Torii Logo

Privacy Shield Notice

Effective: Oct-1, 2019

Torii Software, Inc. (“Torii”, “We” or “Our”) has certified with the EU-U.S. Privacy Shield and the Swiss-U.S. Privacy Shield with respect to the Personal Data (defined below) that We receive from the Customers (defined below) or from Torii Labs Ltd. (“Torii Labs Ltd.”).

Torii complies with the principles of the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of Personal Data transferred to the United States. Torii has certified to the Department of Commerce that it adheres to the Privacy Shield Principles and Our Privacy Shield certification, when approved, will be available here.

If there is any conflict between the terms in this Privacy Shield Notice and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, please visit https://www.privacyshield.gov/welcome.

  1. DEFINITIONS.

    Customer(s)” means prospective, current, or former customers, or clients of Torii and/or Torii Labs Ltd.

    Personal Data” means any information relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

    Processing” means any operation or set of operations which is performed on Personal Data or on sets of Personal Data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

  2. SCOPE.

    Torii's participation in the Privacy Shield applies to the Personal Data subject to EU and Swiss data protection law that (i) Torii receives from Torii Labs Ltd. and/or (ii) Torii collects and/or Processes on behalf of Torii Labs Ltd.

  3. PURPOSES OF DATA PROCESSING.

    Torii is an organizational SaaS management Platform (the “Service”).

    In order to perform the Service, we, Torii, Inc. may use Personal Information, namely, for the purpose of providing a SaaS management platform for organizations, which allows Torii’s customers to manage, optimize and control their SaaS usage and costs.

    Torii will Process the Personal Data it receives as described in Section 2, for the purposes of offering and/or providing the Service to Customers. To fulfill these purposes, We may, without limitation, use the Personal Data to contact data subjects, to discuss or execute contracts, to provide the Service, to provide support and maintenance, to correct and address technical or service problems, for marketing purposes, to comply with applicable laws, regulations and orders from public authorities or courts and/or for the establishment, exercise or defense of legal claims, whether in court proceedings or in an administrative or out-of- court procedures.

  4. ONWARD TRANSFERS OF PERSONAL DATA

    Subject to Section ‎6 below, We will not transfer Personal Data originating in the EU and/or Switzerland to third parties unless such third parties have entered into an agreement in writing with us requiring them to provide at least the same level of protection to the Personal Data as required by the Principles of the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework. We may transfer Personal Data to processors, service providers, vendors, contractors, partners and agents (collectively "Processors") who need the information in order to provide services to or perform activities on Our behalf. In cases of onward transfer to third parties of Personal Data received pursuant to the EU-U.S. Privacy Shield and the Swiss-U.S. Privacy Shield, Torii is potentially liable.

    The abovementioned Processors and the description of the services that they provide and/or the activities that they perform are set out in the table below:

    ProcessorService/Activity
    DocusignDigital Signature
    AWSCloud hosting
    AirtableDifferent databases, Project management
    PapertrailLog reporting
    HubspotCRM,Marketing automation
    DropboxFile hosting and file sharing
    ZoomVideo conference
    SlackTeam communication
    NetlifyCDN
    SentryClient-side debugging
    Zoho invoicesOnline invoices
    Google analyticsWeb Analytics
    SparkpostTransactional emails
    SegmentAnalytics data integration
    MixpanelWeb Analytics
    Google (G Suite)Email and productivity tools
    IntercomAnalytics,Customer support
    FullstorySession analytics
    PandaDocDigital Signature
    RedashBI dashboard
  5. RIGHT TO ACCESS, CHANGE AND DELETE PERSONAL DATA.

    Data subjects have the right to access Personal Data about them, and in some cases to limit use and disclosure of their Personal Data. If you would like to request access to the Personal Data We have processed on behalf of one of the Customers or to limit use and disclosure of your personal data, please contact: privacyshield@toriihq.com and provide your name, contact information and observe the required formalities under applicable law.

  6. REQUIREMENT TO DISCLOSE.

    Torii may be required in certain circumstances to disclose Personal Data in response to lawful requests by courts or public authorities, including to meet national security or law enforcement requirement.

  7. PRIVACY SHIELD INDEPENDENT RECOURSE MECHANISM

    In compliance with the Privacy Shield Principles, Torii commits to resolve complaints about Our collection or use of your Personal Data. EU and Swiss individuals with inquiries or complaints regarding Our Privacy Shield policy should first contact Torii at: privacyshield@toriihq.com or by postal mail sent to:
    Torii Software, Inc.
    Attn: Privacy Shield Inquiry
    500 7th Avenue
    New York
    NY 10018
    USA

    Torii has further committed to refer unresolved privacy complaints under the EU-U.S. Privacy Shield Principles and the Swiss-U.S. Privacy Shield Principles to JAMS, a non-profit alternative dispute resolution provider located in the United States to assist with the complaint resolution process. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit https://www.jamsadr.com/eu-us-privacy-shield for more information and to file a complaint. The services of JAMS are provided at no cost to you.

  8. U.S. FEDERAL TRADE COMMISSION ENFORCEMENT.

    Torii is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC) to ensure compliance with the EU-US Privacy Shield Principles and the Swiss-U.S. Privacy Shield Principles outlined in this notice.

  9. ARBITRATION.

    Under certain conditions, more fully described on the Privacy Shield website https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint, you may also be able to invoke binding arbitration when other dispute resolution procedures have been exhausted.