Privacy Policy

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Privacy Policy

Last Modified: May 17, 2022.
 

We — meaning Virtual Value, Inc., doing business as Virtual Value (also "Virtual Value," "we," "our," or "us") — prepared this Privacy Policy to help you understand our practices with respect to the collection, use, and disclosure of information we collect from you through Virtual Value’s web or mobile applications, our hosted services, our websites that link to this Privacy Policy, and any other services we provide to our customers or end users (collectively, the "Services").

We may collect information from you when you:

• Create or register an account, or administer your account
• Input, post, or upload information, data, or other content through the Services
• Submit questions, requests, or other communications to us via various communication channels
• Contact us for customer support or technical support
• Visit any of our websites or download any of our applications
• Participate in any promotions, demonstrations, contests, surveys, or other marketing events
• Interact with other Virtual Value users and guests on our community forums
• Integrate third-party products and services with your Virtual Value account

Below is additional information that we may collect from you, depending on how you interact with the Services:

You (and anyone who can interact with your use of the Services) own and control the nature of the information, data, and other content you input, post, or upload through the Services ("Content"), subject to any applicable terms and conditions. Our collection, use, and disclosure practices with respect to Content are distinct from those with respect to other sorts of information, as explained in Section 2.a. below. 

Information related to the creation of accounts or that otherwise identifies you as a customer or end user of the Services is what we call "Customer Information." Customer Information may include personal information, such as your name, email address, gender, postal address, phone number and payment card information. If you are an end user using the Services through an account created on your behalf by another Virtual Value customer (such as an employer, an organization of which you are a member, or another individual), we may collect and process Customer Information about you on behalf of the Virtual Value customer with whom your use of the Services is associated.

When you create an account with Virtual Value, we may collect certain Customer Information directly from you or, if you create your account using a third-party service such as Google, Apple, or a single-sign-on service such as Okta, we may collect Customer Information about you from the third-party service (such as your username or user ID associated with that third-party service). If you create your account using such a third-party service, or if you give us permission by changing the settings on your Virtual Value account, we may also collect, and you authorize us to collect, information about your personal contacts as may be stored within that third-party service, which we may use to facilitate your invitation of collaborators to Virtual Value. By choosing to create an account using a third-party service, you also authorize us to collect Customer Information necessary to authenticate your account with the third-party service provider.

We collect information about how you use the Services and your actions on the Services, including your IP addresses, browser types, operating systems, ISPs, platform types, device types, mobile device identifiers such as make and model, and mobile carrier. We may also use tools, including third-party tools, to collect analytics data. Some of this information is collected through the use of "cookies" and other tracking technologies, such as web beacons, pixels, session replay scripts, and similar technologies ("tracking technologies").

We may also work with third-party partners to employ cookies and tracking technologies. For example, we may work with online advertising networks, social media companies and other third-party services that use cookies, tracking technologies, or other information about your use of our Services over time in order to display personalized or interest-based ads on the Services, on other websites, through apps or services you may use, and on other devices you may use. We and our third-party partners use this information to make the advertisements you see online more relevant to your interests, as well as to provide advertising-related services such as reporting, attribution, analytics and market research. Certain tracking technologies we use are related to advertising networks, and through those technologies we may share certain information such as IP addresses. Please note that the information we share with those advertising networks might be combined with other information about you that those networks may have collected from other sources.

Our uses of cookies and tracking technologies fall into the following general categories:

• Operationally Necessary. This includes tools and technologies that allow you access to our Services; are required to identify irregular site behavior, prevent fraudulent activity and improve security; and allow you to make use of our functionality;
• Performance Related. We may use technologies to assess the performance of our Services, including as part of our analytic practices to help us understand how our visitors use the Services;
• Functionality Related. We may use technologies that allow us to offer you enhanced functionality when accessing or using our Services, including, for example, identifying you when you sign into our Services or keeping track of your specified preferences, interests, or past items viewed;
• Advertising or Targeting Related. We may use first-party or third-party technologies to deliver content,      including ads, relevant to your interests, on our Services or on third-party sites.

Notwithstanding anything to the contrary in this Privacy Policy, we will not use or access your Content except in the following cases: to provide, maintain, or improve the Services; where you (or the organization through which you have an account) explicitly approve access (e.g., during a customer support inquiry); in response to lawful requests by law enforcement or government authorities; in response to subpoenas, court orders, or other legal process or requests, as required by applicable law as determined in our discretion; where necessary to ensure the stability and security of the Services and our systems (e.g., where we have reason to believe specific Content is degrading server stability); and where necessary to protect the rights, privacy, safety, or property of you, us, or others. We also may analyze metadata related to Content.

