Privacy Policy

Welcome to Torquay eTrading LLC’s ("YourFacePillow," "we," "us" or "our") website, located at (“Website”). Our Privacy Policy explains how we collect, use, share and protect information in relation to the Website and any software provided on or in connection with YourFacePillow products and services, and your choices about the collection and use of your information. This Privacy Policy applies to all visitors, users, and others who access this Website, or any of YourFacePillow’s websites, applications, or online services that link to this Privacy Policy (“Users”).

By visiting our Website, you are accepting the practices described in this Privacy Policy. If you do not agree to the terms of this Privacy Policy, please do not use the Website. We reserve the right to modify the terms of this Privacy Policy from time to time without notice. Your continued use of our Website following the posting of changes will mean you accept those changes.

If you have any questions about this Privacy Policy, you should contact us by email at

We collect two basic types of information from you: (1) personally identifiable information (“PII”) and (2) non-personally identifiable information (“non-PII”). PII is any information that you supply to us that can individually identify you. PII includes, among other things, your name, contact information (e.g., email address, postal address, telephone number), payment information (e.g., credit/debit card information, bank account number), and photographs and videos in which you may be recognized. Non-PII includes information that does not personally identify you. Non-PII includes, among other things, information about your use of the Site, such as your IP address, device identifiers, general location information, and demographic data.

Information You Provide to Us Directly
While you can browse the Website without submitting your PII to us, there are a number of circumstances in which you may supply us with your PII. The following list comprises the most common ways in which we may collect your PII:

Registering for an account or creating a profile;
Requesting customer service or other assistance, or otherwise communicating with YourFacePillow;
Signing up to receive e-mail offers, newsletters or alerts;
Participating in surveys, panels, or market research;
Participating in special events, contests or sweepstakes;
Making purchases on the Website, including subscriptions to YourFacePillow’s services;
Participating on social media accounts involving YourFacePillow;
Participation in communities, comment threads, other forums, and other interactive services;
Submitting user generated content; and
Any other activity on the Website where you knowingly volunteer information.
Collection of Personally Identifiable Information From Social Media Sites
When you interact with any YourFacePillow page or account on a social media platform, we may collect the PII that you make available to us on that page, including your account ID or username. If you choose to log in to your YourFacePillow account with or through a social networking service, YourFacePillow and that service may share certain information about you and your activities. With your permission, we also may share information about your activities, including what you view on the Website, with that social network’s users.

Non-Personally Identifiable Information
As stated above, we also collect non-PII when users interact with the Website. Non-PII does not personally identify you. Generally, we collect and store the following categories of non-PII:

Demographic data such as age, gender, and five-digit ZIP code;
Information about the device(s) used to access the Website, such as they type of browser used;
“Traffic data” such as the date and time the Website was accessed, software crash reports, and referring website addresses; and
User search terms and search results.
Use of Cookies, Web Beacons and Other Technologies
Like many websites, we may use tracking technologies such as cookies, web beacons, and embedded scripts. For example, we may use cookies, which are small text files that are stored on your computer or equipment when you visit certain online pages that record your preferences and actions in order to monitor traffic and improve the Website, making it easier to use and more relevant. Most web browsers automatically accept cookies but, if you prefer, you can usually modify your browser setting to disable or reject cookies. If you delete your cookies or if you set your browser to decline cookies, some features of the Website may not work or may not work as designed. For more information on cookies and how to disable them, you can consult the information provided by the Interactive Advertising Bureau at

Some content or applications on the Website are served by third parties. We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about a third party’s use of tracking technologies, you should contact the responsible third party directly.

Your browser or device may include “Do Not Track” functionality. YourFacePillow’s information collection and disclosure practices, and the choices that we provide to customers, will continue to operate as described in this Privacy Policy, whether or not a Do Not Track signal is received.

Log File Information
Log file information is automatically reported by your browser each time you make a request to access (i.e., visit) a web page or app. It can also be provided when the content of the webpage or app is downloaded to your browser or device.

