Privacy Policy

VCV Digital Group LLC – Website Privacy Policy

Last modified: [May 2, 2022]

Introduction

VCV Digital Group LLC (“Company”, “we”, “us” or “our”) respects your privacy and is committed to protecting it through our compliance with this policy.

This policy describes the types of information we may collect from you, the user (“user”, “you”, or “your”) or that you may provide when you visit the website www.vcvdigital.com (our “Website”) and our practices for collecting, using, maintaining, protecting, and disclosing that information.

This policy applies to information we collect:

  • On this Website.
  • In email and other electronic messages between you and this Website.

It does not apply to information collected by:

  • Us offline or through any other means, including on any other website operated by the Company or any third-party (including those operated by our affiliates and subsidiaries); or
  • Any third-party (including our affiliates and subsidiaries), including through any application or content that may link to or be accessible from or through the Website.

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Website. By accessing or using this Website, you agree to this Privacy Policy. This policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of this Website after we make changes is deemed to be acceptance of those changes, so please check the Privacy Policy periodically for updates.

Children Under the Age of 16

Our Website is not intended for children under 16 years of age. No one under age 16 may provide any personal information to the Website. We do not knowingly collect personal information from children under 16. If you are under 16, do not use or provide any information on this Website or provide any information about yourself to us, including your name, address, telephone number, or email address. If we learn we have collected or received personal information from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us at the email address provided in the Contact Information section.

California residents under 16 years of age may have additional rights regarding the collection and sale of their personal information. Please see State Specific Privacy Rights for more information.

Information We Collect About You and How We Collect It

We may collect several types of information from and about users of our Website, including information:

  • By which you may be personally identified, such as name, postal address, email address, telephone number (“personal information”);
  • That is about you but individually does not identify you;
  • About your internet connection, the equipment you use to access our Website, and usage details.

We may collect this information:

  • Directly from you when you provide it to us.
  • Automatically as you navigate through the Website. Information collected automatically may include usage details, IP addresses, and information collected through cookies, and other tracking technologies.

Information You Provide to Us 

The information we collect on or through our Website may include:

  • Information that you provide by filling in forms on our Website. This includes information provided through our “Contact Us” page. We may also ask you for information when you report a problem with our Website.
  • Records and copies of your correspondence (including email addresses), if you contact us.
  • Your search queries on the Website.

Information We Collect Through Automatic Data Collection Technologies 

As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

  • Details of your visits to our Website, including traffic data, logs, and other communication data and the resources that you access and use on the Website.
  • Information about your computer and internet connection, including your IP address, operating system, and browser type.

We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking).

The information we collect automatically does not include personal information and we will not associate information collected automatically with personal information we collect in other ways unless we suspect a violation of the Website Terms of Use or this Privacy Policy. The information we collect automatically helps us to improve our Website and to deliver a better and more personalized service, including by enabling us to:

  • Estimate our audience size and usage patterns.
  • Speed up your searches.
  • Recognize you when you return to our Website.

The technologies we use for this automatic data collection may include:

  • Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.
  • Web Beacons. Pages of our Website may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages and to obtain other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

The categories of personal information collected by the Company from its Website users within the last twelve (12) months are set out in Exhibit A attached to this Privacy Policy.

How We Use Your Information

We use information that we collect about you or that you provide to us, including any personal information:

  • To present our Website and its contents to you.
  • To provide you with information, products, or services that you request from us.
  • To fulfill any other purpose for which you provide it.
  • To carry out our obligations and enforce our rights arising from any contracts entered into between you and us including our Website Terms of Use.
  • To notify you about changes to our Website or any products or services we offer or provide though it.
  • 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 products and services that may be of interest to you. If you do not want us to use your information in this way, please contact us as described in the Contact Information section.

Disclosure of Your Information

We may disclose aggregated information about our users without restriction.

The Company does not sell any of your personal information to any third-party for any purpose, including for advertising or marketing, nor have we sold personal information to a third-party in the preceding twelve (12) months. We may disclose personal information that we collect or you provide as described in this Privacy Policy:

  • To our subsidiaries and affiliates.
  • To contractors, service providers, and other third-parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.
  • To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of the Company’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by the Company about our Website users is among the assets transferred.
  • To fulfill the purpose for which you provide it.
  • 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.
  • To enforce or apply our Terms of Use and other agreements.
  • If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the Company, our customers, or others.

In the preceding twelve (12) months, the Company has disclosed for a business purpose only such categories of personal information as set out in Exhibit A attached to this Privacy Policy.

Choices About How We Collect, Use, and Disclose Your Information

We strive to provide you with choices regarding the personal information you provide to us. You are not obligated to provide your name, e-mail address, phone number, or other personal information to access or use the Website but only if you wish to provide such information on our “Contact Us” page. You may also set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, however, please note that some parts of this site may then be inaccessible or not function properly.