We use the information we collect for a variety of purposes, and how we use it depends on what we collect and what Services (or features of the Services) you use. These purposes may include:

• Fulfilling our Contract with You and Providing the Services to You. We may use information we collect for: (i) responding to requests or inquiries from you (including requests for customer support or technical assistance); (ii) providing customer support or technical assistance; (iii) contacting you to provide product updates, information about products you have requested or purchased, marketing Virtual Value      products, services and features that you may be interested in, and monitoring the performance of our advertisements and marketing efforts; and (iv) creating, managing, or administering your information and account, including identifying you with your account or the account of an Virtual Value customer.
• Analyzing and Improving our Services Pursuant to our  Legitimate Interest. We may use information we collect      for: (i) deriving market insights, ways to improve the Services, and other business analysis or research purposes; (ii) customizing existing and future product offerings and other aspects of the Services to you and  other users; (iii) securing the Services and our systems, and protecting  your information and data; (iv) detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, and prosecuting  those responsible for that activity; and (v) measuring interest and engagement in our Services and short-term, transient use, such as  contextual customization of ads.
• Providing You with Additional Content and Services. We may use information we collect for: (i) furnishing you with customized materials about offers, products, and services that may be of interest, including new content or services; and (ii) auditing relating to interactions, transactions and other compliance activities.
• Marketing Our Products and Services. We  may use personal information to tailor and provide you with content and  advertisements.
• Legal Obligations and Rights. We  may disclose personal information to third parties, such as legal advisors      and law enforcement: (i) in connection with the establishment, exercise, or defense of legal claims; (ii) to comply with laws or to respond to lawful requests and legal process; (iii) to protect the rights and      property of Virtual Value, our agents, customers, and others, including to enforce our agreements, policies, and Terms of Service; (iv) to detect, suppress, or prevent fraud; (v) to reduce credit risk and collect debts owed to us; (vi) to protect the health and safety of Virtual Value, our customers, or any      person; or (vii) as otherwise required by applicable law.
• Consent. We may use personal information for other purposes that are clearly disclosed to you at the time you provide personal information, or with your consent.
• Aggregated or De-Identified Data. We may use aggregated or de-identified information for a wide variety of      statistical, analytical, and Services improvement purposes. The aggregation or de-identification process prevents the information from being reassociated or identified with any one customer account, user, or      individual.
• Other Purposes. We may use information we collect for our other, legitimate business purposes.

We may disclose information we collect:

• When you ask us to, or otherwise give your specific approval to do so;
• With affiliates and subsidiaries to provide you with aspects of the Services, such as customer support;
• With vendors we engage to provide you with aspects of the Services, such as data storage, hosting, and payment processing;
• With third-party service providers who enable certain features or functionalities of the Services that you’ve requested (for example, by installing applications in Virtual Value using the Apps feature);
• With vendors we engage to help us with marketing and email campaigns, to advertise, gain insights, and perform analytics into how the Services are used and how they might be improved (for example, we may      share Customer Information with various social media platforms to engage in custom audience advertising or use third-party data enrichment services to match Customer Information or other personal information we collect with publicly available database information in order to communicate more effectively with you);
• With an employer or other organization on whose behalf you use the Services, that created an Virtual Value account on your behalf, or that owns, manages, or is associated with the email domain for an email      address on your account; or with the owner of an Virtual Value workspace to which you have access or on which you are a collaborator, but only to the extent the information pertains to such workspace or owner;
• As necessary to comply with applicable law, including  governmental requests, law enforcement requests, and otherwise to protect the rights, privacy, safety, or property of you, us, or others;
• As necessary in the event of a proposed or actual reorganization, merger, sale, joint venture, assignment, transfer,  financing, or other disposition of all or any portion of Virtual Value business, assets, or stock;
• With others for any legitimate business purpose that does not conflict with the statements made in this Privacy Policy.

For instructions on how to permanently delete Content from your Virtual Value account, please contact us at support@virtualvalue.com. Please note that permanent deletion of Content through this process may impair or disable some features of the Services (such as revision history and base snapshots) with respect to that Content.

