C60 Privacy Policy

Last updated December 16, 2022

This Privacy Policy (“Policy”) sets out how Volt RMC Solutions, Inc. and its affiliates (collectively, “C60”, “we”, “us”, or “our”) collects, uses and discloses information related to users of our Site (defined below), as well as any associated content, features, functionality, offers, material, or services made available through the Site (collectively, the “Services”). If you do not agree with this Policy, please do not use the Services or provide us with any Personal Information (as defined below). This Policy does not apply to (1) websites, software applications, and other online properties and services that do not link to this Policy; or (2) any other collection, use or disclosure of data other than via the Services. Specifically, this Policy does not apply to information collected by any third-party, including through any application or content (including advertising) that may link to or be accessible from or through the Site. If you have questions regarding this Policy, please contact Volt RMC Solutions via our contact page.

CHANGES TO THIS POLICY

Volt RMC Solutions may modify this Policy at any time, without prior notice, and changes may apply to any Personal Information we already hold about you, as well as any new Personal Information collected after the Policy is modified. We will notify you of any changes by posting the revised Policy on this page. We will notify you via email in case of major changes and/or prominent notice on our Website (defined below) prior to any significant changes becoming effective and will revise the date at the top of this Policy. If you continue to access or use our Services after being provided with the notice of changes, you acknowledge your acceptance of the updated Policy. You are advised to review this Policy from time to time for any changes. Changes to this Policy are effective when they are posted on this page.

PERSONAL INFORMATION

For purposes of this Policy, unless otherwise required by applicable law, “Personal Information” means any information that identifies, relates to, describes, or is reasonably capable of being associated, linked or linkable with a particular individual or household, including any information that is subject to applicable data protection laws.

Individual Rights. Please see the Your Data Rights section below for a description of the choices we provide and the rights you have regarding your Personal Information. If you are a California, Colorado, Connecticut, Nevada, Utah, or Virginia resident, please also review the United States Residents section below for information about the categories of Personal Information we collect and disclose and your rights under your state’s privacy laws.

Scope. This Policy applies to our collection, use, and disclosure of Personal Information related to:

• Users of our website https://c60.ai/ (“Website”), as well as other websites, and online services that display or link to this Policy; and
• Individuals who otherwise interact or communicate with us related to our Services.

COLLECTION OF PERSONAL INFORMATION

The Personal Information we collect varies depending upon the nature of the Services provided or used and our interactions with individuals.

Categories of Personal Information. While the Personal Information we collect varies depending upon the circumstances, we may collect the following categories of Personal Information (subject to applicable legal requirements and restrictions):

• Name, Contact Information, and other Identifiers: identifiers such as name, email address, and online identifier.
• Professional or Employment-related Information: work email address and company name.
• Device Information: internet protocol (IP) address, web browser type, operating system version, phone carrier and manufacturer, application installations, device identifiers, mobile advertising identifiers, and push notification tokens.
• Communications: direct communication, web forms, or interactions with our posts.
• Usage Data: internet or other electronic network activity information including, but not limited to, browsing history, search history, and information regarding interactions with an Internet website, application, or advertisement.
• Profiles and Inferences: inferences drawn from any of the information identified above to create a profile reflecting preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, or aptitudes.

Sources of Personal Information. We may collect Personal Information:

• Directly from You: such as when you book or request a demo with us, register to receive marketing and other communications from us or contact us for support purposes.
• From Third Parties: such as public records, third-party providers of services to us, consumer data resellers, social networks, joint marketing partners and affiliate companies.
• Related to Your use of Our Services: including information we collect when you use our Website, or interact with us, or information we derive about you and your preferences or interests based on the Personal Information we collect and our interactions with you.

