Privacy Policy

Effective: January 1st, 2025

Last Updated: January 1st, 2025

About This Policy

We value your privacy. This Privacy Policy explains how Toorak Capital Partners (“Toorak,” “we,” “us,” or “our”) collects, uses, discloses, and protects personal information (“PI”) of individuals in the United States. It also summarizes rights available under applicable U.S. state privacy laws (including California’s CCPA/CPRA).

1) PI We Collect

  • Identifiers: name, postal address, email, phone number, IP address, account ID.
  • Commercial information: records of products/services purchased, obtained, or considered.
  • Financial information: payment card or bank details.
  • Internet / network activity: device identifiers, pages viewed, interactions with our site.
  • Geolocation data: approximate location (e.g., from IP address).
  • Employment / professional data: if you apply for a job or interact in a business capacity.
  • Sensitive information: government ID, precise geolocation, account login credentials.
  • We do not knowingly collect PI from children under 13.

2) Sources of PI

  • You directly (e.g., registrations, purchases, support).
  • Automatically from your device (e.g.: cookies, analytics, log files).
  • Service providers, business partners, and publicly available sources.

3) How We Use PI

  • Provide, operate, maintain, and improve our services and website.
  • Process transactions, fulfill requests & orders.
  • Authenticate Users and detect, prevent, and protect against fraud, abuse, and security risks.
  • Comply with legal, regulatory, and audit obligations.
  • Perform analytics, research, and service improvement.
  • Marketing and advertising (consistent with your choices).

4) Sharing & Disclosure of PI

We may disclose PI to:

  • (i)Service providers (IT, hosting, analytics, security, payment processing, customer support).
  • (ii)Business partners as needed to provide or improve services.
  • (iii)Regulators or government entities as required by law.
  • (iv)Advertising / analytics vendors for measurement or targeted advertising.

We do not sell PI for monetary consideration. Some states define “share” to include cross-context behavioral/targeted advertising.

5) Retention

We retain PI only for as long as necessary to fulfill the purposes described in this Policy or as required by law. We apply data minimization and purpose limitation principles.

6) Your Privacy Rights

Depending on your state, you may have the right to access, correct, or delete your PI; opt out of sale or sharing of PI (including targeted advertising); limit use of certain sensitive PI; and request data portability. We will not discriminate against you for exercising these rights.

Submit requests via:

7) State-Specific Notices

  • California (CCPA/CPRA): additional rights include the right to know categories/specific pieces of PI collected, and to limit use of sensitive PI. We honor Global Privacy Control signals.
  • Virginia, Colorado, Connecticut, Utah: rights to access, delete, correct, and opt-out of targeted advertising or sale (as defined by state law). Includes right to appeal our decision on your request.
  • Other states: We will update this section as new privacy laws become effective.

8) Children’s Data

We do not knowingly collect PI from children under 13. For services directed to teens 13–16, we do not sell or share PI without opt-in consent (and require parental consent under 13).

9) Data Security

We implement reasonable administrative, technical, and physical safeguards to protect PI. No system is 100% secure, and we cannot guarantee absolute security.

10) Changes to This Policy

We may update this Policy from time to time. Material changes will be posted here with a new “Effective Date.”

11) Contact Us

Toorak Capital Partners
Email: policy@toorakcapital.com
Phone (toll-free): (212) 393-4100