Privacy Policy

Eagletech Ltd., Co. No. 516353679 (hereinafter: “the Company” or “Torox”), respects the privacy of users of the platforms it operates and acts with transparency and in accordance with the provisions of the Protection of Privacy Law, 5741-1981, Amendment 13 to the Law, and the regulations and guidelines applicable thereunder.
This Privacy Policy is intended to explain, in clear and accessible language, what information is collected in the course of using the Company’s platforms, for what purposes it is used, how it is stored and protected, and what the users’ rights are with respect to this information.

1. To Whom This Policy Applies
This Privacy Policy applies to any use of the Company’s platforms, including:
· The website www.torox.io
· Technological products and systems operated by the Company;
· Company applications or software components embedded in third-party sites and systems;
· Inquiries to the Company via “Contact Us” forms, email, or support systems;
This Privacy Policy pertains to information collected in the course of using the website and the Company’s platforms.
In addition, the Company processes personal information about its employees, suppliers, and business partners, in accordance with the provisions of the law and operational needs, but this information is not collected in the course of using the website and is not regulated by this policy.

2. What Information is Collected About End Users
When using Torox’s platforms, technological and statistical information is collected automatically as part of the system’s operation. This information is not collected by filling out forms, but rather as a result of the use itself.
2.1. Activity Data and Technological Identifiers
When using the platform, data such as the following is collected:
· IP address.
· Geographic location at the city level.
· Device type and operating system.
· Encrypted internal user identifier.
· Platform activity data (such as steps performed, activity times, and responses to actions).
This information is required for the purpose of:
· Proper operation of the product.
· Measuring activity and results.
· Pricing of activity.
· Fraud prevention.
· System security.
It is important to clarify: this information does not, as a rule, include direct identifying details such as name, residential address, or identity number, and it is associated with an internal technological identifier of the system. However, according to the law, technological information of this type may also be considered personal information.
2.2. Log Files (System Logs)
When using the website and platforms, technical data is collected in system logs for the purpose of securing the site and the system, detecting malfunctions, monitoring unusual activity, analyzing usage traffic, and improving service performance.
The data collected includes, among other things, IP address, browser type, operating system, date and time of use, pages viewed, and actions performed in the course of using the services.
This information is used for analyzing trends and improving the service, and is not collected for the purpose of personally identifying users.
2.3. Cookies and Similar Tracking Technologies:
The website and platforms use cookies and similar tracking technologies for the proper operation of the services, saving user preferences, information security, preventing misuse or fraud, and analyzing general usage statistics.
These cookies allow, among other things, to identify malfunctions, improve the user experience, understand how the website and system are used, and ensure that the services operate efficiently and securely.
Some of the cookies may be operated by third parties that provide us with technological, analytical, or operational services, for the sole purpose of measuring, monitoring, and improving the service. The information collected in this context is technical or statistical information and is not intended for the personal identification of users.
Upon your first visit to the website, a cookie notice will be displayed that includes general information about the use of cookies, the choices available to you, and a reference to this Privacy Policy.
You can change or block the use of cookies at any time through your browser settings or through the cookie management mechanism on the website, but blocking certain cookies may affect the availability or quality of some of the services.

3. Information Provided at the User’s Initiative – Inquiries and Support
In most cases, the use of Torox’s platforms does not require the provision of identifying details such as name or email address.
However, in certain cases, you may choose to provide us with personal information proactively, for example:
3.1. Contacting Customer Service or Support
When contacting us via a “Contact Us” form, support system, or email, you may be asked to provide details such as:
· Email address;
· Name (if you choose to provide it);
· The content of the inquiry and any additional information you choose to share.
The information is required so that we can:
· Respond to your inquiry;
· Handle the request or malfunction;
· Continue communication with you if necessary.
If you do not provide an email address or contact details, we may not be able to respond to your inquiry or provide the requested assistance.
3.2. Establishing Contact in the Course of Platform Activity
In exceptional cases where a specific activity on the platform requires human contact (for example, for clarification, verification, or handling a malfunction), you may be asked to provide an email address for further handling.
The Company does not use these details for other purposes and does not send marketing communications unless explicit consent has been given, where relevant.

