DMAIC App Privacy Notice
Last updated: 30 April 2026
Effective date: 30 April 2026
This Privacy Notice explains how Torque Management Limited ("Torque", "we", "us") collects, uses, and protects personal data in connection with the DMAIC application and related services. It is written to meet the requirements of the EU General Data Protection Regulation (GDPR) and the Irish Data Protection Act 2018.
Please read this notice alongside our website privacy notice at https://www.torquemanagement.com/privacy-cookies, which covers the use of our website and other Torque services.
[H2] 1. Who we are
Torque Management Limited is an Irish registered company (CRO 353260), with principal offices at Mill House, Millbrook, Naas, Co Kildare, Ireland W91 DYY6.
For privacy-related enquiries, including requests to exercise your data protection rights, please contact us at dmaicapp@torquemanagement.com.
[H2] 2. Scope of this notice
This notice applies to personal data that Torque processes in connection with:
- The DMAIC application as offered through the Microsoft Azure Marketplace and Microsoft AppSource.
- Enquiries submitted via the "Contact me" function on our Marketplace and AppSource listings.
- Communications relating to your use of, or interest in, the DMAIC application.
This notice does not cover personal data created by your organisation's users while using the DMAIC application within your own Microsoft Power Platform tenant. See section 3 below for important information about how that data is handled.
[H2] 3. How DMAIC handles your organisation's data
The DMAIC application is delivered as a managed solution that runs inside your organisation's own Microsoft Power Platform environment. All data created or recorded by your users while using DMAIC — including project data, process improvement records, attachments, and any personal data associated with your own users — remains in your organisation's own Microsoft Dataverse environment.
Torque does not have access to this data and does not store, copy, transfer, or otherwise process it. Your organisation acts as the data controller for that data, and is responsible for handling it in line with your own data protection obligations. Microsoft acts as the underlying data processor for your Power Platform environment under your agreement with Microsoft.
The only information that flows from your organisation to Torque-controlled infrastructure is your Microsoft Entra tenant identifier and Marketplace subscription metadata, used solely to authorise your organisation's licence to use the application.
[H2] 4. Personal data we collect and process
[H3] 4.1 Licence authorisation data
When users in your organisation access the DMAIC application, Torque-hosted infrastructure receives and processes:
- Your organisation's Microsoft Entra tenant identifier (a system-generated unique reference, not personal data in itself).
- Marketplace subscription metadata: subscription identifier, plan tier, subscription status, activation timestamp, expiry timestamp, and event metadata for audit purposes.
This information is used solely to determine whether your organisation holds a valid licence to use the application. It is not used to identify, profile, or track individual users.
[H3] 4.2 Lead-capture data
When you submit an enquiry via the "Contact me" function on our Microsoft Marketplace or Microsoft AppSource listings, we receive the following personal data:
- Your name (first and last).
- Your work email address.
- Your company or organisation.
- Your country.
- Your telephone number (if provided).
[H2] 5. How we use your personal data
We use lead-capture data to respond to your enquiry, follow up where appropriate, and communicate with you about the DMAIC application. We do not use this data for unrelated marketing, profiling, or analytics, and we do not sell or rent it to any third party.
We use licence authorisation data to deliver the DMAIC service to your organisation, including resolving your subscription, granting access in line with your licence, and maintaining audit records of licence events.
[H2] 6. Legal bases for processing
We rely on the following legal bases under GDPR Article 6:
- Contractual necessity (Article 6(1)(b)) — for processing licence authorisation data to deliver the DMAIC service to your organisation under our agreement.
- Legitimate interests (Article 6(1)(f)) — for processing lead-capture data to respond to enquiries and communicate with prospective customers. We have considered your interests and rights and consider this processing to be reasonable and expected in the context of a business enquiry.
We do not process special categories of personal data, and we do not knowingly collect or process personal data from individuals under the age of 16.
[H2] 7. Where your data is stored
Personal data we process is stored in Microsoft Azure data centres in the Western Europe region. We do not transfer personal data outside the European Economic Area.
[H2] 8. Who we share your data with
We share personal data only with:
- Microsoft, as the operator of the underlying Azure platform and Microsoft Power Platform services we use to deliver DMAIC. Microsoft acts as a data processor in this capacity.
- Our internal personnel with a legitimate need to access it.
We do not share personal data with any other third party for marketing, advertising, profiling, or any other commercial purpose.
[H2] 9. How long we keep your data
We retain lead-capture data for as long as it is reasonably needed to support our communication with you, and for a reasonable period thereafter to maintain a record of the enquiry. We periodically review records and delete those no longer needed.
We retain licence authorisation data for the duration of your organisation's subscription and for a reasonable period thereafter to support licence audit and lifecycle activities.
If you would like us to delete personal data we hold about you, please contact us at dmaicapp@torquemanagement.com.
[H2] 10. Your data protection rights
If you are located in the European Economic Area or the United Kingdom, you have the following rights in respect of your personal data:
- The right to be informed about how your data is processed (this notice).
- The right of access — to obtain a copy of the personal data we hold about you.
- The right to rectification — to have inaccurate or incomplete data corrected.
- The right to erasure ("right to be forgotten") — to have your data deleted in defined circumstances.
- The right to restrict processing — to limit how we use your data in defined circumstances.
- The right to data portability — to receive your data in a structured, machine-readable format.
- The right to object — to processing carried out on the basis of legitimate interests.
To exercise any of these rights, please contact us at dmaicapp@torquemanagement.com. We will respond within one calendar month.
We do not carry out automated decision-making or profiling that has legal or similarly significant effects on individuals.
[H2] 11. Right to complain
You have the right to lodge a complaint with a data protection supervisory authority if you consider that our processing of your personal data does not comply with applicable law. The supervisory authority for Torque Management Limited is the Irish Data Protection Commission:
Data Protection Commission
21 Fitzwilliam Square South
Dublin 2
D02 RD28
Ireland
Website: www.dataprotection.ie
[H2] 12. Security
We use Microsoft Azure platform security controls to protect personal data we hold, including transport-layer encryption (TLS 1.2 or higher) for data in transit, encryption at rest, and access control via Microsoft Entra ID. Access to personal data is limited to personnel with a legitimate need.
[H2] 13. Changes to this notice
We may update this notice from time to time. The "Last updated" date at the top of this page indicates when it was last revised. Material changes will be notified by updating this page; we encourage you to review it periodically.
[H2] 14. Contact
For any questions about this notice, or to exercise your rights, please contact:
Torque Management Limited
Mill House, Millbrook, Naas, Co Kildare, Ireland W91 DYY6