Privacy Policy

Torc Robotics, Inc. and its affiliates (“Torc,” “we, “us”) appreciates your interest in its products and services and your visit to its internet site torc.ai and other Torc sites that link to this Privacy Statement (the “Site”). Your privacy is important to us and we want you to feel comfortable visiting our Site and using our products and services. Protecting your privacy in the processing of your personal data is an important concern to which we pay special attention. This online privacy statement (“Privacy Statement”) tells you about the information that Torc may collect from you through the Site and through your use of our products and services, how we use that information, and how you can opt out of certain uses of information we may collect. Please read this Privacy Statement carefully to understand our policies and practices regarding your information and how we treat it. If you do not agree with our policies and practices, your choice is not to use our Site, our products or our services. By using our services and accessing our Site, you are consenting to the information collection and use practices described in this Privacy Statement, as modified from time to time by us. If we decide to change this Privacy Statement, we will post a new Privacy Statement on our Site and change the date at the top of the page. Therefore, we encourage you to check the date of our Privacy Statement whenever you visit this Site for any updates or changes. Your continued use of this Site, our products and services after we make changes is deemed acceptance of those changes. Our Privacy Statement complies with the Daimler AG Data Protection Code of Conduct applicable company-wide for Daimler AG. Our Site may include, however, links to other websites which are not covered by this Privacy Statement. These sites have their own privacy and information security policies and terms and conditions. Please review the privacy policy and terms and conditions sections of such websites for additional details.

Torc Services

If you are a customer utilizing Torc’s services, you may load electronic data into these services and Torc may upload data collected from your vehicle for your use through the services (“Customer Data”). Torc will not share or distribute any Customer Data except as provided for in the agreement between Torc and the customer, or as required by applicable law. The use of information collected through Torc services is limited to the purpose of providing the service requested by the customer, including the improvement of services and products, and the development of new services and products. Torc may use, access, and process information in order to provide the service, respond to support requests, prevent or address technical issues, carry out customer instructions, or comply with applicable law, in accordance with the relevant agreement between customer and Torc.

Torc processes Customer Data under the direction of its Customers, and Torc has no direct control or ownership of personal data provided by Customers. Customers are responsible for complying with any laws and regulations that require obtaining consent or providing notice and disclosure before sharing any data with Torc.

If you are a user of any services provided by Torc on behalf of a Customer, your use of the services is governed by the rules and policies set by your organization. Please direct your concerns or privacy related questions to your employer. Torc will forward all requests for the disclosure of personal information made by law enforcement or government officials to its customers unless otherwise required by law.

Torc’s Use and Collection of Information

Information That We Collect
Some features of the Site and service may ask you to provide us with specific categories of information in order to enjoy complete functionality. If you do not provide us with the categories of information requested, your ability to fully interact with the Site and services may be limited. Please note that there may be other uses, which we would describe to you when we collect that information.

Torc uses the information we collect about you to provide you with services, and support. For example, if you provide information to us in a “Contact Us” form, we will use your information to respond to the request and communicate with you. Torc may use the contact information we collect from you and information about your activity on our Site to send you information that we believe may be of interest to you, such as product announcements, newsletters, educational materials, details on upcoming events and other marketing communications. We also use it to send administrative information, such as notices related to products, services, or policy changes.

We use certain third-party web analytics services, such as Google Analytics, to help understand how our Site and services are being used and to make improvements. Your information also may be used to personalize your experience on our Site.

Torc or our service providers use website tracking technologies to display products or features that are tailored to your interests. For more information on managing your choices in relation to cookies, you may visit the Cookies section of this Privacy Statement.

We may use your information to diagnose technical problems with our Site, as well as to prevent, detect, mitigate, and investigate potential security issues, as well as fraudulent or illegal activity.

In some instances, we may combine the information you have provided to us with other publicly available information. We may also purchase data from third parties and combine this with information we have already collected. We use this combined information to update, expand, and analyze our marketing leads; identify new customers; and create more tailored advertising.

Your web browser may have settings that allow you to transmit a “Do Not Track” signal when you visit various websites or use online services. Similar to other websites, our Site is not designed to respond to “Do Not Track” signals received from browsers.

Torc will retain your personal information only as long as needed to provide you with the services or as necessary to comply with legal obligations, enforce agreements, or to resolve disputes. Data collected pursuant to a service is retained in accordance with the terms of the agreement for that service.

Some specific features that require you to provide information to Torc are described in detail below:

Surveys

You may be asked to participate in surveys about your experience with the Torc Site. When participating in surveys, any information you provide in the comments field will be shared with us, so please do not include any sensitive personal information or other information you do not wish to share.

