Privacy Policy

Last updated: May 25, 2026

Torgen respects your privacy. This Privacy Policy explains how Torgen collects, uses, discloses, and protects information when you visit our website, request a demo, contact us, or interact with our services.

For purposes of this Policy, “Torgen,” “we,” “us,” and “our” refer to Torgen and its website, products, research, and related services.

Our website is built on Google Sites, our forms are powered by Google Forms, our traffic is analyzed via Google Analytics, and our backend operations are managed using Google Workspace. By interacting with our site, your data will be processed through Google's cloud infrastructure in accordance with this policy.

1. Information We Collect and Categorize (CCPA Notice at Collection)

We may collect the following categories of personal information:

• Identifiers: Name, business email address, company or organization name, job title, or role.

• Commercial Information: Details regarding demos requested, business inquiries, and interest expressed in our cybersecurity risk intelligence products.

• Internet or Other Electronic Network Activity (Google Sites & Google Analytics): IP address, browser type, device type, operating system, pages viewed, referring website, time/date of visit, and general usage and performance data automatically collected via Google infrastructure and Google Analytics.

• Geolocation Data: General, non-precise geographic location (such as city or country) derived from your IP address.

• Professional or Employment-Related Information: Job title, company size, and context relevant to evaluating cybersecurity risks or vendor relationships.

Please do not submit sensitive personal information, protected health information, passwords, credentials, confidential incident data, or regulated customer data through public website forms.

2. Legal Bases for Processing (GDPR Compliance)

If you are a resident of the European Economic Area (EEA), United Kingdom (UK), or Switzerland, we process your personal data under the following legal bases pursuant to the General Data Protection Regulation (GDPR):

• Consent: For tracking cookies, utilizing Google Analytics, and sending marketing communications where required by law. (You can withdraw consent at any time).

• Performance of a Contract: To take steps at your request prior to entering into a contract, such as processing your request for a product demo or evaluating a vendor relationship.

• Legitimate Interests: To maintain the security and integrity of our Google Sites website, optimize website performance, defend against fraud, troubleshoot technical issues, and conduct cybersecurity research to develop graph-based risk intelligence.

3. How We Use Information

We may use information to:

• Respond to inquiries and demo requests.

• Provide, improve, and develop our website, products, research, and services.

• Communicate with you about Torgen, including demos, updates, and relevant content.

• Analyze website performance and usage using Google Analytics.

• Maintain security, prevent abuse, and troubleshoot technical issues on our Google Sites infrastructure.

• Conduct cybersecurity research and develop graph-based risk intelligence.

• Comply with legal obligations and enforce our rights.

AI Training Exclusions: We do not use information submitted through website demo forms, contact forms, or hosted Google Workspace applications to train public AI models.

4. How We Share and Disclose Information

We do not sell personal information. We do not "share" your personal information for cross-context behavioral advertising as defined under the CCPA.

We disclose your information to the following categories of recipients:

• Primary Infrastructure Providers (Google): Because we use the Google Ecosystem, your information is stored and processed securely within Google Workspace, Google Drive, Google Sites, and Google Forms. Google acts as a data processor adhering to strict security standards.

• Professional Advisors: Such as attorneys, accountants, or consultants who assist in corporate operations.

• Authorities or Other Parties: When required by law, legal process, security obligations, or to protect rights, safety, and integrity.

• Corporate Transactions: If Torgen is involved in a merger, acquisition, financing, reorganization, or sale of assets, information may be transferred as part of that transaction.

5. Cookies and Google Analytics

Our website uses cookies and similar technologies dropped by Google Sites to maintain necessary site functionality and security.

We also utilize Google Analytics to understand how visitors interact with our content. Google Analytics uses cookies to collect standard internet log information and visitor behavior information in an anonymous form.

• To learn more about how Google uses data when you use our site, visit Google's Privacy & Terms.

• You can opt-out of Google Analytics tracking entirely across the web by installing the Google Analytics Opt-out Browser Add-on.

• You can control or disable cookies through your individual browser settings, though some functional features of Google Sites may require cookies to load properly.

6. International Data Transfers (GDPR Compliance)

Torgen is headquartered in the United States. Information collected via our website will be transferred to, stored, and processed in the United States or other jurisdictions where Google operates its data centers.

To ensure an adequate level of data protection for EU and UK citizens, Google utilizes Standard Contractual Clauses (SCCs) approved by the European Commission and relies on the EU-U.S. Data Privacy Framework (DPF) to legitimize transatlantic transfers of data within Google Workspace and Analytics services. By submitting your data, you acknowledge this international transfer.

7. Data Retention

We retain your personal information only for as long as reasonably necessary to fulfill the purposes described in this Policy (e.g., to fulfill a demo request or maintain an active business relationship), satisfy legal or accounting obligations, or resolve disputes.

Retention criteria are based on the nature of the relationship, legal statutes of limitations, and the operational necessity of the data within our Google Workspace environments.

8. Your Privacy Rights

Depending on your jurisdiction (including California (CCPA), EEA/UK (GDPR), and other US state privacy laws), you may have the following rights regarding your personal information:

• Right to Know / Access: Request a copy of the specific personal data we hold about you.

• Right to Correction / Rectification: Request that we correct inaccurate or incomplete data.

• Right to Deletion / Erasure ("Right to be Forgotten"): Request that we delete personal data collected from you, subject to certain legal exceptions.

• Right to Restrict or Object to Processing: Object to processing based on legitimate interests or request that we limit how your data is processed.

• Right to Data Portability: Request a copy of your data in a structured, machine-readable format.

• Right to Opt-Out of Sale or Sharing: (Torgen does not sell your data or share it for targeted advertising, but you retain the right to confirm this).

• Right to Non-Discrimination: Torgen will never discriminate or retaliate against you for exercising your privacy rights.

To exercise any of these rights, please contact us using the information in Section 11. We will verify your identity (which may require matching information you previously provided) before fulfilling the request.

If you are in the EU/UK, you also have the right to lodge a complaint with your local Data Protection Supervisory Authority if you believe our data processing violates applicable law.

9. Children’s Privacy

Torgen’s website and services are intended strictly for business users and are not directed to children. We do not knowingly collect personal information from children under 13 (or under 16 in the EEA/California).

10. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our services or legal obligations. The updated version will be posted on this Google Sites page with a revised “Last updated” date.

11. Contact and Data Controller Identity

For the purposes of the GDPR, the Data Controller is Torgen.

For privacy-related questions, to exercise your rights, or to submit a privacy request, please contact us via our website contact form.