Privacy Policy
1. Overview
Torch Key Asset Management, LLC (“Company,” “we,” “our,” or “us”) respects your privacy and is committed to protecting the personal information you provide through our website located at www.tkam.com (the “Site”).
2. Information We Collect
This privacy policy (the “Privacy Policy”) describes how we collect, use, disclose, and safeguard information obtained through the Site. It also outlines your rights and choices regarding your information.
By using this Site, you consent to the practices described in this Privacy Policy.
We may collect the following categories of information:
A. Information You Voluntarily Provide
We collect personal information that you choose to provide, including when you:
- Contact us via email or contact form
- Subscribe to updates or communications
- Submit investor inquiries
- Apply for employment
- Request information about our funds or services
This may include:
- Name
- Email address
- Phone number
- Company or organization
- Job title
- Any other information you voluntarily submit
B. Automatically Collected Information
When you visit the Site, certain information may be collected automatically, including:
- IP address
- Browser type and version
- Device type
- Operating system
- Pages visited and time spent
- Referring website
- General geographic region
This information helps us analyze website usage and improve functionality.
C. Cookies and Tracking Technologies
We may use cookies, pixels, and similar tracking technologies to:
- Enhance user experience
- Analyze traffic and engagement
- Maintain security
- Improve site performance
You can modify your browser settings to decline cookies; however, some features of the Site may not function properly.
3. How We Use Information
We may use collected information to:
- Respond to inquiries and communications
- Provide information about our firm, funds, and services
- Maintain and improve the Site
- Monitor usage trends and analytics
- Comply with legal and regulatory obligations
- Protect against fraud or misuse
- Evaluate employment applications
We do not sell personal information.
4. Sharing and Disclosure of Information
We may share information in the following circumstances:
A. Service Providers
We may share information with trusted third-party service providers who assist with:
- Website hosting
- Analytics
- IT and security
- Communications or email distribution
These providers are contractually obligated to protect your information.
B. Legal and Regulatory Requirements
We may disclose information:
- To comply with applicable laws or regulations
- In response to lawful requests by public authorities
- To protect our rights, investors, or users
- In connection with audits, compliance reviews, or regulatory obligations
C. Business Transfers
In the event of a merger, acquisition, restructuring, or sale of assets, information may be transferred as part of that transaction.
5. Investor-Related Information
Information submitted through the Site does not constitute an offer to sell or solicitation of an offer to buy any securities. If you engage with us as a prospective or existing investor, additional privacy terms may apply and will be provided separately where required.
6. Data Security
We implement reasonable administrative, technical, and organizational safeguards designed to protect personal information from unauthorized access, disclosure, or misuse.
However, no method of transmission over the internet or electronic storage is completely secure, and we cannot guarantee absolute security.
7. Data Retention
We retain personal information only as long as necessary to:
- Fulfill the purposes outlined in this policy
- Comply with legal and regulatory obligations
- Resolve disputes and enforce agreements
8. Third-Party Links
The Site may contain links to third-party websites. We are not responsible for the privacy practices or content of those external sites. We encourage users to review their privacy policies.
9. Your Rights and Choices
Depending on your jurisdiction, you may have rights to:
- Request access to personal information we hold
- Request correction or deletion
- Opt out of certain communications
- Restrict or object to processing
To make a request, contact us at: info@tkam.com
California Privacy Rights (if applicable)
California residents may have additional rights under the California Consumer Privacy Act (CCPA/CPRA), including the right to request disclosure or deletion of personal information.
We do not sell personal information as defined by California law.
10. International Visitors
If you access the Site from outside the United States, your information may be transferred to and processed in the United States or other jurisdictions where our service providers operate.
By using the Site, you consent to such transfers.
11. Children’s Privacy
This Site is not directed to individuals under the age of 18. We do not knowingly collect personal information from children.
12. Updates to This Policy
We may update this Privacy Policy periodically. When we do, we will revise the “Effective Date” above. Continued use of the Site after updates constitutes acceptance of the revised policy.
13. Contact Us
For questions about this Privacy Policy or our data practices, contact:
Torch Key Asset Management, LLC
11355 W. Olympic Blvd.
Los Angeles, California 90064
Email: info@tkam.com
