Privacy Policy

Tora Trading Services Limited

Privacy Policy

Effective January 1, 2008

We appreciate your interest in the Tora Trading Services Limited website (the “Website”). We at Tora Trading Services Limited (“Tora,” “our,” “we” or “us”), recognize and appreciate the importance of respecting the privacy of our customers and are committed to safeguarding against unauthorized disclosure of, or access to, personal information of our customers. Tora’s privacy policy (the “Privacy Policy”) sets forth Tora’s current policies and practices with respect to nonpublic personal information of our visitors.

Information That is Collected

Personal Information

We only collect the personally identifiable information that you provide to us.

If you request certain services available on this Website, you may be asked to provide certain personally identifiable information, such as your first and last name, e-mail address and telephone number.

We may use personally identifiable information in order to develop, offer and deliver products and services; respond to inquiries from you or your representative(s); or to fulfill legal and regulatory requirements. Tora may collect nonpublic personal information about you from any of the following sources:

  • From you or your representative(s) on applications, registrations or other forms (e.g., your contact information);
  • From you or your representative(s) regarding your preferences (e.g., based on your activity on the Website);
  • From other interactions with Tora (e.g., discussions with our customer service staff or your entry of information into our interactive tools); or
  • From e-mail correspondence from you (e.g., we may retain the information in a file specific to you).

Non-Personal Information

We also may collect certain non-personally identifiable information when you visit the Website. This information includes the type of Internet browser and operating system you are using, the domain name of your Internet service provider, your IP (Internet Protocol) address, pages visited and average time spent on the Website. This information may be used, for example, to alert you to software compatibility issues, or it may be analyzed to improve the Website design and functionality. When you contact us through the Website, you consent to Tora’s review and internal use of your communication. We also may use non-personally identifiable information in the aggregate to analyze Website usage and to gather broad demographic information.

Cookies

Like most major websites, Tora uses cookies on the Website. Cookies are pieces of information that a website transfers to a user's hard drive for record-keeping purposes while visiting a Website. Cookies make using the Internet easier by, among other things, saving your passwords and preferences for you. For example, a cookie lets the Website remember that you have registered, which allows us to speed up your future activities on the Website, and which allows you to enter your password/log in ID less frequently while visiting the Website. Our cookies do not contain any personally identifying information, though cookies may enable us to relate your use of the Website to personally identifying information that you previously submitted.

How We Use and Disclose the Information

As a general rule, Tora will not share, rent, sell or otherwise disclose any of your personal information, except with your permission. However, Tora may disclose your personal information:

  1. to unaffiliated persons or entities whom you designate;
  2. to affiliates, including affiliated services providers;
  3. to our third party contractors, service providers and agents who perform services for Tora, provided that such contractors, service providers and agents use the personal information only for the purposes of such services;
  4. to the government, law enforcement officials or third parties under certain circumstances, for example, in response to legal process, a court order or a subpoena or to report taxes, or if we believe it is necessary to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of our Website Terms of Use, abuse of the Website, security breaches of the Website, or as necessary to protect our systems, business, users or others or as otherwise required by law;
  5. as part of a merger, acquisition or other sale or disposition of our assets or business;
  6. to other organizations, with your consent or as directed by your representative(s); or
  7. to other organizations, as permitted or required by the laws that protect your privacy (for example, for fraud prevention).

In addition, we may disclose aggregated information to advertisers and for marketing or promotional purposes. In these situations, we do not disclose to these entities any information that could be used to personally identify you.

We require each of the above parties to adhere to our privacy standards and to use this information only for the limited purpose for which it was shared. Individuals interact with us in a variety of ways, and under some of these variations, we may exchange information with parties in addition to those described above.

Former Customers

If you are a former customer, your information is treated in the same manner as the information of current customers. If you have any questions or concerns regarding your privacy with Tora, please contact us at .

Security

Except as described above, we do not reveal information about you to unaffiliated third parties. We restrict access to nonpublic personal information about you to those employees who need to know that information to provide products or services to you. We maintain reasonable physical, electronic, and procedural safeguards to guard your nonpublic personal information. With respect to information given on the Internet, Tora uses a variety of proven protections to maintain the security of your online session. This may include the use of firewall barriers, encryption techniques and authentication procedures.

Linked Websites and Other Third Parties

This Privacy Policy only addresses the use and disclosure of information we collect from you. The Website, or services on the Website, may contain links to other websites whose information, security, and privacy practices may be different than ours. You should consult the other websites' privacy policies and terms of use because we do not control information that is submitted to, or collected by, these unaffiliated third parties or the content of those linked websites. Once you access another website, you are subject to the privacy policy and terms of use of that website.

How You Can Access or Correct Information

For details on how to access your personally identifiable information collected through this Website, and how to update that information or correct factual errors in it, please contact us at . For our records, we may retain original and updated information for reasons such as technical constraints, dispute resolution, troubleshooting, record retention and agreement enforcement. For security purposes, we may request information to help verify your identity before granting access or making changes to the information.

Modifications

From time to time, we may modify this Privacy Policy. We encourage you to periodically review our Privacy Policy so that you always will know what information we collect, how we use it, and to whom we disclose such information. However, we will only use personally identifiable information in accordance with the Privacy Policy that was in effect at the time the information was collected.

Request of Certain Information

You may request certain information from us regarding our disclosure of your personal information to unaffiliated third parties for their direct marketing purposes. To make such a request, please send an e-mail to or write us at:

Attn: Privacy Department, Tora Trading Services,
China Basin Landing, Wharfside Building,
185 Berry Street, Suite 2001,
San Francisco, CA 94107, USA.

Terms of Use

Please note that access to and use of the Website and its services are also subject to the Website Terms of Use.

Contacting Us

If you have any questions or concerns about this Privacy Policy, please contact us at .