Privacy Policy
Effective Date: May 12, 2025
This Privacy Policy is designed to inform you of our policies and procedures regarding the information we collect, how we use it, and the choices available to you. This Privacy Policy applies to information we collect about you in the course of our business, including the Torrpa website, services, marketing campaigns, any other online services operated by or on behalf of Torrpa, and any other services that display this Privacy Policy (collectively, the “Services”). When we use the terms “Torrpa,” “we,” or “our,” we are referring to Torrpa.
1. Information We May Collect
The information we collect about you depends on the Services you use, how you use them, and the information you provide to us. We collect information in three primary ways: (1) information you choose to provide to us; (2) information we collect automatically through technology when you use the Services; and (3) information we collect from other sources.
Information You Choose to Provide to Us
When you use the Services, you may choose to provide us with certain information. For example, we collect information directly from you when you place an order to purchase something, create or use a Torrpa account, post a comment or submit a question, contact us with questions or comments, participate in the "Refer a Friend" program, or sign up to receive marketing emails from us. Some of the most common categories of information we collect directly include:
Contact and account information, such as your name, address, phone number, email address, and login credentials, including your Torrpa account information.
Financial and transaction information, such as billing and payment information (processed by our payment processor) and purchase and transaction history.
Customer service interaction information, such as messages submitted to us via online forms or email.
User-generated content, such as reviews, ratings, questions, photos, or other content, which may be publicly viewable depending on where you post it on our Services.
Information you provide in connection with surveys and sweepstakes, such as your interests, preferences, demographics (e.g., gender), photos and videos, and information necessary for you to participate and for us to fulfill your prize or participation reward (if any).
Information We Collect Automatically Through Technology When You Use the Services
In addition, like most websites or applications, we may also automatically collect certain information about the computer or device (including mobile devices) you use to access our Services. For example, we may collect and store your IP address, browser type, referring/exit pages, operating system, search terms you use on the Services, and general location information (e.g., city/state/province based on IP address).
We and our vendors may use "cookie" technology and other online tools (such as web beacons and web pixels) to automatically collect this information. A "cookie" is a small text file that is downloaded to your computer or mobile device when you visit a website or application and is used to store information about your use of such services. The information collected through cookies enables us to provide you with better customer service and improve the functionality of our Services in various ways, including determining whether you have visited the Services before and which parts of our Services you have visited. Cookies (or other mechanisms) may also track shopping cart activity to determine when a shopping cart is abandoned and to send shopping cart reminder messages via text message.
When you use the Services, we or third parties that operate analytics or advertising technology may also use information collected through cookies and similar technologies to analyze your use of the Services (and other websites, applications, and services tracked by these third parties) and/or to help deliver Torrpa and third-party advertisements to you through the Services and third-party websites, applications, and services. These advertising technologies can also help limit the number of times you see a particular advertisement, deliver advertisements relevant to your interests, and measure the effectiveness of advertising campaigns.
We or our partners may use some of these technologies to link your information collected over time from two or more websites or online services. Additionally, we may combine the information we collect with information from third parties that may identify you. We may use this linked and/or combined information to enhance or market our Services and for other purposes described in this Privacy Policy.
Most web browsers automatically accept cookies, but you can block certain cookies using the privacy settings and options provided by your web browser (e.g., disabling cookies). Please note that if you decide to block all cookies, this may affect your ability to perform certain transactions, use certain features, and access certain content on the Services.
Information We Collect from Other Sources
We may receive information about you from other sources (such as business partners, marketers, researchers, data analytics partners, social networking services, and others) to help us supplement our records.
If you access our services through a third-party website, application, or social media platform (such as Instagram or Facebook), we may receive your information from that third-party service, depending on the third party's data processing practices and your settings (for example, your name, email address, and comments or content you post). We are not responsible for their content or processing practices and encourage you to read their privacy and security policies.
Third-Party Pixels and Cookies
When you visit our website, log in, register, or open an email, our online data partners or vendors may use cookies, advertising beacons, and similar technologies to link those activities to information they or others hold about you, including your email address. We (or our service providers on our behalf) may send communications and marketing messages to those email addresses.
