Torch Solutions Group

Privacy Policy

Effective Date: June 6, 2026

Scope of This Policy

This Privacy Policy applies to the websites hosting Torch Solutions Group (“TSG”) content and services, including torchsolutionsgroup.com (collectively, the “Sites”). It governs TSG’s collection and use of personal information in connection with the Meaningful Competence® Consultant Certification program and related TSG products and services.

This policy does not apply to the My Value App, which is owned and operated by My Value Applications, LLC ("My Value Applications") and is a separate legal entity. TSG’s licensing relationship with My Value Applications does not extend TSG’s privacy obligations to that application. When you access the My Value App through a link on TSG’s Sites, you leave TSG’s properties and are subject to My Value Applications’ own privacy policy. TSG is not responsible for data collected by My Value Applications.

Information We Collect

Because most data capture occurs within the My Value App, TSG directly collects a limited set of personal information. Specifically, TSG may collect:

Contact Information

For leads, subscribers, and consultants, we may collect:

  Name

  Email address

  Telephone number

  General location (city, state, country)

Professional Information

In connection with the Meaningful Competence® Consultant Certification, we may collect:

  Employer name and job title

  Career history relevant to certification

  Certification credentials and completion records

Non-Personal Information

We may also collect information that does not directly identify you, including demographic data, aggregated usage data, device type, browser type, IP address, and behavioral data collected through cookies and similar technologies. Where local law treats certain identifiers (such as IP addresses) as personal information, we endeavor to comply with those requirements.

How We Use Your Information

TSG uses the information we collect to:

• Fulfill your purchases and deliver products and services

• Communicate with you about your account, certification status, or purchases

• Send product announcements, helpful information, and upcoming events (with opt-out available)

• Improve our Sites, products, and services

• Administer promotions, contests, or special offers

• Comply with legal obligations

TSG does not collect or retain sensitive personal information such as Social Security numbers, financial account numbers, medical records, or similar data. Financial transactions are routed directly through a payment vendor; TSG does not retain that information.

Communications Opt-Out

If you do not wish to receive optional communications from TSG, you may opt out at any time by:

• Clicking the unsubscribe link included in every marketing email, or

• Sending an email request to [email protected]

Important communications related to your purchases or account access are not subject to opt-out.

Data Retention

In the event of a data breach that is reasonably likely to result in risk to your rights or interests, TSG will notify affected individuals by email within 72 hours of becoming aware of the breach, to the extent reasonably practicable. Where 72-hour notification is not achievable, TSG will provide notice as soon as possible with an explanation of the delay.

Breach notifications will include: a description of what occurred, the categories of information involved, the steps TSG is taking in response, and guidance on steps you may take to protect yourself. Where required by applicable law, TSG will also notify relevant regulatory authorities.

Cookies and Similar Technologies

TSG’s Sites use cookies, pixel tags, and similar technologies to understand how visitors use our Sites, measure the effectiveness of communications and advertising, and improve your experience. We may use cookies to remember your preferences and settings across visits.

Some cookies are essential to the operation of the Sites (such as those supporting the checkout process). Others improve functionality but are not strictly required. You may disable cookies through your browser or device settings, though some features of the Sites may not function properly if you do so.

TSG may use cookies in connection with advertising services to measure ad effectiveness. We may also track actions taken in response to our email communications (such as link clicks) to gauge interest and improve future communications. If you prefer not to have email link clicks tracked, do not click links in those messages.

Social Media

TSG may collect certain information if you interact with us via social media, including LinkedIn, Facebook, TikTok, and Instagram. For example, you may register for webinars or receive mailings via your social media account. Information collected through these interactions is governed in part by the policies of those platforms. We may use the information you provide through social media to contact you or improve our services. You may opt out of communications at any time.

Any information you disclose in public areas of our Sites or on social media becomes public. Exercise caution when sharing personal information in those environments.

Personal Information Protection

TSG uses commercially reasonable security measures to protect against unauthorized access, alteration, disclosure, or destruction of personal data. Access to personal information is limited to employees, contractors, and agents who need it to perform their job functions. Those individuals are bound by confidentiality obligations. TSG’s third-party providers use SSL encryption for all pages where personal information is transmitted.

You are solely responsible for any personal information you choose to share in public areas of our Sites or on social media.

Disclosure to Third Parties

Service Providers

TSG works with third-party service providers to deliver its products and services. These providers may include email delivery services, web hosting, payment processing, video hosting, and customer support. TSG provides personal information to these companies only as required for them to perform services on our behalf. They are contractually obligated to protect your information and may not use it for their own purposes.

Legal Obligations and Safety

TSG may disclose personal information when required by law, court order, or lawful request from authorities, or where TSG reasonably believes disclosure is necessary to protect users from fraud or to enforce TSG’s terms and conditions.

Business Transfers

If TSG undergoes a merger, acquisition, sale, or similar change in control, personal information in TSG’s possession may be transferred to the successor entity. Any such transfer will be subject to the same privacy commitments described in this policy.

No Sale to Third Parties

TSG does not sell or share personal information with third parties for their own marketing purposes.

Access to Your Personal Information

You may request access to, correction of, or deletion of personal information TSG holds about you by contacting us at [email protected]. TSG will respond within 30 days of receiving your request. Where reasonable and permitted by law, TSG will fulfill such requests in good faith. We reserve the right to decline requests that require undue technical effort or where retention is required by law or legitimate business need.

Please note that TSG retains certification records—including records of credential issuance, annual maintenance, lapse, reinstatement, and revocation—as a legitimate business need, independent of any account data deletion request. Deletion of your TSG account data does not erase your certification history.

Links to Third-Party Sites

Our Sites, products, and communications may contain links to third-party websites, including the My Value App. Information collected by third parties is governed by their privacy practices, not this Privacy Policy. TSG is not responsible for the privacy practices or content of any third-party site, including My Value Applications.

Minors

TSG’s Sites and services are designed for working adults. We do not offer any products or services targeted to individuals under the age of 18. COPPA does not apply to TSG’s Sites. If TSG discovers or has reasonable belief that it has inadvertently received personal information from an individual under 18, TSG will delete that information promptly.

Notice to California Residents

Under the California Online Privacy Protection Act and the California Business and Professions Code, California residents have specific rights regarding their personal information.

Categories of Information Collected

TSG may collect the following categories of personally identifiable information through its Sites and services:

• First and last name

• Email address

• Telephone number

• Physical or mailing address

• Professional information (employer, role, career history, certification credentials)

• Any other identifier that permits physical or online contact

California Shine the Light

Under California Law SB 27, California residents may request, once per year, information about any third parties with whom TSG has shared personal information for their direct marketing purposes during the previous calendar year. To submit such a request, email [email protected] with “California Privacy Request” in the subject line, and include the domain name of the site you are inquiring about, your name, address, and email address. TSG will respond within thirty (30) days.

European Union Users

If you are located in the European Union or United Kingdom, please contact us at [email protected] before using our services, as additional terms may apply.

Changes to This Privacy Policy

This Privacy Policy may be updated from time to time at TSG’s sole discretion. When material changes are made, TSG will post a notice on its website along with a link to the updated policy. Your continued use of our Sites following the posting of changes constitutes acceptance of those changes. Information collected prior to any change will be used according to the rules that applied at the time of collection.

Questions or concerns about this Privacy Policy may be directed to:

Torch Solutions Group

6311 Bolsa Chica Ln

Houston, TX 77041

[email protected]