Privacy Notice

This Privacy Notice describes how Torque.ai Incorporated, a Delaware corporation operating as RunTorque (“we,” “us,” or “our”), collects, uses, shares, and protects nonpublic personal information (“NPI”) about consumers. This Notice is provided pursuant to the Gramm-Leach-Bliley Act (15 U.S.C. § 6801 et seq.) and is supplemented, where applicable, by additional state-specific disclosures.

1. Why We Collect Your Information

We collect information about you to:

• Process your credit application and route it to participating Lenders
• Verify your identity, income, and employment
• Detect and prevent fraud
• Comply with our legal and regulatory obligations
• Communicate with you about your application and our Service
• Improve and operate our platform

2. Information We Collect

• Information you provide: name, address, date of birth, Social Security number, government identification numbers, contact information, employment details, income information, and details about your application (vehicle or other goods being financed, amount requested, etc.)
• Information from consumer reporting agencies: credit reports, credit scores, and related information obtained from Experian, Equifax, TransUnion, and other consumer reporting agencies in accordance with the Fair Credit Reporting Act
• Information from verification partners: verified income, employment, and bank account information from Plaid, Argyle, and similar verification services where you have authorized the connection
• Information from third parties: information from Dealers, Lenders, or other counterparties involved in your application
• Technical information: device identifiers, IP address, browser type, and information about how you interact with our Service

3. How We Use Your Information

We use your information only for the purposes described in Section 1 and for related operational purposes. We do not sell your personal information.

4. How We Share Your Information

We share NPI in the following circumstances:

• With participating Lenders to enable them to evaluate your application
• With the originating Dealer to enable them to facilitate your transaction
• With consumer reporting agencies and verification partners as necessary to process your application
• With our service providers who assist us in operating the platform under written confidentiality agreements
• With third parties as required by law, including in response to lawful subpoenas, court orders, or regulatory requests
• With your consent for purposes not otherwise listed

We do not share your information with non-affiliated third parties for their marketing purposes.

5. How We Protect Your Information

We maintain administrative, technical, and physical safeguards designed to protect NPI against unauthorized access, use, alteration, or disclosure. Our Written Information Security Policy is available at /legal/wisp. Key safeguards include encryption of NPI in transit and at rest, multi-factor authentication for administrative access, role-based access controls, audit logging, and regular security reviews of our service providers.

6. Retention

We retain NPI only as long as necessary to fulfill the purposes for which it was collected and to satisfy applicable legal retention requirements, typically not less than six (6) years for records related to credit decisions.

7. Your Rights

Subject to applicable law, you may have the following rights:

• The right to know what NPI we have about you and how we use it
• The right to request correction of inaccurate information
• The right to request deletion of your information, subject to legal retention obligations
• The right to opt out of certain information sharing where applicable
• The right to dispute inaccurate consumer report information directly with the relevant consumer reporting agency

To exercise these rights, contact us at privacy@runtorque.ai. We will respond within the timeframes required by applicable law.

8. California Residents

California residents have additional rights under the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA), including the right to know specific pieces of personal information we have collected, the right to request deletion, and the right to opt out of the sale or sharing of personal information. We do not sell personal information. To exercise CCPA/CPRA rights, contact privacy@runtorque.ai.

9. Children

Our Service is not directed to individuals under 18 years of age. We do not knowingly collect information from children.

10. Changes to This Notice

We may update this Notice from time to time. The version date at the top reflects the most recent update. Material changes will be communicated to active users.

11. Contact

Questions or requests regarding privacy may be directed to:

Privacy Officer
Torque.ai Incorporated
800 N. King Street, Suite 304
Wilmington, DE 19801
privacy@runtorque.ai