Privacy Policy
Last updated: April 21, 2023
Volta Talent Strategies LLC is committed to protecting your privacy. This Privacy Policy describes our practices in connection with information that we collect through our websites located at www.voltapeople.com and www.voltacareercenter.com (collectively, the “Site”).
This Privacy Policy applies only to our online information-gathering and dissemination practices through the Site, and does not apply to any of our practices conducted offline. If you have any questions or comments about the Privacy Policy or our privacy practices, please contact us at legal@voltapeople.com.
If you are located within the European Union, European Economic Area, or the United Kingdom, you may have different or additional rights. Please read the Privacy Notice for EU Users.
If you are a resident of California, you may have different or additional rights. Please read the Privacy Notice for California Residents.
IF YOU DO NOT UNDERSTAND OR DISAGREE WITH ANY PART OF THIS PRIVACY POLICY, DO NOT USE THIS SITE.
Visiting the public areas of our Site does not require you to provide any personally identifiable information, such as your name, address, email address, or phone number ("Personal Information"). The cookies used on the public areas of the Site do not gather Personal Information, although your computer's browser may automatically provide us with certain other information, such as the date and time of your visit, your computer's browser type, operating system and IP and any referring and exiting URLs.
PERSONAL INFORMATION WE MAY COLLECT
"Personal Information" is information that identifies you as an individual, such as your name, mailing address, telephone number and email address.
How We May Collect Personal Information
We and our service providers may collect Personal Information through the Site, e.g., when you sign up for any newsletter we publish or send us an email using our “Contact Us” page.
How We May Use Personal Information
We may use Personal Information:
To respond to your inquiries and fulfill your requests, such as to send you newsletters or publications that you request.
To send you company updates and mailings relating to our ideas, services or events that we think may be of interest to you.
To keep a record of your contact information and correspondence, and use it to respond to you, if you contact us through the Site.
For our business purposes, such as data analysis, audits, fraud monitoring and prevention, enhancing, improving or modifying our services, identifying usage trends, determining the effectiveness of our promotional campaigns and operating and expanding our business activities.
How Personal Information May Be Disclosed Your Personal Information may be disclosed:
To our third-party service providers that provide services such as website hosting, services- related consulting and monitoring, data analysis, information technology and related infrastructure, customer service, email delivery, auditing and other similar services.
To identify you to anyone to whom you send messages through the Site.
To a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings)
In Addition…
We may use or disclose Personal Information as we understand to be necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property and/or that of our affiliates, you or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.
Except as otherwise disclosed in this Privacy Policy, we will not sell, rent or transfer Personal Information to third parties without your consent.
OTHER INFORMATION WE MAY COLLECT
"Other Information" is any information that does not reveal your specific identity or does not directly relate to an individual, such as:Browser and device information;
Site usage data and analytics;
Information collected through cookies, pixel tags and other technologies; and
Demographic information and other information provided by you.
How We May Collect Other Information
We and our third party service providers may collect Other Information in a variety of ways, including:
Through your browser or device: Certain information is collected by most browsers or automatically through your device, such as your Media Access Control (MAC) address, computer type (Windows or Macintosh), screen resolution, operating system name and version, device manufacturer and model, language and Internet browser type and version. We use this information to ensure that the Site functions properly.
Using cookies: Cookies are pieces of information stored directly on the computer that you are using. We may use cookies in connection with the Site.
Using pixel tags and other similar technologies: Pixel tags (also known as web beacons and clear GIFs) may be used in connection with the Site to, among other things, track the actions of users of the Site, measure the success of our marketing campaigns and compile statistics about usage of the Site and response rates.
IP Address: Your "IP Address" is a number that is automatically assigned to the computer that you are using by your Internet Service Provider (ISP). An IP Address may be identified and logged automatically in our server log files whenever a user accesses the Services, along with the time of the visit and the page(s) that were visited. Collecting IP Addresses is standard practice and is done automatically by many websites and applications. We use IP Addresses for purposes such as calculating usage levels of the Site, helping diagnose server problems and administering the Site.
