Last Updated: November 1st, 2020
Thank you for choosing to be part of our community at Voltage Incorporated (“Voltage”, “we”, “us”, or “our”). We are committed to protecting your personal information and your right to privacy.
1. WHAT INFORMATION DO WE COLLECT?
We collect personal information that you voluntarily provide to us when you register on the Website, when you express an interest in obtaining information about us or our products and Services, when you participate in activities on the Website, or otherwise when you contact us.
We may collect technical data such as your Internet Protocol (IP) address, browser, or device characteristics automatically when you use the Services. This information is necessary to maintain the security and operation of our Website, and for our internal analytics and reporting purposes. We also may collect information via cookies or similar technologies.
We may also collect log and usage data, which includes without limitation service-related, diagnostic usage and performance information our servers automatically collect when you access or use our Website. This log data may include without limitation data like your IP address, device information, browser type and settings and information about your activity in the Website.
We collect device data regarding the device you use to access the Website. This device data may include without limitation device type, IP address, location, browser type, or hardware model.
We collect information data such as information about your device’s location (precise or imprecise) depending on the settings of the device you use to access the Website. You can opt out of allowing us to collect this information either by refusing access to the information or by disabling certain settings on your device. Note if you choose to opt out, you may not be able to use certain aspects of the Services.
2. HOW DO WE USE YOUR INFORMATION?
We process your information for purposes based on legitimate business interests, the fulfillment of our contract with you, compliance with our legal obligations, or your consent. We use personal information collected via our Website for a variety of business purposes described below. We process your personal information for these purposes in reliance on our legitimate business interests, in order to enter into or perform a contract with you, with your consent, or for compliance with our legal obligations. We indicate the specific processing grounds we rely on next to each purpose listed below.
We use the information we collect or receive:
- To facilitate account creation and logon process. If you link your account to a third-party account, we use the information you allowed us to collect from those third parties in account creation and logon process for the performance of the contract.
- To request feedback.
- To enable user-to-user communications, with each user’s consent.
- To manage user accounts, for the purposes of managing and delivering your account.
- To send administrative information to you, including without limitation new feature information or information about changes to our terms.
- To protect our Services. We may use your information as part of our efforts to keep our Website safe and secure (for example, fraud monitoring and prevention). We may also use your information to enforce our terms, conditions and policies, to comply with contractual legal and regulatory obligations.
- To respond to legal requests and prevent harm, and we may inspect relevant data.
- To fulfill and manage your orders.
- To administer prize draws and competitions, upon your election to participate.
- To deliver and facilitate delivery of requested services to the user.
- To respond to user inquiries and offer support to users.
- To send you marketing, promotional communications, and tailored advertising. We, or our third-party marketing partners, may use the personal information you send to us for our marketing purposes, if in accordance with your marketing preferences. You may opt-out of our marketing emails at any time. We (with or without the work of third parties) may also use your information to develop and display personalized content and advertising tailored to your interests or location and to measure its effectiveness.
3. WILL YOUR INFORMATION BE SHARED WITH ANYONE?
We only share information with your consent, to comply with laws, to provide you with services, to protect your rights, or to fulfill business obligations.
We may process or share your data that we hold based on any of the following legal bases:
- We may process your data if you have given us specific consent to use your personal information in a specific purpose.
- We may process your data when it is reasonably necessary to achieve our legitimate business interests.
- We may process your data to fulfill the terms of any contract between you and Voltage.
- We may disclose your information where we are legally required to do so, including without limitation, governmental
- We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, potential threats to safety of any person, illegal activities, or evidence in litigation in which we are involved.
- We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
We collect Device Information using the following technologies:
- “Cookies” are data files that are placed on your device or computer and often include an anonymous unique identifier. For more information about cookies, and how to disable cookies, visit http://www.allaboutcookies.org.
- “Log files” track actions occurring on parts of the Services, and collect data including your IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps.
- “Web beacons”, “tags”, and “pixels” are electronic files used to record information about how you browse the Services.
You can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove or reject cookies, you could affect certain features or services of our Website. To opt-out of interest-based advertising on our Website visit http://www.aboutads.info/choices/.
You can unsubscribe from our marketing email list at any time by clicking on the unsubscribe link in our emails or by contacting us using the details provided below. We may still communicate with you, for reasons including without limitation sending service-related emails that are necessary for the administration and use of your account, or for other non-marketing purposes. To otherwise opt-out, you may contact us using the contact information provided.
5. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?
We may transfer, store, and process your information in countries other than your own. Our servers are located in United States. If you are accessing our Website from outside United States, please be aware that your information may be transferred to, stored, and processed by us in our facilities and by those third parties with whom we may share your personal information pursuant to these Terms, in United States, and other countries.
