PRIVACY POLICY

1: Our Approach to Privacy

TORC (“we“, “our“, or “us“) is committed to protecting your privacy. This privacy policy sets out how we collect, store, process, transfer, share and use data that identifies or is associated with you (“personal information“) and information regarding our use of cookies and similar technologies.

Before accessing or using our website, please ensure that you have read and understood our collection, storage, use and disclosure of your personal information as described in this privacy policy. By accessing or using our website, you are accepting and consenting to the practices described in this privacy policy.

2: Personal Information we collect about you and how we use it

We collect personal information about you when you voluntarily submit information directly to us by filling in forms on our website or by corresponding with us by phone, email or otherwise. Generally, this information is only necessary when you are submitting a request for product support, product information, or when asking a general question. Personal information collected by TORC is most often limited to your name, email address, and location. Additional information is sometimes necessary to provide you with additional services. Please note, that if you choose not to provide personal information, we will not be able to respond to your requests.

The following table sets out the categories of personal information you provide to us and that we receive from other sources and how we use that information. The table also lists the legal basis which we rely on to process the personal information and information as to how we determine applicable retention periods.

Category of personal information How we use it Legal basis for the processing

Contact information and basic personal details. Such as your name, phone number, address, location, IP address, and e-mail address

We use this information to communicate with you.

We use this information to deal with enquiries and other requests made by you, including product support issues, relating to TORC products.

The processing is necessary for our legitimate interests, namely for communicating with you effectively and responding to your queries.

The processing is necessary for the performance of a contract and to take steps prior to entering into a contract.

Correspondence and comments. When you contact us directly, e.g. by email, phone, mail, or when you interact with customer service, we will record your comments and opinions.

To address your questions, issues and concerns and resolve your customer service issues.

The processing is necessary for our legitimate interests, namely communicating with you effectively for the purposes of resolving your issues.

Payment information.
Details such as your credit card or other payment information.

We use this information to facilitate payment for TORC products.

The processing for facilitating payment is necessary for the performance of our contract with you.
The processing is necessary for our legitimate interests, namely the detection and prevention of fraud.

All personal information set out above.

We will use all the personal information we collect to operate, maintain and provide to you excellent customer service, to monitor and improve our website and business, for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes, to keep the website safe and secure and to help us develop new products and services.

The processing is necessary for our legitimate interest, namely to administer and improve our business and develop new customers.

 

Please note that we may link or combine the personal information we collect and/or receive about you and the information we collect automatically. This allows us to provide you with a personalized experience regardless of how you interact with us.

We may also anonymize and aggregate any of the personal information we collect (so that it does not identify you). We may use anonymized information for purposes that include testing our IT systems, research, data analysis, improving our service and developing new website features.

3: Disclosure of your Personal Information

We will not share your personal information with any third parties except as described in this privacy policy or in connection with the website. We may share your information with selected third parties, including:

  • Business partners, distributors, suppliers and subcontractors who perform services on our behalf (these companies are authorized to use your personal information only as necessary to provide these services to us);
  • Analytics and search engine providers that assist us in the improvement and optimization of our Website;
  • Payment processors for the purpose of fulfilling relevant payment transactions;
  • Third parties in connection with a business transaction. Personal information may be disclosed to third parties in connection with a transaction, such as a merger, sale of assets or shares, reorganization, financing, change of control or acquisition of all or a portion of our business. If we are involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via email and/or a prominent notice on our Website of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.

In certain situations, we may be required to disclose personal information in response to lawful requests by public authorities, including to meet law enforcement requirements. If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce our terms and conditions of service and other agreements; or to protect the rights, property, or safety of TORC, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

4: Marketing and Advertising

From time to time we may contact you with relevant information about our products and services. Most messages will be sent electronically. For some messages, we may use personal information we collect about you to help us determine the most relevant information to share with you.

If you do not want to receive such messages from us, you will be able to tell us by replying to the email or by following the unsubscribe link at the bottom of our emails.

5: Storing and Transferring Your Personal Information

A: Security.  All information you provide to us is stored on secure servers in a controlled environment with limited access.  Internally, your information is stored on TORC’s password-controlled remote server with guarded user access.

While no transmission of information via the internet is completely secure, we take reasonable measures to protect your personal information. We cannot guarantee the security of your personal information transmitted to our Website; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access.

B: International Transfers of Personal Information. The personal information we collect may be transferred to and stored in countries outside of the jurisdiction you are in, where we have operations. If you are located in the European Union (“EU“), your personal information will be processed outside of the EU, in most instances in the United States; these international transfers of your personal information are made pursuant to appropriate safeguards, such as standard data protection clauses adopted by the European Commission. If you wish to inquire further about these safeguards used, please contact us using the details set out at the end of this privacy policy.