Account Registration

When you register for an account with our Site or services, you must provide your name and email address. You also have the option to allow Torc to contact you with information about products or services that may be of interest to you. Once your account is established, you have the option to provide us with additional information such as your address and phone number. You will also have the ability to save vehicle configurations and fleet information in your account. We store that information for as long as your account is active. You may modify your accounts at any time by visiting the “Profile” settings and making changes to individual fields.

Information Collected From Third Parties

We also obtain information about the traffic and usage of the Site and services from third parties such as Google. These third parties also use cookies and other tracking technologies to capture information about your interactions with the Site and Torc services. Torc does not have control over the information that is collected, used, and shared by these third parties, though Torc may combine this information with information you provide to us. We encourage you to review the privacy statements of these third parties to understand their privacy practices.

Information Sharing

Torc may share information with its affiliates, and third-party service providers or vendors that Torc contracts with to provide services on your behalf. These third-party service providers and vendors may use information we provide them only as instructed by Torc.

Aside from the instances described above, we will only share your personal information: to comply with the law; to respond to claims; to comply with legal process served on Torc, its subsidiaries, or our parent company Daimler AG (e.g., a lawful subpoena, warrant, or court order); to enforce or apply our policies or agreements; (including to bill and collect payments); to protect and defend our rights or property or that of our dealers, customers, employees, visitors, or the public; in connection with a business transfer, sale, liquidation, or merger; and if we reasonably believe that an emergency involving immediate danger of death or serious physical injury to any person requires disclosure; with your consent.

Children’s Online Privacy Protection Act (COPPA)

The Site and services are neither designed for nor targeted to children under the age of 13. If you are under the age of 13, do not provide your personal information through the Site or services. If you believe your child has impermissibly provided us with their personal information, please contact us, so that we can identify and delete their information.

Security

We use commercially reasonable administrative, technical, and physical safeguards to protect personal information collected through the Site and Services.

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: info2@torc.ai

Phone: 1 800 530-9285

Mailing Address:

Attn: Privacy Officer

Torc Robotics, Inc.
405 Partnership Drive
Blacksburg, VA 24060

Updates

Torc may update or change this Privacy Statement from time to time and without prior notice to you. The top of this Privacy Statement will indicate when it was most recently updated.

Links to Other Websites

Please be aware that we provide links to third-party sites as a service to our visitors, and that we are not responsible for the content or information collection practices of those sites. We encourage you to review and understand their privacy practices before providing them with information.

Privacy Statement Revisions

A revised Privacy Statement will only apply to data collected subsequent to its effective date on this version of our website. Any revisions will be posted at least seven days prior to its effective date.

Use of Non-Personal and Aggregate Information

We may use non-personal and aggregate information to better design our Site and share with our marketing and advertising agencies.

Tracking Technologies

The Site uses cookies to personalize and control access to content, to provide social media features and to analyze our website traffic. Cookies are small text files that can be used by websites to make a user’s experience more efficient. We also share information about your use of our site with our social media and analytics partners who may combine it with other information that you’ve provided to them or that they’ve collected from your use of their services. You consent to our cookies if you continue to use our Site.

The law states that we can store cookies on your device if they are strictly necessary for the operation of this site. For all other types of cookies we need your permission.

The Torc Site uses different types of cookies. Some cookies are placed by third party services that appear on our pages.

CALIFORNIA SUPPLEMENT TO PRIVACY STATEMENT (CALIFORNIA RESIDENTS)

This California Supplement to the Privacy Statement supplements the information contained in the Privacy Statement above and applies solely to all visitors, users, and others who reside in the State of California (”consumers” or “you”). Torc has adopted this notice to comply with the California Consumer Privacy Act of 2018 (CCPA). Any terms defined in the CCPA have the same meaning as in the CCPA when used in this notice.

Information Torc Collects

As more fully explained in the Privacy Statement above, this Site collects information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (”personal information”). In particular, the Site has collected the following categories of personal information from its users within the last twelve (12) months:

Category A: Identifiers

Examples: A real name, Internet Protocol address, email address, or other similar identifiers.

Collected: YES

Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).

Examples: A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.

Collected: YES

Examples: Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).

Collected: NO

Personal information does not include:

  • Publicly available information from government records.
  • De-identified or aggregated consumer information.
  • Information excluded from the CCPA’s scope, such as:
    • health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
    • personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

Torc collects the categories of personal information listed above from the following types of sources:

  • Directly from you. For example, from forms you complete on the Site.
  • Indirectly from you. For example, through your employer, dealerships and fleet managers who provide Torc with your information so that we may provide products and services, or from observing your actions on the Site, or your interactions with advertisers.

