At C3STROM, we take your privacy seriously and recognize that you expect privacy and security for all your personal information. We understand the need to protect and safeguard sensitive information about you, and we maintain strict standards and procedures designed to prevent misuse of your information.

We encourage you to read this privacy notice (the “Privacy Notice”) carefully to understand the information we collect and what we do with it.

C3STROM Inc. and its affiliates and subsidiaries (collectively “C3STROM,” “us,” “our,” or “we”) are responsible for your information, and this Privacy Notice constitutes an agreement between you and C3STROM. When you access and use our United States website (the “Site”), you acknowledge that you have read this Privacy Notice, understood it and that you do not object to our processing activities.

This Privacy Notice describes how C3STROM collects, protects, uses, and discloses information and data collected and created in the course of your access to and use of the C3STROM Site, products, and services, as well as your interactions with C3STROM via telephone, through mail or at our physical locations. It also explains your rights, which may differ depending on where you are located.

At specific points in your interaction with the Site, certain third-party service providers engaged by C3STROM (“Service Providers”) may be responsible for collecting information about you, your interactions with the Site, your preferences, settings, or other general information. For example, at different points, you will need to submit various pieces of information to a Service Provider to take advantage of services offered by C3STROM, including but not limited to making a purchase, financing a purchase, applying for employment, or entering a contest. This Privacy Notice will identify instances where your information is collected, transmitted, or stored by a Service Provider. In such cases, your data will become subject to terms and conditions and a privacy policy operated by that Service Provider. Please see the “Access to Your Information” section below for more information about our Service Providers.

1. Legal information

The Owner may process Personal Data relating to Users if one of the following applies:

• Users have given their consent for one or more specific purposes. Note: Under some legislations the Owner may be allowed to process Personal Data until the User objects to such processing (“opt-out”), without having to rely on consent or any other of the following legal bases. This, however, does not apply, whenever the processing of Personal Data is subject to European data protection law;
• provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
• processing is necessary for compliance with a legal obligation to which the Owner is subject;

processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner;

• processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.

In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

This privacy statement has been prepared based on provisions of multiple legislations, including Art. 13/14 of Regulation (EU) 2016/679 (General Data Protection Regulation).

2. What data do we collect and process and how do we use your data?
   • If you access or submit an inquiry through our Sites, set up an account, subscribe to a service, register to receive marketing materials, participate in contests, sweepstakes or promotions, upload a photo, or receive other services, we may ask you to provide certain personal information such as your name, email address, phone number, location, and zip code, and other personally identifiable information.

• We use your Personal Information for the purposes described at the time of collection and to manage the internal operations and security of our Site consistent with this Privacy Notice. We may also use your Personal Information for analytical and direct marketing purposes, such as:

• Sending you periodic email and newsletter communications;
• Confirming, sending, and tracking your order, subscription, or registration;
• Communicating with you about your order, subscription, or registration;
• Responding to customer inquiries;
• Sending you surveys and other communications;
• Analyzing preferences, trends, and statistics;
• Informing you of our new products, services, and offers; and
• Providing you with other information from and about C3STROM.
• We will only contact you in ways compatible with your communications choices. However,
• even if you have opted-out of receiving marketing communications from us, we may need to

contact you to address questions or issues specific to the services you have requested.

• Other Ways We Might Use Your Information. In addition to the specific uses and purposes described above, we might use information that we collect about you or that you provide to us, including any Personal Information:

(1)To present our Site and its contents to you.

(2)To provide you with information, products, or services that you request from us.

(3)To allow you to participate in interactive features on our Site or to notify you about changes to our Site or any products or services we offer or provide though it.

(4)To provide you with other information from and about C3STROM or a business or organization with which we are associated.

(5)To protect your privacy and enforce this Privacy Notice;

(6)If we believe it is necessary to identify, contact or bring legal action against persons or entities who may be causing injury to you, to C3STROM, or to others.

(7)To fulfill any other purpose for which you provide your information.

(8)To analyze preferences, trends, and statistics.

(9)To protect our rights and property.

(10)To comply with a law, regulation, legal process or court order.

(11)For any other purpose with your consent.

3. Access To Your Information
   • We do not share, sell, rent, or transfer your personal information other than as described in this Privacy Notice. Your information will be accessible to C3STROM employees who are trained to comply with our internal policies for handling Personal Information and assisting you in exercising your legal rights over your personal information.

Service Providers may also have access to your personal information while they are carrying out their services. However, we require all Service Providers to maintain confidentiality standards that are commercially reasonable to ensure the security of your Personal Information.

