Legal Information

Privacy policy

Last updated: October 19, 2025

The privacy of your data—and it is your data, not ours!—is a big deal to us. In this policy, we lay out: what data we collect and why; how your data is handled; and your rights with respect to your data. We promise we never sell your data: never have, never will.

This policy is split into sections. For your convenience, links to each of those sections is as follows:

This policy applies to all services built and maintained by Versa Arc Consulting Ltd, trading as Torru, including our voice agent platform and related services.

This policy applies to our handling of information about site visitors, prospective customers, and customers and authorized users (in relation to their procurement of the services and management of their relationship with Torru). We refer collectively to these categories of individuals as "you" throughout this policy.

However, this policy does not cover information about a customer's end users that Torru receives from a customer, or otherwise processes on a customer's behalf, in connection with the services provided by Torru to the customer pursuant to an applicable services agreement. Torru processes such data under the instructions of the relevant customer, which is the "data controller" or "business" (or occupies a similar role as defined in applicable privacy laws), as described in the applicable services agreement between such customer and Torru. Torru's obligations as a "data processor" or "service provider" with respect to such information are defined in such services agreement and applicable data protection addendum and are not made part of this policy.

If you are a customer's end user and you have questions about how your information is collected and processed through the services, please contact the organization who has provided your information to us for more information.

If you are a California resident, please click here to see our California Notice at Collection, which includes additional disclosures as required by California law.

What we collect and why

Our guiding principle is to collect only what we need. Here’s what that means in practice:

Identity and access

When you sign up for Torru, we ask for identifying information such as your name, email address, and company name. That's so you can personalize your new account, and we can send you product updates and other essential information. We may also send you optional surveys from time to time to help us understand how you use our service and to make improvements. With your consent, we will send you our newsletter and other updates.

We'll never sell your personal information to third parties, and we won't use your name or company in marketing statements without your permission either.

Billing information

If you sign up for a paid Torru service, you will be asked to provide your payment information and billing address. Bank details/credit card information is submitted directly to our primary payment processor (Access Suite) and doesn't hit Torru servers. We store a record of the payment transaction, for purposes of account history, invoicing, and billing support. We store your billing address so we can charge you for service, calculate any VAT or sales tax due, send you invoices, and detect fraudulent credit card transactions. We occasionally use aggregate billing information to guide our marketing efforts.

Voice transcription and AI processing

When you use Torru's voice agent services, we process voice data through our AI and transcription partners (including 11labs, OpenAI, Anthropic, Cartesia, Gemini, Telnyx and Retell). We do not store voice recordings. We only store the resulting text transcripts of voice interactions. These transcripts are stored on our servers so you can access, review, and manage your voice agent conversations.

You can request deletion of your transcripts at any time by contacting [email protected]. We keep transcripts as long as your account is active unless you request earlier deletion. If you delete your account, we'll delete all transcripts within 60 days.

Business and operational information for service customization

In order to provide a customized voice assistant service tailored to your business, we collect information about the workflows within your business. This includes:

  • Typical questions asked by your customers or users
  • Domain-specific information relevant to your industry
  • Company-specific information
  • Operational and logistical details such as:
    • Opening hours
    • Services that you provide
    • Areas where you provide services (locations)
    • Availability information
    • Pricing information

This is not an exhaustive list. All information shared, and the extent of the information shared, is decided by you, the client or customer of Torru Services. You maintain full control over what business information is provided to customize your voice assistant.

General Geolocation data

We log the full IP address used to sign up for a Torru account and retain that for use in mitigating future spammy signups. We also log all account access by full IP address for security and fraud prevention purposes, and we keep this login data for as long as your account is active.

Website interactions

We collect information about your account activity for analytics and statistical purposes such as conversion rate testing and experimenting with new product designs. This includes, for example, your browser and operating system versions, your IP address, which web pages you visited and how long they took to load, and which website referred you to us. If you have an account and are signed in, these web analytics data are tied to your IP address and user account until your account is no longer active. The web analytics we use are described further in the Advertising and Cookies section.

