TorcSill Foundations, LLC.
Privacy Policy

Personal Information does not include:
· Publicly available information from government records.
· Deidentified or aggregated consumer information.
· Information excluded from the CCPA’s scope, like:
· health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
· personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

How We Collect Information About You.
We obtain the categories of Personal Information listed above either directly from you (e.g., from forms you complete or products and services you purchase) or indirectly from you (e.g., from observing your actions on our website).

Use of Personal Information.
We may use the Personal Information we collect for any legitimate and lawful business purpose, including those listed in the Section below titled “How TorcSill May Use and Share Your Information.”

Sharing Personal Information.
We may share your Personal Information as described in the Section below titled “How TorcSill May Use and Share Your Information.”

Disclosures of Personal Information for a Business Purpose.
In the preceding twelve (12) months, TorcSill has disclosed the following categories of Personal Information for a business purpose:

• Category A: Identifiers.
• Category B: California Customer Records personal information categories.
• Category D: Commercial Information.
• Category F: Internet or other similar network activity.

Sales of Personal Information.
In the preceding twelve (12) months, TorcSill has not sold any Personal Information.

Your Rights and Choices.
The CCPA provides California residents with specific rights regarding their personal information. The following describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights.
You have the right to request that we disclose certain information to you about our collection and use of your Personal Information over the past twelve (12) months. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will disclose to you:

• The categories of personal information we collected about you.
• The categories of sources for the personal information we collected about you.
• Our business or commercial purpose for collecting or selling that personal information.
• The categories of third parties with whom we share that personal information.
• The specific pieces of personal information we collected about you (also called a data portability request).
• If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:

o   sales, identifying the personal information categories that each category of recipient purchased; and

o   disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

Deletion Request Rights.
You have the right to request that TorcSill delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

• Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
• Debug products to identify and repair errors that impair existing intended functionality.
• Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
• Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
• Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
• Comply with a legal obligation.
• Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Access, Data Portability, and Deletion Rights.
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:

• Calling us at 1-800-731-8672.
• Filling out this online form.

Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within a twelve (12) month period. The verifiable consumer request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Response Timing and Format.
We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the twelve (12) month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance. We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Non-Discrimination.
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

• Deny you goods or services.
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
• Provide you a different level or quality of goods or services.
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

How TorcSill May Use and Share Your Information

Subject to applicable local law, TorcSill may use the personal information we collect through our website for any legitimate and lawful business purpose, including but not limited to the following:

• to provide products, information and services you request;
• to provide you with effective customer service or technical support;
• to contact you with information regarding health and safety, applicable regulations, or stewardship of our products;
• to improve the content, functionality, performance and usability of our website;
• to improve our marketing and promotional efforts;
• to provide technical support and troubleshooting; and
• for security, credit or fraud prevention purposes;
• for any other purpose identified in an applicable privacy statement or other agreement you may have with TorcSill.

TorcSill may use or disclose aggregated or anonymized data about our users, if that information does not identify any individual, in TorcSill’s sole discretion.

Dow may also share your information with third parties in specific cases such as:

• Our Service Providers.We may share your personal information with companies or organizations, including subsidiaries, affiliates, and other entities that perform services on our behalf, such as marketing and website support service providers.
• Business Transactions and Transfers.Dow may buy, sell, form, or otherwise reorganize one or more of its businesses or sell stock or assets, for example, as the result of a sale, merger, reorganization or liquidation. A transaction of this type may involve the disclosure of your information to prospective purchasers or partners who have signed a confidentiality agreement with TorcSill.
• Compliance with Laws and Protection of Our Rights and the Rights of Others.We may disclose personal information when we, in good faith, believe disclosure is appropriate to comply with the law, a court order or a subpoena. We may also disclose personal information to cooperate with a government investigation; to prevent or investigate a possible crime, such as fraud or identity theft; to enforce or apply our online terms of use or other agreements; or to protect our own rights or property or the rights, property or safety of our users or others.

Other than as described above, TorcSill does not provide or sell your personal information to third parties.