2. How We Use Your Information
We may use the information we collect in the following ways:
Provide the services you request, such as completing a purchase or responding to a customer service request;
Communicate with you, including updating you on purchases, shipments, and changes to our terms, conditions, and policies;
For marketing and advertising purposes, including providing you with the latest shopping announcements, promotions, and information about upcoming events from Torrpa and other companies whose products or services we think you might like;
Personalize your experience and customize the Services, such as providing relevant content and recommendations through our Services.
Improve our Services, including error detection and error reporting, understand how users interact with our Services and ads, and conduct research and analysis to help develop better products;
Protect the rights of the Services and others by using the information we believe in good faith is necessary or appropriate to secure, protect, enforce, or defend the legal rights, privacy, safety, or property of the Services, its employees or agents, or other users, and to comply with applicable laws and legal process;
And for such other purposes for which we have your consent.
Aggregate Information
For the purposes discussed in this Privacy Policy, we may combine information collected through the Services with information we receive from other online sources and use such combined information in accordance with this Privacy Policy.
Aggregate and/or De-identified Information
We may aggregate and/or de-identify any information collected through the Services so that such information is no longer associated with you or your device ("Aggregate/De-identified Information"). We may use Aggregate/De-identified Information for any purpose, including, but not limited to, research and marketing purposes, and may share such data with any third party (including advertisers, promotional partners, and sponsors) at our discretion.
3. Legal Basis for Using Your Information
The laws of some jurisdictions require companies to tell you about the legal basis on which they process your information. The legal basis for processing your information described in this Privacy Policy is as follows:
Performance of a Contract or Commitment
When we need to use your information to perform a contract or commitment between us and you. For example, to provide a service you requested (such as completing a purchase or complying with our Terms of Use).
Legitimate Interests
Where the use of your information is in our or a third party's legitimate interests. For example, to provide security for our services, operate our business and services, process and collect payments, enforce our legal rights, and prevent fraud.
Comply with Legal Obligations
We will use your information to comply with applicable legal obligations in Hong Kong. For example, to track purchases for tax and audit purposes.
By using our services, you consent to our processing of your information for the specific purposes listed above.
4. How We Share Your Information
We may share your information in the following ways:
Affiliated Entities: We may share your information with our subsidiaries and affiliates for various purposes, including providing products and services to you, operating our business, and enhancing your customer experience.
Service Providers: We may share information with third-party vendors who are hired to perform business functions on our behalf or provide services to us. These services may include:
Payment processing, order fulfillment, and delivery
Customer service and support
Email service delivery
Advertising, marketing, surveys, and promotions
Information technology and office services, such as website development and hosting
Payment processing services, fraud protection, and credit risk reduction
Legal, accounting, auditing, and other professional services
Marketing Partners: We may use and share information you provide to us, or that we collect about you, including your contact and billing/shipping information, as well as information about your interactions with our Services and third-party promotions on the Services, so that we and other brands can contact you about products and services you may like.
Protection of Torrpa and Other Organizations: We reserve the right to disclose your personal information as required by law, such as to comply with a subpoena or similar legal process, or when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request.
Business Transfers: As our business continues to develop, we may be involved in a merger, acquisition, or sale of all or a portion of our assets. In such transactions, including those currently under consideration, your information may be among the assets transferred. If some or all of our assets are sold or transferred to a third party, we may share or transfer your information as part of that transaction.
5. Your Controls and Choices
Email Marketing
If you do not want to receive marketing communications from us, you can follow the unsubscribe instructions included in the email you receive or contact customer@torrpa.com. Torrpa will continue to send you non-promotional service emails related to your account, such as order questions, billing and payment information, and other emails related to your account, orders, and/or your use of the Services.
Requests Regarding Your Personal Information
We provide you with the ability to exercise certain controls and choices regarding our collection, use, and sharing of your personal information. Your legal rights to exercise such controls and choices vary depending on the laws of your jurisdiction. For example, you may have the right to:
obtain access to or a copy of your information and, in certain circumstances, receive it in a structured, commonly used, and machine-readable format or transmit it to a third party in this form;
update, correct, or delete your information;
object to the use, sale, or disclosure of that information;
withdraw consent previously provided for the processing of your information (without affecting the lawfulness of any prior use or disclosure of that information); and
obtain restrictions on the use of your information.