Information We Collect from You. We may collect Personal Information from you related to:

• Registration, accounts and profiles: when you book or request a demo with us, we collect your name and work email, phone number, and company name; we may also collect additional information you may provide such as your preferences, location, and Microsoft Teams account information as well as any comments you make on our Website.
• Marketing and Surveys: if you sign up to receive news, updates, offers and other marketing communications from us, we may collect your name and email address. We may also collect your name, email address, and other information when you submit surveys or feedback to us.
• Your Communications and Requests: when you email us, call us, or otherwise send us communications, we collect and maintain a record of your contact details, communications and our responses.

Information We Collect or Derive About You Automatically. We may collect or derive Personal Information about your use of our Website or other interactions with us:

• Website: We and our third-party providers may use cookies, pixels, tags, log-files, and other technologies to collect information about a user from their browser or device, including, without limitation, your browser type, device type, operating system, software version, phone model, phone operating system, platform-dependent information, requested document, referring URL, date and time of your visit, clickstream data (e.g. about the pages you view, links you click and date and time stamps for your activities on our Website) and the IP address associated with your transactions in the system. This information that we collect automatically may be linked with other Personal Information we have collected. For more information, see the Cookies and Tracking section below.
• Information Collected by Cookies and Other Tracking Technologies: we use various technologies to collect information, including cookies. Cookies are small data files stored on your hard drive or in device memory that help us improve our Services and your experience, see which areas and features of our Services are popular and count visits. For more information about cookies, and how to disable them, please see the Cookies and Analytics Section below.

USE OF PERSONAL INFORMATION

We may use Personal Information for a variety of purposes, including, without limitation:

• Providing Support and Services: including to operate our Website and online services; respond to your inquiries; and for other support purposes.
• Analyzing and Improving Our Business: including to better understand how users access and use our Services and Website, to evaluate and improve our Website, Services and business operations; ; to monitor interest in our Services; to troubleshoot problems that may arise on the Website; to increase our understanding of our user database; to increase our understanding of our users; and for other research and analytical purposes.
• Personalizing Content and Experiences: including to tailor content we send or display on our Website. To assist in this purpose, as well as the other purposes identified in this Policy, at certain times, we create a profile relating to you in order to show you the content that we think you might be interested in and to display the content according to your preferences.
• Advertising, Marketing and Promotional Purposes: including to reach you with more relevant ads and to evaluate, measure and improve the effectiveness of our ad campaigns; to send you newsletters, offers or other information we think may interest you; to contact you about our Services or other information we think may interest you; to identify potential new users; and to administer promotions, sweepstakes, contests or other events.
• Securing and Protecting Our Business: including to protect and secure our business operations, assets, Services, network and information and technology resources; to investigate, prevent, detect and take action regarding fraud, unauthorized access, situations involving potential threats to the rights or safety of any person or third party, or other unauthorized activities or misconduct.
• Defending Our Legal Rights: including to manage and respond to actual and potential legal disputes and claims, and to otherwise establish, defend or protect our rights or interests, including in the context of anticipated or actual litigation with third parties.
• Auditing, Reporting, Corporate Governance, and Internal Operations: including relating to financial, tax and accounting audits; audits and assessments of our operations, privacy, security and financial controls, risk, and compliance with legal obligations; our general business, accounting, record keeping and legal functions; and related to any actual or contemplated merger, acquisition, asset sale or transfer, financing, bankruptcy or restructuring of all or part of our business.
• Complying with Legal Obligations: including to comply with the law, our legal obligations and legal process, such as warrants, subpoenas, court orders, and regulatory or law enforcement requests.
• For Our Legitimate Business Interests: including where the interest of our business in conducting and managing our business to enable us to give you the best service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your Personal Information for our legitimate interests. We do not use your Personal Information for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
• To Perform any Contracts in Place between Us and You: where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

We may Combine Information from Different Sources. For example, we may combine information that we have collected offline with information we collect online, or we may combine information we get from a third-party with information we already have.

If you submit any Personal Information relating to other people to us, you represent that you have the authority to do so and have informed that other person about the contents of this Policy.

