Privacy Policy

Who this is about

Torva OS (“Torva”, “we”, “us”) is operated by DC Northern Holdings LLC, 10177 Marmot Circle, Anchorage, Alaska 99515, United States.

There are three different relationships in this document and it is worth separating them at the start, because your rights differ in each:

• You, visiting torvaos.com. We decide what to collect here and why, so we are the controller of it.
• You, as a Torva merchant. Your account, your workspace, your subscription. We are the controller of that too.
• Your customers, shopping on your store. You decide what to collect from them and why. You are the controller; Torva is a processor acting on your instructions. We do not use your customers’ data for our own purposes, we do not sell it, and we do not market to them.

What torvaos.com collects

The public marketing site, the Help Center and the guides use the measurement tools described below. None of it runs on the Desk, the operator console, sign-in, the API, a store preview or a merchant’s storefront — the check is on the hostname and the path, in code, not a setting somebody can forget.

• Google Analytics 4. Standard GA4 measurement of public pages and signup steps, including the cookies GA sets. Google processes it as our processor; Google’s own privacy terms apply.
• Microsoft Clarity. Heatmaps and session replay of public pages — a recording of clicks, scrolling and movement, used to see where a page confuses people. Clarity masks input fields by default. Do not type anything confidential into a public page.
• Torva’s own first-party analytics. Deliberately minimal, and worth stating precisely: a random visitor id and session id generated in your browser, the page path with the query string stripped off, whether it was the entry page, whether you are returning, the referring hostname, any utm source, medium and campaign, a device class of mobile, tablet or desktop, the two-letter country the hosting edge reports, and how long the page was actually visible. No IP address is stored, and no user agent. The country comes from the edge’s geolocation header, not from an IP lookup we perform.
• Signup funnel steps. Which step a visitor reached — visit, build started, preview ready, account created, checkout started, paid — against that same random id, at most once per step per hour. No name, no email.
• Google Ads. Torva advertises on Google, and the Google Ads tag loads with Google Analytics on the same public pages. It records visits and whether a visit that came from a Torva ad went on to buy a subscription, and — on Google’s default settings — it lets Google use a visit to torvaos.com to show Torva ads to that browser elsewhere (remarketing). Google processes this under its own terms and privacy policy.
• Meta Pixel. On the Torva homepage and /start builder, we measure page visits, builds started, previews ready and email requests successfully saved. Meta receives these event names, the page URL and referrer, browser and network information, and advertising cookie identifiers. We do not send the email address, store content or account/payment details in these events; automatic advanced matching and automatic event detection are off. We exclude private/account/checkout pages, non-campaign query strings, private referrers and merchant storefronts. The pixel does not load when Global Privacy Control is enabled. Meta uses this information under its own terms and privacy policy to measure and deliver advertising.
• Store-builder quality. When you build a free preview we record the quality score of that build, whether it passed, which tested design it fell back to if it did, which path you took, and the website you asked us to take inspiration from. This is how we tell whether the builder is handing people something worth paying for.

Email addresses and details you give us

torvaos.com never collects an email address without you typing it and pressing a button. Where you do:

• The free risk check and the compliance scan. Your email, the store address you checked, and the exact consent wording you agreed to, with the time. We use it for that report and, where you ticked the box that says so, to email you about your store’s results or Torva. Ask and we remove it.
• “Email me my store when it’s ready.” While your store is being read and built on /start, or under the finished preview (“Email me my store link”), you can leave your email. We keep it with the store name, the website being read, and the exact consent wording you were shown, its version and the time. We use it to send you the private link to your preview, and up to 3 follow-ups about that preview: the day after it is built, three days after, and the day before it expires. They stop as soon as you make it your store, use the unsubscribe link in any of them, or reply “no”. An address that unsubscribes stays on a do-not-email list so it is not emailed about a later preview either. If you leave before your build finishes, a person at Torva finishes it and emails it to you.
• “We’ll build it for you.” If a scan or build fails and you ask us to build the store, we keep your email, the website address, why the automatic build stopped, and the consent wording with its version and time. A person at Torva uses them to build the store and email you its preview link, followed by up to 3 follow-ups about that preview on the same terms as above.
• “Email me when the back office connects.” Your email, used for that one message and nothing else.
• Partner and affiliate applications on a store. The details you enter, plus the IP address and browser the application came from, kept as a record of who applied.
• The contact form. It stores nothing: it prepares an email that you send from your own email app.

Cookies and browser storage

Torva’s own analytics do not use cookies. They use localStorage and sessionStorage keys in your browser: torva:v (visitor id), torva:vt (when it was created), torva:touch (first-touch source), torva:s (session) and torva:visited. Clearing site data removes them and you become a new visitor.

Cookies on torvaos.com come from these places: Google Analytics and the Google Ads tag (cookies such as _ga and _gcl_au), Microsoft Clarity (such as _clck and _clsk), Meta Pixel on the homepage and /start (such as _fbp and _fbc), and Torva itself. Torva’s own cookies are: torva_ref, set for 90 days only when you arrive through a referral partner’s link, so the partner can be credited; torva_preview_owner, for 30 days once you build a free preview, so the preview stays yours without an account; torva-workspace, which remembers the store you last opened in the Desk; and, once you sign in, the session cookies that keep you signed in. The sign-in and preview cookies are strictly necessary for those features.

We do not sell personal information for money. The Google Ads tag and Meta Pixel described above share visit information for advertising, and some US state laws, including California’s, may treat that as “sharing” personal information for cross-context behavioural advertising. You can opt out of it: turn on Global Privacy Control in your browser and torvaos.com tells Google’s tags not to use your visit for advertising and disables the Meta Pixel; or email us and we will honour the request.