When you use our Service, our servers automatically record certain log file information, including your web request, Internet Protocol ("IP") address, browser type, referring / exit pages and URLs, number of clicks and how you interact with links on our Website, domain names, landing pages, pages viewed, and other such information. We may also collect similar information from emails sent to our Users which then help us track which emails are opened and which links are clicked by recipients. The information allows for more accurate reporting and improvement of our Website.

Device Identifiers
When you use a mobile device like a tablet or phone to access our Service, we may access, collect, monitor, store on your device, and/or remotely store one or more "device identifiers." Device identifiers are small data files or similar data structures stored on or associated with your mobile device, which uniquely identify your mobile device. A device identifier may be data stored in connection with the device hardware, data stored in connection with the device's operating system or other software, or data sent to the device by YourFacePillow.

A device identifier may deliver information to us or to a third party partner about how you browse and use our Website and may help us or others provide reports or personalized content and ads. Some features of our Website may not function properly if use or availability of device identifiers is impaired or disabled.

Collection of Your Location Information
You may send us information which may disclose the general location of your device at the time you access the Website. Advertisements and certain content may be directed to you as a result of the collection of this data. In addition, in some cases the Website can deliver content based on your specific location if you choose to enable that feature.

Collection of Information From Other Sources
We also may collect information about you that we may receive from other sources or from our offline interactions with you to, among other things, enable us to verify, update information contained in our records and to better customize the Website for you.

In addition to some of the specific uses of information we describe in this Privacy Policy, we may use information that we receive to:

Provide requested content, products, and services;
Post user generated content as requested;
Communicate with users about their accounts or transactions;
Communicate about changes to company policies;
Communicate about a comment posted on our Website;
Personalize content, including by providing recommendations based on preferences;
Send newsletters, offer, and promotions for our products and services or special events by e-mail, text, or another medium;
Administer loyalty or referral programs;
Administer contests, sweepstakes, promotions, and surveys;
Optimize or improve our products, services, and operations;
Detect, investigate, and prevent activities that may violate our policies or be illegal;
Diagnose or fix technological issues with the Website;
And perform statistical, demographic, and marketing analyses of users and purchasing patterns.
Combination of Your Personally Identifiable Information
We may use the information from one portion of the Website on other portions of the Website, and we may combine information gathered from multiple portions of the Website into a single record. We may also use or combine information that we collect offline or we collect or receive from third-party sources to enhance, expand, and check the accuracy of your customer records.

We may disclose your PII collected on the Website to our agents, affiliates, partners, and other third parties as described below.

Parties with Whom we May Share Your Information
We have third-party agents, subsidiaries, affiliates and service providers that perform functions on our behalf, including, but not limited to: hosting, content syndication, content management, technical integration, marketing, analytics, customer service, and fraud protection. These entities may have access to PII if needed to perform their functions.

Public Areas, Interactive Features, and Activities
Please remember that any information you share in public areas, such as posting a comment to our Blog (“Public Social Features”), becomes public and anyone may take and use that information. Please be careful about what you disclose and do not post any information that you expect to keep private. Your submission of content for our Public Social Features must comply with the terms of this Privacy Policy and our Terms and Conditions, as well as any other applicable guidelines, if any, for use of these features. YourFacePillow cannot control who views information that you post in public areas of the Website and is not responsible for how third parties may use or disclose information that you post in public areas of the Website.

When we run a contest, sweepstake or game relating to our Website, it will be accompanied by a set of rules. The rules for each contest, sweepstakes or game will specify how the information gathered from you for entry will be used and disclosed if it is different than as described in this Privacy Policy. In conjunction with your entry in such contest or sweepstakes, PII will be collected if you voluntarily submit it.

We may change our ownership or corporate organization while providing the Website. We may also sell certain assets associated with the Website. In such event, we may transfer some or all of your information to an entity acquiring all or part of our assets or to another entity with which we have merged. Under such circumstances, we would request the acquiring party to follow the practices described in this Privacy Policy. Nevertheless, we cannot promise that an acquiring party or the merged entity will have the same privacy practices or treat your information the same as described in this Privacy Policy.

