PRIVACY POLICY

Last Updated: January 11, 2021

The Company (collectively “we”, “us” or “our”) provides or otherwise makes available to you certain online services, including websites, software, software add-ins, tools, content, and other online programs (collectively, the “Services”). This Privacy Policy (the “Policy”) describes our privacy practices and the possible uses of the information that we collect via the Services. This Policy should be considered along with the applicable Terms and Conditions of Use of the website and any End User License Agreement, if any, for any applications provided through the website.

By accessing or using the Services, you agree with and consent to be bound by the terms and conditions of this Policy. We may update this Policy from time to time in our sole discretion. Any updates to this Policy will be posted on this website, or you will be notified of any updates when you access the website or log into the website, where applicable. Except in circumstances where we are required to obtain your express consent under applicable law, it is your responsibility to review the Policy for any changes each time that you use the Services and you are bound by such changes. Use of the Services by you following our posting of a new privacy policy constitutes your acceptance of the Policy as modified.

1. INFORMATION WE COLLECT
   We collect information about our users in various ways, including by your voluntary submissions, participation in the Services and through cookies and other tracking technology. This information helps us personalize and improve the Services and provide the Services’ functionality. We may collect the following information:
   1. Personal Information. “Personal Information” means information about an identifiable individual that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with you. We may collect the following Personal Information from you in connection with your use of the Services: your name, company, title, phone number, email address, fax, postal address, city, state or province, zip code, credit information of you or your company (such as accounts payable contact information, corporate contacts, bank references, D&B numbers, trade references, tax exemption certificates, financial statements, W-9 forms, or other credit information), IP address, username, device name, or other identifying information that may be provided through your use of the Services and that may identify you. This Personal Information is usually provided by you when you register to use certain Services or download certain software available via the Services, or is collected from you or the device you use to access the Services. You can choose not to provide certain information by not entering or providing the information, but as a result, you may not be able to take advantage of some or all of the Services.
   2. User Generated Content. We may collect other information that you voluntarily provide that would not be considered Personal Information as part of the Services, including but not limited to comments, communications, specifications, drawings, computer models, or other information provided by you through the Services (“User Generated Content”). We may, in our sole discretion, share your User Generated Content with others in connection with the Services provided, however, we will not share any information which may identify you together with such User Generated Content. If you do not want certain information shared with others, you should not submit User Generated Content that contains information that you do not want shared.
   3. Geolocation Information. If you consent, we may collect geolocation information generated by your mobile computing device, computer or other devices in order to provide you with Services that are specifically tailored to your location, such as providing Company locations to you based on the geolocation information. You can choose not to provide geolocation information, but as a result, you may not be able to take advantage of some of the Services’ features. If you do not want this information shared with others, you should choose not to provide geolocation information.
   4. Automatic Information. We may collect general, non-personal, statistical information about the use of the Services automatically, such as how many visitors visit a specific website page, how long they stay on that page, the hyperlinks users click, the usage of tools provided on the website or downloaded by the users, the functionally used within the tools, the frequency of the use of the functionality within the tools, or the like. We collect this information by using cookies, web beacons and other technologies. This information represents a generic overview of our users and allows us to modify the Services based on user traffic and behavior. We collect this information in order to help enhance the Services and improve the user experience.
      Cookies are small text files that a website uses to recognize repeat users, track user behavior and target advertising and content. Cookies do not identify specific users, only a user’s device. Like most websites, we may use cookies to store and track information about users of the Services. You may set your browser to notify you when you receive a new cookie or to disable cookies. However, this may hinder performance of the Services and prevent you from using some of the features of the Services.
      Other tracking technologies may record information such as Internet domain and host names, Internet protocol (IP) addresses, browser software and operating system types, clickstream patterns, and dates and times the Services are accessed. We may link the information we record using tracking technologies to Personal Information we collect.
      We may use Google Analytics to collect information regarding visitor behavior and visitor demographics on some of our Services, and to develop website content. For more information about Google Analytics, please visit https://policies.google.com/technologies/partner-sites. You can opt out of Google’s collection and processing of data generated by your use of the Services by going to http://tools.google.com/dlpage/gaoptout.
2. HOW WE USE & SHARE INFORMATION
   We use the information, including the Personal Information, we collect for a number of purposes, including to provide the Services’ functionality, improve the Services, communicate with users (including for marketing purposes subject to applicable anti-spam laws), and/or for internal business analysis of the use and effectiveness of the Services. We may use the Personal Information, including the credit information, to evaluate your eligibility for products and/or services that we offer, including the extension of credit to purchase products and/or services from us. Additionally, subject to applicable anti-spam laws, we may use your contact information to send notifications to you regarding updates to the Services, such as updated software versions, as well as to provide our marketing material to you.
   On reasonable notice, you may withdraw your consent to use your Personal Information at any time, subject to certain restrictions prescribed by applicable law.
   We do not disclose Personal Information to third parties, except (1) when we have your permission to make the disclosure, (2) when the disclosure is necessary for the purpose for which the information was obtained as set out in this Policy, (3) when the third party is acting on behalf of us to provide or manage the Services, or (4) where otherwise stated in this Policy. We also may disclose Personal Information where required by applicable law or when the disclosure is necessary for the establishment or maintenance of legal claims or legal compliance, to satisfy any law, regulation, subpoena or government request, or in connection with litigation.
   If you are located in Mexico, by accessing or using the Services you agree with and consent to such disclosure to third parties of your Personal Information in accordance with this Policy. With respect to the obligations regarding your Personal Information under this Policy, if we disclose your Personal Information the recipient will receive your Personal Information under obligations that are not less stringent than the obligations under this Policy.
   Some of the recipients to whom we disclose your Personal Information as contemplated in, and in accordance with, this Policy may be located in jurisdictions outside your jurisdiction of residence. As a result, your Personal Information may be used, stored and/or accessed in countries outside of your jurisdiction of residence, including for residents of Canada or Mexico within the United States. However, all such Personal Information, transferred to third parties located in either your country or abroad, will be protected in accordance with this Policy. Please note that when your Personal Information is located outside of your jurisdiction of residence it will be subject to the laws of the country in which it is situated and these jurisdictions may not have an equivalent level of data protection laws as those in your country.
   We may share aggregated user data with third parties in order to describe the use of the Services to existing or potential business partners or in response to a government request. We may also share aggregated demographic and preference data with third parties for research purposes or to enable the provision of targeted information, promotions, offers and/or discounts or to create a better overall experience for the users.
   In the event that we are, or a division or subsidiary is, acquired by, or merged into, another entity, or if there is a sale of all or a portion of our assets, your Personal Information may be transferred to the entity acquiring us, or a division or subsidiary, or into which we are, or a division or subsidiary is, merged or the entity that is purchasing our assets. You acknowledge and agree that in the foregoing circumstances, your Personal Information may be disclosed to such third-party acquirer or purchaser.
   
