Last updated: June 14, 2023
Please note that our privacy practices for the Vimocity application and other services are described separately in the Vimocity Services Privacy Notice.
- “PERSONAL DATA” DEFINED
When we say, “Personal Data,” we mean any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. Personal Data falls within certain categories, for example:
- Identifiers (e.g., name, email, telephone number, address, username);
- Sensitive Personal Data (e.g., government identification number; precise geolocation; racial or ethnic origin; religious beliefs; health information; contents of messages when we are not the recipient; in some cases, information about a known child);
- Legally protected information (e.g., race, citizenship, marital status, sex);
- Employment-related information (e.g., current or past employment);
- Non-public educational information, including information protected under the Family Educational Rights and Privacy Act (20 U.S.C. § 1232g, 34 C.F.R. Part 99);
- Biometrics (e.g., DNA, face/voice prints, health data) and audio, electronic, visual, thermal, or olfactory information;
- Commercial information (e.g., products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies);
- Internet or other similar activity (e.g., browsing history; content interactions); and
- Inferences that are drawn from Personal Data to create a profile about preferences, characteristics, trends, predispositions, behavior, attitudes, intelligence, and aptitudes.
Please note that certain information is exempt from privacy law protections. For example, publicly available information, aggregated information (meaning data summaries or reports with Personal Data removed), and anonymized information that cannot be linked back to an individual are types of information that may not be legally protected as Personal Data.
- PERSONAL DATA COLLECTION & USE
- Identifiers collected with Site visitor consent. Vimocity collects identifiers, specifically names and email addresses, directly from Site visitors with their consent. Visitors submit this Personal Data via the Site to inquire about our services or to otherwise communicate with us. We use this Personal Data to respond to Site visitor inquiries and to communicate with the Site visitor according to their stated preferences.
- Internet activity collected with a legitimate interest. Vimocity collects Site visitor internet activity to achieve our legitimate interests related to improving the Site visitor experience and troubleshooting Site functionality. Internet activity is technical data that may include some Personal Data, for example, Site visitor IP address, log data, generalized geolocation, error messages, and device identifiers.
- Site Cookies. Like most commercial websites, the Site uses session and persistent Cookies for visitor authentication, fraud prevention, and remembering visitor logins and language preferences from one session to the next. These cookies are essential to the functionality of the Site.
- RETENTION OF PERSONAL DATA
Vimocity retains Personal Data only as long as necessary for the purpose of its collection. We securely delete data after the applicable retention period. Vimocity reserves the right to retain data for longer periods as required by law or court order or if doing so is critical to our business.
- DISCLOSURES OF PERSONAL DATA
Vimocity will only disclose Personal Data collected via the Site as described in this section, with the Site visitor’s permission, or as required by law. In the preceding 12 months, we have disclosed Personal Data for a business purpose to:
- Our Service Providers. Service Providers like IT support, billing processors, or email and data hosting providers may have access to Personal Data as needed to perform their contractual obligations to us. We prohibit our service providers from selling or further disclosing Personal Data, and we require all service providers to maintain confidentiality standards and appropriate technical and organizational measures to ensure the security of your Personal Data.
- Other third parties, as permitted by applicable law, for example, if we go through a business transition (e.g., merger, acquisition, or sale of a portion of our assets), to comply with a legal requirement or a court order, when we believe it is appropriate to take action regarding illegal activities or prevent fraud or harm to any person, to exercise or defend our legal claims, to law enforcement or other government agencies where required by law, or for any other reason with your consent.
- Aggregated and Deidentified Information. Vimocity reserves the right to share aggregated data sets with nonaffiliated entities for any purpose without restriction.
- YOUR PRIVACY CONTROLS
You can directly control how we collect and use your Personal Data as follows:
- Device Settings. You can control the data we collect through cookies and related technologies by adjusting your device settings. Please note that blocking cookies may result in your inability to use certain Site features.
- Emails. Vimocity may send you emails related to your inquiries to us or marketing emails according to your stated communication preferences. If you do not wish to receive emails from us, you can unsubscribe or change your preferences via the links provided in the emails.
- Texting. If you provide us with your wireless phone number, you consent to Vimocity sending you informational text messages. The number of texts you receive will depend on the Site you use and the information you request from us. You can unsubscribe from our text messages by replying STOP or UNSUBSCRIBE to any of these text messages. Messaging and data charges may apply to any text message you receive or send. Please contact your wireless carrier if you have questions about messaging or data charges.