European Commission’s Standard Contractual Clauses:
We have implemented measures to protect your personal information, including by using the European Commission’s Standard Contractual Clauses for transfers of personal information between our group companies and between us and our third-party providers. These clauses require all recipients to protect all personal information that they process originating from the EEA in accordance with European data protection laws and regulations. Our Standard Contractual Clauses can be provided upon request. We have implemented similar appropriate safeguards with our third-party service providers and partners and further details can be provided upon request.
6. HOW LONG DO WE KEEP YOUR INFORMATION?
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible, then we will securely store your personal information and isolate it from any further processing until deletion is possible.
7. HOW DO WE KEEP YOUR INFORMATION SAFE?
We aim to protect your personal information through with organizational and technical security measures. We have implemented appropriate technical and organizational security measures to protect the security of any personal information we process. Despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure. We cannot promise or guarantee that unauthorized third parties will not be able to bypass our security, and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Website is at your own risk. You should only access the Website within a secure environment.
8. WHAT ARE YOUR PRIVACY RIGHTS?
In some regions (like the European Economic Area), you have certain rights under applicable data protection laws. These may include the rights (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; or (iv) to data portability. You may also have the right to object to the processing of your personal information. To make such a request, please use the contact details provided below. We will consider and act upon any request according to applicable laws.
If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time. Please note that this will not affect the lawfulness of the processing before its withdrawal, nor will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.
If you are resident in the European Economic Area and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.
If you would at any time like to review or change the information in your account or terminate your account, you can contact us using the contact information provided. Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. We may retain some information to prevent fraud, troubleshoot problems, assist with investigations, enforce our Terms, or comply with applicable legal requirements.
What Are Your Rights Under the GDPR?
Under the General Data Protection Regulation (“GDPR”), Voltage is a data controller and data processor for the information we collect from you. If you are a European Union resident, you have the right to access personal information we hold about you and to ask that your personal information be corrected, updated, or deleted. If you would like to exercise this right, please contact us using the contact information below.
Additionally, if you are a European Union resident, note that we are processing your information in order to fulfill contracts we might have with you (for example if you make an order through the Services), or otherwise to pursue our legitimate business interests. Additionally, please note that your information will be transferred outside of Europe, including to the United States.
Note that you have specific rights under the GDPR, as follows:
- You may withdraw your previously provided consent to the processing of your Personal Information at any time.
- You may object to the processing of your Personal Information if it is being carried out for a purpose for which you have previously provided consent.
- You may access your specific Personal Information in the possession of the Services, obtain disclosure regarding certain aspects of the processing, and obtain a copy of your Personal Information subject to processing.
- You may seek to have your Personal Information updated or corrected.
- Under certain circumstances, you may restrict the processing of your Personal Information, and we will refrain from any processing activity other than storage.
- You may seek to have your Personal Information deleted. We will honor your request to the extent that retention of your Personal Information is no longer necessary for us to fulfill legitimate business purposes, legal, or contractual recordkeeping requirements.
- You may receive a copy of your Personal Information in a structured, commonly-used machine readable format that may be transferred to another controller without hindrance.
What is your right to access specific information?
You have the right to request that the Services discloses certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm a verifiable request from you, we will disclose to you:
the categories of personal information we collected about you;the categories of sources for the personal information we collected about you;our business or commercial purpose for selling that personal information;the categories of third parties with whom we share that personal information;the specific pieces of personal information we collected about youif we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
- sales, identifying the personal information categories that each category of recipient purchased; and
- disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
How Can You Exercise Your Rights?
You may request to exercise your rights to access, correction, deletion, and data portability of your Personal Information by contacting us at the contact information provided below. We will endeavor to respond to your request as promptly as possible and no more than 30 days from the receipt of your verifiable request.
1050 S Sagebrush St
Wichita, KS 67230
Email Address: email@example.com
Telephone number: 620-755-1703
Only you may request to exercise your rights or those of your minor child, and your request must be verifiable. Your verifiable consumer request must:
- provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative; and
- your request will sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you. We will only use Personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request. We consider requests made through your password protected account sufficiently verified when the request relates to Personal Information associated with that specific account. If you have an account with us, we will reply to your account. If you do not have an account with us, we will reply by mail or electronically, at your option.
For requests to transfer your Personal Information to another entity, we will provide your Personal Information in our chosen format that is readily useable and should allow you to transmit the information without hindrance. Any disclosures we provide will only cover the 12-month period preceding our receipt of your verifiable consumer request. If applicable, our response will provide the reasons we cannot comply with your request.
We will not charge you a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why and provide a cost estimate before completing your request.
We will not discriminate against you for exercising your rights.
We will not discriminate against you for exercising any of your privacy rights. Unless permitted under applicable laws, solely due to the exercise of your rights hereunder, we will not:
- deny you goods or services;
- charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties;
- provide you a different level or quality of goods or services; or
- suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
If you are resident in Switzerland, the contact details for the data protection authorities are available here: https://www.edoeb.admin.ch/edoeb/en/home.html.