From you: Information such as your location, as well as other information, such as your preferred means of communication, is collected when you voluntarily provide this information. Unless combined with Personal Information, this information does not personally identify you or any other user of the Services.
By aggregating information: Aggregated Personal Information does not personally identify you or any other user of the Services (for example, we may use aggregated Personal Information to calculate the percentage of our users who have a particular telephone area code).
By using Google Analytics, which is a web analysis service provided by Google that collects usage and cookie data. Google utilizes the data collected to track and examine the use of www.voltapeople.com and www.voltacareercenter.com to prepare reports on its activities and share them with other Google services. Google may use the data collected to contextualize and personalize the ads of its own advertising network. Find Google’s privacy policy here: www.google.com/policies/privacy/partners/
How We May Use and Disclose Other Information
Please note that we may use and disclose Other Information for any purpose, except where we are required to do otherwise under applicable law. If we are required to treat Other Information as Personal Information under applicable law, then we may use it as described in "How We May Collect Other Information" section above, as well as for all the purposes for which we use and disclose Personal Information.
In some instances, we may combine Other Information with Personal Information (such as combining your name with your geographical location). If we combine any Other Information with Personal Information, the combined information will be treated by us as Personal Information as long as it is combined.
THIRD PARTIES
This Privacy Policy does not address, and we are not responsible for, the privacy, information or other practices of any third parties, including any third party operating any site or service to which the Site links. The inclusion of a link does not imply endorsement of the linked site or service by us. We encourage you to read the privacy policies of other websites you link to from the Sites or otherwise visit.
SECURITY
We seek to use reasonable organizational, technical and administrative measures to protect Personal Information within our organization. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please immediately notify us of the problem by contacting us in accordance with the "Contacting Us" section below.
YOUR CHOICES
Your choices regarding our use of your Personal Information for marketing purposes
If you no longer want to receive marketing-related emails from us on a going-forward basis, you may opt-out of receiving these marketing-related emails by following the unsubscribe instructions in any such message or by contacting us by email atlegal@voltapeople.com. We will try to comply with your request(s) as soon as reasonably practicable. Please note that if you do opt out of receiving marketing-related emails from us, we may still send you important administrative messages, and you cannot opt out from receiving administrative messages.
How you can access, change or suppress your Personal Information
You may request to review, correct, update, suppress or otherwise modify any of your Personal Information that you have previously provided to us through the Services, or object to the use or processing of such Personal Information by us. You may exercise these rights by contacting us by email at legal@voltapeople.com.
Access and Change. We allow our users the option to access and obtain a copy of their Personal Information and to rectify such Personal Information if it is not accurate, complete or updated. However, we may first ask you to provide us certain credentials to permit us to identify your Personal Information.
To Delete Personal Information or Restrict Processing. You may request that we delete your Personal Information or restrict its processing. We may postpone or deny your request if your Personal Information is in current use for the purposes for which it was collected or for other legitimate purposes such as compliance with legal obligations.
Withdrawing Your Consent. You have the right to withdraw your consent to the processing of your Personal Information.
Right of Data Portability. Where technically feasible, you have the right to ask to transfer your Personal Information in accordance with your right to data portability.
In your request, please make clear what Personal Information you would like to have changed, whether you would like to have your Personal Information that you have provided to us suppressed from our database or otherwise let us know what limitations you would like to put on our use of your Personal Information that you have provided to us. For your protection, we may only implement requests with respect to the Personal Information associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable.
Please note that we may need to retain certain information for recordkeeping purposes, and there may also be residual information that will remain within our databases and other records, which will not be removed.
ONWARD TRANSFER OF YOUR INFORMATION
Your information will be collected, processed, stored and used by us, and if/when applicable may be passed to and processed by our subsidiaries and/or affiliated companies. Information contributed by or collected from users may be stored and processed in any country in which we or our affiliates, subsidiaries or agents maintain facilities, and which may be outside of the European Economic Area. Please read the Privacy Notice for EU Users for further information on onward transfers.