- Privacy Requests. To exercise your rights under your applicable privacy laws (see Section 6) beyond the methods described above, or if you want to express concerns, revoke your consent, lodge a complaint, or request information, please contact firstname.lastname@example.org. In some cases, we may be required to forward your request to your Employer for processing. In all cases, Vimocity can only assist with or fulfill a privacy request when we have sufficient information to verify that the requester is the person or an authorized representative of the person about whom we have collected Personal Data, and to properly understand, evaluate, and respond to the request. We do not charge a fee to process or respond to a verifiable request unless we have legal grounds to do so. 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. We endeavor to respond to privacy requests following the requirements of the law applicable to your jurisdiction.
- Do Not Track. Do Not Track signals are signals sent through a browser informing us that you do not want to be tracked. Currently, our systems do not recognize browser “do-not-track” requests.
- NOTICE OF PRIVACY RIGHTS
Depending on where you reside, you may be legally entitled to certain privacy rights over the Personal Data that we collect and process about you. For Site visitors in the United States, consumer privacy is governed by federal privacy laws covering specific industries or data uses and state privacy laws providing general consumer privacy rights. For example, California, Colorado, Connecticut, Iowa, Nevada, Utah, Virginia, and other states require companies to inform consumers about their privacy rights and provide a method to exercise those rights.
The European Union’s General Data Protection Regulation and its counterpart regulation in the United Kingdom entitle data subjects to control whether and how their Personal Data is collected and used by businesses. Vimocity collects and processes the Personal Data of Data Subjects via the Site as a controller. Please note that any Personal Data collected through the Site is collected as processor and service provider to the Data Subject’s Employer.
If you are in Canada, the Personal Data Protection and Electronic Documents Act and other provincial privacy laws give Canadians specific rights regarding their Personal Data. Additionally, Australia, as well as many countries within the continents of Africa, South America, and Asia, have enacted comprehensive consumer privacy laws offering a broad spectrum of consumer rights over their Personal Data.
As part of our commitment to your privacy, Vimocity provides this notice of privacy rights:
- Vimocity does not intend to collect any health data about you. However, if you provide us with health data, we will never share or sell it.
- You have the right to the accuracy of your Personal Data. If your Personal Data on our systems is not accurate, you may have it corrected. If you learn that we are holding inaccurate or outdated Personal Data about you, please inform us and we will update our records.
- Upon request, we will provide you with copies of your Personal Data. Please be specific in your request so we can send you the most helpful data.
- You may request that we delete your Personal Data. We may permanently delete, deidentify, or aggregate Personal Data in response to a request for deletion. If you submit a deletion request, we will confirm the Personal Data to be deleted before its deletion, and we will notify you when your request is complete. The right to deletion is not absolute, and we may be entitled to retain and process your Personal Data despite your request.
- You can request more details about how we use your Personal Data and with whom we may share it. Upon request, we will send you a list of the Personal Data we have collected about you, where we got it, and details about how we have used it. We will tell you if we disclose your Personal Data to affiliates and/or third parties for marketing purposes.
- Vimocity does not intend to collect Personal Data that is sensitive in nature, and in no case will we use or disclose sensitive Personal Data for inferring characteristics about you.
- Vimocity does not sell Personal Data or share it with third parties for cross-contextual advertising.
- The Site does not use profiling or automated decision-making.
- We will limit our processing of your Personal Data upon your request and where we are required to do so by law. For example, if the data is inaccurate, we no longer need the data, you object to processing, or our processing violates your rights.
- Vimocity will not treat you differently or offer you a different service level as a result of your exercise of privacy rights.
- You are welcome to submit requests, questions, or complaints to Vimocity at email@example.com.
- If you are a data subject from the EU or UK and you feel we have not adequately resolved a privacy issue, you have the right to file a complaint with a supervisory authority. We suggest the Data Protection Commissioner of Ireland.
It is Vimocity’s policy to provide the Site in compliance with all applicable laws. If you wish to exercise a privacy right available to you, please contact firstname.lastname@example.org. We will respond to your request as required by applicable law.
- DATA SECURITY
Vimocity has implemented and maintains reasonable security measures to secure your Personal Data from accidental loss and unauthorized access, use, alteration, and disclosure. Our security measures are appropriate to the volume, scope, and nature of the Personal Data processed and designed to meet our duty of care for your Personal Data. Nevertheless, given the possibility of the unlawful interception of information, we cannot guarantee, and you should not expect that the information you provide to us will always remain private or secure. Should you suspect any misuse, loss of, or unauthorized access to your Personal Data, you should contact us immediately.
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