Privacy Policy
At ToroNet, we respect your privacy and are committed to protecting the personal information entrusted to us. This Privacy Policy explains how we collect, use, store, disclose, and protect information when you visit our website, use our products and services, interact with our applications, participate in the ToroNet ecosystem, or communicate with us.
ToroNet is a blockchain and financial technology ecosystem designed to support digital assets, payments, financial inclusion, community economies, and real-world applications across emerging markets.
By using our website, applications, products, or services, you acknowledge that you have read and understood this Privacy Policy.
1. Who We Are
For the purposes of this Privacy Policy, “ToroNet,” “we,” “us,” or “our” refers to the relevant ToroNet entity responsible for operating the applicable website, application, product, or service.
Different ToroNet ecosystem projects may operate independently and may have their own privacy policies or data-processing practices. Where a specific ToroNet product or project provides a separate privacy notice, that notice will apply to the relevant service.
Data Controller/Responsible Entity: ToroNet Software Development Corp.
Privacy Contact: info@toronet.org
2. Information We Collect
The information we collect depends on how you interact with ToroNet and which products or services you use.
2.1 Information You Provide Directly
We may collect information you voluntarily provide to us, including:
- Full name
- Email address
- Telephone number
- Residential or business address
- Account or profile information
- Organisation or company information
- Information submitted through contact forms
- Information provided when requesting support
- Information submitted when participating in events, programmes, campaigns, or community activities
- Communications and correspondence with us
- Information submitted for applications, partnerships, grants, or ecosystem participation
Where a ToroNet service requires identity verification or Know Your Customer (KYC) procedures, additional information may be collected as required by applicable law and the relevant service.
3. Blockchain and Digital Asset Information
Because ToroNet operates blockchain-based infrastructure, certain information associated with blockchain transactions may be publicly visible or permanently recorded on a distributed ledger.
This may include:
- Blockchain wallet addresses
- Public keys
- Transaction hashes
- Token balances or transaction information
- Transaction timestamps
- Smart-contract interactions
- Other information recorded on the blockchain
Important Notice
Blockchain transactions are generally designed to be transparent and may be immutable. Information recorded on a public blockchain may not be capable of being deleted, modified, or removed by ToroNet.
You should therefore avoid publishing personal information in blockchain transaction fields, wallet metadata, smart-contract inputs, or other publicly accessible blockchain records.
A wallet address may not directly identify you, but it can potentially be associated with other information that identifies or relates to you.
4. Technical and Usage Information
When you access our website, applications, or services, we may automatically collect certain technical information, where permitted by applicable law.
This may include:
- IP address
- Browser type and version
- Device type
- Operating system
- Language preferences
- Approximate location derived from technical information
- Website pages visited
- Referring and exit pages
- Date and time of access
- Interaction with our website or applications
- Error and diagnostic information
- Security and authentication logs
We use this information to operate, secure, maintain, and improve our services.
5. Cookies and Similar Technologies
ToroNet may use cookies, pixels, local storage, analytics technologies, and similar technologies to operate our website and improve your experience.
Cookies may be used for purposes such as:
- Keeping our website functioning properly
- Remembering preferences
- Understanding how visitors use our website
- Measuring website performance
- Detecting security issues
- Improving our services
- Supporting communications and marketing, where permitted
Where required by applicable law, we will request your consent before placing non-essential cookies on your device.
You may manage or disable cookies through your browser settings or through any cookie-management tools made available on our website. Disabling certain cookies may affect the functionality of some services.
6. How We Use Your Information
We may process personal information for the following purposes:
Providing and Operating Our Services
We may use information to:
- Create and manage accounts
- Provide requested services
- Process transactions and requests
- Provide customer and technical support
- Communicate with you about our services
- Maintain and improve our platforms
Security and Fraud Prevention
We may use information to:
- Detect and prevent fraud
- Protect accounts and systems
- Investigate suspicious activity
- Prevent abuse and unauthorized access
- Maintain the security and integrity of our services
Legal and Regulatory Compliance
We may process information when necessary to:
- Comply with applicable laws and regulations
- Meet regulatory requirements
- Respond to lawful requests from government authorities
- Fulfil KYC, AML, sanctions-screening, or other compliance requirements where applicable
- Establish, exercise, or defend legal claims
Business and Product Development
We may use information to:
- Analyse service performance
- Understand user needs
- Develop new products and services
- Conduct research and analytics
- Improve user experience
- Measure the effectiveness of our programmes and initiatives
Communications
Where permitted by law, we may use your contact information to send:
- Service announcements
- Security notifications
- Important account information
- Product updates
- Newsletters
- Events and ecosystem updates
- Marketing communications
You may unsubscribe from non-essential marketing communications at any time.
