and does not cover the use of Cookies by third-party entities.
Privacy Policy Changes
Although most changes are likely to be minor, Torch may change its Privacy Policy from time to time, and at Torch’s sole discretion. We encourage Users to frequently check this page for any changes to its Privacy Policy. Your continued use of this site after any change in this Privacy Policy will constitute your acceptance of such change. In the event that Torch is acquired by or merged with another company, the personal information may be transferred to the new owners in order for us to continue to sell our products and services. Nonetheless, we will ensure that any personal information will remain confidential and we will provide the affected Data Subjects with notice before the pertinent personal information is transferred or becomes subject to an updated or different Privacy Statement.