Who We Are

torinalyqua operates as a financial services platform connecting startups with funding opportunities across Australia. Our registered office is located at Unit 2/30 Verbena Ave, Port Macquarie NSW 2444, Australia.

This privacy policy applies to all personal information we collect through our website (torinalyqua.com), mobile applications, email communications, and any other digital channels we operate. When we say "personal information," we're talking about data that identifies you or could reasonably identify you.

We're bound by the Australian Privacy Act 1988 and the Australian Privacy Principles (APPs). These laws give you specific rights about how your information gets handled, and we'll explain those throughout this document.

Information We Collect

The type of information we gather depends on how you use our platform. Here's what we typically collect:

Information You Give Us Directly

• Account Registration: Name, email address, phone number, business name, ABN/ACN, and password when you create an account
• Profile Information: Professional background, business details, funding requirements, industry sector, and startup stage
• Financial Data: Bank account details for transactions, business financial statements, revenue data, and funding history
• Communication Records: Messages you send through our platform, support tickets, and feedback you provide
• Verification Documents: Identification documents, proof of address, and business registration certificates for compliance purposes

Information We Collect Automatically

• Device Information: IP address, browser type, operating system, device identifiers, and screen resolution
• Usage Data: Pages visited, time spent on pages, click patterns, search queries, and feature interactions
• Location Data: General location based on IP address (we don't track precise GPS location unless you explicitly permit it)
• Cookies and Similar Technologies: Session data, preferences, and authentication tokens stored in your browser

Information From Third Parties

• Credit Reference Agencies: Credit scores and business credit reports for risk assessment
• Business Registers: Publicly available company information from ASIC and ABR
• Partner Platforms: Data shared by funding partners or ecosystem services you've authorized
• Social Media: Public profile information if you connect social accounts to your torinalyqua profile

How We Use Your Information

We use your personal information for specific purposes. We won't use it in ways you wouldn't reasonably expect.

Purpose	Legal Basis
Provide and maintain our platform services	Contract performance
Process funding applications and match startups with investors	Contract performance
Verify identity and prevent fraud	Legal obligation / Legitimate interest
Communicate about your account and services	Contract performance
Send marketing communications (with your consent)	Consent
Improve platform functionality and user experience	Legitimate interest
Comply with financial regulations and reporting	Legal obligation
Resolve disputes and enforce our terms	Legitimate interest

Sharing Your Information

We don't sell your personal information to anyone. We share it only in these specific circumstances:

With Your Explicit Consent

When you apply for funding or express interest in specific opportunities, we share relevant information with potential investors or funding partners. You control which opportunities you pursue, and we clearly indicate what information will be shared before you proceed.

Service Providers

We work with third-party companies that help us run our platform. These include:

• Cloud hosting providers (AWS Australia) for data storage and processing
• Payment processors for handling financial transactions
• Email service providers for communication delivery
• Identity verification services for compliance checks
• Analytics providers to understand platform usage

All service providers are contractually required to protect your data and use it only for the services they provide to us.

Legal Requirements

We may disclose your information if required by Australian law, court order, or regulatory authority. This includes AUSTRAC reporting obligations, AML/CTF compliance, and responses to lawful requests from law enforcement.

Business Transfers

If torinalyqua is acquired or merges with another company, your information may transfer to the new entity. We'd notify you before this happens and explain any changes to how your data gets handled.

Your Privacy Rights

Under Australian privacy law, you have several rights regarding your personal information:

Data Security

Protecting your information is something we invest in continuously. Our security measures include:

• Encryption: All data transmitted between your device and our servers uses TLS 1.3 encryption. Sensitive data at rest is encrypted using AES-256.
• Access Controls: Staff access to personal information is restricted based on role requirements. All access is logged and monitored.
• Infrastructure Security: Our servers are hosted in Australian data centers with physical security, redundancy, and regular backups.
• Authentication: Multi-factor authentication is required for accounts handling sensitive financial data.
• Regular Audits: We conduct quarterly security assessments and annual penetration testing by independent specialists.
• Incident Response: We maintain a documented breach response plan and will notify affected users within 72 hours of discovering any unauthorized access.

While we implement strong security measures, no system is completely impenetrable. If you suspect unauthorized access to your account, change your password immediately and contact us at info@torinalyqua.com.

Data Retention

We keep your information only as long as necessary for the purposes we collected it:

• Active Accounts: Information is retained while your account remains active and for 7 years after closure to comply with financial record-keeping obligations.
• Financial Transactions: Transaction records and related communications are kept for 7 years as required by Australian tax law.
• Marketing Data: If you opt out of marketing, we keep minimal data (email address and opt-out preference) to honor your choice.
• Support Records: Customer service interactions are retained for 3 years for quality assurance and dispute resolution.
• Verification Documents: Identity documents are kept for 7 years after account closure for AML/CTF compliance.

After these retention periods expire, we securely delete or anonymize your information so it can no longer identify you.

Cookies and Tracking

Our website uses cookies and similar technologies. Here's what you should know:

Essential Cookies

These are necessary for the platform to function. They handle authentication, security, and basic functionality. You can't disable these without breaking the site.

Functional Cookies

These remember your preferences (like display settings) and provide enhanced features. They're optional but improve your experience.

Analytics Cookies

We use these to understand how people use our platform so we can make improvements. They collect anonymized usage statistics.

Managing Cookies

Your browser settings allow you to refuse cookies or delete them. Keep in mind this might affect platform functionality. Our cookie banner lets you adjust preferences for non-essential cookies.

We don't use third-party advertising cookies or tracking pixels on our platform.

International Data Transfers

Your data is primarily stored and processed in Australia. In some cases, we may transfer information internationally:

• To service providers operating outside Australia who help us run the platform
• If you interact with funding partners or investors based overseas
• For cloud backup services with international redundancy

When we transfer data internationally, we ensure the recipient country has adequate data protection laws or we implement contractual safeguards (like Standard Contractual Clauses) to protect your information.

You can request details about specific international transfers by contacting our privacy team.

Children's Privacy

torinalyqua's services are not intended for anyone under 18. We don't knowingly collect information from children. If you're a parent who believes your child has provided us with personal information, contact us immediately and we'll delete it.

Our platform requires users to represent businesses or be involved in investment activities, which are adult endeavors under Australian law.

Changes to This Policy

We update this privacy policy periodically to reflect changes in our practices or legal requirements. When we make significant changes, we'll notify you by email and display a notice on the platform for 30 days.

The "Last Updated" date at the top shows when the current version was published. Continued use of our services after changes take effect means you accept the updated policy.

Previous versions of this policy are available on request if you want to review what's changed.

Complaints and Disputes

If you're not happy with how we've handled your personal information, here's what to do:

1. Contact Us First: Email info@torinalyqua.com with details of your concern. We'll investigate and respond within 30 days.
2. Escalate Internally: If you're not satisfied with the initial response, ask for escalation to our Privacy Officer.
3. External Complaint: You have the right to lodge a complaint with the Office of the Australian Information Commissioner (OAIC) at www.oaic.gov.au or by calling 1300 363 992.

We take all privacy concerns seriously and will work with you to resolve issues fairly.