2. PROCESSING ACTIVITIES COVERED.
- You provide information through your use of our Websites.
- You visit our branded social media pages.
- You or we send or receive communications, including e-mail, text and/or other electronic messages.
- You download mobile and/or desktop applications from this Website, if any, which provide dedicated non-browser-based interaction between you and this Website.
- You interact with our advertising and applications on third-party websites and services, if those applications or advertising include links to this Website.
- You respond to any surveys that we might ask you to complete for research purposes or other purposes we may identify.
- Us offline or through any other means, including without limitation, on any third party website, through your visits to our office and your attendance at events; or
- Any third party, including through any application or content (including advertising) that may link to or be accessible from or on this Website.
2.3. Links from this Website.
This Website may contain links to other websites, applications and services maintained by third parties. The information practices of such other services, or of social media networks that host our branded social media pages are governed by third parties’ privacy policies or statements, which we encourage you to review to better understand such third parties’ privacy practices.
3. WHAT PERSONAL INFORMATION DO WE COLLECT AND HOW WE COLLECT IT.
3.1 Personal Information We Collect Directly from You.
The information we collect from you on or through our Websites, which includes Personal Information, includes:
- For all users – name, telephone number and email address.
- Information that you provide by filling in forms on our Websites. This includes information provided at the time of registering to use our Website, subscribing to our service, posting material and/or User Contributions or requesting further services. We may also ask you for information when you report a problem with our Websites.
- Records and copies of your correspondence (including e-mail addresses), if you contact us.
- Your responses to surveys that we might ask you to complete for research purposes.
- Details of transactions you carry out through our Websites, if any. You may be required to provide financial information before making certain uses of our Websites.
- Your search queries on our Websites.
- When you use and interact with this Website, we automatically collect log files and other information about your device and your usage of this Website and other details of your visits to this Website, which may include traffic data, location data, other communication data, resources that you access and use on the Websites through cookies, web beacons or similar technologies, such as Internet Protocol (IP) addresses or other identifiers, which may qualify as Personal Information (please see Section 3.2, “Automatic Data Collection Technologies We Use” below).
3.2 Automatic Data Collection Technologies We Use.
- Flash Cookies. Certain features of our Websites may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from and on our Websites. Flash cookies are not managed by the same browser settings as are used for browser cookies. For information about managing your privacy and security settings for Flash cookies, please see Section 5.2, “Choices about How We Use and Disclose Your Information”, below.
- Log Files. When you access our Websites, our servers automatically record information sent from your browser, which may include your web request, Internet Protocol address, domain names, referring Uniform Resource Locator, browser type, browser language, and operating system; the date and time of your request and access; and Cookies that may uniquely identify your browser (collectively, “Usage Data”). We may combine Usage Data with Personal Information in a manner that enables us to trace Usage Data to an individual user, and may collect, use, preserve and disclose Usage Data in any manner that we may collect, use, preserve and disclose Personal Information as provided herein (whether Usage Data is combined with any Personal Information or otherwise).
- Web Beacons. Pages of our the Websites and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs. pixel tags and single-pixel gifs) that permit us, for example, to count users who have visited those pages or opened an e-mail and for other related Website statistics (for example, recording the popularity of certain Website content and verifying system and server integrity).
We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.
4. WHY WE PROCESS YOUR PERSONAL INFORMATION.
We process information that we collect from and/or about you, including Personal Information to perform services for you, to pursue our legitimate interests, and for other purposes, including:
- To provide our Websites and their content to you and allow you to review our services, create an account or profile or register for services on the Websites. Where we do not have an account with you or provide you with any services, we process your Personal Information.
- To provide you access to our services.
- To provide you with information, products or services that you request from us. Where we do not have an account with you or provide you with any services, we process your Personal Information based on our legitimate interest to operate and administer our Websites and to provide you with content you access and may request.
- To provide you with customer support and communication, and notices about your account, which may include expiration and renewal notices.
- For analytical purposes, which may include generate and analyze statistics about your use of the Websites for operational and/or security purposes, measurement of effectiveness of our marketing activities, performance improvements, research, testing and other business purposes.
- To notify you about changes to our Websites or services we offer or provide through one or more of the Websites.
- To allow you to use participate in interactive features on our Websites.
- To process your Personal Information by managing your user account for the purpose of providing services to you.
- To develop and improve our Websites.
- To conduct marketing research, advertise to you, provide personalized information about us on and off our Websites and to provide other personalized content based upon the services we provide to you to the extent it is necessary for our legitimate interest in advertising our Websites or, where necessary, to the extent you have provided your prior consent, including without limitation, through requests made by you or use of built-in convenience features of the services we provide to you.
