Privacy policy

Last updated: June 2, 2025

This Privacy Policy describes how TORNA (the 'Site', 'we', 'us', or 'our') collects, uses, and discloses your personal data when you visit our Site, use our services, or make a purchase on www.tornadesign.com (the 'Site'), or otherwise communicate with us regarding the Site (collectively, the 'Services'). For the purposes of this Privacy Policy, 'you' and 'your' refer to you as a user of the Services, whether as a customer, website visitor, or any other person from whom we have collected information under this Privacy Policy.

Please read this Privacy Policy carefully.

Changes to this Privacy Policy

We may update this Privacy Policy from time to time, including to reflect changes in our practices or for other operational, legal, or regulatory reasons. We will post the updated Privacy Policy on the Site, update the 'Last updated' date, and take all other steps required by applicable law.

How we collect and use your personal data

To provide the Services, we gather personal information about you from various sources, as detailed below. The information we collect and use depends on your interactions with us.

In addition to the specific uses set out below, we may use the information we collect about you to communicate with you, deliver or improve the Services, comply with all applicable legal obligations, enforce applicable service terms, and protect or defend the Services, our rights, and the rights of our users or others.

What personal data we collect

The kind of personal data we obtain about you depends on your interactions with our Site and your use of our Services. When we use the term 'personal data', we mean data that identifies, relates to, describes, or can be associated with you. The following sections describe the categories and specific types of personal data we collect.

Information we collect directly from you

Information you provide directly to us through our Services may include:

• Contact details, including your name, address, phone number, and email address.
• Order details, including your name, billing address, delivery address, payment confirmation, email address, and phone number.
• Account details, including your username, password, security questions, and other information used for account security.
• Customer support information, including the information you share in communication with us, for example, when you send a message via the Services.

For some functions of the Services, you may need to provide us with certain information about yourself directly. You may choose not to provide this information, but in that case, you may not be able to use or access these functions.

Information we collect about your use

We may also automatically collect certain information about your interaction with the Services ('Usage Data'). We may use cookies, pixels, and similar technologies ("Cookies") for this. Usage data may include information about how you access and use our Site and your account, including device information, browser information, information about your network connection, your IP address, and other information about your interaction with the Services.

Information we obtain from third parties

Lastly, we may obtain information about you from third parties, including from vendors and service providers that may collect information on our behalf, such as:

• Companies that support our Site and Services, such as Shopify.
• Our payment processors, who collect payment information (e.g., bank account, credit, or debit card details, billing address) to process your payment, fulfill your orders, and deliver the products or services you have requested so that we can execute the agreement we have with you.
• When you visit our Site, open or click on emails we send you, or interact with our Services or advertisements, we, or third parties we work with, may automatically collect certain information using online tracking technologies, such as pixels, web beacons, software development kits, third-party libraries, and cookies.

All information we obtain from third parties will be treated in accordance with this Privacy Policy. Also, see the section below, Third-party websites and links.

How we use your personal data

• Delivery of products and services. We use your personal data to provide you with the Services according to the agreement we have with you, including processing your payments, fulfilling your orders, sending notifications related to your account, purchases, returns, exchanges, or other transactions, creating, maintaining, and otherwise managing your account, arranging shipping, facilitating returns and exchanges, and other functions and features related to your account. We may also enhance your shopping experience by enabling Shopify to match your account with other Shopify services you might want to use. In this case, Shopify processes your data as outlined in the Privacy Policy and the Consumer Privacy Policy .
• Marketing and advertising. We may use your personal data for marketing and promotional purposes, such as sending marketing, advertising, and promotional communications via email, SMS, or post, and displaying ads for products or services to you. This may involve using your personal data to better tailor the Services and ads on our Site and other websites. If you are a resident of the EEA, the legal basis for these data processing activities is our legitimate interest in selling our products, according to Art. 6 (1) (f) GDPR .
• Security and fraud prevention. We use your personal data to detect, investigate, or take action on potential fraudulent, illegal, or malicious activities. If you choose to use the Services and register an account, you are responsible for keeping your account login credentials secure. We highly recommend that you do not share your username, password, or other access details with anyone else. If you believe your account has been compromised, contact us immediately. If you are a resident of the EEA, the legal basis for these data processing activities is our legitimate interest in keeping our website secure for you and other customers, according to Art. 6 (1) (f) GDPR.
• Communication and service improvement. We use your personal data to provide you with customer support and improve our Services. This is in our legitimate interest to communicate with you, provide you with effective services, and maintain our business relationship with you according to Art. 6 (1) (f) GDPR.

Cookies

Like many other websites, we use Cookies on our Site. Specific information about the Cookies we use concerning supporting our store with Shopify can be found via https://www.shopify.com/legal/cookies. We use Cookies to support and improve our Site and Services (including remembering your actions and preferences), conduct analyses, and gain more insight into user interaction with the Services (for our legitimate interest to manage, improve, and optimize the Services). We may also allow third parties and service providers to use Cookies on our Site to better tailor services, products, and advertising on our Site and other websites.

Most browsers automatically accept Cookies by default, but you can set your browser to remove or reject cookies in the browser settings. Please be aware that deleting or blocking cookies might negatively affect your user experience, and some Services, including certain features and overall functionality, may not work correctly or become unavailable. Additionally, blocking Cookies may not entirely prevent the way we share information with third parties, such as our advertising partners.