If you have questions or comments about your privacy rights, you may email us at firstname.lastname@example.org.
9. CONTROLS FOR DO-NOT-TRACK FEATURES
10. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
If you are a California resident, you have specific rights regarding access to your personal information. California Civil Code Section 1798.83 permits California resident users to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes, and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you qualify and would like to make such a request, please submit your request in writing to us using the contact information provided below.
If you are under 18 years of age, reside in California, and have a registered account with the Website, you have the right to request removal of unwanted data that you publicly post on the Website. To request removal of such data, please contact us using the contact information provided below, and include your account’s email address and a statement that you reside in California. We will make sure the data is not publicly displayed on the Website, but please be aware that the data may not be completely or comprehensively removed from all our systems (e.g. backups, etc.).
CCPA Privacy Notice
What categories of personal information do we collect?
We have collected the following categories of personal information in the past twelve (12) months:
|Categories of Information||YES/NO|
|A. Identifiers Contact details, such as real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address and account name||YES|
|B. Personal information categories listed in the California Customer Records statute Name, contact information, education, employment, employment history and financial information||YES|
|C. Protected classification characteristics under California or federal law Gender and date of birth||NO|
|D. Commercial information, Transaction information, purchase history, financial details and payment information||NO|
|E. Biometric information, Fingerprints and voiceprints||NO|
|F. Internet or other similar network activity, Browsing history, search history, online behavior, interest data, and interactions with our and other websites, applications, systems and advertisements||NO|
|G. Geolocation data, Device location||NO|
|H. Audio, electronic, visual, thermal, olfactory, or similar information Images and audio, video or call recordings created in connection with our business activities||NO|
|I. Professional or employment-related information Business contact details in order to provide you our services at a business level, job title as well as work history and professional qualifications if you apply for a job with us||NO|
|J. Education Information Student records and directory information||NO|
|K. Inferences drawn from other personal information Inferences drawn from any of the collected personal information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics||NO|
We may also collect other personal information outside of these categories in instances where you interact with us in-person, online, or by phone or mail in the context of receiving help through our customer support channels, participation in customer surveys or contests, or facilitation in the delivery of our Services, or to respond to your inquiries.
If you are using an authorized agent to exercise your right to opt-out, we may deny a request if the authorized agent does not submit proof that they have been validly authorized to act on your behalf.
We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider. Each service provider may be a for-profit entity that processes the information on our behalf. We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered “selling” of your personal data.
We have not disclosed or sold any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months. Voltage Incorporated will not sell personal information in the future belonging to website visitors, users, or other consumers.
Your rights with respect to your personal data
Right to request deletion of the data – Request to delete
You can ask for the deletion of your personal information. If you ask us to delete your personal information, we will respect your request and delete your personal information, subject to certain exceptions provided by law, such as (but not limited to) the exercise by another consumer of his or her right to free speech, our compliance requirements resulting from a legal obligation or any processing that may be required to protect against illegal activities.
Right to be informed – Request to know
Depending on the circumstances, you have a right to know:
- whether we collect and use your personal information;
- the categories of personal information that we collect;
- the purposes for which the collected personal information is used; whether we sell your personal information to third parties;
- the categories of personal information that we sold or disclosed for a business purpose;
- the categories of third parties to whom the personal information was sold or disclosed for a business purpose; and
- the business or commercial purpose for collecting or selling personal information.
In accordance with applicable law, we are not obligated to provide or delete consumer information that is de-identified in response to a consumer request or to re-identify individual data to verify a consumer request.
Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights
We will not discriminate against you if you exercise your privacy rights.
Upon receiving your request, we will need to verify your identity. These verification efforts require us to ask you to provide information so that we can match it with the information you have previously provided us. We may also use other verification methods as the circumstances dictate.
We will only use personal information provided in your request to verify your identity or authority to make the request. To the extent possible, we will avoid requesting additional information from you for the purposes of verification. If we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity, and for security or fraud-prevention purposes. We will delete such additional information as soon as we finish verifying your identity.
Other privacy rights
You may request correction of your personal data if it is incorrect or no longer relevant, or ask to restrict the processing of the data. You can designate an authorized agent to make a request under the CCPA on your behalf. We may deny a request from an authorized agent that does not submit proof of valid authorization to act on your behalf in accordance with the CCPA.
You may request to opt-out from future selling of your personal information to third parties. Upon receiving a request to opt-out, we will act upon the request as soon as feasibly possible, but no later than 15 days from the date of the request submission.
To exercise these rights, you can contact us by email at email@example.com, or by referring to the contact details at the bottom of this document. If you have a complaint about how we handle your data, we would like to hear from you.
11. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
If you have any questions about our privacy practices or this Privacy Notice, please contact us at: firstname.lastname@example.org.