DISCLOSURE OF PERSONAL INFORMATION

We may share or disclosure the Personal Information we collect as follows:

• Service Providers: We may disclose Personal Information with third-party service providers who use this information to perform services for us, such as hosting providers, auditors, advisors, consultants, customer service and/or support providers..
• Advertising and Marketing Partners: We may share Personal Information with third parties that provide advertising, campaign measurement, online and/or mobile analytics, and related services. These third parties may receive or access browsing and/or other data about your use of the Services, in order to help us better reach individuals with relevant ads and/or measure our ad campaigns, and/or to better understand how individuals interact with our Website and Services overtime and across devices.
• Subsidiaries and Affiliates: We may share your Personal Information with our affiliated companies (i.e., our parent company and other companies under common ownership, control or management with us); they may use such Personal Information for the purposes set out in this Policy.
• Legal Compliance: We may be required to share Personal Information in response to a valid court order, subpoena, government investigation, or as otherwise required by law. We also reserve the right to report to law enforcement agencies any activities that we, in good faith, believe to be unlawful. In addition, we may share certain Personal Information when we believe that doing so is reasonably necessary to protect the rights, property and safety of our company and/or others.
• Business Transfers: We may disclose and/or transfer Personal Information as part of any actual or contemplated merger, sale, transfer of assets, acquisition, financing and/or restructuring of all or part of our business, bankruptcy or similar event, including related to due diligence conducted prior to such event where permitted by law.
• Protect our Rights: We may disclose Personal Information where we believe it necessary to respond to claims asserted against us, to enforce or administer our agreements and terms, for fraud prevention, risk assessment, investigation and/or to protect the rights, property or safety of Volt RMC Solutions or our affiliates, clients, users and/or others.
• Your Consent: we may disclose Personal Information with your consent.

Aggregate and De-Identified Data. We may share aggregate or de-identified information with third-parties for research, marketing, advertising, analytics and/or other purposes.

COOKIES AND ANALYTICS

We use cookies, pixels, tags, and other technologies, which may be provided by third parties, on our Website to enable certain functionality and for security and fraud detection and prevention, as well as to collect usage information about our Website and the emails that we send and to personalize content and provide more relevant ads and information. We may combine the information we collect via these technologies with other information, including Personal Information.

Cookies. By placing a small file known as a “cookie” on your device, our and our third party providers’ servers passively gather information about all visitor’s use of the Website for the following purposes: statistics collection and analysis, system optimization, analytics (as described below), market research, and maintenance of user login information. The information that we and our third-party providers track with cookies includes, but is not limited to, the type of browser (such as Google Chrome or Internet Explorer) and Internet-connected devices being used to access the Website, your Internet protocol (“IP”) address, your home domain or Internet service provider, your referrer URL (which is the URL for the website that you were viewing prior to visiting the Website), how you were directed to the Website, which specific pages you access on the Website, how long you view each page, the time and date you access our Services and the total number of visitors to the Services and any portions thereof. We, and/or our third-party providers, may use the information collected from cookies or similar files on your computer for security purposes (such as authentication), to facilitate site navigation and to personalize your experience while utilizing the Services. This data helps us and our third-party providers improve our respective product and services. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us. Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove or reject browser cookies. Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of our Services. For more information, please refer to http://www.allaboutcookies.org/manage-cookies/.

• Types of Cookies. Our Website uses three kinds of cookies: Strictly Necessary cookies, Functionality cookies and Analytical cookies.
  • Strictly Necessary Cookies. Strictly Necessary cookies allow us to offer you the best possible experience when accessing and navigating through our Website and using its features. These are essential to enable you to move around our Website and to allow the features of the site to work correctly. Without these, services you request—such as navigating between pages—cannot be provided.
  • Functionality Cookies. Functionality cookies record information about choices you have made and allow us to remember your preferences. If you are known to us and we hold your details, we may use this information to help us build up your profile based on your web journey, and choices.
  • Analytical Cookies. Analytical cookies enable us and third-party services to collect aggregated data for statistical purposes on how our visitors use the Website. These cookies do not contain personal information such as names and email addresses and are used to help us improve your user experience of the Website.