7. Lawful Bases for Processing
Where applicable, we process personal data based on one or more lawful grounds, including:
- Your consent
- Performance of a contract or provision of a requested service
- Compliance with a legal or regulatory obligation
- Protection of vital interests
- Our legitimate interests, where permitted by applicable law
- Other lawful grounds recognized by applicable data-protection legislation
Where we rely on consent, you may withdraw your consent, subject to applicable legal limitations and the consequences of doing so.
8. KYC and Verification Information
Certain ToroNet products or ecosystem projects may require identity verification before providing particular services.
Where applicable, KYC information may include:
- Name
- Date of birth
- Nationality
- Identification documents
- Address information
- Contact information
- Verification information
- Information required to comply with applicable financial, anti-money-laundering, sanctions, or regulatory requirements
The exact information collected will depend on the service and applicable legal requirements.
KYC information will only be collected where necessary for the relevant service or legal obligation.
9. Sharing of Personal Information
We do not sell your personal information simply because you use ToroNet.
We may share information where reasonably necessary with:
Service Providers
We may use trusted third-party providers that support our operations, including providers of:
- Cloud hosting
- Website infrastructure
- Analytics
- Customer support
- Communication services
- Identity verification
- Payment processing
- Security and fraud prevention
- Technology infrastructure
These providers may process personal data only as necessary to provide their services to us and subject to appropriate contractual or legal safeguards.
ToroNet Ecosystem Projects
ToroNet supports independent projects and applications within its ecosystem. Where you interact directly with an independent project, that project may collect and process your information according to its own privacy notice.
You should review the applicable privacy policy before providing personal information to an independent ToroNet ecosystem project.
Legal and Regulatory Authorities
We may disclose information where required or permitted by law, including to:
- Courts
- Regulators
- Law-enforcement authorities
- Government agencies
- Tax authorities
- Other competent public authorities
Business Transactions
If ToroNet or any relevant business unit is involved in a merger, acquisition, restructuring, financing, sale of assets, or similar transaction, personal information may be transferred as part of that transaction, subject to applicable privacy requirements.
10. International Transfers
ToroNet and its service providers may process or store information in countries other than the country in which you live.
Where personal information is transferred across borders, we will take reasonable steps to ensure that the transfer is carried out in accordance with applicable data-protection laws and appropriate safeguards.
Depending on the circumstances, safeguards may include contractual protections, adequacy decisions, consent, or other legally recognized mechanisms.
11. Data Security
We take reasonable technical and organisational measures designed to protect personal information against:
- Unauthorized access
- Accidental loss
- Destruction
- Alteration
- Disclosure
- Fraud
- Misuse
Security measures may include access controls, encryption where appropriate, authentication mechanisms, monitoring, and other safeguards.
However, no internet transmission, blockchain network, digital wallet, or electronic storage system can be guaranteed to be completely secure.
You are responsible for protecting your account credentials, passwords, private keys, seed phrases, and other authentication information.
ToroNet will never ask you to disclose your private key or recovery/seed phrase.
12. Blockchain Transactions and Privacy
ToroNet uses blockchain technology, which is designed to provide transparency, integrity, and verifiability.
Information recorded on a blockchain may be distributed across multiple network participants and may be difficult or impossible to delete.
Accordingly:
- Blockchain transactions may be publicly accessible.
- Transaction records may remain available indefinitely.
- ToroNet may not be able to modify or delete information already recorded on a blockchain.
- You should carefully consider the information you associate with your wallet address.
- You should not include sensitive personal information in public blockchain transactions.
Nothing in this Privacy Policy should be interpreted as a guarantee that blockchain transactions are anonymous.