6: Retaining your information

We will only retain your personal information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of our legitimate business interests and satisfying any legal or reporting requirements.

To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and the applicable legal requirements.

7: Your rights in respect of your Personal Information

In accordance with applicable privacy law, you have the following rights in respect of your personal information that we hold:

  • Right of access and transferability. The right to obtain access to your personal information along with certain information, and to receive that personal information in a commonly used format and to have it transported to another data controller.
  • Right to rectification. The right to obtain rectification of your personal information without undue delay where that personal information is inaccurate or incomplete.
  • Right to delete. The right to have your personal information deleted without undue delay in certain circumstances, such as where the personal information is no longer necessary in relation to the purposes for which it was collected or processed.
  • Right to restriction. The right to obtain the restriction of the processing undertaken by us on your personal information in certain circumstances, such as where the accuracy of the personal information is contested by you, for a period enabling us to verify the accuracy of that personal information.
  • Right to object. The right to object, on grounds relating to your particular situation, to the processing of your personal information, and to object to processing of your personal information for direct marketing purposes, to the extent it is related to such direct marketing.

If you wish to exercise one of these rights, please contact us using the contact details at the end of this privacy policy. Upon request, we will provide you with information about whether we hold any of your personal information. You may access, correct or request deletion of your personal information by contacting our Data Protection Officer, on the details outlined below. We will respond to your request within 30 days.

If you reside in the European Union (EU), TORC is the controller of your personal information for purposes of European data protection legislation. You also have the right to lodge a complaint to your local data protection authority. Information about how to contact your local data protection authority is available at ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

8: Cookies and Similar Technologies

Our website uses cookies and similar technologies (collectively referred to as cookies) to distinguish you from other users of our website. This helps us to provide you with a good service. This helps us enhance and personalize your user experience, to monitor and improve our website and services, and for other internal purposes. As is true of most websites, we gather certain information automatically.

We use the following types of cookies:

  • Strictly necessary cookies. These cookies are required for the essential operation of our website such as to authenticate you and prevent fraudulent use.
  • Analytical/performance cookies. These cookies allow us to recognize and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that you can find information easily.
  • Functionality cookies. These cookies are used to recognize you when you return to our website. This enables us to personalize our content for you and remember your preferences (for example, your choice of language or region).
  • Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it, if any, more relevant to your interests. We may also share this information with third parties for this purpose.

Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.

We partner with a third party to either display advertising on our website or to manage our advertising on other sites. Our third-party partner may use technologies such as cookies to gather information about your activities on this website and other sites in order to provide you advertising based upon your browsing activities and interests. If you wish to not have this information used to serve you interest-based ads, please contact us on the contact details set out below. Please note this does not opt you out of being served ads. You will continue to receive generic ads.

You block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including strictly necessary cookies) you may not be able to access all or parts of our website.

Social Media. Our website includes social media features. These features may collect your IP address, which page you are visiting on our website, and may set a cookie to enable the feature to function properly. Social media features and widgets are hosted on our site or by a third party, and your interactions with these features are governed by the privacy policy of the company providing it.

9: Links to Third Party Sites

The Website contains hyperlinks to websites operated by third parties. The hyperlinks are provided for the benefit of the users of the Website. A hyperlink to a third party website does not imply that TORC endorses the content on or the business activity of the hyperlinked website. User is solely responsible for determining the integrity and reliability of the information on the hyperlinked website.  If you follow a link to any of these websites, we recommend that you check the individual policies before you submit any information to those websites.

10: Our Policy Towards Children

The Website is not directed at persons under 16 and we do not intend to collect personal information from children under 16 in our capacity as a processor. If you become aware that a child has provided us with personal information without appropriate consent, then please contact us using the details below so that we can take the appropriate steps in accordance with our legal obligations and this privacy policy.

11: Changes to this Policy

We may update this privacy policy from time to time and so you should review this page periodically. When we change this privacy policy in a material way, we will update the “last modified” date at the end of this privacy policy. Changes to this privacy policy are effective when they are posted on this page.

12: Notice to you

If we need to provide you with information about something, whether for legal, marketing or other business related purposes, we will select what we believe is the best way to get in contact with you. We will usually do this through email or by placing a notice on our website. The fact that we may send notices to you will not stop you from being able to opt out of certain types of contact as described in this privacy policy.

13: Contacting Us

Any questions, comments and requests regarding this privacy policy are welcome and should be addressed to press@torc.ai. Communication can also be addressed to:

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

This privacy policy was last modified on May 7, 2019.

Jim DudleyPrivacy