Effective Date: 2 June 2018

Welcome to the Volute Technologies, Inc. (hereinafter “VOLUTE,” “we” or “us”) website at http://www.volute.education or another website that posts this policy (the “SITE”) and its Software as a Service ("SaaS") platform (“PLATFORM”). VOLUTE is committed to protecting your privacy, and we have prepared this privacy policy (“Privacy Policy”) to describe our practices regarding the personal information that may be collected from users of our SITE and PLATFORM. The VOLUTE services such as the SITE, subscriptions to the PLATFORM that we provide via the SITE, as well as data, information, tools, functionality, updates and similar materials are referred to herein as the “Services.”

It is important that you take the time to read and understand this Privacy Policy so that you can appreciate how we use your personal information. This Privacy Policy applies only to you as an individual person using the Services, and does not apply to the companies or organizations at which you may be employed or that you may otherwise represent.

REMEMBER IF YOU USE OR ACCESS THE WEBSITE, YOU AGREE TO THIS PRIVACY POLICY. AS WE UPDATE THE WEBSITE OR EXPAND OUR SERVICES, WE MAY CHANGE THIS PRIVACY POLICY UPON NOTICE TO YOU, HOWEVER, PLEASE REVIEW IT FROM TIME TO TIME. Please refer to the “Effective Date” above to see when this Privacy Policy was last updated.

This Privacy Policy is subject to the provisions of the General Data Protection Regulation ("GDPR") for its European Union ("EU") users, as well as other applicable privacy laws. VOLUTE agrees that under the GDPR, VOLUTE is a data “Controller” and you are a “Data Subject” with certain protected privacy rights concerning your “Personal Data.” VOLUTE will take commercially reasonable steps to maintain compliance with GDPR requirements with respect to EU users and others to whom GDPR applies. Your Personal Data may identify you as a person, and thus is often referred to as Personally Identifiable Information ("PII").

Who Collects Your Information On Our Services?

We do. Under the GDPR, VOLUTE is what is known as the “Controller” of the Personal Data that you provide to us.

What Information Does VOLUTE Collect?

Requested PII. On various pages or areas of the Services, we may request specific PII about you in order to register you to use our Services, add you to our email list, facilitate your payments for Services, or fulfill your requests for information. You may choose not to provide your PII, but then you might not be able to take advantage of some of the features of our Services. We only collect basic personal data about you that does not include any special types of information (e.g., health-related) as defined in the GDPR. The types of Personal Data we collect and save include:

  • Contact and account registration information such as name, phone number, email address, username, physical address, social media account names and information, work history and information, location data, business name, business URL, and type of industry;
  • Information that you provide in using our Services, including enrollment and purchase history;
  • Information you provide such as survey data, feedback, comments or other messages; and Technical information collected in our logs. Such information may include standard web log entries that contain your IP address, page URL, device identifiers, device information and identifier, operating system information, and timestamp.

Aggregate Information. We may also collect anonymous, non-identifying and aggregate information such as the type of browser you are using, device type, the operating system you are using, and the domain name of your Internet service provider.

Why Is My Information Being Collected?

We need to collect your Personal Data so that we can respond to your requests for information and demonstrations, and to process your requests for access to our Services. We also collect aggregate information to help us better design the Services. We collect log information for monitoring purposes to help us to diagnose problems with our servers, administer the Services, calculate usage levels, and otherwise provide services to you.

How Do We Use the Information We Collect?

We use the Personal Data you provide for the purposes for which you have submitted it including:

  • Responding To Your Inquiries and Fulfilling Your Requests. We may use your PII to respond to your inquiries and to fulfill your requests for information.
  • Creating and Maintaining Your User Account. We may use your PII to create and maintain an account for you to allow you to use our Services
  • Communicating With You About Our Services. We may use your PII to send you information about new Services and other items that may be of interest to you.
  • Sending Administrative Emails. We may use your PII to send you emails to: (a) confirm your account and your other PII, (b) provide you with information regarding our Services, or (c) inform you of changes to this Privacy Policy or our other policies.