We do not currently show a cookie consent banner, and analytics and session replay load on public pages without asking first. If you would rather they did not, you can block them in your browser or with an extension, use Google’s Analytics opt-out add-on, and browse in a private window. If you are in a jurisdiction that requires prior consent, email us and we will honour an objection for your visits.

A merchant’s storefront is separate: what it sets is governed by that store’s own privacy policy, which the merchant publishes.

Your Torva account

To give you a workspace we hold: your name and email address; your authentication record, held by our authentication provider, including a hash of your password and any two-step verification factors you enrol — we never see or store your password itself; your store and workspace records, your role and your team’s roles; your business details, including the trading name, support address and postal address you enter for your own storefront; your plan, subscription status and billing period from the billing provider; your support conversations with us; and, if you connect it, the chat identifier for the notification channel you chose.

We use it to run the service, to bill you, to answer you, to keep the platform secure, and to email you about your account — your welcome and receipt-style messages, outages, security, billing, compliance alerts you switched on, and changes to these policies. Those are not marketing and you cannot unsubscribe from them while you have an account. Setup tips and compliance alerts can each be switched off in Settings → Email & notifications. If we send marketing email to merchants it will have an unsubscribe link and we will honour it.

Card numbers never reach Torva. Subscription checkout happens on the billing provider’s own page.

Your customers’ data, and our role in it

When you run a store on Torva, we process your customers’ data because you asked us to. Depending on what your store collects that can include: name, email address, phone number, shipping and billing address, order contents and amounts, order history and events, fulfilment and tracking, support messages, marketing consent and its record, affiliate attribution, and the age and research-use declaration a visitor makes at your storefront gate.

We process it to operate your store — showing the storefront, taking the order, sending the confirmation, buying the label, running the automation you switched on — and for nothing else. We do not build profiles across stores, we do not sell it, and we do not use it to train models.

Two things you can do yourself, without asking us:

• Export everything. Settings → Advanced produces one file with every record your store holds. Owner or admin only.
• Erase one person. Settings → Advanced honours a deletion request directly: the customer record, their consent record and the contents of email sent to them are deleted, and their orders are anonymised — the order keeps its number, its money and the country and region, because it is an accounting record, and loses the name, email, phone, street address and notes. It cannot be undone. Torva keeps proof that it happened, stored as a one-way hash of the address so the proof does not preserve the thing erased.

Where your data lives, and who else touches it

Torva’s database, file storage and authentication run on managed infrastructure in the United States, and the application is served from a global content network. Every company we rely on to run the platform, what it does and what it can see, is listed on one page: subprocessors. We keep that page current rather than saying “affiliates and service providers” and leaving you to guess.

If you or your customers are outside the United States, using Torva means your data is transferred to and processed in the United States, where privacy law differs from your own. Where a transfer mechanism is required for that, we rely on the standard contractual clauses in our providers’ data processing terms.

We disclose data outside that list only when we have to: to comply with law or valid legal process, to protect the rights and safety of merchants, their customers or the public, or to a successor in a merger or acquisition of the business. We do not sell personal information.

How long we keep it

Merchant account and workspace data is kept while your account exists, and for at least 90 days after a subscription ends so that you can still export it. After that we may delete it, and we will delete it sooner if you ask.

Customer data in your store is kept as long as you keep it. You control it: erase an individual at any time, and export the rest.

torvaos.com’s own analytics rows — the random-id page views and funnel steps described above — are deleted automatically 13 months after they are recorded; until then we use them for trend reporting. Email addresses given through the tools above are kept until you ask us to remove them. Google Analytics, Google Ads and Microsoft Clarity apply their own retention to what they hold.

Records we are required to keep — billing records, an anonymised order, proof that an erasure was carried out — are kept for as long as the law requires, and no longer than we need them.

Security

The short version: every tenant is isolated in the database itself rather than by application code remembering to filter; stored provider credentials and tokens are encrypted; two-step verification is available on every account and can be required for a whole workspace; error reports are stripped of request data before they leave; and exports exclude secrets. The detail, and the parts that are not finished, are on the security page.

No system is perfectly secure. If you find a vulnerability, email support@torvaos.com — please do not test against another merchant’s store.

Your rights, and how to use them

Depending on where you live you may have the right to know and access the personal data we hold about you, correct it, delete it, receive a copy in a portable form, opt out of its “sale” or “sharing” for advertising (see “Cookies and browser storage”), object to or restrict certain processing, and not be discriminated against for asking. Residents of California, Colorado, Connecticut, Virginia and other US states with privacy laws, and people in the UK, EU and EEA, have these rights under their own law.

Email hello@torvaos.com from the address on your account and we will answer within 30 days. We may need to verify who you are first — we will ask for the least that does. There is no charge.

If you are a customer of a store built on Torva, the store is the controller of your data, not Torva. Send your request to the store — its privacy policy names the address. If you send it to us we will pass it to the merchant and tell you we have. We cannot decide on the merchant’s behalf.

If you are unhappy with our answer you can complain to your data protection authority. We would rather you told us first.

Children

Torva OS is business software and is not directed at anyone under 18. We do not knowingly collect personal information from anyone under 18, and merchant accounts require you to be 18 or older. Storefronts built on Torva carry a 21-and-over gate. If you believe a child has given us information, email us and we will delete it.

Changes to this policy

When this policy changes we update the date at the top. If a change materially affects how we handle your data we will email the account owner before it takes effect. Earlier versions are available on request.

Contact

Privacy questions, requests and complaints: hello@torvaos.com, or write to DC Northern Holdings LLC, 10177 Marmot Circle, Anchorage, Alaska 99515, United States.