Use of Personal Information

Torc may use, or disclose the personal information it collects for one or more of the following business purposes:

  • To fulfill or meet the reason your information was provided to Torc. For example, if you share your name and contact information to request a price quote or ask a question about our products or services, Torc or the third party vendors with which it contracts will use that personal information to respond to your inquiry. If you provide your personal information to purchase a product or service, Torc, through the third-party payment service with which it contracts, will use that information to process your payment and facilitate delivery. Torc may also save your information to facilitate new product orders or process returns.
  • To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve Torc’s responses.
  • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
  • As described to you when collecting your personal information or as otherwise set forth in the CCPA.
  • Torc will not collect additional categories of personal information or use the personal information Torc has collected for materially different, unrelated, or incompatible purposes without providing you notice. Such notice may be provided by changes to this privacy statement.

Sharing Personal Information

Torc may disclose your personal information to a third party for a business purpose. When Torc discloses personal information for a business purpose, Torc enters a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

Torc shares your personal information with the following categories of third parties: payment processing companies, third party service providers necessary for providing services requested by you, and companies that manage Torc’s purchase order website and Torc brand sites.

Disclosures of Personal Information for a Business Purpose

In the preceding twelve (12) months, Torc has disclosed personal information for the purpose of managing its Site.

Torc does not sell personal information.

Your Rights and Choices

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights

You have the right to request that Torc disclose certain information to you about its collection and use of your personal information over the past 12 months. Once Torc receives and confirms your verifiable consumer request, Torc will disclose to you:

  • The categories of personal information Torc collected about you.
  • The categories of sources for the personal information Torc collected about you.
  • Torc’s business or commercial purpose for collecting personal information.
  • The categories of third parties with whom Torc shares personal information.
  • The specific pieces of personal information Torc collected about you (also called a data portability request).
  • If Torc disclosed your personal information for a business purpose, Torc will also disclose:
    • for disclosures for a business purpose: a list identifying the personal information categories that each category of recipient obtained.

Deletion Request Rights

You have the right to request that Torc delete any of your personal information that Torc has collected and retained, subject to certain exceptions. Once Torc receives and confirms your verifiable consumer request, Torc will delete (and direct our service providers to delete) your personal information from its records, unless an exception applies.

Torc may deny your deletion request if retaining the information is necessary for Torc or its service provider(s) to:

  • Complete the transaction for which Torc or its service providers collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of Torc’s ongoing business relationship with you, or otherwise perform Torc’s contract with you.
  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
  • Debug products to identify and repair errors that impair existing intended functionality.
  • Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
  • Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
  • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
  • Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with Torc.
  • Comply with a legal obligation.
  • Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by sending us a message on the Site. Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

  • Provide sufficient information that allows Torc to reasonably verify you are the person about whom Torc collected personal information or an authorized representative.
  • Describe your request with sufficient detail to allow Torc to properly understand, evaluate, and respond to it.

Torc cannot respond to your request or provide you with personal information if Torc cannot verify your identity or authority to make the request and confirm that the personal information relates to you. Torc will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Response Timing and Format

Torc makes reasonable efforts to respond to a verifiable consumer request within forty-five (45) days of its receipt. If Torc require more time (up to ninety (90) days), Torc will inform you of the reason and extension period in writing. Torc will deliver its written response by mail or electronically, at your option. Any disclosures Torc provides will only cover the 12-month period preceding the verifiable consumer request’s receipt. Torc’s response will also explain the reasons Torc cannot comply with a request, if applicable. For data portability requests, Torc will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance, specifically by electronic mail communication.

Torc does not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If Torc determines that the request warrants a fee, Torc will tell you why it made that decision and provide you with a cost estimate before completing your request.

Non-Discrimination

Torc will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, Torc will not:

  • Deny you goods or services, unless the deletion of your personal information prevents Torc from providing such goods or performing such 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, unless the deletion of your personal information prevents Torc from providing you with the same level or quality of goods or services as it does for customers whose personal information has not been deleted.
  • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services, unless the deletion of your personal information would prevent Torc from providing you with the same level or quality of goods or services as it does for customers whose personal information has not been deleted.
    However, Torc may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive Torc offers will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.

Changes to Torc’s California Privacy Notice

Torc reserves the right to amend this privacy notice at its discretion and at any time. When Torc makes changes to this privacy notice, it will post the updated notice on the Site and update the notice’s effective date. Your continued use of the Site following the posting of changes constitutes your acceptance of such changes.

Contact Information

If you have any questions or comments about this Privacy Statement, the ways in which Torc collects and uses your information, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact Torc as follows

Via the Site: please send Torc an electronic message through the Site.

Write us at:

Attn: Privacy Officer

Torc Robotics, Inc.
405 Partnership Drive
Blacksburg, VA 24060