Privacy Notice

This Privacy Notice explains how Torque AI, Inc. ("Torque AI", "we", "us") collects, uses, and shares personal data when you use Executive Headshot Pro (the "Service"). Torque AI is the data controller for personal data processed through the Service.

1. Data we collect

• Account data: name, email, login credentials.
• Uploaded content: photos you submit for portrait generation.
• Generated content: AI portraits produced from your inputs.
• Support data: messages and attachments you send us.
• Usage and device data: IP address, browser, device identifiers, log events.
• Order data: the plan you bought and order metadata (payment details are handled by Paddle, not us).

2. How we use it

• Create and operate your account and deliver the Service.
• Generate, deliver, and improve your portrait outputs.
• Provide customer support and respond to inquiries.
• Secure the Service, prevent fraud and abuse, and meet legal obligations.
• Send transactional emails about your account and orders.

3. Legal bases

We process personal data under one or more of: performance of our contract with you, our legitimate interests in operating and securing the Service, your consent (where required), and compliance with legal obligations.

4. Sharing

We share personal data with:

• Service providers / subprocessors that host, store, and process data on our behalf (cloud hosting, AI model inference, email delivery, analytics).
• Paddle.com Market Limited, our Merchant of Record, for the sale of the Service, subscription management, payments, tax compliance, invoicing, and refunds.
• Professional advisers (legal, accounting) where necessary.
• Authorities where required by law or to protect our rights.

5. Retention

We retain personal data for as long as needed to provide the Service, comply with legal and tax obligations, resolve disputes, and enforce our agreements. Uploaded source photos are deleted shortly after your portraits are generated unless you ask us to retain them. When data is no longer needed, we delete or anonymise it.

6. Your rights

Subject to your local law, you may have the right to access, correct, delete, restrict, or port your personal data, object to processing, withdraw consent, and lodge a complaint with a supervisory authority. To exercise these rights, contact us at privacy@executiveheadshotpro.com. We aim to respond within 30 days.

7. International transfers

We may transfer personal data outside your country, including to the United States. Where required, we use appropriate safeguards such as Standard Contractual Clauses or rely on adequacy decisions.

8. Security

We use appropriate technical and organisational measures — including encryption in transit, access controls, and least-privilege practices — to protect personal data. No system is perfectly secure, but we work to keep your data safe.

9. Cookies

We use essential cookies for authentication and security, and limited analytics cookies to understand how the Service is used. You can manage cookies through your browser settings.

10. Contact

Torque AI, Inc. — privacy@executiveheadshotpro.com.