Privacy Policy

We place great importance on the security of our business and services. This page describes the data that we, Torpedo – Serviços de Informática, Lda (Torpedo), collect, process and share. It also describes the rights that you, as the data subject, have, and how you can exercise them should any data protection problem arise from the use of our products and services.

This Privacy Policy has been developed in accordance with the General Data Protection Regulation (GDPR), as outlined in the Regulation (EU) 2016/679 of the European Parliament and of the Council. It includes information about what data we collect, how we use it, why we use it, who we share it with, and which means are used to keep it safe, useful, and up to date.

Our products and services are subject to this Privacy Policy, so we recommend that You read it carefully before acquiring them.

1. Overview

Personal Data is any information relating to a person (data subject), that allow for the person’s identification by direct or indirect means. In the context of your personal data, Torpedo acts as either a data controller or a data processor.

A Data controller is someone (a person or entity) who collects and processes data, for various (legitimate) purposes. Similarly, a Data processor is someone who processes personal data on behalf of the data controller. One such example is when the organization you work for acquires our products or services: you are the data subject, your employer is the data controller, and Torpedo is the data processor.

Processing of personal data relates to any operation(s) performed on said data, for example: collecting, organizing, storing, altering, retrieving, consulting, using, and disclosing, regardless of whether these operations are made though manual or automated means.

In this matter, most of our Products and Services require installation on-premises. This means we will not access or control any personal data, aside from the data required for our solutions’ functionalities. Any further access to or control over your personal data by Torpedo will require your consent, either by opt-in mechanisms or because you provide such data voluntarily (for example, when giving us feedback or requesting our support services).

2. Personal Data we collect

All personal data collected by Torpedo respects the principles for processing personal data: a) lawful, fair and transparent; b) limited to explicit and legitimate purposes; c) minimized to what is adequate and necessary for its purpose; d) accurate and up to date; e) stored in a way and for the duration strictly necessary to meet its purpose and the legal and regulatory requirements; f) protected in order to preserve its integrity and confidentiality.

In general, we collect information directly from you, your company, your device, or third parties (as long as they have your permission and/or a lawful reason for disclosing it).

While navigating and interacting with our website, no Personal Data is collected. Some anonymous data is collected via Cookies, that are small files that your browser stores on your computer to improve your browsing experience (for example, for faster page loads and assistance on form-filling). Information about Cookies can be found in our Cookie Policy page.

Once you decide to contact us, download our online resources, start a trial version or acquire one of our Products, you will be asked to provide personal details that may include:  contact information, full name, the company you’re representing, billing information, payment information. These are necessary for different purposes, further explained in the next sections.

Additionally, we may also request your login data, namely, your Microsoft 365 username and password. These are necessary to ensure that the Product you acquire works properly, as our products are developed to work on your SharePoint environment. When you purchase a license to a Product, we will also collect your IP address for the purpose of license management.

Finally, your contact information (email and/or phone number) may be used to provide you with important technical information about the Product you purchased, such as information about new updates available or even updates to the Terms of Service or the Privacy Policy.

No other Personal Data is necessary for the provision of our products and services, as the information available in your IT infrastructure will not be accessed by Torpedo, except for information we may access in the event of a technical support session requested by you.

3. How we use Personal Data

We process the Personal Data necessary to provide our services, to improve on our products, to better your experience as a user and to monitor our business. Torpedo will only use or process your personal data for the explicit purposes it has been collected for, and will only store it for the duration necessary to fulfil its purpose.

Under no circumstances will any information provided by you be used for automated decision-making or for profiling purposes. We will also never share your information with third parties, except for the ones necessary to guarantee: a) the purchase and payment of our Products, b) the fulfillment of the Terms of Service, c) compliance with accounting, fiscal and legal obligations. These third parties include bank entities, external accountants and auditors, email service providers, legal advisors, governments, public authorities, and law enforcement agencies.

A note on international data transfers: If we need to transfer your information across borders to any of the third parties listed above, we will only do so if the appropriate international data transfer safeguards outlined in the GDPR are in place.

4. Why we use Personal Data

Please note that some data is necessary for Torpedo’s legal and fiscal compliance; this is the data you provide when acquiring our Products, and such data will not be used or processed for any other purpose without Your consent.

Other Personal Data provided by you, such as login and other information, are necessary for the provision of our services and for the correct functioning of our Products; when you acquire one or more of our Products, you may be required to fill out some of your information for this purpose, and this data will not be used for any additional purposes without your consent.

Our Products collect some information necessary to monitor its operating status and to flag any performance or security issues. This information is essential for monitoring the quality of our products and services and is composed of anonymous information (in the sense that it does not make you identifiable).

Finally, Personal Data regarding your interactions with our Products, and feedback or support requests, will only be processed if it is either given voluntarily (for example, by rating our Products in the store) or if you have given us consent for its processing (for example, by selectin an “opt-in” option). This data is used to improve the Products or to fix any issues detected by you, the user.

Personal Data may also be used for marketing purposes and for advertising our Products, if you freely choose to receive this information periodically via email or other alternative means. You can unsubscribe or withdraw your consent at any time to stop receiving these communications.

5. What are your Rights regarding Personal Data

As the data subject, you have the right to be informed about what data, how and why it is processed by Torpedo. This information is outlined in this Privacy Policy. However, if you feel the need for additional information about data protection or GDPR compliance, you may contact us via the email address available at the end of this page.

Additionally, you may also request access to or a copy of the Personal Data we have on you, as well as requesting its rectification or erasure. Please note that some information may not be immediately erased upon request, namely in the case information necessary for legal or fiscal compliance; it will, however, be erased as soon as such obligations cease to exist.

Any information processed by Torpedo that depends on your consent will cease to be processed if you decide, at any time, to withdraw such consent. Bear in mind that withdrawing your consent does not affect the legitimacy of the data processing that was happening while the consent was in effect.

6. Data security

Data security is a very important matter. To ensure it, we have adopted a variety of administrative, technical, physical, and organizational measures that aim to protect against accidental or unlawful destruction, loss, alteration, disclosure, or access to any Personal Data under our control or being processed by us.

However, no matter how many measures are in place, there is always a small risk of breach. As well as your information is protected while under our control, external factors or cyber attacks may pose a risk to the integrity or confidentiality of the data. We will address such events as soon as we become aware of them and inform you about the types of data accessed and the extend of the compromise. If you become aware a breach has happened and fear for your personal data’s integrity, you may contact us at any time.

As an alternative to contacting us or if, by any chance, we are unable to resolve your complaint or provide you with the information you need, you should contact the data protection supervisory authority in your country.

Policy last updated: November/2023