Effective: March 22, 2019
We use the terms “personal information” and “personal data” to mean any information relating to an identified or identifiable individual. If you are located in the European Economic Area (“EEA”), please also see our Supplemental EEA Privacy Statement below.
Should you have any questions regarding this Policy, you can contact our Data Protection Officer by email at firstname.lastname@example.org, or by mail at:
200 Granville Street, Mezzanine Floor
Vancouver, BC V6C 1S4
Attention: Data Protection Officer
You may also call us at any of our numbers listed at www.visioncritical.com/contact-us/.
What Types of Information Do We Collect?
Information You Actively Submit on our Site: If you create an account, fill out a form, send an email to our team, or otherwise send us information through the Site, we collect personal information about you. The Site has webpages that allow you to submit a variety of personal information to us, including contact information such as your name, email address and physical address, social media information such as your social media account name, login information such as a user name and password, and other information such as survey responses, photo uploads, and forum posts. In each instance, you will know what personal information we collect because you will actively submit it.
Combined: We may link information that you automatically provide with information that you actively submit. When such
How Do We Use Your Personal Information?
We use personal information that we collect about you as follows:
• Upon request, to create an account for you;
• To enable you to use online interactive forums that we may offer;
• To provide requested services and information;
• To respond appropriately to your inquiries and requests;
• To discharge our contractual obligations to you;
• To send you invites and service emails if you become a member of our communities as part of your ongoing membership;
• To contact you to administer rewards such as sweepstakes/contests;
• To comply with any legal obligations that apply to us;
• If you submit an employment application, to administer and evaluate your application and comply with legal obligations we have in relation to your application; and
• To secure, optimize and customize your experience on the Site.
To the extent permitted by applicable law, we may use your personal information to contact you with sales and marketing communications. You may at any time choose to stop receiving marketing emails from us by using one of the unsubscribe options we provide. Please see the Your Choices section of this Policy for more information about opting-out of communications. Service-related communications that Vision Critical sends to our own customers are covered in the Our Clients section of this Policy.
For How Long Do We Keep Your Personal Information?
We generally retain your personal data for as long as you have a business relationship with us and for 3 years thereafter, unless we are required to delete or anonymize it sooner. In some cases, we may be required to retain personal data for a longer period of time based on laws or regulations that apply to our business or for other necessary business purposes. Where possible, we aim to anonymize the information or remove unnecessary identifiers from records that we may need to keep for periods beyond the original retention period.
To Whom Do We Disclose Your Personal Information?
We do not share your personal information with third parties, except in the following cases:
• with your consent;
• with affiliated and unaffiliated services providers that act on our behalf and under our instructions to help us operate our business (data processors);
• in redacted or aggregated form that cannot be used to identify you individually;
• if required or permitted by law, including as necessary to comply with the law, to protect the rights or safety of Site users, other users, or third parties (e.g., for fraud protection and credit risk reduction purposes; for protecting and defending the rights or property of Vision Critical, its customers, other users, or members of the public); or
• with a buyer of all or substantially all of our assets relating to a particular business line or division, or in connection with a merger, acquisition, reorganization or restructuring.
You have a variety of choices regarding which personal information we may collect, process and use and for what purposes. Wherever reasonably practical, we will provide you with the ability to use the features of the Site without submitting personal information to us or to use a pseudonym. Some areas of the Site however, such as registration forms, questionnaires and submissions to our Careers section require you to provide accurate and up to date personal information and your choice is to not use such areas and features.
You can contact us to request that we correct or stop using your personal information, or to find out what personal information we have collected about you:
• Email Communications – You may opt-out of receiving marketing and other promotional emails from us at any time by clicking the unsubscribe links embedded within the emails we send, or by contacting us directly at email@example.com. Members of communities we own can opt-out of participating by using the unsubscribe links embedded in emails, or by using the subscription preference options in the Profile / Settings section of the member hub. Some emails are transactional in nature, including emails we send to our clients regarding the services they have purchased. These emails do not provide the ability to opt-out.
• Data Access, Correction & Deletion – You may request access to your personal information to confirm that it is in our possession, to ensure that it is accurate and to make corrections, or to request that it be removed/anonymized. We will respond to your request as quickly as possible and will need to verify your identity before providing you with access to the personal information we hold about you.
In some cases, we may be unable to accommodate your request if we are unable to verify your identity, if we are prohibited by law, if disclosure would result in the disclosure of the personal information of others, or if the request is unreasonable or impractical. If we are unable to process your request for these or any other reasons, we will provide you with an explanation of the reason for denial, and you will be permitted to request a review.
All requests for information should be sent by email to firstname.lastname@example.org or to the mailing address listed above.
International Considerations and Data Transfers
Information collected on this Site may be processed outside of the country you are visiting from. We process personal information in Canada, the United States, Australia, the European Union, the United Kingdom, South Africa, Singapore, Hong Kong and Japan. Occasionally, we use service providers located in these and other jurisdictions including Israel and India to process data on our behalf and under our instructions. When transferring your personal information, we take appropriate measures to protect it in accordance with applicable laws and this Policy.
Vision Critical has implemented commercially reasonable safeguards and precautions to protect your personal information, including technical and organizational measures against unauthorized access, improper use, alteration, unlawful or accidental destruction, and accidental loss. These measures include utilizing secure Transport Layer Security (“TLS”) connections for data collected via our platform, employee training, policies, and secure facilities. Access to personal information is restricted to employees and contractors who have a need to know and who are required to maintain the confidentiality and security of information. Please note that despite our use of the safeguards described above, we cannot guarantee that personal information you submit to us will never be accessed, disclosed, altered, or destroyed in a manner that is inconsistent with this Policy.
• AUP / Reporting Abuse – Vision Critical has a comprehensive Acceptable Use Policy (“AUP”), available at http://www.visioncritical.com/legal/AUP.pdf outlining the acceptable use of our services and our clients are required to abide by the terms of the AUP at all times. Vision Critical disclaims any responsibility for clients who use our services to engage in illegal or unethical behavior and will take any action we deem necessary should we discover such activity is taking place including suspension or termination of service. If you suspect a breach of the AUP, or have concerns with the manner in which our clients are using our services, please immediately contact us at email@example.com. If you have general questions including requesting to opt-out of our client’s use of your data, please use the support link provided within your member hub.
• Vision Critical Communications to our Clients – When we are required to do so in order to provide services to our clients, we may send service-related emails such as maintenance notifications, responses to support inquiries, billing notices, account management emails, and password reset emails. Generally, you may not opt-out of these types of communications as they are not promotional in nature. We will occasionally send promotional emails as well, which do provide you the ability to opt-out of similar communications. We may also communicate with you by phone or postal mail.
This site is not intended for or directed at children and we do not knowingly collect personal information from any person under the age of 13. If we discover that we have inadvertently collected personal information from a person under 13 years of age, we will promptly take commercially reasonable measures to delete such information from our systems.
Changes To This Policy
We may change the terms of this Policy at any time at our sole discretion so please review it periodically. To view previous versions of this Policy, please visit the Archive linked below.
Supplemental EEA Privacy Statement
European Union Regulation 2016/679 of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (“EU GDPR”), requires Vision Critical as the data controller to provide additional and different information about its data processing practices to data subjects in the EEA. If you are accessing the Site from a member state of the EEA, this Supplemental EEA Online Privacy Statement applies to you in addition to the Policy above.
Our GDPR-specific representative is Vision Critical GmbH, Kaiser-Wilhelm-Ring 17-21, 50672, Cologne, Phone: +49 221 65088931. Our Data Protection Officer may be contacted at firstname.lastname@example.org.
What Are Our Legal Bases for Processing Personal Data?
We process the personal data of users of our Site on several different legal bases, as follows:
Where Do We Transfer Personal Data and How Do We Protect Such Transfers?
We disclose your personal data to recipients in the following jurisdiction or jurisdictions outside of the EEA which provide adequate protection to personal data according to the European Commission: Canada, Israel, and the United States (limited to the Privacy Shield framework). In each case, the transfer is thereby recognized as providing an adequate level of data protection from a European data protection law perspective (see Article 45 of the EU GDPR).
We disclose your personal data to recipients in the following jurisdiction or jurisdictions outside of the EEA which do not provide adequate protection to personal data according to the European Commission: Australia, the United States (where the Privacy Shield framework has not been applied), South Africa, Singapore, Hong Kong, Japan and India. By entering into appropriate data transfer agreements based on Standard Contractual Clauses (2010/87/EU and/or 2004/915/EC) as referred to in Article 46(5) of the EU GDPR or other adequate means, we have established that all such recipients will provide an adequate level of data protection and that appropriate technical and organizational security measures are in place to protect personal data against accidental or unlawful destruction, loss or alteration, unauthorized disclosure or access, and against all other unlawful forms of processing. Any onward transfer (including to our affiliates outside the EEA) is subject to appropriate onward transfer requirements as required by the applicable contract or applicable law. You can ask for a copy of such appropriate data transfer agreements by contacting email@example.com.
What Data Subject Rights Do You Have?
Under the conditions set out under the EU GDPR and any other national data protection laws in the EEA, you have the following rights:
Please note that these rights may be limited under the applicable national data protection law. To exercise your rights please contact us at firstname.lastname@example.org.
Are You Required to Provide Personal Data?
You are not required to provide any personal data to us, but if you do not provide any personal data to us, you may not be able to use certain features of the Site, such as those available to account holders, such as participants on our platform, job applicants, among others. You can use the Site without consenting to cookies that are not strictly necessary; which will mean that your experience on the Site will be less tailored to you and certain features of the Site may not function as intended. You can also use the Site without consenting to receiving marketing communications from us; which will mean that you may not receive marketing communications that you may be interested in.