We may use some of the information we collect for marketing purposes, including to send you promotional communications about new Virtual Value features, products, events, or other opportunities. If you wish to stop receiving these communications or to opt out of use of your information for these purposes, please follow the opt-out instructions by clicking "Unsubscribe" (or similar opt-out language) in those communications. You can also contact us at support@virtualvalue.com to opt out.

Any information that we collect is subject to the Privacy Policy in effect at the time such information is collected. We may, however, revise the Privacy Policy from time to time. If a revision is material, as determined solely by us, we will notify you, for example via email. The current version will always be posted to our Privacy Policy page.

If you have any questions about this Privacy Policy, please contact us at support@virtualvalue.com.

If you are a resident of the State of Nevada, please see below for Nevada-specific privacy disclosures:

For residents of the State of Nevada, Chapter 603A of the Nevada Revised Statutes permits a Nevada resident to opt out of future sales of certain covered information that a website operator has collected or will collect about the resident. Although we do not currently sell covered information, please contact us at support@virtualvalue.com to submit such a request.

The disclosures in this section apply solely to individual residents of the State of California ("consumers" or "you") and provide additional information about how we collect, use, disclose, and otherwise process personal information of individual residents of the State of California within the scope of the California Consumer Privacy Act of 2018 ("CCPA").

In the last 12 months, we have collected the following categories of personal information:

• Identifiers, such as your name, mailing address, email address, zip code, telephone number, or other similar identifiers.
• California Customer Records (Cal. Civ. Code §1798.80(e)), such as username and password, payment information, company name, job title, business email address, and department.
• Commercial Information, such as information about products or services purchased, obtained or considered.
• Internet/Network Information, such as your browsing history, log and analytics data, information about      the device(s) used to access the Services, domain server, search history and information regarding your interaction with our websites or Services and other usage data.
• Other Personal Information, such as personal information you provide to us in relation to a survey, comment, question, request or inquiry, information you provide when connecting a third-party account,      product or service, and any other Content you upload.
• Inferences, including information generated from your use of our Services reflecting predictions about your preferences,  characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

We collect personal information directly from you, from our business partners, from your browser or device when you visit our websites, from third parties that you permit to share information with us, and as otherwise stated above.

As described above, we share personal information with third parties for business purposes, subject to your right to opt out (see the "The Right to Opt-Out of Personal Information Sales" section below). The categories of third parties to whom we disclose your personal information may include: (i) our service providers and advisors, (ii) marketing and strategic partners; (iii) ad networks and advertising partners; (iv) analytics providers; and (v) social networks. Please see the "How We Share Information" section of the Privacy Policy above for more information about how we may share your personal information.

We do not "sell" personal information as most people would typically understand that term. However, we do use cookies and related technologies that enable certain advertising networks, social media companies and other third-party businesses to collect and disclose your personal information directly from your browser or device when you visit or interact with our websites or otherwise engage with us online. Please see the "Online Advertising and Data Collection" section below for more information about how third parties use cookies and related technologies to collect information automatically on our websites and other online Services, and the choices you may have in relation to those practices.

As a California resident, you may be able to exercise the following rights in relation to the personal information about you that we have collected (subject to certain limitations at law):

• The Right to Know any or all of the following information relating to your personal information      we have collected and disclosed in the last 12 months, upon verification of your identity:
  • The specific pieces of personal information we have collected about you;
  • The categories of personal information we have collected about you;
  • The categories of sources of the personal information;
  • The categories of personal information that we have disclosed to third parties for a business purpose, and the categories of recipients to whom this information was disclosed;
  • The categories of personal information we have sold and the categories of third parties to whom the information was sold; and
  • The business or commercial purposes for collecting or selling the personal information.
• The Right to Request Deletion of personal information we have collected from you, subject to certain      exceptions.
• The Right to Opt Out of Personal Information Sales to third parties now or in the  future.

You also have the right to be free of discrimination for exercising these rights. However, please note that if the exercise of these rights limits our ability to process personal information (such as in the case of a deletion request), we may no longer be able to provide you our products and services or engage with you in the same manner.

To Exercise Your Right to Know or Right to Deletion

To exercise your right to know and/or your right to deletion, please submit a request by emailing support@virtualvalue.com with the subject line "California Rights Request".

We will need to verify your identity before processing your request. In order to verify your identity, we will generally require either the successful login to your account (if applicable) or the matching of sufficient information you provide us to the information we maintain about you in our systems. Although we try to limit the personal information collected in connection with a request to exercise the right to know and/or the right to deletion to that personal information identified in your request, certain requests may require us to obtain additional personal information from you. In certain circumstances, we may decline a request to exercise the right to know and/or right to deletion, particularly where we are unable to verify your identity or locate your information in our systems, or as permitted by law.

