U.S. WEBSITE AND CLIENT PRIVACY NOTICE

Privacy Policy

Effective date: August 31, 2026

Last updated: August 31, 2026

TORTH Marketing | TORTH ENTERPRISE LLC · Denver, Colorado

TORTH Marketing respects your privacy. This Privacy Policy explains how TORTH ENTERPRISE LLC, operating the TORTH Marketing brand (“TORTH Marketing,” “we,” “us,” or “our”), collects, uses, discloses, and protects personal information when you visit torthent.com, contact us, book a call, subscribe to communications, become a client, or receive our services.

This Policy also explains how we handle personal information that clients give us for marketing, website, advertising, lead-generation, email, and related work. In those cases, our role depends on the engagement and the instructions in the applicable client agreement.

1. Scope

This Policy applies to personal information connected with:

the TORTH Marketing website, forms, landing pages, scheduling tools, and communications;
sales inquiries, proposals, client onboarding, billing, support, and project delivery;
marketing campaigns, analytics, advertising pixels, cookies, and similar tools used on our digital properties;
and personal information processed for clients under a proposal, statement of work, data processing addendum, or other written agreement.

This Policy does not govern a third party’s independent privacy practices. Google, Meta, TikTok, Shopify, WooCommerce service providers, hosting companies, payment processors, scheduling tools, social networks, and other outside platforms may collect information under their own policies.

2. Who We Are

TORTH Marketing is a U.S. digital marketing and content business operated through TORTH ENTERPRISE LLC and based in Sheridan, Wyoming. We provide social media management, email marketing, technical writing, marketing and sales

copywriting, sales funnel building and lead generation, marketing strategy for products, WooCommerce and Shopify website content, SEO/AEO/GEO services, paid advertising, and website building and hosting.

Website: https://torthent.com

Privacy contact: hello@torthent.com

3. Personal Information We Collect

Information You Give Us

We may collect the following information when you contact us, submit a form, book a call, request a proposal, sign an agreement, make a payment, or work with us:

Identifiers and contact details, such as your name, business name, job title, email address, telephone number, mailing address, and social media profile.
Business and project details, such as your website, marketing goals, audience, products, services, budget, timelines, brand information, campaign data, account preferences, and content requirements.
Commercial information, such as services requested or purchased, proposals, statements of work, invoices, payment status, renewal dates, and support history.
Communications, such as emails, messages, call notes, meeting recordings when notice or consent is provided, feedback, approvals, revision requests, and support inquiries.
Account and access information, such as usernames, access tokens, or credentials you choose to provide so we can work in approved business accounts. We recommend granting role-based access instead of sharing passwords whenever the platform supports it.
Payment-related information. Payment processors may collect card or bank details directly. We generally receive transaction confirmations, billing contact information, and limited payment records instead of full payment-card numbers.
Content and files, such as documents, images, videos, product catalogs, customer lists, analytics exports, campaign assets, technical materials, and other items submitted for a project.

Information Collected Automatically

When you use our website or digital properties, we and approved providers may collect:

Device and network information, including Internet Protocol address, browser type, operating system, device identifiers, language, and approximate location based on IP address.
Website activity, including pages viewed, links clicked, referring pages, dates and times, session duration, form interactions, and navigation patterns.
Cookie and tracking information from cookies, pixels, tags, local storage, analytics tools, and advertising technologies, subject to the choices described below.
Security and diagnostic information, including logs, error reports, suspected fraud signals, and data used to maintain website and account security.

Information From Other Sources We may receive information from:

referral partners, business contacts, public websites, professional networks, and social media platforms;
analytics, advertising, lead-generation, scheduling, payment, hosting, security, and email providers;
clients that ask us to work with their prospects, customers, employees, contractors, or other contacts; and
publicly available business records and lawful business-to-business data sources used for prospecting or account research.

When another party gives us personal information, that party is responsible for having the rights, notices, permissions, and legal basis needed to disclose the information to us.

4. How We Use Personal Information

We may use personal information to:

provide, manage, personalize, and support our website and services;
respond to inquiries, book calls, prepare proposals, enter contracts, and manage client relationships;
plan, create, review, publish, host, measure, and improve approved client work;
process invoices, payments, renewals, credits, refunds, and tax or accounting records;
send service messages, project updates, notices, and requested marketing communications;
analyze website and campaign performance, improve content, and understand how people find and use our digital properties;
prevent fraud, protect accounts, debug problems, enforce agreements, and maintain security;
comply with law, lawful requests, recordkeeping duties, and professional obligations; and
establish, exercise, or defend legal claims and protect the rights, safety, and property of TORTH Marketing, our clients, users, and others.