If you wish to exercise any rights provided by applicable law, you may email customer@torrpa.com and provide your name and a description of your request. We may verify your identity, where permitted by law. This allows us to reasonably respond to your inquiries and requests.
Please note that if you have registered an account with us, you can also update your contact information, such as your address, on your account page, which you access after logging in.
Controls Related to Cookies and Other Automated Data Collection
You can manage your cookie preferences through the "Cookie Settings" (or "Do Not Sell My Personal Information") link in the footer of our websites. This will launch a tool where you can adjust your preferences for the use of certain cookies and similar technologies on our participating websites. You will need to repeat this process for each browser and device where you want your preferences to apply.
You can change the settings on your mobile device to manage how your device collects and shares your mobile advertising identifier for advertising and analytics purposes, including our use of it for these purposes.
On iOS mobile devices, depending on your iOS version, you may be able to select "Limit Ad Tracking" under "Ads" or make choices for all or certain apps under "Tracking."
On Android mobile devices, you may be able to "Opt out of interest-based ads" by clicking on the "Opting Out of Interest-Based Ads" box.
In addition, you can review and use the privacy options of these vendors:
Google allows you to install the Google Analytics Opt-Out Browser Add-on for each web browser you use to limit their browser-based activity.
If you are interested in learning more about tailored advertising and your choices about preventing certain third parties from serving tailored ads, you can visit the following third-party websites: the Network Advertising Initiative Consumer Opt-Out Page or the Digital Advertising Alliance Consumer Opt-Out Page.
We are committed to providing you with meaningful choices about whether to allow third-party collection of information on our website, and therefore we offer the various opt-out mechanisms described above. Because technology evolves rapidly and there is still uncertainty about the meaning of "Do Not Track" signals, we currently do not guarantee compliance with "Do Not Track" signals.
Data Retention and Account Closure
We retain information for varying periods of time, depending on the purposes for which we collect and use the information as described in this Privacy Policy. We will delete or de-identify the information when it is no longer necessary for those purposes, unless a longer retention period is required under applicable law.
If you have created an account on the Services and wish to close it, you can do so by emailing customer@torrpa.com. We may retain a record of your information for a period of time after you close your account. This is to allow us to follow up on requests related to your order history, resolve disputes, maintain security, prevent fraud and abuse, enforce our Terms of Use, fulfill your requests to "unsubscribe" from our follow-up communications, meet regulatory requirements, or comply with applicable state or local laws (including law enforcement requests).
6. How We Protect Your Personal Information
The security of your information is important to us, and we are committed to handling it with care. We implement a variety of safeguards designed to protect your information. Unfortunately, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, while we strive to use commercially acceptable means to protect your information, we cannot guarantee its absolute security.
Please note that when you register for an account, you will be prompted to select a password. For maximum security, you should choose a strong password. You are entirely responsible for maintaining the confidentiality of your password and all account information.
7. Notice to International Users
We operate globally and may transfer, store, and/or process your information to other entities located around the world for the purposes described in this Privacy Policy. By providing us with your information, you consent to any such transfer, storage, or processing.
If you have any concerns or complaints about our data processing practices, we encourage you to first attempt to resolve them directly with us. However, if applicable, you may lodge a complaint with the data protection regulator in your country or seek remedies through your local courts if you believe your rights have been violated.
8. Children's Information
Our websites and services are intended for the general public and are not directed to children. If we discover that we have collected data from children under the age of majority without valid parental consent, we will take reasonable steps to delete such information from our database and will not use it again (unless necessary to protect the child's safety or as otherwise required or permitted by law). If you become aware of any such information, please contact us at customer@torrpa.com.
9. Updates to This Privacy Policy
We reserve the right to change, modify, add, or remove portions of this Privacy Policy at any time. You should review this page periodically to stay informed of changes since your last review by checking the "Effective Date" at the beginning of this document. Your continued use of the Services after changes to this Privacy Policy are posted will be deemed confirmation that you have read and understood the most recent version of this Privacy Policy. If we make material changes to this Policy, we will provide notice through our Services or other means, as required by applicable law, to give you an opportunity to review the changes before they take effect.
10. Support and Contact
If you have any questions about this Privacy Policy, please contact us at customer@torrpa.com.