3. ACCESSING AND UPDATING YOUR INFORMATION
   You can always choose not to provide certain information to us, although this may prevent you from using some of the features of the Services. Some portions of the Services may also enable you to access and update your Personal Information by visiting a specific webpage or similar functionality within the Services. On these pages you can update your information as well as manage your email preferences. Please note that not all portions of the Services may offer you the ability to update your information and/or manage your email preferences.
   If you wish to access or update your Personal Information and are not able to do so through the Services, please contact us. You can also ask us whether we are keeping information about you and, if so, how it is being used and disclosed, including with respect to disclosures made to third parties outside your jurisdiction of residence. To update your Personal Information, to ask us how we are keeping information about you, or if located in Mexico, to exercise your ARCO rights (by means of which you can access, rectify and cancel your Personal Information, oppose to its processing, limit its use or disclosure, or revoke the consent you have given us for the processing of your Personal Information), please use the addresses in Section 8 entitled CONTACT.
   If you are located in Mexico, please include in your privacy request the following information: (i) your name and address or other means to notify you of the response to your privacy request; (ii) documents establishing your identity or, where appropriate, your legal representation; (iii) a clear and precise description of the Personal Information for which you seek to exercise any of your ARCO rights; (iv) any other item or document that facilitates locating the Personal Information; and (v) in the case of privacy requests for rectification of Personal Information documentation indicating and supporting the requested changes. In accordance with Mexican privacy laws, we shall respond to a privacy request within 20 days from the date of receipt of such privacy request, if such request is possible; or if we require additional information for such privacy request, we shall respond to an affirmative response from you providing such additional information within 15 days from the date of the receipt of such affirmative response from you including such additional information, such 15 day period may be extended once for an additional period of 15 days.
   
4. DATA SECURITY
   We take the protection of your Personal Information seriously. We protect Personal Information against loss and theft as well as unauthorized access, disclosure, copying, use, and modification using security safeguards, including physical, organization and technological measures, commensurate with the sensitivity of your Personal Information. Employees who have access to your information are made aware of the importance of keeping it confidential.
   Where we use service providers who might have access to your Personal Information, we require them to have privacy and security standards that are comparable to ours. We use contracts and other measures with our service providers to maintain the confidentiality and security of your Personal Information and to prevent it from being used for any other purpose.
   However, since no method of electronic storage is 100% secure, we cannot guarantee the absolute security of the information stored. We also cannot guarantee that information you supply will not be intercepted while being transmitted to us over the Internet.
   We retain Personal Information that we collect only as long as reasonably necessary to fulfill the purposes for which it was collected or to meet any applicable legal requirements.
   In some instances, you may be required to choose a user ID and password when you register for the Services. To the extent user IDs and passwords are utilized, you may not share your user ID and password with anyone else, and you are solely responsible for maintaining and protecting the confidentiality of your user ID and password. You are fully responsible for all activities that occur through the use of your user ID and password.
   
5. DO NOT TRACK DISCLOSURES
   We do not respond to Do Not Track (DNT) signals.
   
6. ADDITIONAL DISCLOSURES REGARDING CALIFORNIA PRIVACY RIGHTS
   If you are a resident of California, you have additional rights pursuant to the California Consumer Privacy Act of 2018 (the “CCPA”). Additional information regarding your rights under the CCPA and how to exercise them can be found here: https://www.vulcraft.com/About/Privacy#ccpa
7. USE BY MINORS
   We do not intend the Services to be used by individuals under the age of eighteen. We also do not knowingly collect any Personal Information about children under the age of thirteen. If we become aware that we have unknowingly collected Personal Information from a child under the age of thirteen, we will make commercially reasonable efforts to delete such information.
   
8. CONTACT
   You have the right to obtain information regarding our policies and practices with respect to the collection, use and disclosure of your Personal Information including with respect to our use of service providers outside your jurisdiction of residence. To obtain such information or for any other questions, comments, or concerns about this Policy, please contact us by mail or email as follows: