Privacy Policy

Last updated on 25 March, 2024.

VOLTRON TECHNOLOGY LLC and its affiliates (collectively “VOLTRON TECHNOLOGY”, “we” or “our”) take privacy seriously. We are committed to conducting business and providing services in a way that complies with applicable privacy and data protection laws and regulations in every country in which VOLTRON TECHNOLOGY operates. This Privacy Statement describes how we process personal information and personal data (collectively “Personal Information”) in the context of our operations. It also provides information about your rights and how you can contact us if you have questions about how we handle your Personal Information.

This Privacy Statement applies when VOLTRON TECHNOLOGY processes Personal Information in the context of its operations as a data controller (or the equivalent terminology under applicable law). As such, Personal Information may be processed in the following circumstances, namely:

  • When you contact us via a contact form on our website, by phone, or by email;

  • When you visit the sites managed by us or under our control, including websites and social media sites and applications (“VOLTRON TECHNOLOGY Sites”)

Please do not provide us with any Personal Information if you do not agree with this Privacy Statement.

VOLTRON TECHNOLOGY’s Sites may contain links to the sites of third parties or parts of their sites. However, VOLTRON TECHNOLOGY has no control over the content or operation of these sites, nor does it control the confidentiality or privacy practices of the site operators. Consequently, any personal information you submit through such sites is governed by the privacy policies of the sites in question. It is therefore your responsibility to find out about their policies in order to protect information that concerns you.

What Personal Information We Collect

VOLTRON TECHNOLOGY may collect the following Personal Information depending on the nature of our interactions:

  • Basic contact information such as name, employer name, job title, mailing and email addresses and telephone numbers;

  • Information related to the operation of our services;

  • Website usage and other technical information such as computer internet protocol (IP) address, unique device identifier and other information linked to a device, information about usage of our sites collected through cookies or other tracking technologies;

  • Other personal information you provide to us such as when you submit feedback, make inquiries, contact us for support or inquiries.

We collect your Personal Information from you, from your employer, from our customers, from third parties or through cookies and other tracking technologies. We do not knowingly collect Personal Information from anyone under the age of 16.

Why we collect your Personal Information and our lawful basis for processing it

We process your Personal Information only where we are satisfied that we have a business purpose and a lawful basis for doing so. Depending on the jurisdictions in which we operate, the legal bases justifying our processing of your Personal Information may include:

  • Legal obligation: where using your Personal Information is necessary to comply with applicable laws and regulations.

  • Contract performance: where using your Personal Information is necessary to establish and perform a contract with you.

  • Legitimate interests: where using your Personal Information is necessary to achieve a legitimate interest and our reasons for using it outweigh any prejudice to your data protection rights.

Consent: where you have given consent, as required by law, to process your Personal Information.

Finally, VOLTRON TECHNOLOGY may process Personal Information to protect anyone's vital interests, perform audits and defend legal claims. Such processing will be in accordance with applicable laws.We may also process your Personal Information to perform various analyses and research, and to create dashboards and databases for business purposes, including to i) provide training insights to trainees, instructors and employers, ii) improve training delivery, iii) develop new products and solutions, iv) identify usage trends, v) enhance, improve or modify our services and vi) perform audits. When doing so, we rely on the legal basis mentioned in the above table. Otherwise, we ensure that data is anonymized or aggregated so that it is not possible to identify you.

Some of the processing activities mentioned above are based on your consent. You can provide consent by a clear affirmative action either verbally, in writing or by electronic means. VOLTRON TECHNOLOGY will provide you with the necessary information on the processing activity that requires your consent under applicable laws. Your consent is voluntary (meaning you choose whether to give it), and it can be withdrawn at any time. This will result in the termination of the processing without affecting the lawfulness of the processing that occurred prior to any consent withdrawal.

How we transfer and share your Personal Information

Because we are a global business, we may process your Personal Information within the VOLTRON TECHNOLOGY group of companies (including our controlled subsidiaries and joint ventures).

We may also share your Personal Information with various categories of third parties, for example:

  • the regulators that govern certain of our activities, such as the competent authorities in civil aviation;

  • our professional advisors, including our legal counsel and auditors;

  • financial institutions that process payment transactions;

  • our service providers (e.g., Hubspot, payment service providers, and others) that help us run our business, including for the management of our technology assets and cloud services.

We may disclose your Personal Information to other third parties to comply with legal or regulatory requirements (e.g., audits, inspections or investigations by competent authorities), fulfill our contractual obligations, enforce our corporate policies, respond to claims, or protect anyone's vital interests. We may also disclose your Personal Information to a third party in connection with a sale or transfer of business or assets, a merger or consolidation, reorganization or financing of parts of our business. In the event the transaction is completed, your Personal Information will remain protected by applicable data protection laws. However, in the event the transaction is not completed, VOLTRON TECHNOLOGY will require the other party not to use or disclose your Personal Information in any manner whatsoever and to delete it. Such disclosures will be in accordance with applicable laws.

We only transfer Personal Information to third parties in a jurisdiction recognized as providing an adequate data protection level or that have signed a contract with VOLTRON TECHNOLOGY for processing personal information in compliance with applicable laws.

Except as otherwise mentioned herein, VOLTRON TECHNOLOGY will not transfer, sell or disclose your Personal Information to any third party without your consent.

How long we keep your Personal Information for

The longer that Personal Information is retained, the higher the likelihood is of accidental disclosure, loss, theft and/or information growing stale (rendering it inaccurate). At VOLTRON TECHNOLOGY, your Personal Information is retained for no longer than necessary to support the business purpose for which it was collected or to comply with applicable laws. Afterwards all Personal Information will be deleted or anonymized as applicable. VOLTRON TECHNOLOGY periodically reviews the need for certain Personal Information processed.

How we protect and secure your Personal Information

VOLTRON TECHNOLOGY is committed to ensure that your Personal Information is processed securely and accessible only by authorized persons. We have internal policies and controls in place to prevent your Personal Information from being lost, accidentally destroyed, misused, unintentionally disclosed, or accessed other than by our employees or third parties hired by VOLTRON TECHNOLOGY. We also provide mandatory training to VOLTRON TECHNOLOGY employees to raise awareness on our policies and procedures designed to manage information security threats. VOLTRON TECHNOLOGY has in place a cybersecurity incident response plan.

Nonetheless, some third parties may try to access our systems or intercept transmissions or communications unlawfully. VOLTRON TECHNOLOGY continuously uses reasonable measures in line with recognized security standards to protect your Personal Information, but we cannot absolutely guarantee that unlawful actions will not occur.

For any questions regarding this Privacy Policy or to request removal or deletion of your data please contact info@voltrontechnology.com