Residents of certain states, such as California and Nevada, may have additional personal information rights and choices. Please see State Specific Privacy Rights for more information.

Accessing and Correcting Your Information

You may send us an email at the email address specified in the Contact Information section to request access to, correct or delete any personal information that you have provided to us. We will retain and use your information after deletion only as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. We cannot guarantee that any information that remains in backup or archived media retained by our third-party service providers will be deleted in its entirety. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

Third-Party Websites and Applications

We may provide links to other websites or applications operated by third-parties for your convenience and information. All of these websites and applications operate independently from us and we do not control their privacy practices. We encourage you to review the privacy policies of any third-party websites or applications that you use to better understand their privacy practices.

State Specific Privacy Rights

California Residents’ Rights

This section applies solely to natural persons using our Website who reside in the State of California (“consumers”, “you” or “your” as used in this section). Any terms defined in the California Consumer Privacy Act of 2018 (CCPA) have the same meaning when used in this section of the Privacy Policy.

The CCPA provides you with specific rights regarding your personal information. This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights. You have the right to request us to 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 or your authorized agent’s verifiable consumer request, we will disclose to you or your authorized agent:

  • 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:
    • sales, identifying the personal information categories that each category of recipient purchased and for each category identified, the categories of third-parties to whom we sold that particular category; and
    • disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained and for each category identified, the categories of third-parties to whom we disclosed that particular category.

Deletion Request Rights. You have the right to request the Company to delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and verify a request from you or your authorized agent, we will delete (and direct our service providers to delete) your personal information from our, and their 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, fulfill the terms of a written warranty, 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, or prosecute those responsible for such activities.
  • Debug products to identify and repair errors that impair existing intended functionality.
  • Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another 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 your expectations based on your relationship with us.
  • Comply with a legal obligation.
  • Make other internal, lawful uses of that information 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, you or your authorized agent must submit a verifiable consumer request to us using one of the methods noted under the Contact Information section.

Only you, or someone legally authorized 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 twelve (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; and
  • 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 that the personal information relates to you.

Making a verifiable consumer request does not require that you fill out any form on our Website or otherwise register with us.

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 endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 45 days), we will inform you of the reason and extension period in writing.

Any disclosures we provide will only cover the twelve (12) month period preceding the date of your verifiable request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will provide your personal information in the manner you choose at the time of submitting the request.

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.

Non-Discrimination.  We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

  • Deny you goods or services;
  • Charge you different prices or rates for products 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 products or services or a different level or quality of products or services.

Other California Privacy Rights. California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Website 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 an email to the address specified in the Contact Information section.

Nevada Residents’ Rights

Nevada residents who wish to exercise their sale opt-out rights under Nevada Revised Statutes Chapter 603A may submit a request to the email specified in the Contact Information section. However, please know we do not currently sell data triggering that statute’s opt-out requirements.

Data Security

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.

Information Collected from Users Outside the United States

If you utilize the Website from outside the United States and provide us with personal information, please note that your personal information collected by us will be transferred, stored and processed in the United States. The laws of the United States applicable to the storage and use of personal information may be less protective than the law of your jurisdiction. By accessing our Website or contacting us on our Website, you are voluntarily transferring your personal information to facilities located in the United States and other of the Company’s facility locations.

Changes to Our Privacy Policy

It is our policy to post any changes we make to our Privacy Policy on this page. If we make material changes to how we treat our users’ personal information, we will notify you through a notice on the Website home page. The date the Privacy Policy was last revised is identified at the top of the page. You are responsible for periodically visiting our Website and this Privacy Policy to check for any changes.

Contact Information

To ask questions or comment about this Privacy Policy and our privacy practices, or to otherwise notify us as provided in this Privacy Policy, contact us at privacy@vcvdigital.com or call 1-800-745-7419.

Exhibit A

Categories of Personal Information Collected and Disclosed During the Last 12 Months

 

 

Category Examples Collected Categories of Third-Party Recipients
Business Purpose Disclosures Sales
A. Identifiers. A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers. Yes To affiliates and service providers No
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).

A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.

Some personal information included in this category may overlap with other categories.

Yes To affiliates and service providers No
C. Protected classification characteristics under California or federal law.

Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).

 

No No No
D. Commercial information. Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. No No No
E. Biometric information. Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data. No No No
F. Internet or other similar network activity. Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement. Yes To affiliates and service providers No
G. Geolocation data. Physical location or movements via IP address only. Yes No No
H. Sensory data. Audio, electronic, visual, thermal, olfactory, or similar information. No No No
I. Professional or employment-related information. Current or past job history or performance evaluations. No No No
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)). Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. No No No
K. Inferences drawn from other personal information. Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. No No No

 

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