RETENTION PERIOD
We will retain your Personal Information for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law.
USE OF SERVICES BY MINORS
The Sites are not directed to nor intended for use by any individual under the age of thirteen (13), and therefore such individuals are requested and advised not to provide Personal Information through the Sites.
SENSITIVE INFORMATION
You agree not send or disclose to us any sensitive Personal Information (e.g., Social Security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, or health) on or through the Site or otherwise to us unless specifically required in connection with an engagement for which there are agreed terms.
UPDATES TO THIS PRIVACY POLICY
We may change this Privacy Policy. Please take a look at the "Last Updated" legend at the top of this page to see when this Privacy Policy was last revised. Any changes to this Privacy Policy will become effective when we post the revised Privacy Policy on the Site. When we make material changes to this Privacy Policy, we will notify you by using the email address you have provided to us. Your use of the Site following these changes means that you accept the revised Privacy Policy.
CONTACTING US
If you have any questions about this Privacy Policy, please contact us by email at legal@voltapeople.com, or please write to the following address:
Volta Talent Strategies LLC Attn: Chief Executive Officer
1330 Avenue of the Americas, Floor 23 New York, NY 10019
Please note that email communications are not always secure; so please do not include sensitive personal or professional information in your emails to us through the Site.
PRIVACY NOTICE FOR EU USERS
This Privacy Notice for EU Users is part of this Privacy Policy and applies solely to visitors, users, and others who reside in the European Union, European Economic Area, or the United Kingdom in compliance with the General Data Protection Regulation (GDPR) and the UK General Data Protection Regulation (UK GDPR). PLEASE READ THE PRIVACY POLICY IN ADDITION TO THIS PRIVACY NOTICE FOR EU USERS. Terms defined in the GDPR have the same meaning when used in this Notice.
Under certain circumstances, EU residents have rights under data protection laws in relation to their personal data. If you are an EU resident, you have the right to:
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact us directly at legal@voltapeople.com or at Volta Talent Strategies LLC, 1330 Avenue of the Americas, Floor 23, New York, NY 10019.
NO FEE USUALLY REQUIRED
You will not have to pay a fee to access your personal data (or to exercise any of the other rights unless your request is clearly unfounded, repetitive or excessive, in which case we may charge a reasonable fee. Alternatively, we may refuse to comply with your request in these circumstances.
WHAT WE MAY NEED FROM YOU
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
TIME LIMIT TO RESPOND
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
INTERNATIONAL TRANSFERS
Whenever we transfer personal data out of the European Economic Area, we ensure that a similar degree of protection is afforded to it by implementing at least one of the following safeguards:
We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
Where we use providers based in the US, we may transfer data to them using Standard Contractual Clauses and if they provide adequate protection of personal data shared between the Europe and the US.
PRIVACY NOTICE FOR CALIFORNIA USERS
This Privacy Notice for California Residents is part of the Privacy Policy and applies solely to visitors, users, and others who reside in the State of California (“consumers” or “you”) in compliance with the California Consumer Privacy Act of 2018 (CCPA). PLEASE READ THE PRIVACY POLICY IN ADDITION TO THIS PRIVACY NOTICE FOR CALIFORNIA RESIDENTS. Terms defined in the CCPA have the same meaning when used in this Notice.
Information We Collect
Our Site collects Personal Information, further defined in this Privacy Policy. For purposes of this Notice, “Personal Information” also includes information that identifies or could reasonably be linked, directly or indirectly, with a particular consumer or device.
Our Site has collected the following categories of Personal Information from its consumers within the last twelve (12) months:
A. Identifiers.
First name, last name, email address, telephone number, email data, system usage data, location data (IP address), and other electronic data/UGC (reviews, photos) submitted, stored, sent, or received by the Data Subjects.
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
First name, last name, email address, telephone number, email data, system usage data, location data (IP address), and other electronic data/UGC (reviews, photos) submitted, stored, sent, or received by the consumers. Note: Some personal information included in this category may overlap with other categories.
