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Home/Privacy Policy

Privacy Policy

Effective date: 10 June 2025  ·  Last updated: 10 June 2025

Data controller: Torro Exchange d.o.o., Croatia  ·  support@usetorro.com

1. Introduction

Torro Exchange d.o.o. ("Torro", "we", "our", or "us") operates the Torro platform available at usetorro.com — a short-term rental operations and housekeeping management platform.

This Privacy Policy explains what personal data we collect, why we collect it, how we use it, and what rights you have under the General Data Protection Regulation (GDPR) and applicable Croatian data protection law.

By using our website or platform, you acknowledge that you have read and understood this policy. If you do not agree with any part of it, please discontinue use of our services.

2. Data We Collect

2.1 Account and contact data

When you register for a Torro account, we collect:

  • Your email address
  • Your name (first and last)
  • Your company name (if provided)

2.2 Billing and invoicing data

If you choose to receive invoices or require VAT documentation, we may additionally collect your company's registered address and VAT identification number. This data is used solely for the purpose of issuing legally compliant invoices.

Payment transactions are processed exclusively by Stripe, Inc. Torro does not store, process, or have access to your full payment card details. Please refer to Stripe's Privacy Policy for information on how your payment data is handled.

2.3 Usage and analytics data

We use Google Analytics to understand how visitors interact with our website. This involves the collection of anonymised data including pages visited, session duration, browser type, and approximate geographic location based on IP address. We do not use this data to identify individuals.

2.4 Data you do not need to provide

We do not require, and ask that you do not provide, any sensitive personal data (such as health information, racial or ethnic origin, political opinions, religious beliefs, or biometric data) in connection with using Torro.

3. Legal Basis for Processing

We process your personal data on the following legal bases under Article 6 of the GDPR:

  • Performance of a contract — processing your email, name, and account data is necessary to provide the Torro service you have subscribed to.
  • Legal obligation — we are required by Croatian tax and accounting law to retain invoicing and billing records.
  • Legitimate interests — we use anonymised analytics data to improve our product and website. This does not override your rights and freedoms.
  • Consent — where required (e.g. non-essential cookies), we will ask for your explicit consent before processing.

4. How We Use Your Data

  • To create and manage your Torro account
  • To deliver and maintain the Torro platform and its features
  • To communicate with you about your account, subscription, or support requests
  • To issue invoices and comply with tax and accounting obligations
  • To send product updates, release notes, or relevant operational information (you may opt out at any time)
  • To analyse and improve the performance and usability of our website and platform

We do not sell your personal data to third parties. We do not use your data for automated decision-making or profiling that produces legal or similarly significant effects.

5. Third-Party Services

We share your data only with third-party service providers who are necessary to operate the Torro service. These providers are contractually bound to handle your data securely and only for the purposes we specify.

ProviderPurposeLocation
Stripe, Inc.Payment processingUSA (SCC)
Google LLCWebsite analytics (Google Analytics)USA (SCC)
Cloud infrastructure providerPlatform hosting and data storageUSA (SCC)

SCC = Standard Contractual Clauses approved by the European Commission, providing appropriate safeguards for transfers of personal data outside the European Economic Area.

6. Data Retention

We retain your personal data for as long as your account remains active. If you close your account, we will delete or anonymise your personal data within 90 days, except where we are required by law to retain it for longer (for example, invoicing records must be retained for a minimum period under Croatian accounting law).

Anonymised analytics data does not contain personal identifiers and is retained indefinitely for product improvement purposes.

7. Your Rights Under GDPR

As a data subject located in the European Economic Area, you have the following rights:

  • Right of access — you may request a copy of the personal data we hold about you.
  • Right to rectification — you may ask us to correct inaccurate or incomplete data.
  • Right to erasure — you may request deletion of your personal data, subject to our legal retention obligations.
  • Right to restriction — you may ask us to restrict processing of your data in certain circumstances.
  • Right to data portability — you may request your data in a structured, commonly used, machine-readable format.
  • Right to object — you may object to processing based on legitimate interests.
  • Right to withdraw consent — where processing is based on consent, you may withdraw it at any time without affecting prior processing.

To exercise any of these rights, contact us at support@usetorro.com. We will respond within 30 days. You also have the right to lodge a complaint with the Croatian Personal Data Protection Agency (AZOP) at azop.hr.

8. Data Security

We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, accidental loss, destruction, or disclosure. These include encrypted data transmission (HTTPS), access controls, and regular security reviews.

No method of transmission over the Internet is 100% secure. While we take the protection of your data seriously, we cannot guarantee absolute security. In the event of a data breach that is likely to result in a high risk to your rights and freedoms, we will notify you and the relevant supervisory authority as required by law.

9. Children

The Torro platform is intended for use by business professionals and is not directed at children under the age of 16. We do not knowingly collect personal data from anyone under 16. If we become aware that we have inadvertently collected such data, we will delete it promptly.

10. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. When we make material changes, we will notify you by email or by a prominent notice on our website. The updated policy will take effect on the date indicated at the top of this page.

11. Contact

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:

Torro Exchange d.o.o.

Petrinjska 51, 10 000 Zagreb, Croatia

OIB (VAT ID): 74903766410

Email: support@usetorro.com