Last updated: May 2018
WHAT DATA WE COLLECT
Our customers and users voluntarily provide us with data, including data that can be used to identify, either directly or indirectly, an individual (“Personal Data”) when they purchase or use our products and services (together, “Products and Services”) and access our websites or portals (“Websites” or “Portals”).
Data Provided by Users and Customers.
- Company, Name, email, country, state and telephone number, (collectively “Account Information”)
- Credit card, debit card, banking or other payment information
- Information submitted as a result of completing forms on our Websites or Portals, subscribing to, commenting on or downloading information from our Websites or Portals
- Any other information shared with us directly or indirectly through a customer’s or user’s use of the Products and Services, Websites or Portals
WHY WE USE DATA
We processes data, including Personal Data, for a variety of purposes, such as:
- With customer or user consent, e.g., to receive marketing materials
- Where necessary to comply with law
- Where the processing is necessary for the purposes of our legitimate interests, taking into account individual interests. Our legitimate interests include providing the Products and Services, internal record-keeping, billing and administrative purposes and to operate, maintain and improve the Websites or Portals
We use certain automatic data collection technologies such as cookies, and other technologies to collect data, including Personal Data, when users or customers visit the Websites or Portals, use the Products and Services or interact with us, and may share this data with our third-party marketing vendors (including for example, advertising networks and providers of external services like web traffic analysis services and analytics tools). We explain these technologies below.
Cookies. Cookies are small text files placed on a computer by a web server when browsing online and are used to store user preference data so that a web server doesn’t have to repeatedly request this information. A user may block cookies by activating the settings on the browser that blocks all or some cookies. However, if a user blocks all cookies (including strictly necessary cookies), a user may not be able to access all or parts of our Websites or Portals. We use the following cookies:
- Analytical and Performance Cookies. These cookies allow us to recognize and count the number of users visiting our Websites and Portals and see how those users navigate our Websites or Portals. This helps us to improve our Websites and Portals.
- Targeting Cookies. These cookies record visits to our Websites or Portals and the links followed. We use this information to improve our Websites or Portals and ensure the advertising displayed is relevant to users.
GLOBAL DATA MANAGEMENT
Virtual Consulting is a US organization. As a result, data collected by us, including Personal Data, may be transferred or regardless of a customer or user country of residence. Please note that by using the Products and Services, Websites or Portals or by providing Personal Data to us, customers and users acknowledge and agree that Personal Data may be sent to and processed in countries outside your country of residence, including the U.S. For individuals residing in the European Economic Area (“EEA”), and for Personal Data subject to European data protection laws, this includes transfers outside of the EEA. Some of these countries may not have data protection laws that provide an equivalent level of data protection as the laws in your country of residence, however, we will take steps to ensure Personal Data is handled in accordance with the EU-U.S. and Swiss Privacy Shield Frameworks and/or the General Data Protection Regulation, as applicable.
WHEN AND WHY WE SHARE YOUR PERSONAL DATA
We do not and will not sell Personal Data to marketers or other vendors.
We may share data, including Personal Data, in the following circumstances:
Service Providers. We may share data, including Personal Data, with our contracted third-party service providers in order to provide and improve our Products and Services, Websites or Portals or to administer surveys and user analysis to better understand user needs and preferences. These third-parties include affiliates and subsidiaries, business partners, payment and delivery services, advertising networks, analytics providers, credit reference agencies, social media companies, email distributors, marketing automation partners, customer survey companies, data storage and hosting partners, IT specialists and product developers.
Legal Purposes. We may share data, including Personal Data, as necessary to comply with applicable law, court orders, governmental agencies, for the administration of justice, to protect vital interests, to protect the security or integrity of our databases, Products and Services, Websites or Portals, or to take precautions against legal liability.
Sale. In the event of a merger, consolidation, or acquisition of all, substantially all or a portion of our business or assets, We may share data, including Personal Data. Customers and users acknowledge and agree that data, including encrypted stored data and Personal Data that We have collected, may be securely shared, disclosed and transferred to such successor or assignee.
RETENTION OF DATA
We may retain data, including Personal Data, for as long as necessary to deliver the Products and Services or as needed for other lawful purposes. We may retain anonymized or pseudonymized, aggregated data indefinitely or to the extent permitted under applicable law.