13. Data Retention
We retain personal information only for as long as reasonably necessary for the purposes for which it was collected, including to:
- Provide our services
- Maintain business and financial records
- Meet legal and regulatory obligations
- Resolve disputes
- Enforce agreements
- Prevent fraud and abuse
- Maintain security records
The appropriate retention period may vary depending on the nature of the information and the service involved.
Where information is no longer required, we will take reasonable steps to delete, anonymise, or securely dispose of it, subject to applicable legal obligations and the technical limitations of blockchain systems.
14. Your Privacy Rights
Depending on your location and applicable law, you may have rights relating to your personal information.
These may include the right to:
- Know whether we process your personal information
- Request access to your personal information
- Request correction of inaccurate or incomplete information
- Request deletion of personal information where legally applicable
- Request restriction of certain processing
- Object to certain processing
- Withdraw consent where processing is based on consent
- Request information about how your personal information is processed
- Request portability of your information where applicable
- Lodge a complaint with a relevant data-protection authority
These rights are subject to applicable legal exceptions and limitations.
Because blockchain records may be immutable, requests for deletion or modification may not be technically possible for information already recorded on a blockchain.
15. How to Exercise Your Rights
To exercise your privacy rights or ask questions about this Privacy Policy, contact us at:
Email: info@toronet.org
Please provide enough information for us to understand your request and verify your identity where necessary.
We may need to request additional information to verify that the person making a request is authorized to do so.
We will respond to valid requests within the timeframe required by applicable law.
16. Children’s Privacy
Our services are not intended for children where the applicable law prohibits us from providing those services to them.
We do not knowingly collect personal information from children in circumstances where such collection is prohibited by applicable law.
If you believe that a child has provided personal information to us in violation of applicable requirements, please contact us so that we can investigate and take appropriate action.
17. Third-Party Websites and Services
Our website and applications may contain links to websites, applications, wallets, exchanges, payment providers, or other third-party services.
We do not control the privacy practices of third parties.
When you leave ToroNet’s website or interact with a third-party service, that third party’s privacy policy and terms may apply.
We encourage you to review the privacy policies of third-party services before providing them with personal information.
18. Marketing Communications
Where permitted by applicable law, we may send you information about ToroNet, our products, services, ecosystem activities, events, research, and other developments.
You can unsubscribe from marketing communications by:
- Clicking the unsubscribe link included in our communications; or
- Contacting us using the privacy contact information provided in this Privacy Policy.
Even if you opt out of marketing communications, we may continue to send essential service, security, transactional, or legal communications.
19. Data Protection Incidents
If we become aware of a personal-data breach that requires notification under applicable law, we will take appropriate steps to investigate, contain, mitigate, and report the incident as required.
Where legally required, we will notify affected individuals and/or relevant regulatory authorities.
20. Changes to This Privacy Policy
We may update this Privacy Policy from time to time to reflect:
- Changes to our services
- Changes in technology
- Changes in applicable laws
- Changes to our data-processing practices
- Regulatory guidance
- Improvements to our privacy practices
When we make material changes, we may provide additional notice where required by applicable law.
We encourage you to review this page periodically.
21. Contact Us
If you have questions, concerns, complaints, or requests relating to this Privacy Policy or the way ToroNet processes personal information, please contact:
ToroNet
Privacy Email: info@toronet.org
General Email: info@toronet.org
We are committed to handling privacy-related enquiries responsibly and in accordance with applicable data-protection requirements.
22. Applicable Data Protection Laws
ToroNet seeks to handle personal information in accordance with applicable privacy and data-protection laws.
For users in Nigeria, this may include the Nigeria Data Protection Act, 2023, together with applicable regulations, guidelines, and directives issued by the Nigeria Data Protection Commission.
Where other jurisdictions’ privacy laws apply to our processing activities, we will take appropriate steps to comply with those requirements.
23. Your Continued Use of Our Services
By continuing to use ToroNet’s websites, applications, and services after this Privacy Policy has been updated, you acknowledge the updated policy to the extent permitted by applicable law.
Where applicable law requires affirmative consent for particular processing activities, we will obtain that consent separately.