4. Purposes of Use of Information
The Company uses the information collected in the course of using the platforms solely for the purposes detailed below, and to the extent necessary to realize them. We do not use the information for purposes that exceed the original purpose of collection.
4.1. Operating the Platform and Providing the Services
The technological information collected during the use of the platforms is required to enable the proper operation of the product, including:
· Identifying actions performed in the system.
· Calculating rewards, results, or pricing of activity.
· Adapting the user experience to the technological characteristics of the device and system.
Without this information, the platform will not be able to operate efficiently or accurately.
4.2. Measurement, Analysis, and Pricing of Activity
As part of Torox’s business model, technological information (such as city-level location, device type, user ID, and activity data) is collected for the purpose of:
· Measuring user activity on the platform.
· Analyzing performance and results.
· Pricing activity for clients and business partners.
The information is used for operational and business analyses and is not intended for the personal identification of users.
4.3. Fraud Prevention and Activity Security (Anti-Fraud)
The Company uses technological information for the purpose of detecting and preventing unusual, suspicious, or malicious activity, including:
· Fraud attempts.
· Use of prohibited means (such as VPN).
· Activity that does not comply with the terms of use.
This use is intended to protect both the users and the integrity of the system and business activity.
4.4. Customer Service and Support
In the event of an inquiry to customer service or the support team, the information provided (such as email address and the content of the inquiry) is used by us for the purpose of:
· Providing a response to the inquiry.
· Handling malfunctions.
· Improving the quality of service.
If an email address or contact details are not provided, we may not be able to respond to or handle the inquiry.
4.5. Improving the Service and User Experience
We use aggregate and statistical information for the purpose of:
· Analyzing usage patterns on the platform.
· Identifying malfunctions and operational problems.
· Improving performance, stability, and user experience.
These analyses are performed, as far as possible, on the basis of information that does not directly identify users.
4.6. Enforcing the Terms of Use and Complying with Legal Requirements
The information may be used by us for the purpose of:
· Enforcing the terms of use.
· Investigating disputes.
· Complying with legal provisions and regulatory requirements.
· Exercising legal rights or defending against claims.

5. Sharing and Transfer of Information to Third Parties
The Company does not sell users’ personal information.
However, information may be transferred to third parties, only to the extent required, including to:
· Infrastructure and cloud providers;
· Security and fraud prevention service providers;
· Support and service system providers.
As a rule, the transfer of information to business partners and business clients is done on the basis of technological, aggregate, or non-personally identifiable information, and to the extent necessary for the analysis and pricing of activity.

6. Use of Cookies and Similar Technologies
The platforms use cookies and similar tracking technologies for the purpose of:

Proper operation of the system.

Information security.

Analysis of usage statistics.

Fraud prevention.
Upon entering the website, a cookie mechanism is displayed that allows you to choose which types of cookies to approve.
You can change your cookie usage preferences at any time through your browser settings or the consent management mechanism on the website.

7. Information Security

We take reasonable and accepted information security measures, adapted to the nature of the information and the platform’s activity, including:

Management of permissions and access according to role.

Use of passwords and two-factor authentication.

Restriction of access to systems.

Monitoring, control, and backup measures.
Despite these efforts, we cannot guarantee absolute immunity from information security incidents.
The person responsible for the field of privacy protection at the Company is data privacy manager.
In the event of a material information security incident, we will act to investigate, handle, and report in accordance with the provisions of the law.

8. Your Rights Regarding Your Information
You have the right to know what is done with your information and to control it.
The Company places great importance on transparency and on protecting users’ rights, and in accordance with the Protection of Privacy Law, you have the rights detailed below regarding your personal information.
8.1. Right to Access Information
You may contact us and ask to know whether personal information about you exists in our systems, and to receive a copy of this information, to the extent it exists.
8.2. Right to Rectify or Update Information
If you find that information about you is incorrect, incomplete, or not up-to-date, you may request to rectify or update it, and we will act in accordance with the request, subject to the provisions of the law.
8.3. Right to Request Deletion
To the extent that your personal information is no longer needed for the purposes for which it was collected, you may request its deletion from the Company’s databases, unless the Company has a legal obligation to retain the information.
8.4. Right to Object to the Use of Information for Certain Purposes
To the extent that your information is used for sending inquiries or updates, you may request to stop this use at any time by contacting us.
8.5. Right to Receive a Copy of Information
You may request to receive the personal information concerning you in a readable format, to the extent that this is technically possible and in accordance with the law.
8.6. How to Submit Requests
Requests to exercise your rights can be sent to the dedicated privacy email address:
privacy@torox.io
We will act to handle every inquiry and will respond to it within 30 days of its receipt, unless a longer period is required in accordance with the provisions of the law.

9. Data Retention Period
Your information will be retained only as long as there is a genuine or legal need for it:
9.1. Client data – for the duration of the engagement and according to tax requirements.
9.2. Registration or inquiry data – up to 24 months, to allow for quality control of the service.
9.3. Cookie data – according to the duration defined for each cookie (usually up to one year).
Upon the end of the period or the exercise of your right to deletion, the information will be deleted or will undergo an anonymization process so that you can no longer be identified.

10. Policy Updates
From time to time, we will update the Privacy Policy in accordance with technological, business, or legal changes.
The date of the last update appears at the top of the document.
A material change to the policy will be brought to your attention by means of a notice on the website.