Subject to applicable data protection laws, customers and users have the following rights with respect to our handling of Personal Data:
- The right to access Personal Data held by us.
- Opt-Out. The right to object to certain processing of Personal Data (unless we have overriding compelling grounds to continue processing), including the right to opt-out of receiving direct marketing.
- The right to request correction of Personal Data that is incomplete, incorrect, unnecessary or outdated.
- Right to be Forgotten. The right to request erasure of all Personal Data that is incomplete, incorrect, unnecessary or outdated within a reasonable period of time. We will do everything possible to erase Personal Data if a user or customer so requests. However, we will not be able to erase all Personal Data if it is technically impossible due to limitations of existing technology or for legal reasons, such as we are mandated by applicable law to retain Personal Data.
- Restriction of Processing. The right to request restriction of processing Personal Data for certain reasons, such as the inaccuracy of Personal Data.
- Data Portability. If requested, we will provide Personal Data in a structured, secure, commonly used and machine-readable format.
- Right to Withdraw Consent. If Personal Data is processed solely based on consent, and not based on any other legal basis, customers can withdraw consent at any time.
- Data Protection Contact. The right to contact the relevant data protection regulator regarding our handling of Personal Data.
To exercise any of the above listed rights, email us at firstname.lastname@example.org, contact customer support at 1-310-428-1240, or mail Virtual Consulting, Inc., 11826 Dorothy St, #301, Los Angeles, CA 90049 USA Attn: Privacy. We will process requests in accordance with applicable law and within a reasonable period of time.
Virtual Consulting, Inc AS A DATA CONTROLLER AND PROCESSOR
DO NOT TRACK
Virtual Consulting belongs to advertising networks that may use browsing history across participating websites to show interest-based advertisements. Currently, our Products and Services do not recognize if a browser sends a “do not track” signal or similar mechanism to indicate the wish not to be tracked or receive interest-based advertisements.
CALIFORNIA PRIVACY RIGHTS
Under California’s “Shine the Light” law, California residents who provide Personal Data in obtaining Products and Services for personal, family or household use are entitled to request and obtain from Virtual Consulting, once per calendar year, information about Personal Data Virtual Consulting has shared, if any, with other businesses for their own direct marketing uses. Virtual Consulting does not currently share your Personal Data with other businesses for their own direct marketing uses. However, if applicable, this information would include the categories of Personal Data and the names and addresses of those businesses with which Virtual Consulting shared Personal Data for the immediately prior calendar year (e.g., requests made in 2018 will receive information regarding 2017 sharing activities). To obtain this information, please send an email to email@example.com with “Request for California Privacy Information” in the subject line, or mail Virtual Consulting, Inc., 11826 Dorothy St, #301, Los Angeles, CA 90049 USA Attn: Privacy.
Virtual Consulting, Inc and its global third-party cloud storage providers have reasonable and appropriate technical and organizational security measures in place to protect against unauthorized processing, loss, misuse and alteration of Personal Data under its control, including: (a) pseudonymization (such as where data is separated from identifiers so that linkage to an identity is not possible without additional information that is stored separately) and encryption, (b) ensuring the ongoing confidentiality, integrity, availability and resilience of systems and services used to process Personal Data, and (c) ensuring a process for regularly testing, assessing and evaluating the effectiveness of technical and organizational security measures. Please be advised that we cannot, and we do not believe that anyone can, genuinely guarantee or warrant absolute security of Personal Data disclosed or transmitted via the Internet to us or a third-party. As a result, absent Virtual Consulting, Inc gross negligence, customers and users agree to not hold Virtual Consulting, Inc responsible for the theft, destruction, loss, damage or inadvertent disclosure of Personal Data or other data provided to Virtual Consulting, Inc.
The Websites and Portals may contain links to third-party websites that Virtual Consulting, Inc does not control or maintain. Virtual Consulting, Inc is not responsible for the privacy practices employed by these third-party websites. We encourages users to read the privacy statements of such other websites before submitting any Personal Data.
Virtual Consulting, Inc does not knowingly collect or distribute any Personal Data from children under 13 years old. If a child under 13 has provided Virtual Consulting, Inc with Personal Data, the parent or guardian of that child should contact us immediately at firstname.lastname@example.org to delete this Personal Data.
CONTACT Virtual Consulting, Inc