C. Protected classification characteristics under California or federal law.
None.
D. Commercial information.
Purchased product/service.
E. Biometric information.
None
F. Internet or other similar network activity.
IP Address, system usage data, aggregated data.
G. Geolocation data.
None.
H. Sensory data.
None
I. Professional or employment-related information.
None.
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).
None.
K. Inferences drawn from other personal information.
None.
For purposes of this Notice, “Personal Information” does not include:
Publicly available information from government records.
Deidentified or aggregated consumer information.
Information excluded from the CCPA’s scope, such as:
Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
Personal Information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.
We obtain the Personal Information listed above from directly from you when you submit it to us and indirectly from you (for example, through cookies or other tracking mechanisms.) For more information about how we collect your Personal Information, see “Personal Information We May Collect” and “Other Information We May Collect” in the Privacy Policy.
Use of Personal Information
We may use or disclose the Personal Information we collect for the business purposes set forth in the Privacy Policy under “How We May Use Personal Information”, “How Personal Information May Be Disclosed” and “How We May Use and Disclose Other Information”.
Sharing Personal Information
We do not sell or disclose your Personal Information to third parties for commercial purposes or otherwise except as set forth in the Privacy Policy under “How We May Use Personal Information”, “How Personal Information May Be Disclosed” and “How We May Use and Disclose Other Information”.
California Residents’ Individual Rights
The CCPA provides California residents with specific rights regarding their Personal Information. This section describes your CCPA rights and explains how to exercise those rights.
Access and Data Portability Rights
You have the right to request that we disclose certain information to you about our collection and use of your Personal Information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:
The categories of Personal Information we collected about you.
The categories of sources for the Personal Information we collected about you.
Our business or commercial purpose for collecting or selling that Personal Information.
The categories of third parties with whom we share that Personal Information.
The specific pieces of Personal Information we collected about you (also called a data portability request).
If we sold or disclosed your Personal Information for a business purpose, two separate lists disclosing (i) sales, identifying the Personal Information categories that each category of recipient purchased; and (ii) disclosures for a business purpose, identifying the Personal Information categories that each category of recipient obtained.
Deletion Request Rights
You have the right to request that we delete your Personal Information, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:
Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity (including fraudulent user generated content such as product reviews), or prosecute those responsible for such activities.
Debug products to identify and repair errors that impair existing intended functionality.
Exercise a right provided for by law.
Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
Comply with a legal obligation.
Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
Exercising Access, Data Portability, and Deletion Rights
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by sending us a message on our Site. Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your Personal Information. You may also make a verifiable consumer request on behalf of your minor child.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative.
Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you.
We will only use Personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
Response Timing and Format
We try to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time, we will inform you of the reason and extension period in writing.
Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your Personal Information that is readily useable and should allow you to transmit the information from one entity to another entity.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
Opt-Out and Opt-In Rights
If you are 16 years of age or older, you have the right to direct us to not sell your Personal Information at any time (the “right to opt-out”). We do not sell the Personal Information of consumers we actually know are less than 16 years of age, unless we receive affirmative authorization (the “right to opt-in”) from either the consumer who is between 13 and 16 years of age, or the parent or guardian of a consumer less than 13 years of age. Consumers who opt-in to Personal Information sales may opt-out of future sales at any time.
To exercise the right to opt-out, you (or your authorized representative) may submit a request to us at legal@voltapeople.com or at Volta Talent Strategies LLC, 1330 Avenue of the Americas, Floor 23, New York, NY 10019.
We will only use Personal Information provided in an opt-out request to review and comply with the request.
Non-Discrimination
We will not discriminate against you for exercising any of your CCPA rights. However, note that many features of our Site, our products, or our services will not function without your Personal Information. Unless permitted by the CCPA, we will not:
Deny you goods or services.
Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
Provide you a different level or quality of goods or services.
Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your Personal Information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.
California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Site that are 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 send us an electronic message through our Site or write us at our address listed on our webpage.