- To cooperate with public and government authorities, courts or regulators in accordance with our legal obligations under applicable laws to the extent this requires the processing or disclosure of Personal Data to protect our rights or is necessary for our legitimate interest in protecting against misuse or abuse of our Websites, protecting personal property or safety, pursuing remedies available to us and limiting our damages, complying with judicial proceedings, court orders or legal processes or to respond to lawful requests.
- In any other way we may describe when you provide the information.
- For any other purpose with your consent.
We may also use your information to contact you about our own and third-parties’ services that may be of interest to you.
We may use the information we have collected from you to enable us to display advertisements to our advertisers’ target audiences. Even though we do not disclose your Personal Information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.
5. HOW WE USE OR SHARE YOUR INFORMATION
5.1. Disclosure of Your Information.
- To our subsidiaries, affiliates and/or Licensees.
- To contractors, service providers and other third parties we use to support our business service providers. We may share Personal Information collected through our Websites with companies that perform services on our behalf, including companies that provide website development, hosting, payment processing and billing services.
- To fulfill the purpose for which you provide it.
- With third-party social media networks, advertising networks and websites, which may also act as separate controllers, so that we can market and advertise on such third-party platforms and websites.
- For the purpose of providing services, to your professional advisors including lawyers, bankers and insurers acting as joint processors or joint controllers.
- For any other purpose disclosed by us when you provide the information.
- With your consent.
We may also disclose your Personal Information:
- To comply with any court order, law or legal process, including to respond to any government or regulatory request. We may disclose your personal information when we believe disclosure is appropriate to comply with the law or respond to a court order or subpoena; to prevent or investigate a possible crime, such as fraud or identity theft; or to protect the rights, property or safety of ourselves or others. We reserve the right to report to appropriate law enforcement, governmental authorities and other third parties any activities that we, in good faith, believe to be harmful or unlawful, with or without providing notice to you
- If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of VIPrivate Care, our customers or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
We may also disclose aggregated information about you and other users that does not identify you or any other individual, without restriction.
5.2 Choices About How We Use and Disclose Your Information.
We strive to provide you with choices regarding the Personal Information you provide to us. We have created mechanisms to provide you with the following control over your Personal Information:
- Disclosure of Your Information for Third-Party Advertising. If you do not want us to share your Personal Information with unaffiliated or non-agent third parties for promotional purposes, you can opt-out by unchecking the relevant box located on the form on which we collect your data (the order form/registration form). You can also always opt-out by logging into the applicable Website and adjusting your user preferences in your account profile by checking or unchecking the relevant boxes or by sending us an e-mail stating your request to viprivatecare.com/privacypolicies.
- Links to Internet or Mobile Sites. Our Websites may contain links to Internet or mobile sites not owned or operated by us, including to sites featuring companies, products, services or news that may be of interest or to pages that we maintain on YouTube, Facebook, Twitter or other social media sites. You should review the privacy and other policies of other Internet and mobile site providers carefully, as these policies may be different than the policies of our Websites. We assume no responsibility or liability for any third party Internet or mobile site operator’s privacy practices.
- Promotional Offers from the Company. If you do not wish to have your e-mail address/contact information used to promote our own or third parties’ products or services, you can opt-out by unchecking the relevant box located on the form on which we collect your data (the order form/registration form) or at any other time by logging into the applicable Website and adjusting your user preferences in your account profile by checking or unchecking the relevant boxes. If we have sent you a promotional e-mail, you may send us a return e-mail asking to be omitted from future e-mail distributions. This opt out does not apply to information provided to the Company as a result of a product purchase, warranty registration, product service experience or other transactions.
We do not control third parties’ collection or use of your information to serve interest-based advertising. However these third parties may provide you with ways to choose not to have your information collected or used in this way.
5.3 Accessing, Controlling Updating, Correcting and Deleting Your Personal Information.
When you use our Websites, we work to provide you the ability to access, review, correct, edit, or remove your Personal Information and related content that you have provided to us. You can do this by logging into the Website and visiting your account profile page. Although most changes will occur immediately, some information may stay stored on your browser’s web cache. We take no responsibility and are not liable for information stored in your cache or on any other electronic devices through which you may access our Websites.
For your information, removal of your Personal Information may impact our ability to provide you or your ability to use our services.
If you delete your User Contributions from our Websites, copies of your User Contributions may remain viewable in cached and archived pages, or might have been copied or stored by other Website users.
5.4 Choices for Personal Information.
5.5 Opt-Out/Changing Your Account.
You may unsubscribe or opt out of any of our email lists, electronic newsletters, bulletins, guides or marketing campaigns at any time by following the instructions included in such email or other communication by emailing to viprivatecare.com/privacypolicies.