We may use anonymous information that we collect to improve the design and content of our Services, and to enable us to personalize your user experience. We also may use this information in the aggregate to analyze how our Services are used, analyze industry trends, as well as to offer you programs or services

Do We Share Your Personal Information?

In general, we will not share your Personal Data except: (a) for the purposes for which you provided it; (b) with your consent; (c) as may be required by law or as we think necessary to protect our organization or others from injury (e.g., in response to a court order or subpoena, in response to a law enforcement agency request, or when we believe that someone is causing, or is about to cause, injury to or interference with the rights or property of another); or (d) on a confidential basis with persons or organizations with whom we contract to carry out internal site operations or as necessary to render the Services. With your knowledge and consent, we may share your Personal Data with our business partners. We may also share aggregate information with others, including affiliated and non-affiliated organizations. Finally, we may transfer your Personal Data to our successor-in-interest in the event of an acquisition, sale, merger or bankruptcy.

Are There Other Ways My Personal Data Could Be Shared?

You may elect to share certain Personal Data with individuals or with the public via your use of the Services. In this case, you will control such sharing via settings that we provide. For example, the Services may make it possible for you to publicly share information via social media such as Facebook, Twitter or LinkedIn. Be aware that when you choose to share information with friends or the public, you may be disclosing sensitive information, or information from which sensitive information can be inferred. Always use caution when sharing information through the Services. You understand and agree that VOLUTE is not responsible for any consequences of your sharing of information through and beyond the Services.

How Can You Access and Control Your Information?

If you register for an account on the Services, you may log-in to the account and edit your Personal Data in your profile. For instructions on how you can further access your Personal Data that we have collected, or how to correct errors in such information, please send an e-mail to operations@volute.co. We will also promptly stop using your information and remove it from our servers and database at any time upon your e-mail request, except as permitted by law. To protect your privacy and security, we will take reasonable steps to help verify your identity before granting access, making corrections or removing your information.

If you are a user from the EU, Switzerland or the United Kingdom, or another location where GDPR applies, upon request, free of charge, you have the right to:

  • access and obtain a copy of the Personal Data we hold about you;
  • obtain information about the purposes for which we process your Personal Data and the categories of Personal Data concerned;
  • obtain information on the recipients or categories of recipients (including international recipients) to whom your Personal Data has been or will be disclosed;
  • transfer your Personal Data from us to another data Controller;
  • in certain circumstances, erase all Personal Data we hold about you;
  • lodge a complaint to the Supervisory Authority in your jurisdiction in respect of our collection or use of your Personal Data; and
  • withdraw your consent to our collection, use, storage, and dissemination of your Personal Data at any time

A request for any of the information above may be made by sending an email message to operations@volute.co with “Request for Privacy Information” in the subject line.

Please be aware that any request for withdrawal of consent will not affect the lawfulness of Personal Data collected, processed, and transferred prior to the date of such withdrawal of consent.

How Do We Store and Protect Your Information?

After receiving your Personal Data, we will store it on our systems for future use. We have physical, electronic, and managerial procedures in place to safeguard and help prevent unauthorized access, maintain data security, and correctly use the information we collect. Unfortunately, no data

transmission over the Internet or data storage solution can ever be completely secure. As a result, although we take industry-standard steps to protect your information (e.g., strong encryption), we cannot ensure or warrant the security of any information you transmit to or receive from us or that we store on our or our service providers' systems.

Although we have servers for our EU users in the European Union, if you are visiting or using the Services from outside of the US, you understand that your connection may be through and to servers located in the US, and the information you provide may be securely stored in our web servers and internal systems located within the US.

We store your Personal Data until you request us to remove it from our servers. We store our logs and other technical records indefinitely.

How Do We Use Cookies And Other Network Technologies?

To enhance your online experience with us, our web pages may presently or in the future use "cookies." Cookies are text files that our web server may place on your hard disk to store your preferences. We may use session, persistent, first-party and third-party cookies. Cookies, by themselves, do not tell us your e-mail address or other PII unless you choose to provide this information to us. Once you choose to provide PII, however, this information may be linked to the data stored in the cookie.