Location of Information

TorcSill maintains its corporate headquarters in the United States. Our servers, databases, and service providers are located in the United States. Different countries have different privacy laws and requirements, and some, including the United States, may provide less legal protection for your personal information than others

Use of Special Features or Areas of Our Website

This Privacy Statement may be supplemented by additional privacy statements that may be specific to individual Dow websites or features, such as our investor and career sites. TorcSill’s websites may include special features such as surveys, licensed content, online stores, or password protected areas, such as a customer-only area or a careers area, and these areas or websites may be subject to additional terms of use or privacy statements which may further specify additional personal information TorcSill may collect in these areas, why we need that information, and choices you may have about the use of that information. 

When you sign up to use a special feature or password-protected area, you may be asked to agree to additional terms governing your use of the special feature or password-protected area. In such cases, you may be asked to expressly consent to the additional terms, for example, by checking a box or clicking on a button marked “I agree.” (This type of agreement is known as a “click-through” agreement.) If any of the terms of a click-through agreement or another agreement between you and TorcSill are different than the terms of this Privacy Statement, the terms of that agreement will control over this Privacy Statement.

Children’s Privacy

TorcSill’s website is not intended for children under 16 years of age, and TorcSill does not knowingly collect information from children to sell or promote our products or services. No one under the age of 16 may provide information to TorcSill on or through our website, and if we learn that we have received information from a child under the age of 16, we will delete that information.

If you believe a child under the age of eighteen has sent personal contact information to TorcSill, please contact us immediately and we will use reasonable efforts to promptly remove that information from our systems.

Security

We take commercially reasonable precautions to protect the confidentiality, integrity and security of your personal information. We urge users to be careful with personal information while using the Internet.

Many TorcSill websites, including torcsill.com, are able to provide a secure connection between your computer and our server be established. We use an encryption technology called Secure Socket Layers (SSL). A secure connection is maintained until you leave the secure area of the site. Although we use SSL encryption to safeguard the confidentiality of personal information as it travels over the Internet, “perfect security” does not exist on the Internet and we cannot guarantee the safety of transmitting personal information over the Internet.

Password Protection. You are responsible for maintaining the confidentiality of your passwords. We have the right to assume that anyone accessing one of our websites using a password assigned to you has the right to do so. You will be solely responsible for the activities of anyone accessing our website using a password assigned to you, even if the individual is not, in fact authorized by you. If you have reason to believe that your password has been compromised or used without authorization, you must promptly change it using the functionality provided on the site or notify TorcSill that your account has been compromised.

External Links

Some of our websites may contain links to other websites on the Internet that are not under the control of or maintained by TorcSill. Such links do not constitute an endorsement by TorcSill of those websites, the content displayed, or the persons or entities associated with them. By visiting a linked website from a TorcSill website, you acknowledge that TorcSill is providing these links to you only as a convenience and you agree that TorcSill is not responsible for the content of such websites. External sites are governed by their own terms and policies and are not governed by TorcSill’s Privacy Statement, Terms of Use, Accessibility Statement, or other terms and policies.

Changes to This Privacy Statement

We reserve the right to modify this Privacy Statement and related business practices at any time by posting updated text on this site and updated effective date at the bottom of this page. As we add new features and functionality to our websites or TorcSill policies or applicable laws evolve, we may need to update or revise this Privacy Statement. We reserve the right to do so, at any time and without prior notice, by posting a revised version on our website. These changes will be effective as of the date we post a revised version on our website.

If we make changes to this Privacy Statement that materially change how we treat your personal data, we will make a reasonable effort to notify you promptly through reasonable means.

Your Choices

We respect your right to make choices about how you would like to interact with TorcSill and the extent of the personal information you choose to share with TorcSill. In some cases, we will ask you to indicate your choices at the time we collect your personal information. If you have previously agreed to receive email or marketing communications from TorcSill, you may “opt-out” at any time by using the unsubscribe feature included in the e-mails we send.

Access, Update or Correct Your Personal Information

If you have created an account or a personal profile on one of our websites, you may be able to access and update some or all of your personal information on your account settings or profile page. If you wish to access, update or correct other personal information, please contact us. We will contact you and may ask you for additional information to verify your identity. In most cases, we will update information as requested. In some cases, however, we may limit or deny your request if permitted or required by law or if we are unable to verify your identity.