Log Files. Most browsers collect certain information, such as your IP address, device type, screen resolution, operating system version and internet browser type and version. This information is gathered automatically and stored in log files.

Third-Party Analytics Tools. Our Website uses automated devices and applications operated by third-parties, such as Google Analytics. Google Analytics uses cookies and similar technologies to collect and analyze information about use of the Website and report on activities and trends. This service may also collect information regarding the use of other websites, apps and online resources. You can learn about Google’s practices by going to www.google.com/policies/privacy/partners/, and you can opt out of them by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout.

Do-Not-Track Requests. Certain state laws require that we indicate whether we honor “Do Not Track” settings in your browser. We adhere to the standards set out in this Policy and do not monitor or follow any Do Not Track browser requests.

INTEREST-BASED ADVERTISING

We work with third-party ad networks, channel partners, affiliates, measurement services, analytics and others such as LinkedIn, Google, and Facebook (“Third-Party Ad Companies”) to display advertising on our Services, and to manage or measure our advertising on third-party sites, social media platforms, mobile apps and online services, as well as to send you promotional materials or offers via email or direct mail. We and these Third-Party Ad Companies may use cookies, pixels tags, and other tools to collect activity information on our Services (as well as on third-party sites and services), as well as IP address, device ID, cookie and advertising IDs, and other identifiers, general location information, and, with your consent, your device’s geolocation information; we and these Third-Party Ad Companies use this information to provide you more relevant ads and content and to evaluate the success of such ads and content.

Custom Lists and Matching. We may create and disclose hashed user list information (such as name and email address) with third parties—such as Facebook—so that we can better target ads and content to you and others with similar interests, within these third-party services. These third parties use the Personal Information we provide to help us target ads and to enforce their terms, but we do not permit them to use or share the data we submit with other third-party advertisers.

Opt out of Targeted Ads. You may control how participating Third-Party Ad Companies use the information that they collect about your visits to our Website, and those of third parties, in order to display more relevant targeted advertising to you; for more information and to opt-out go to:

• www.networkadvertising.org/optout_nonppii.asp (Network Advertising Initiative)
• www.aboutads.info/choices (Digital Advertising Alliance)

Opting out of participating ad networks does not opt you out of being served advertising. You may continue to receive generic or “contextual” ads on our Services. You may also continue to receive targeted ads on other websites, from companies that do not participate in the above programs.

CHILDREN’S PRIVACY

Our Website is not directed to children under the age of 13, and Volt RMC Solutions does not knowingly collect or maintain Personal Information online from children we actually know at the time of collection are under the age of 13. Should we discover that we have collected Personal Information online from a child who is under 13, we will promptly delete that Personal Information. If you have concerns over the collection of children’s Personal Information on the Website, please contact us at the information provided in the Contact Us section below. Although our Website is not directed to children under the age of 13, if your child uses our Services and you wish to review or delete your child’s Personal Information, you may so request by contacting us at the location or email address set forth below in the Contact Us section.

SECURITY

The security of your Personal Information is important to us. In order to prevent unauthorized access, use or disclosure, we have in place safeguards. However, we cannot guarantee that unauthorized access, hacking, data loss, or other breaches will never occur. We urge you to take steps to keep your Personal Information safe, such as choosing a strong password and logging out of your User Account and closing your web browser when finished using the Services.

EXTERNAL LINKS

The Website provides links to various websites operated by third-parties. This Policy does not apply to third-party websites that are accessible through the Volt RMC Solutions Website. When you click on one of these links, you will be transferred out of the Website and connected to the website of the organization or company that maintains that website. Even if an affiliation exists between the Website and a third-party website, we exercise no control over linked websites. Each of these linked websites maintains its own independent privacy and data collection policies and procedures. We encourage you to read the privacy policies of those other websites to learn how they collect, use, share and secure your information before providing any Personal Information.