5. Cookies, Analytics, and Advertising Tools

We may use cookies and similar technologies to keep the website working, remember choices, measure traffic, understand performance, and support advertising. Tools from Google, Meta, TikTok, or other providers may be enabled on certain pages or campaigns.

Cookie categories may include:

Strictly necessary cookies used for security, forms, consent settings, and core website functions.
Functional cookies used to remember preferences or support embedded features.
Analytics cookies used to measure visits, performance, and engagement.
Advertising cookies and pixels used to measure campaigns, build audiences, limit repeated ads, or show ads based on activity across services.

You can use our cookie controls, when available, or your browser settings to reject or remove nonessential cookies. Blocking some cookies may affect website features. Where required, we honor recognized opt-out preference signals, including Global Privacy Control, for the browser or device sending the signal.

6. How We Disclose Personal Information

We may disclose personal information to the following categories of recipients when needed for a valid business purpose:

Hosting, cloud storage, website, cybersecurity, backup, and information technology providers.
Email, customer relationship management, scheduling, communications, collaboration, and file-sharing providers.
Analytics, advertising, social media, search, and campaign-measurement providers.
Payment processors, accounting providers, banks, and tax advisers.
Contractors and professional advisers that are bound by confidentiality or data-protection duties.
A client when the information relates to work we perform for that client.
Government agencies, courts, regulators, law enforcement, or other parties when disclosure is required or permitted by law.
A buyer, investor, lender, insurer, adviser, or successor connected with a merger, financing, asset sale, reorganization, due diligence process, or similar business transaction, subject to reasonable confidentiality safeguards.

We may also disclose information with your direction or consent. We do not disclose client confidential information for another client’s use.

7. Sale, Sharing, and Targeted Advertising

We do not sell personal information for money. Some U.S. state laws define “sale” or “sharing” broadly enough to cover the use of advertising cookies, pixels, or similar technologies for cross-context behavioral advertising. When those tools are enabled, identifiers, Internet activity, commercial information, approximate location, or marketing inferences may be disclosed to advertising and analytics partners.

You may opt out of this activity through the cookie controls on our website, a recognized browser-based opt-out preference signal, or a request to hello@torthent.com. We do not knowingly sell or share the personal information of anyone under 16 years old.

8. Client Data and Our Service-Provider Role

Some services require us to process personal information for a client. Examples include email subscriber lists, lead information, social media messages, website form submissions, advertising audiences, customer records, analytics data, and eCommerce information.

When we process that information only for a client’s documented business purpose, the client generally acts as the business or controller and TORTH Marketing acts as the service provider, contractor, or processor. We process the information under the client’s instructions, the applicable agreement, and any required data processing addendum. The client is responsible for privacy notices, consent, legal basis, preference records, suppression lists, data accuracy, and lawful collection.

We do not accept protected health information, full payment-card data, Social Security numbers, government identification numbers, biometric templates, precise geolocation, or other highly sensitive information for routine services unless we approve the use in writing and the parties sign any required security or data-protection terms.

9. Data Retention

We retain personal information only for as long as reasonably needed for the purpose for which it was collected, the client relationship, security, dispute handling, tax and accounting requirements, and other legal duties. Typical periods include:

Sales inquiries and business contact records: up to 24 months after the last meaningful interaction, unless the relationship continues or law permits a longer period.
Client agreements, approvals, invoices, tax records, and material business correspondence: generally seven years after the relationship or transaction ends.
Project files and working materials: for the engagement and a reasonable backup period, generally up to three years after completion unless the agreement requires a different period.
Marketing subscription records: while you remain subscribed, plus a suppression record after opt-out so we can honor your choice.
Website analytics and cookie information: according to provider settings, generally no longer than 26 months unless a shorter period is selected.
Security and diagnostic logs: generally up to 12 months, with longer retention when needed for an investigation or legal claim.

We may retain de-identified or aggregated information when it can no longer reasonably identify you. Backup copies may remain for a limited period before routine deletion

10. Data Security

We use administrative, technical, and physical safeguards designed to protect personal information based on its nature and risk. Measures may include access controls, multifactor authentication where available, encryption in transit, secure hosting, backups, confidentiality duties, provider review, and limited access to client accounts.

No website, transmission, storage system, or security measure can be guaranteed to be completely secure. You are responsible for protecting your devices, passwords, account permissions, and access links. Please contact us promptly if you believe information connected with TORTH Marketing has been compromised.