How we disclose personal data

Under certain circumstances, we may disclose your personal data to third parties for contract execution, legitimate purposes, and other reasons within this Privacy Policy. Such circumstances may include:

• With vendors or other third parties that perform services on our behalf (such as IT management, payment processing, data analysis, customer support, cloud storage, fulfillment, and shipping).
• With business and marketing partners to provide services and display advertisements to you. Our business and marketing partners will use your data in accordance with their own privacy statements.
• When you instruct us, request us, or otherwise consent to the transfer of certain data to third parties, for example, to provide you with products or through your use of social media widgets or login integrations, with your consent.
• With our affiliates or otherwise within our corporate group, in our legitimate interests to run a successful business.
• In connection with a business transaction, such as a merger or bankruptcy, to comply with applicable legal obligations (including responding to subpoenas, search warrants, and similar requests), enforce applicable service terms, and protect or defend the Services, our rights, and the rights of our users or others.

We disclose the following categories of personal data and sensitive personal information about users for the purposes set out above in 'How we collect and use your personal data' and 'How we disclose personal data':

We do not use or disclose sensitive personal information without your consent or to infer characteristics about you.

With your consent, we share personal data as follows to perform advertising and marketing activities.

Third-party websites and links

Our Site may contain links to websites or other online platforms operated by third parties. If you follow links to sites not affiliated with or operated by us, it is important to read their privacy and security policies and other terms. We do not guarantee and are not responsible for the privacy or security of such sites, including the accuracy, completeness, or reliability of the information on these sites. Information you provide in public or semi-public areas, including information shared on third-party social networks, may also be visible to other users of the Services and/or users of these third-party platforms, without limitation as to how it is used by us or a third party. The inclusion of such links on our Site does not imply endorsement of the content on such platforms or their owners or operators, except as stated in the Services.

Children's data

The Services are not intended for use by children, and we do not knowingly collect personal data about children. If you are the parent or guardian of a child who has provided us with personal data, you can contact us using the contact information below to request that it be removed.

As of the effective date of this Privacy Policy, we do not knowingly 'share' or 'sell' the personal data of individuals under 16 years of age (as these terms are defined by applicable law).

Security and retention of your data

Please note that no security measure is perfect or impenetrable, and we cannot guarantee 'perfect security'. Furthermore, information you send to us may not be secure during transmission. We recommend not using insecure channels to send sensitive or confidential information to us.

How long we retain your personal data depends on several factors, such as whether we need the data to maintain your account, provide the Services, comply with legal obligations, resolve disputes, or fulfill other applicable contracts and policies.

Your rights

Depending on where you live, you may have some or all of the following rights regarding your personal data. However, these rights are not absolute and may apply only in certain circumstances, and in certain cases, we may deny your request to the extent permitted by law.

• Right to access/know: You may have the right to request access to the personal data we hold about you, including details about how we use and share your data.
• Right to delete: You may have the right to request that we delete the personal data we hold about you.
• Right to correction: You may have the right to request that we correct inaccurate personal data we hold about you.
• Right to portability: Under certain circumstances and with certain exceptions, you may have the right to receive a copy of the personal data we hold about you and request that we transfer it to a third party.
• Right to opt-out of sales, sharing, or targeted advertising: You may have the right to request that we do not 'sell' or 'share' your personal data, or suspend processing your personal data for purposes considered 'targeted advertising', as defined under applicable privacy laws. Please note that if you visit our Site while the Global Privacy Control opt-out preference signal is enabled, we will automatically treat this, depending on your location, as a request to opt-out of the 'selling' or 'sharing' of information for the device and browser you are using to visit the Site.
• Restriction of processing: You may have the right to request that we cease or restrict the processing of personal data.
• Withdrawal of consent: When we require your consent to process your personal data, you may have the right to withdraw that consent.
• Appeal: If we refuse to process your request, you may have the right to appeal our decision. You can do this by responding directly to our denial.
• Manage communication preferences: We may send you promotional emails, and you can opt-out of receiving these at any time by using the opt-out feature included in the emails we send you. If you opt-out, we may still send you non-promotional emails, such as emails about your account or orders you have placed.

You can exercise any of these rights where indicated on our Site or by contacting us via the contact details below.

We will not discriminate against you for exercising any of these rights. We may need to collect information about you to verify your identity, such as your email address or account information, before providing a substantive response to the request. In accordance with applicable law, you may appoint an authorized agent to submit requests to exercise your rights on your behalf. Before we accept such a request from an authorized agent, we require the agent to provide proof of this authorization to act on your behalf, and we may ask you to verify your identity directly with us. We will respond to your request promptly, as required under applicable law.

Complaints

If you have any complaints about how we process your personal data, you can contact us using the contact information below. If you are not satisfied with our response to your complaint, you may, depending on where you live, have the right to appeal our decision by contacting us using the contact information below, or file a complaint with your local data protection authority. For the EEA, you can find here a list of responsible supervisory authorities for data protection.

International users

Please be aware that we may transfer, store, and process your personal data outside of the country where you live. Your personal data will also be processed by staff and third-party service providers and partners in these countries.

If we transfer your personal data outside of Europe, we rely on recognized transfer mechanisms such as the European Commission's standard contractual clauses, or equivalent contracts issued by the relevant competent authority in the United Kingdom, to the extent relevant unless the data is transferred to a country that has been deemed to provide an adequate level of protection.

Contact

If you have any questions about our privacy practices or this Privacy Policy, or if you wish to exercise any of the rights available to you, call us or send us an email at sales@tornadesign.com or contact us at De Hemmen 83, Drachten, 9206 AG, NL.

In accordance with applicable data protection laws and unless explicitly stated otherwise, we are the controller of your personal data.