Effective Date: 04/11/2025
Last Updated: 04/11/2025
This Privacy Policy describes how Torpian, operated by Jithesh Rajendran (pending formal registration as Torpian Technologies Private Limited), (“Torpian,” “we,” “us,” or “our”) collects, uses, discloses, transfers, and protects personal data.
We are committed to respecting your privacy and protecting your personal information in accordance with applicable data protection laws, including:
• The General Data Protection Regulation (EU/UK GDPR)
• The California Consumer Privacy Act (CCPA/CPRA)
• The Digital Personal Data Protection Act (DPDPA) 2023 (India)
• Other applicable international privacy standards
By using our website, requesting a demo, or interacting with Torpian’s services, you agree to the practices described in this Privacy Policy.
1. Who We Are
Torpian is an AI-powered predictive marketing intelligence platform designed to help marketing teams simulate, test, and optimise their campaigns before launch.
Until its formal incorporation, the business is operated by Jithesh Rajendran, who serves as the Data Controller for all personal data collected through Torpian’s website and digital properties.
Legal Entity (Pending Registration): Torpian Technologies Private Limited Interim Controller: Jithesh Rajendran
Registered Jurisdiction: India
Contact Email: contact@torpian.com
2. Scope of this Policy
This Privacy Policy applies to:
• Torpian’s website (www.torpian.com)
• Marketing forms, demo requests, and newsletters
• Communication through email, chat, or contact forms
• Educational resources (eBooks, playbooks, guides)
• Product beta, trials, or early access requests
It does not apply to third-party websites, services, or integrations that are not operated or controlled by Torpian.
3. Information We Collect
We collect the following categories of data:
A. Information You Provide to Us
• Contact Information: name, email address, company name and job title.
• Business Information: industry, company size, marketing goals, or interests shared in demos.
• Account Information: login credentials, password (hashed), authentication data. • Communications: inquiries, support requests, and feedback messages. • Consent Preferences: marketing or educational communication opt-ins.
B. Information We Collect Automatically
When you use our website or platform, we may collect:
• IP address, browser type, device information, and operating system. • Usage data (pages visited, time spent, actions taken).
• Referring URLs, session identifiers, and geolocation (approximate region). • Cookies and similar technologies for analytics and functionality.
C. Information Obtained from Third Parties
• Marketing and analytics partners (e.g., Google, LinkedIn) for campaign attribution. • Public data sources such as business directories or professional networks. • Co-marketing partners for joint webinars or educational content (with consent).
4. How We Use Personal Data
We use your data only for lawful purposes and never sell or trade personal information.
Purpose Description Lawful Basis (GDPR)
Service delivery To provide requested demos, early access, and communications
Contract
performance
Marketing
communications
To send updates, insights, and offers (opt-in only) Consent
Educational content To send guides, playbooks, and product-related materials Consent
Purpose Description Lawful Basis (GDPR)
Customer support To respond to inquiries and provide assistance Legitimate interest
Analytics and improvements
Compliance and enforcement
To analyse usage, trends, and enhance our
platform Legitimate interest
To comply with laws, prevent fraud, or enforce
agreementsLegal obligation
Security To maintain system integrity and detect
unauthorised accessLegitimate interest
5. Legal Basis for Processing (GDPR)
For users in the EU/UK, Torpian processes personal data based on the following lawful bases: • Consent – for marketing, cookies, and optional analytics.
• Contract performance – for demo access, product usage, or service provision. • Legitimate interest – for security, business analytics, and communication efficiency. • Legal obligation – to comply with applicable data, tax, or legal requirements.
6. Cookies and Tracking Technologies
Torpian uses cookies and similar technologies to enhance your experience. Categories of cookies used:
• Strictly Necessary: for secure login and essential website functionality. • Performance and Analytics: to understand engagement and optimize performance. • Functional: to remember preferences and improve usability.
• Marketing: to measure campaign effectiveness and show relevant content.
You can manage your cookie preferences through your browser or our Cookie Settings. We respect “Do Not Track” and Global Privacy Control (GPC) signals where required.
7. How We Share Personal Data
Torpian does not sell personal data. We may share it only as follows:
• Service Providers: with trusted partners who support our operations (hosting, analytics, CRM, email). All partners are contractually obligated to protect your data.
• Affiliates: within Torpian’s corporate or prospective group for operational purposes.
• Co-marketing Partners: only when you explicitly register or consent to joint events or materials.
• Legal Authorities: when required to comply with applicable law, regulation, or subpoena.
• Business Transactions: in connection with a merger, acquisition, or sale of assets (with notice).
8. International Data Transfers
If personal data is transferred outside India, the EU/EEA, or your home jurisdiction, Torpian ensures:
• Transfers are made only to jurisdictions with adequate data protection. • Standard Contractual Clauses (SCCs) or equivalent safeguards are implemented. • Encryption and limited access principles apply to all transfers.
9. Security and Data Retention
Security Measures
Torpian employs administrative, technical, and organisational safeguards, including: • Encryption at rest and in transit.
• Role-based access control (RBAC) and multi-factor authentication.
• Regular vulnerability scans and penetration tests.
• Employee confidentiality agreements and security training.
Retention
We retain data only as long as necessary for the purpose collected, or as legally required: Data Type Retention Period Purpose
Contact details 3 years after last interaction CRM and marketing management Account data Lifetime of account + 3 years Service provision
Analytics data 2 years Performance measurement Legal/compliance data As required by law Legal and regulatory compliance After expiry, data is anonymized or deleted securely.
10. Your Rights
EU/UK GDPR Rights
You may:
• Access, rectify, or erase your personal data.
• Restrict or object to certain processing.
• Request portability of your data.
• Withdraw consent at any time.
• Lodge a complaint with your local Data Protection Authority.
California (CCPA/CPRA) Rights
You may:
• Request disclosure of categories and specific personal information collected. • Request deletion of your data (subject to legal exceptions).
• Opt out of data sharing (Torpian does not sell data).
• Exercise non-discrimination rights for exercising your privacy rights.
India (DPDPA 2023) Rights
You may:
• Access, correct, or delete your personal data.
• Withdraw consent for any purpose.
• File a grievance with Torpian’s Data Protection Contact (privacy@torpian.com). • Nominate a person to exercise rights on your behalf in case of incapacity.
11. AI and Predictive Data Processing
Torpian uses aggregated, anonymized, or synthetic data to train its predictive algorithms. • Personal data is not directly used for AI training without explicit consent. • AI models are designed to prevent the identification of any individual.
• We adhere to privacy-by-design and federated learning principles to ensure data safety.
12. Children’s Privacy
Torpian’s services are directed toward business users aged 18 and above. We do not knowingly collect data from minors. If discovered, such data will be promptly deleted.
13. Updates to This Policy
We may update this Privacy Policy periodically to reflect changes in law or practice. Material updates will be communicated through our website or by email.
The “Last Updated” date reflects the most recent revision.
14. Contact Us
For any privacy inquiries, access requests, or complaints, contact:
Torpian Privacy Contact
Jithesh Rajendran
contact@torpian.com
www.torpian.com
Transparency Statement Until Torpian’s incorporation is completed, all data processing activities are conducted under the responsibility of Jithesh Rajendran as the interim data controller. Once Torpian Technologies Private Limited is formally registered, this policy will be updated to reflect the corporate entity.