CROSS BORDER TRANSFER

The Website is controlled and operated from the United States and is not intended to subject us to the laws or jurisdiction of any state, country, or territory other than that of the United States. If you are accessing this Website from other jurisdictions, please be advised that you are transferring your Personal Information to us in the United States where data protection and privacy laws may be less stringent than the laws of your jurisdiction.

If you are located in the EEA, UK or Switzerland, note that we may transfer your Personal Information outside this area or countries to countries that do not offer the same level of protection as required by the EEA, UK, or Switzerland. In order to safeguard your Personal Information, we will only make such transfers on the basis of: (i) an adequacy decision by the European Commission or a competent national authority, such as the UK Information Commissioner’s Office, or (ii) subject to European Commission or other competent authority issued and approved standard contractual clauses.

RETENTION

Except to the extent prohibited by law, and subject to this Policy, we will retain and use your Personal Information for as long as it is needed to provide you with any services, communications, information you have requested, or access to this Website, to document our business relationship with you, and as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

YOUR RIGHTS AND CHOICES

Depending on your jurisdiction, you may have certain rights regarding our collection, use, and sharing of your Personal Information. If you have any questions regarding your rights and/or need to update your contact details or other Personal Information provided to us, please contact us using the information provided in the Contact Us section below.

Marketing Choices. You can control your marketing preferences as set forth below:

• Email Opt Out. From time to time, we may notify you by email of special promotions, changes to the Website, new products or service offerings that we think may be of special interest to you. If you decide you no longer want to receive emails notifying you of this information, follow the instructions in the promotional message. Email Opt Out requests will be processed within ten (10) days.
• Mailing list. We may occasionally share our postal mailing list or a part of our mailing list with other organizations. If you do not want your name and address shared with other organizations, or do not wish to receive our mailings, please contact us at privacy@volt-rmc-solutions.com. Please note that requested changes to our postal mailing list may take up to eight (8) weeks to take effect.

Website Preferences. You may control how we collect and manage certain information through our Website:

• Targeted advertising. To opt-out of certain targeted advertising by participating advertisers, go to:
  • www.networkadvertising.org/optout_nonppii.asp (Network Advertising Initiative)
  • www.aboutads.info/choices (Digital Advertising Alliance)

You can also adjust your browser cookies settings to block or delete third-party cookies, as explained in the Cookies and Analytics section above. If you block cookies, certain features on our Website may not be available or function properly.

YOUR DATA RIGHTS

Depending on where you live, you may have certain rights, such as to request access to or correction of your Personal Information that we hold about you. To make a request, please contact us using the information provided in the Contact Us section below.

United States Residents. US data protection laws grant California, Colorado, Connecticut, Nevada, Utah, and Virginia residents the following data rights:

• Right to Know and to Access. You have the right to request that we disclose certain information to you about our collection and use of your personal data over the past 12 months. This information is disclosed in the “Information Collection” Section of this Privacy Policy.

You also have the right to request access to Personal Information collected about you and information regarding the source of that information, the purposes for which we collect it, and the third parties and service providers with whom we share it. You may submit such a request as described below. To protect our users Personal Information, we are required to verify your identify before we can act on your request.