11. Your Choices

Marketing email: use the unsubscribe link in the message or email us. We may still send nonmarketing service or transaction messages.
Cookies: use the available cookie controls or browser settings. Recognized opt-out preference signals are handled where required.
Account access: change permissions in the relevant platform and tell us when access should end.
Correction: ask us to update inaccurate contact or account information.
Project data: contact the client that controls the information when we process it only on that client’s behalf. We may refer your request to the client.

12. U.S. State Privacy Rights

Depending on your state of residence and whether the applicable law covers TORTH Marketing, you may have the right to:

confirm whether we process your personal information and access it;
request correction of inaccurate personal information;
request deletion of personal information, subject to legal exceptions;
receive a portable copy of certain information;
opt out of sale, sharing, targeted advertising, or certain profiling;
limit certain uses or disclosures of sensitive personal information;
appeal a decision we make on a privacy request; and
receive equal service and not be discriminated against for exercising a privacy right.

To submit a request, email hello@torthent.com with the subject line “Privacy Request.” State your name, state of residence, the right you want to exercise, and enough information for us to identify the relevant records. We may verify your identity and authority before completing certain requests. We will not require verification for a request to opt out when the law prohibits it.

An authorized agent may submit a request when permitted by law. We may ask for proof of authorization and may still verify your identity directly. If we deny a request, our response will explain the reason and any available appeal method.

13. California Notice at Collection

The table below describes the categories of personal information we may collect, the business purposes for collection and disclosure, and typical retention. It also summarizes our practices during the preceding 12 months. A category may include information collected directly by us and information processed for a client.

CATEGORY AND EXAMPLES	PURPOSES AND RECIPIENTS	TYPICAL RETENTION
Identifiers and customer records: name, work contact details, IP address, account ID, signature, and billing address.	Client service, communication, billing, security, analytics, and marketing. Recipients: operating systems, hosting, payment, analytics, advertising, advisers, and relevant clients.	Relationship plus 7 years for material records.
Commercial information: services requested or purchased, proposal, invoice, payment status, preferences, and project history.	Sales, contracts, delivery, support, accounting, renewal, and business analysis. Recipients: payment, accounting, client-management, and advisers.	Relationship plus 7 years
Internet or network activity: browser, device, pages viewed, clicks, referring source, cookie IDs, and interactions.	Website operation, security, analytics, campaign measurement, and targeted ads. Recipients: hosting, security, search, social, analytics, and ad providers.	Analytics up to 26 months; security logs up to 12.
Approximate geolocation: general location derived from IP address.	Security, localization, analytics, and advertising. Recipients: hosting, security, analytics, and advertising providers.	Up to 26 months.
Audio, visual, and electronic information: messages, files, images, video, call content, or recordings made with notice or consent.	Communication, delivery, review, training, and disputes. Recipients: communications, storage, collaboration providers, and the relevant client.	Project period plus 3 years; material records longer.
Professional information: company, title, role, work history, professional profile, and business interests.	Business outreach, relationship management, delivery, and account research. Recipients: client-management, communications, referral, and research providers.	24 months after last contact, or for the relationship.
Sensitive personal information: account credentials or payment information handled through approved systems. Highly sensitive data is not requested for routine services.	Account access, payment, fraud prevention, and security. Recipients: approved platform, payment, security, and professional providers. Not used to infer characteristics.	Only as needed for access, records, security, or law.

During the preceding 12 months, we may have disclosed the categories above for the stated business purposes. We have not sold personal information for money. Advertising-cookie disclosures may count as sale or sharing under California law; you may opt out as described in Section 7. We do not use or disclose sensitive personal information for purposes that require a right-to-limit notice.

14. Children

Our website and services are for businesses and adults, not children under 13. We do not knowingly collect personal information from a child under 13. If you believe a child provided information to us, contact hello@torthent.com so we can review and delete it when required.

15. U.S. Processing and International Visitors

TORTH Marketing is based in the United States. If you visit from another country, your information may be processed in the United States or where our providers operate. Local privacy laws may differ from those where you live. We use required safeguards for cross-border transfers.

16. Third-Party Sites and Platforms

Our website may link to or embed outside services. We do not control their privacy, security, content, or data practices. Review the third party’s policy before submitting information or connecting an account.

17. Changes to This Policy

We may update this Policy when law, technology, services, vendors, or business practices change. We will post the revised version and change the Last Updated date. We may give a more direct notice when a change materially affects privacy rights.

18. Contact Us

Questions, privacy requests, and complaints may be sent to:

TORTH Marketing | TORTH ENTERPRISE LLC

Denver, CO, United States

Email: hello@torthent.com

Website: torthent.com

Questions about this page?

Email hello@torthent.com and we will respond as described above.