Anti-bot assessments

We may use CAPTCHA or similar anti-bot measures across our applications to mitigate brute force logins and as a means of spam protection. We have a legitimate interest in protecting our service and the broader Internet community from credential stuffing attacks and spam. When you log into your Torru account or fill in certain forms, (if applicable) the CAPTCHA service evaluates various information (e.g., IP address, how long the visitor has been on the app, mouse movements) to try to detect if the activity is from an automated program instead of a human. The CAPTCHA service then provides Torru with the spam score results; we do not have access to the evaluated information.

Cookies

We use persistent first-party cookies to store certain preferences, make it easier for you to use our application, and support authentication and basic analytics.

A cookie is a piece of text stored by your browser. It may help remember login information and site preferences. It might also collect information such as your browser type, operating system, web pages visited, duration of visit, content viewed, and other click-stream data. You can adjust cookie retention settings and accept or block individual cookies in your browser settings, although our service won't work properly if you turn cookies off.

Voluntary correspondence

When you email Torru with a question or to ask for help, we keep that correspondence, including your email address, so that we have a history of past correspondence to reference if you reach out in the future.

We also store information you may volunteer, for example, written responses to surveys. If you agree to a customer interview, we may ask for your permission to record the conversation for future reference or use. We will only do so with your express consent.

When we access or disclose your information

To provide products or services you've requested. We use some third-party subprocessors to help run our application and provide the Services to you. These include AI, transcription and sim services (11labs, OpenAI, Anthropic, Cartesia, Gemini, Retell and Telnyx), payment processing (AccessSuite), hosting providers (Hetzner), email delivery services (Brevo), and domain routing and security services (Cloudflare). All of our subprocessors are GDPR compliant. You can view the complete list at Subprocessors.

Social media presence. We do not currently maintain social media accounts. In the future, we may create a social media presence to enable you to voluntarily engage with us through those platforms. If we do, your personal information may also be collected by those social media companies according to their own privacy policies.

No Torru team member looks at your content except for limited purposes, for example, if an error occurs that stops an automated process from working or reduces quality of the service provided and requires manual intervention to fix. These are rare cases, and when they happen, we look for root cause solutions as much as possible to avoid them recurring. We may also access your data if required in order to respond to legal process (see "When required under applicable law" below).

To help you troubleshoot or squash a software bug, with your permission. If at any point we need to access your content to help you with a support case, we will ask for your consent before proceeding.

To investigate, prevent, or take action regarding restricted uses. Accessing a customer’s account when investigating potential abuse is a measure of last resort. We want to protect the privacy and safety of both our customers and the people reporting issues to us, and we do our best to balance those responsibilities throughout the process. If we discover you are using our products for a restricted purpose, we will take action as necessary, including notifying appropriate authorities where warranted.

Aggregated and de-identified data. We may aggregate and/or de-identify information collected through the services. We may use de-identified or aggregated data for any purpose, including marketing or analytics.

When required under applicable law. Torru is a UK company (Versa Arc Consulting Ltd) and our data infrastructure is located in the EU.

  • Requests for user data. Our policy is to not respond to government requests for user data unless we are compelled by legal process or in limited circumstances in the event of an emergency request. However, if UK or EU law enforcement authorities have the necessary warrant or court order requiring us to disclose data under applicable UK or EU law, we must comply. It is Torru's policy to notify affected users before we disclose data unless we are legally prohibited from doing so, and except in some emergency cases.

  • Preservation requests. We will comply with requests to preserve data only if compelled by applicable UK or EU law or by a properly served court order. We do not disclose preserved data unless required by law or compelled by a court order that we choose not to appeal. Furthermore, unless we receive a proper warrant or court order before the required preservation period expires, we will destroy any preserved copies of customer data at the end of the preservation period.

  • If we are audited by a tax authority, we may be required to disclose billing-related information. If that happens, we will disclose only the minimum needed, such as billing addresses and tax/VAT information.

Finally, if Torru is acquired by or merges with another company — we don't plan on that, but if it happens — we'll notify you well before any of your personal information is transferred or becomes subject to a different privacy policy.