• Disclosure of Your Information. We will only disclose, sell, or share your Personal Information or other information:

(1)To Service Providers. We may disclose, sell or share Personal Information to one or more Service Providers with which we have contracted to provide services to us or to offer the services you have requested from us. We may also disclose Personal Information to one or more Service Providers who are interested in providing services or products to you. We do not control how these Service Providers use or disclose your Personal Information.

(2)To Affiliated Businesses. We may disclose, sell or share Personal Information to one or more third parties that have contracted with us (“Affiliated Businesses”) specifically in order to provide you with the services you have requested. The Affiliated Businesses may contact you directly by email, telephone, regular mail, in person visits or other means. We do not control how these Affiliated Businesses use or disclose your Personal Information.

(3)To Affiliates. We may disclose some or all of your Personal Information with our parent company, subsidiaries, joint ventures, or other companies under common control with us, in which case this Privacy Notice will apply to the same extent it applies to C3STROM.

(4)For Our Internal Analyses and Operations. We may disclose Personal Information to third party vendors for our own internal statistical, design or operational purposes, such as to estimate our audience size, measure aggregate traffic patterns, and understand demographic trends among our users. The use and disclosure of your Personal Information by these third parties is restricted to performance of such tasks and subject to confidentiality.

(5)For Legal and Other Compliance.We may disclose Personal Information when we believe it is appropriate to:

(a) comply with the law,

(b) enforce or apply this Privacy Notice or our other policies or agreements,

(c) protect our or our users’ rights, property or safety,

(d) protect our users from fraudulent, abusive or unlawful use of, our Site, or

(e) if we reasonably believe that an emergency involving immediate danger of death or serious physical injury to any person requires disclosure of communications or justifies disclosure of records without delay.

3.3. As Part of Business Transfers. We may disclose Personal Information as part of any merger, acquisition, debt financing, sale of company assets or other business transaction.

• As Aggregated Information. We may share or sell aggregated, anonymous information to our advertisers, business partners, and other third parties that includes or is based on information about you. We take technical and organizational measures to anonymize your information and combine it with other users’ information so that it does not directly identify you. This information may be used by those third parties for marketing, promotional or statistical purposes. We do not limit the third parties’ use of the aggregated information.

4. Security

It is C3STROM’s policy to treat your Personal Information with complete confidentiality. We employ commercially appropriate and reasonable safeguards both online and offline to maintain the security, confidentiality, and integrity of information that we collect about you. We maintain physical, electronic and procedural security measures to safeguard your non-public personal information. We update and test our technology to improve the protection of our information about you and to assure the integrity of that information.

We educate our employees about the importance of confidentiality and customer privacy through standard operating procedures and special training programs. We take appropriate disciplinary measures to enforce employee privacy practices.

Please note, however, that no transmission of data over the internet is 100% secure. While we employ reasonable measures to protect your Personal Information, we cannot guarantee that unauthorized third parties will not defeat those measures or use nonpublic Personal Information for improper purposes. We are not responsible for circumvention of any privacy settings or security measures contained on the Site or for actions of third parties. The safety and security of your information also depends on you, and you are responsible for keeping your password confidential. Also remember to log off your account and close your browser window when you have finished your visit. This is to ensure that others cannot access your account, especially if you are sharing a computer with someone else or are using a computer in a public place. All Internet users should take care with how they handle and disclose their personal information.

Please refer to the Federal Trade Commission’s Site: http://www.ftc.gov/bcp/menus/consumer/data.shtm 

for information about how to help protect yourself against identity theft.

5. Retention Time
   • Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.

Therefore:

(1)Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed.

(2)Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner.

• The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.

• Once the retention period expires, Personal Data shall be deleted. Therefore, the right of access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.

6. Newsletter

C3STROMoffers newsletters. That way, you are fully informed of (discount)offers and other news. We use a double opt-in system to be sure of your permission. This means that you verify your permission for any new confirmation. We ask you for this verification via an e-mail that we send to the address you have given us. Every time we send you a newsletter you have the possibility to unsubscribe from the newsletter.

7. Update Notice

We may occasionally update this notice. If we make significant changes, we will notify users in advance of the changes through the Platform or through other means, such as e-mail. We encourage users to periodically review this notice for the latest information on our privacy practices.

8. Contact information

Email: letstalk@c3strom.com

Address: ONE COMMERCE PLAZA

99 WASHINGTON AVE SUITE 805-A

ALBANY, NY 12210822