• Right to Portability. You have the right to request that we provide a copy of the personal data we have collected about you, in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the data to another entity without hindrance. Once we receive your request and confirm your identity, we will provide to you a copy of your data as required under the applicable data protection laws. We may provide this data to you through your User Account with us, or via email to the email address you have provided with your request.
• Right to Delete. Subject to certain exceptions, you have the right to request that we delete any of your personal data. Once we receive your request and confirm your identity, we will review your request to see if an exception allowing us to retain the information applies. We will delete or de-identify personal data not subject to one of these exceptions from our records and will direct our service providers to take similar action.
• Right to Correct. Subject to certain exceptions, you have the right to request that we correct inaccurate personal data that we have collected about you. Once we receive your request and confirm your identity, we will review your request, taking into account the nature of the personal information and the purposes of the processing of the personal information to see if we can correct the data. We may also request additional information showing that the information you want to correct is inaccurate.
• Non-Discrimination. We will not discriminate against you for exercising any of your data privacy rights.
• Exercising Your Rights. To exercise your rights described above, please submit a request by:
  • Emailing us at privacy@volt-rmc-solutions.com

Only you, or someone legally authorized to act on your behalf, may make a request to know or delete related to your personal data. You may also make a request to know or delete on behalf of your child.

Certain data protection laws limit the ability to make a request to know to twice within a 12-month period, and allow us to charge a reasonable fee for responding to numerous requests from the same user. We cannot respond to your request or provide you with personal data if we cannot verify your identity or authority to make the request and confirm the personal data relates to you.

You do not need to create an account with us to submit a request to know or delete. However, we do consider requests made through your password protected account sufficiently verified when the request relates to personal data associated with that specific account.

We will only use personal data provided in the request to verify the requestor’s identity or authority to make it.

California Residents

• Right to Opt-Out of Closing of Sale or Sharing of Personal Information. We do not sell or share your Personal Information with third parties, as those terms are defined under the California law.
• California Shine the Light. Where applicable, California Civil Code Section 1798.83 allows California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request please contact us using the information provided in the Contact Us section below.

Colorado, Connecticut, and Virginia Residents

• Right to Opt-Out. You have the right to out of the processing of the personal data for purposes of (i) targeted advertising, (ii) the sale of personal data, or (iii) profiling in furtherance of decisions that produce legal or similarly significant effects concerning the consumer. We do not process your Personal Information for (i) targeted advertising, (ii) the sale of personal data, or (iii) profiling in furtherance of decisions that produce legal or similarly significant effects concerning the consumer.
• Right to Appeal. If you make a request to exercise any of the above data access rights and we are unable to comply with your request, you may request to appeal our decision. To appeal any data privacy request decision, please contact us by emailing privacy@volt-rmc-solutions.com with the subject line “Data Access Request Appeal.” If after you complete the appeal process with us, you are still unsatisfied with our response, you may contact your Attorney General to file a complaint. Below are the contact information for the appropriate entity where you can inquire about filing an appeal:

Colorado Residents:
Office of the Attorney General
Colorado Department of Law
Ralph L. Carr Judicial Building
1300 Broadway, 10th Floor
Denver, CO 80203
(720) 508-6000
https://coag.gov/

Nevada Residents

• If you are a resident of Nevada, you have the right to opt-out of the sale of certain Personal Information to third parties who intend to license or sell that Personal Information. You can exercise this right by contacting us at privacy@volt-rmc-solutions.com with the subject line “Nevada Do Not Sell Request” and providing us with your name and the email address associated with your account. Please note that we do not currently sell your Personal Information as sales are defined in Nevada Revised Statutes Chapter 603A. If you have any questions, please contact us as set forth below.

Utah Residents

• If you are a resident of Utah, you have the right to out of the processing of the personal data for purposes of (i) targeted advertising and (ii) the sale of personal data. We do not process your Personal Information for (i) targeted advertising or (ii) the sale of personal data.

CHANGES TO YOUR INFORMATION

It is important that the Personal Information we hold about you is accurate and current. Please keep us informed as soon as possible if your Personal Information changes or is inaccurate during your relationship with us by using the contact details set out below.

CONTACT US

If you have any questions about this Policy, including any requests to exercise your legal rights, please contact us using the details set out below.

Email us at: privacy@volt-rmc-solutions.com

251 Little Falls Drive, Wilmington, Delaware 19808, US