Privacy Statement

Last updated: September 26, 2024

1.   Introduction

Torc Robotics, Inc. and its affiliates (“Torc,” “we, “us”) appreciate your interest in our products and services and your visit to our internet site (the “Site”) linked to this Privacy Statement.  We want you to feel comfortable visiting our Site and using our products and services.  Protecting your privacy is an important concern to which we pay special attention.  The following online privacy statement (“Privacy Statement”) describes the collection and use of your information through our Site, product, and services.

2.   Collection and Use of Personal Information

We may collect personal information directly from you.  If you create an account or fill out an on-line form on our website, for example, you may provide your name and contact information.  We may also collect your personal information from someone else.  If you are an employee of one of our customers, for example, your employer may provide us your contact information.  If you use our products or services we may collect information about you through that interaction.  Finally, we may collect your personal information, such as your computer’s IP address, through your interactions with our website.

Here are further details about the personal information we collect, the sources from which we collect it, and the purposes for collecting it:

3.   Disclosure of Personal Information

Torc may disclose your personal information to third parties.  Here are details about the categories of personal information disclosed within the last twelve (12) months, the category of third party to whom this information was disclosed, and the purpose of the disclosure:

4.   Sale and Sharing of Personal Information

Torc does not sell or share your personal information and has not done so in the last twelve (12) months.  Torc does not share personal information for the purpose of cross-context behavioral advertising, targeted advertising, or similar uses, and has not done so in the last twelve (12) months.

5.   Children’s Privacy

We do not knowingly collect Personal Information from individuals under sixteen (16) years of age and have not done so within the last twelve (12) months.  If we learn that we have collected Personal Information from someone under sixteen (16), we will take steps to delete the Personal Information.

6.   Retention Periods

We retain your personal information (all categories unless mentioned below) as long as needed to fulfill the purposes for which we collected it and to meet our legal obligations.  For our employees, for example, we retain personal information for five years after the end of employment.  For employees of our customers or suppliers we may retain contact information for the period of their employment.  We may also have similar information on documents such as invoices or contracts which we are required to keep for longer periods.  We will not retain personal information longer than is reasonably necessary for the purposes disclosed above.

We retain some personal information, such as security camera footage and IT logs, for brief periods determined primarily by availability of storage media and internal policies.

7.   Your Privacy Rights

We are happy to support privacy rights as required in California, Colorado, Connecticut, Oregon, Texas, Utah, and Virginia.  Below you may learn more about your privacy rights, how to exercise them, and what you may expect from that process.

1. Rights

• Right to know and access personal information: You have the right to request that we disclose: (1) the categories of personal information we have collected about you; (2) the sources from which we collected the personal information; (3) the business or commercial purpose for the collection, selling or sharing of personal information; (4) the categories of third parties to whom we disclose personal information; (5) the categories of personal information that we sold or disclosed for a business purpose; and (6) the specific pieces of personal information we have collected about you. 
• Right to opt-out: You have the right to opt out of the sale or sharing of your personal information, the use of your personal information for targeted advertising, and the use of your personal information for profiling.  If you use an opt-out preference signal following the global privacy control (GPC) specification, we will process your opt-out preference in a frictionless manner at the device level using our cookie compliance tool.  You can set your browser to send these signals, but the specific settings that need to be configured depend on the specific browser you use.  Some browsers may require a browser extension.  To learn more about the GPC and browsers which support it, visit the global privacy control website.  If you have questions about opting out or need a different way to opt-out, please contact us through our online form, at privacy@torc.ai, or at 1-800-530-9285.
• Right to correct: If you find that we have inaccurate personal information about you, you have the right to request that we correct that inaccurate personal information, taking into account the nature of the personal information and the purposes of processing the personal information. 
• Right to delete: You have the right to request that we delete your personal information.  There are some exceptions to this right. 
• Right of data portability: You have the right to obtain a copy of your personal data in a portable and readily usable format that allows you to transmit the data to another controller without impediment. There are some limits to this right.
• Right to non-discrimination or retaliation: We will not discriminate or retaliate against you for exercising your privacy rights.

1. Exercising Your Rights

If you wish to exercise your privacy rights or have any questions or concerns about our privacy policies and information practices, please contact us through our online form, at privacy@torc.ai, or at 1-800-530-9285.  To verify your request, you may need to provide proof of identity, such as non-personal information about your account.  You may also designate an authorized agent to make a request.  The agent will follow the same procedures described above.  If you use an authorized agent, we may require proof that the agent acts on your behalf. 

If we decline your request, partially or fully, you may appeal the decision to our senior management.  Simply follow the same process for submitting a request and include “appeal” in the title or other part of the request.  If that appeal is denied, you may be able to contact your attorney general’s office, depending on the state in which you reside, to submit a complaint.

Torc does not use or disclose sensitive personal information for any purposes that would require a user to exercise a right to limit according to California law.

8.   European Union Residents

For the purposes of EU privacy laws, Torc is a data controller.  Here is our contact information:

privacy@torc.ai

Our lawful basis for collecting and processing personal data:

• In most cases, the lawful basis is your consent. You directly provide most of the personal information we have about you, and you can request to have it erased (i.e., withdraw your consent) at any time.
• We collect personal information from applicants and employees to meet requirements of the employment contract.
• We collect contact information for individuals employed by our customers, suppliers, and other entities to meet our legitimate interest in enabling business communication.
• We collect network and IT information to meet our legitimate interest in protecting our systems and data.

You have the following Rights, in addition to those listed above:

• Right to Know (Consent) – You have the right to ask about the possibility of not giving consent and about the consequences of the refusal.
• Right to Withdraw Consent – You have the right to withdraw consent to the processing of your personal data.
• Right to restriction of processing – You have the right to have us restrict processing of your personal data provided that one of the following conditions is met:
  • You dispute the accuracy of your data (restriction can be made for the duration of the review on our side)
  • In the event of unlawful processing and if the data is not to be deleted, restriction of processing shall take the place of deletion
  • If the processing purposes cease to apply, at the same time you need your data for the assertion, exercise or defense of legal claims
  • After you have lodged an objection pursuant to Art. 21 (1) GDPR and for the duration of the examination as to whether our legitimate interests outweigh yours.
• Right to object – You have the right to object to data processing at any time (with effect for the future) if we collect and process personal data from you on the basis of our legitimate interests.
• Right to Lodge a Complaint – You have the right to contact the relevant data protection authority or other regulator with your concerns.

In the context of personal information, Torc does not use automated decision-making.

Torc is based in the United States and may transfer your personal information between Torc legal entities or to our outsourced service suppliers located in countries outside your own.  Torc has put in place standard contractual clauses between these companies to protect your personal data.

9. Updates to the Privacy Statement

We may update this Statement from time to time to address changes in our practices, and as technologies and laws change.  If we make changes to this Statement, we will post an updated version with a revised “Last Updated” date at the top.

10. Contact Us

If you have comments, questions, or concerns about this Privacy Statement or about Torc’s collection, use, or disclosure of your personal information, or if you would like to make a request to review or update your personal information, please contact us using one of the following methods:

Email: privacy@torc.ai

Phone: 1-800-530-9285

Mailing Address:

Attn: Privacy Officer

Torc Robotics, Inc.

405 Partnership Drive

Blacksburg, VA 24060

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Effective Date: 01-Jul-2024
Last Updated: 29-Aug-2024

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