Responding to Legal Requests and Preventing Harm
We may access, preserve, and share your information in response to a legal request (such as a search warrant, court order, or subpoena) if we have a good faith belief that the law requires us to do so. This may include responding to legal requests from jurisdictions outside of the United States where we have a good faith belief that the response is required by law in that jurisdiction, affects users in that jurisdiction, and is consistent with internationally recognized standards. We may also access, preserve, and share information when we have a good faith belief it is necessary to: detect, prevent and address fraud and other illegal activity; to protect ourselves, you and others, including as part of investigations; and to protect our personal safety or that of users of the Website or the public. Information we receive about you may be accessed, processed and retained for an extended period of time when it is the subject of a legal request or obligation, governmental investigation, or investigations concerning possible violations of our terms or policies, or to otherwise prevent harm.

Use of Non-Personally Identifiable Information
We may disclose your non-PII in any other manner that we deem appropriate. Among other things, we may disclose non-PII to third parties to help us determine how people use parts of the Website and how we can improve our Website. We will also disclose non-PII to our service providers and other third parties about how our users collectively use the Website.

Storage and Processing
Your information collected through our Website may be stored and processed in the United States or any other country in which YourFacePillow, its Affiliates or Service Providers maintain facilities. YourFacePillow, its Affiliates, or Service Providers may transfer information that we collect about you, including personal information across borders to other countries or jurisdictions around the world. By registering for and using our Website, you consent to the transfer of information to any other country in which YourFacePillow, its Affiliates or Service Providers maintain facilities and the use and disclosure of information about you as described in this Privacy Policy. We use safeguards to help keep the information collected through Our Website secure and take steps (such as requesting a unique password) to verify your identity before granting you access to your account. These security procedures mean that we may occasionally request proof of identity before we disclose your PII to you. Please understand, however, that while we try our best to safeguard your PII once we receive it, no transmission of data over the Internet or any other public network can be guaranteed to be 100% secure.

Your Obligations to Keep Your Access Rights Secure
Please do your part to help us. You are responsible for maintaining the secrecy of your unique password and account information, and for controlling access to emails between you and YourFacePillow, at all times. Your privacy settings may also be affected by changes the social media services you connect to YourFacePillow. We are not responsible for the functionality, privacy, or security measures of any other entity.

You promise to: (a) provide true, accurate, current and complete information about yourself as prompted by our Website and (b) maintain and promptly update your information to keep it true, accurate, current and complete. If YourFacePillow suspects, in its sole discretion, that such information is untrue, inaccurate, not current or incomplete, YourFacePillow has the right to suspend or terminate your account and refuse any use of the Website.

Your Account Information and Profile/Privacy Settings
If you have an account with YourFacePillow or the Website, you may review and change your information by logging into your account and editing your profile. Please be advised that we may not be able to delete your PII without also deleting your user account. You will not be permitted to examine the PII of any other person or entity and may be required to provide us with PII to verify your identity prior to accessing any records containing information about you.

You may also opt out from receiving e-mails, newsletters, and other communications from us by unsubscribing from the email program. However, you may not opt out of e-mails related to your customer account and orders.

YourFacePillow does not knowingly collect or solicit any information from anyone under the age of 13 or knowingly allow such persons to register or use our Website. Our Website and its content are not directed at children under the age of 13. In the event that we learn that we have collected personal information from a child under age 13 without parental consent, we will promptly delete that information.

We are not responsible for the practices employed by any websites or services linked to or from our Website, including the information or content contained within them. Please remember that when you use a link to go from our Website to another website or service, our Privacy Policy does not apply to those third-party websites or services. Your browsing and interaction on any third-party website or service, including those that have a link on our website, are subject to that third party's own rules and policies. In addition, you agree that we are not responsible and do not have control over any third-parties that you authorize to access your User Content. If you are using a third-party website or service and you allow them to access your User Content you do so at your own risk.

YourFacePillow may modify or update this Privacy Policy from time to time, so please review it periodically. We may provide you additional forms of notice of modifications or updates as appropriate under the circumstances. Your continued use of YourFacePillow Products or Website after any modification to this Privacy Policy will constitute your acceptance of such modification.

Contact Us
Please feel free to contact us with any questions you might have regarding this Privacy Policy.

Torquay eTrading LLC