We or our service providers may also use "pixel tags," "web beacons," "clear GIFs", “embedded links”, and other commonly used information-gathering tools in connection with some Services pages and HTML-formatted email messages for such purposes as compiling aggregate statistics about Services usage and response rates. A pixel tag is an electronic image (often a single pixel), that is ordinarily not visible to website visitors, and may be associated with cookies on visitors’ hard drives. Pixel tags allow us and our service providers to count users who have visited certain pages of the Services, to deliver customized services, and to help determine the effectiveness of our Services. When used in HTML-formatted email messages, pixel tags can inform the sender of the email whether and when the email has been opened.

As you use the Internet, you leave a trail of electronic information at each website you visit. This information, which is sometimes referred to as "clickstream data”, can be collected and stored by a website's server. Clickstream data can reveal the type of computer and browsing software you use and the address of the website from which you linked to the Services. We may use clickstream data as a form of non-personally identifiable information to determine how much time visitors spend on each page of our Services, how visitors navigate through the Services, and how we may tailor our web pages to better meet the needs of visitors. We will only use this information to improve our Services.

At this time, the Services do not specifically respond to do-not-track signals.

Collection of Information by Others

Our Terms of Service document identifies certain third party websites to which we may provide links that you may click on our Services. Please check the privacy policies of these other websites to learn how they collect, use, store and share information that you may submit to them or that they collect. We are not responsible for the privacy practices of such other services.

Children and Young People’s Information

We do not knowingly collect any information from any minors, and we comply with all applicable privacy laws including the GDPR, USA Children's Online Privacy Protection Act (“COPPA”) and associated Federal Trade Commission (“FTC”) rules for collecting Personal Data from minors. Please see the FTC's website (www.ftc.gov) for more information. If you have concerns about the Services, wish to find out if your child has accessed our Services, or wish to remove your child's Personal Data from our servers, please contact us at operations@volute.co. Our Services will not knowingly accept Personal Data from anyone under 13 years old in violation of applicable laws, without consent of a parent or guardian. In the event that we discover that a child under the age of 13 has provided PII to us, we will make efforts to delete the child’s information in accordance with the COPPA. If you believe that your child under 13 has gained access to our Services without your permission, please contact us at operations@volute.co.

California Privacy Rights

California law allows California residents to request information regarding our disclosures in the prior calendar year, if any, of their PII to third parties. To make such a request, please contact us at operations@volute.co with "Request for Privacy Information" in the subject line. Please include enough detail for us to locate your file; at a minimum, your name, email, and username, if any. We will attempt to provide you with the requested information within thirty (30) days of receipt. We reserve our right not to respond to requests sent more than once in a calendar year, or requests submitted to an address other than the one posted in this notice. Please note that this law does not cover all information sharing. Our disclosure only includes information covered by the law.

EU/Swiss Privacy Shield Certification

We comply with the EU-U.S. Privacy Shield framework and the Swiss-U.S. Privacy Shield framework, as set forth by the U.S. Department of Commerce, regarding the collection, use, and retention of Personal Data from EU member countries and Switzerland. We have certified that we adhere to the Privacy Shield principles of notice, choice, accountability for onward transfer, security, data integrity and purpose limitation, access, and recourse, enforcement, and liability. To learn more about the Privacy Shield program, please visit https://www.privacyshield.gov/.

Changes to this Policy

Because our business needs may change over time, we reserve the right to modify this Privacy Policy. If at any time in the future we plan to use your PII in a way that differs from this Privacy Policy, we will revise this Privacy Policy as appropriate. In the event of a change to our Privacy Policy, we will email the updated policy to the email address that you provided to us. Your continued use of the Services following our notice of changes to this Privacy Policy means you accept such changes.

Our Contact Information

If you have any questions or concerns about this Privacy Policy, please contact our Chief Privacy Officer via e-mail at operations@volute.co.

Copyright © Volute Holdings Corp. All rights reserved. The Services are the property of Volute, and are protected by United States and international copyright, trademark, and other applicable laws. This includes the content, appearance, and design of the Services, as well as the trademarks, product names, graphics, logos, service names, slogans, colors, and designs.