Your rights with respect to your information

At Torru, we strive to apply the same data rights to all customers, regardless of their location. Under UK GDPR, EU GDPR, and other applicable data protection laws, some of these rights include:

  • Right to Know. You have the right to know what personal information is collected, used, shared or sold. We outline both the categories and specific bits of data we collect, as well as how they are used, in this privacy policy.
  • Right of Access. This includes your right to access the personal information we gather about you, and your right to obtain information about the sharing, storage, security and processing of that information.
  • Right to Correction. You have the right to request correction of your personal information.
  • Right to Erasure / "To Be Forgotten". This is your right to request, subject to certain limitations under applicable law, that your personal information be erased from our possession and, by extension, from all of our service providers. Fulfillment of some data deletion requests may prevent you from using Torru services because our application may then no longer work. In such cases, a data deletion request may result in closing your account.
  • Right to Complain. You have the right to make a complaint regarding our handling of your personal information with the appropriate supervisory authority (in the UK, the ICO - Information Commissioner's Office).
  • Right to Restrict Processing. This is your right to request restriction of how and why your personal information is used or processed, including opting out of sale of your personal information. (Again: we never have and never will sell your personal data.)
  • Right to Object. You have the right, in certain situations, to object to how or why your personal information is processed.
  • Right to Portability. You have the right to receive the personal information we have about you and the right to transmit it to another party. If you want to export data from your account, please contact [email protected] for assistance.
  • Right to not Be Subject to Automated Decision-Making. You have the right to object to and prevent any decision that could have a legal or similarly significant effect on you from being made solely based on automated processes. This right is limited if the decision is necessary for performance of any contract between you and us, is allowed by applicable law, or is based on your explicit consent.
  • Right to Non-Discrimination. We do not and will not charge you a different amount to use our service, offer you different discounts, or give you a lower level of customer service because you have exercised your data privacy rights. However, the exercise of certain rights may, by virtue of your exercising those rights, prevent you from using our Services.

Many of these rights can be exercised by signing in and updating your account information. Please note that certain information may be exempt from such requests under applicable law. For example, we need to retain certain information in order to provide our services to you.

In some cases, we also need to take reasonable steps to verify your identity before responding to a request, which may include, at a minimum, depending on the sensitivity of the information you are requesting and the type of request you are making, verifying your name and email address. If we are unable to verify you, we may be unable to respond to your requests. If you have questions about exercising these rights or need assistance, please contact us at [email protected] or at Versa Arc Consulting Ltd, 54C Graham Road, London, E8 1BZ, United Kingdom. If an authorized agent is corresponding on your behalf, we will need written consent with a signature from the account holder before proceeding.

Depending on applicable law, you may have the right to appeal our decision to deny your request, if applicable. We will provide information about how to exercise that right in our response denying the request. You also have the right to lodge a complaint with a supervisory authority. If you are in the UK, you can contact the ICO (Information Commissioner's Office) at https://ico.org.uk. If you are in the EU, you can contact your local data protection authority to file a complaint or learn more about local privacy laws.

How we secure your data

For more information about how we keep your information secure, please review our security overview.

What happens when you delete content in your account

You can request deletion of your voice transcripts at any time by contacting [email protected]. Once you request deletion, transcripts will be removed from our active servers within 30 days and from our backups within 60 days total. We cannot recover transcripts once they have been permanently deleted.

If you choose to cancel your account, all of your content (including transcripts) will become immediately inaccessible and will be purged from our systems in full within 60 days. This applies both for cases when an account owner directly cancels and for auto-canceled accounts. Please refer to our Cancellation policy for more details.

Data retention

We keep your information for the time necessary for the purposes for which it is processed. The length of time for which we retain information depends on the purposes for which we collected and use it and your choices, after which time we may delete and/or aggregate it. We may also retain and use this information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. Through this policy, we have provided specific retention periods for certain types of information.

Location of site and data

Torru is operated from the United Kingdom, and our data infrastructure is located in the European Union. Your personal data is stored and processed within the EU, which provides a high level of data protection under EU GDPR and UK GDPR regulations.

Data Processing Addendum

For customers who require a Data Processing Addendum (DPA) with Standard Contractual Clauses for compliance purposes, please contact us at [email protected] and we will provide one that meets the requirements of UK GDPR and EU GDPR.

Changes and questions

We may update this policy as needed to comply with relevant regulations and reflect any new practices. Whenever we make a significant change to our policies, we will refresh the date at the top of this page and take any other appropriate steps to notify users.

Have any questions, comments, or concerns about this privacy policy, your data, or your rights with respect to your information? Please get in touch by emailing us at [email protected] and we'll be happy to try to answer them!