6. STORAGE AND INTERNATIONAL TRANSFER OF PERSONAL INFORMATION.
Please note, not all countries provide the same level of data protection. In this event, we will ensure that the recipient of your Personal Information offers an adequate level of protection in the country in which it is processed, for instance by entering into standard contractual clauses for the transfer of data as approved by the European Commission with respect to the GDPR or other applicable requirements, or we will ask you for your prior consent to such international data transfers.
7. DATA RETENTION AND SECURITY
7.1 Data Retention.
We retain your Personal Information and information stored and collected through our Websites for as long as we have a business or tax need or as applicable laws, regulations, or government orders require. When your information is no longer necessary or relevant for the identified purpose or to fulfill a legal or business requirement, we will use reasonable commercial efforts to securely dispose of and destroy your information collected through the Website.
After expiry of the applicable retention periods, your Personal Information will be deleted. If there is any information that we are unable, for technical reasons, to delete entirely from our systems, we will put in place appropriate measures to prevent any further use of such Information.
7.2 Data Security.
We follow generally accepted standards, including organizational, technical and physical measures to help safeguard against the accidental or unlawful destruction, loss, alteration and unauthorized disclosure of, or access to, the Personal Information we process or use. We are not responsible for circumvention of any privacy settings or security measures contained on this Website.
You are solely responsible for protecting your password, limiting access to your devices and signing out of our Websites after your sessions. Any transmission of Personal Information is at your own risk. If you have any questions about the security of our websites, please contact us by using the information in the “Contact Information” section, below
If you have any questions about the security of our Websites, please contact us by using the information in the “Contact Information” section, below.
8. YOUR RIGHTS.
8.1. Your Rights.
You have certain rights relating to your Personal Information, subject to local data protection laws. Depending on the applicable laws, these rights may include:
- Right to Access. Making a request to access your Personal Information at any time.
- Right to Correct or Rectify. Request correction of the Personal Information that we hold about you.
- Right to Erase/Delete. Request erasure/deletion/removal of your Personal Information. Please Note: we may not always be able to comply with your request for erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Right to Object. Object to processing of your Personal Information where we are relying on a legitimate interest (or those of a 3rd 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.
- Right to Restrict Our Processing. Request restriction of processing of your Personal Information.
- Right to Transfer. Request the transfer of your Personal Information to you or directly to another controller. This right only applies to automated information which you initially provided consent for us to use or where we used the Personal Information to perform a contract with you.
- Right to Withdraw Consent. Withdraw consent at any time where we are relying on your consent to process your Personal Information. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent.
California residents are entitled once a year, free of charge, to request and obtain certain information regarding our disclosure, if any, of certain categories of Personal Information to third parties for their direct marketing purposes in the preceding calendar year. We do not share Personal Information with third parties for their own direct marketing purposes. California residents who have profiles on our Websites and are under the age of 18 are entitled, in accordance with California law, to request and obtain removal of content and information that they themselves post on the our Websites.
8.2. How to Exercise Your Rights.
To exercise your rights, please contact us by using the information in the “Contact Information” section, below. We try to respond to all legitimate requests within a month and will contact you if we need additional information from you in order to honor your request. Occasionally it may take us longer than [a month], taking into account the complexity and number of requests we receive.
To discontinue your account and/or request return or deletion of your Personal Data and other information associated with your account, please contact us by using the information in the “Contact Information” section, below.
8.3. Marketing Messages.
Generally we do not rely on consent as a legal basis for processing Personal Information except in relation to sending direct marketing communications via email or text message.
You may receive marketing communications from us if you provided us with your details when you registered for any services, seminar, promotional or networking event or attended a course and you have given us consent to send you marketing. We may also use your identity, contact details, technical data, usage data and profile data to form a view and decide which services may of interest or relevant for you.
9.2 Children’s Privacy.
We are committed to protecting the privacy of children and encourages parents and guardians to take an active role in their children’s online activities and interests. Our Websites are not directed to children or designed to attract them. You must be at least 16 years of age to use our Websites and Services. We do not knowingly collect, use, or disclose Personal Information about users that are under 16 years of age. If we later learn that a user is under 16 years of age, we will remove that user’s Personal Information from our databases and prevent the user from further using our Websites and services. If you are a user who is identified in this manner, we may require you to submit suitable proof of age, such as a copy of government-issued identification, in order to continue using the our Websites.
9.3 Monitoring and Enforcement.
In accordance with applicable laws, you may request access and raise concerns or complaints regarding your Personal Information processed by us with by contacting us: by email at firstname.lastname@example.org______________________.