To Exercise Your Right to Opt Out of Personal Information Sales

As noted above, we do not "sell" personal information as most people think of that term. Please see the "Online Advertising and Data Collection" section below for more information about how third parties use cookies and related technologies to collect information automatically on our websites and other online Services, and the choices you may have in relation to those activities.

As described above, we use third-party partners to engage in online advertising. By visiting www.privacyrights.info or optout.privacyrights.info, you can opt out from sales of personal information by businesses that participate in the opt out tool. To make opt-out requests related to mobile apps on your device for businesses participating in the DAA’s CCPA App-based Opt-Out Tool, you can download the appropriate app at www.youradchoices.com/appchoices. Please see the "Managing Cookies and Tracking Technologies" section of our Privacy Policy for more information about how third parties use cookies and related technologies to collect information automatically on our websites and other online services, and the choices you may have in relation to those practices.

We do not sell the personal information of consumers we know to be less than 16 years of age. Please contact us at support@virtualvalue.com to inform us if you, or your minor child, are under the age of 16.

In addition to the rights described above, California's "Shine the Light" law (Civil Code Section §1798.83) permits California residents that have an established business relationship with us to request certain information regarding our disclosure of certain types of personal information to third parties for their direct marketing purposes during the immediately preceding calendar year.

To make such a request, please send an email to support@virtualvalue.com.

This section contains disclosures on how we collect, store, process, transfer, share and use data that identifies or is associated with residents of the European Economic Area ("EEA"), Switzerland, and the United Kingdom ("UK") ("personal data"). These EU Disclosures apply solely to residents of the EEA, Switzerland, and the UK ("you"). Unless otherwise expressly stated, all terms in this section have the same meaning as defined in the General Data Protection Regulation ("GDPR"). Virtual Value is the controller of the personal data we hold about you in connection with your use of the Services.

• Personal Data We Collect From You When You Use the Services and How We Use It. We collect personal data as set out in the "What Information We Collect" and "How We Use the Information We Collect"      above. We will indicate to you where the provision of certain personal data is mandatory. If you choose not to provide such personal data, we may not be able to provide those parts of the Services to you or respond to your other requests.
• Information We Collect About You Automatically. Please see the "What Information We Collect"  section above.
• How Long Will We Store Your Personal Data. We will usually store the personal data we collect about you for no longer than necessary for the purposes for which it was collected, including for the purposes of satisfying any legal or reporting requirements, and in accordance with our legal obligations and legitimate business interests.  To determine the appropriate retention period for personal data, we     consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and the applicable legal requirements.
• Lawful Basis of Processing. We collect and process your personal data for purposes set forth in this Privacy Policy. Where required by law, we obtain your consent to use and process your personal data for these purposes. Otherwise, we rely on another authorized legal basis (including but not limited to the (a) performance of a contract or  (b) legitimate interest) to collect and process your Personal Data.
• Recipients of Personal Data. We may share your personal data with the recipients as set out in the "How We  Share Information" section above.
• Marketing and Advertising. From time to time we may contact you with information about our products and services, including sending you marketing or advertising messages and asking for your feedback on our products and services. For some marketing or advertising messages,  we may use personal data we collect about you to help us determine the most relevant marketing or advertising information to share with you. We will only send you marketing or advertising messages if you have given us your consent to do so. You can withdraw your consent at a later date by clicking on the unsubscribe link at the bottom of our marketing or advertising emails or by contacting Virtual Value Support at support@virtualvalue.com.
• International Transfers of Your Personal Data. The personal data we collect may be transferred to and stored in countries outside of the jurisdiction you are in where we and our third-party service providers have operations, including in the United States. If you are accessing our Site from the EEA, your personal data will be processed outside of the EEA. In the event of such a transfer, we ensure that: (i) the personal data is transferred to countries recognised as offering an equivalent level of protection; or (ii) the transfer is made pursuant to appropriate safeguards, such as standard data protection clauses adopted   by the European Commission. Virtual Value is closely monitoring developments and guidance from both European and U.S. regulatory authorities and will update these EU Disclosures as needed. If you wish to enquire further about these safeguards used, please contact us using the details set out at the end of these EU Disclosures.
• Your Rights in Respect of Your Personal Data. In accordance with applicable privacy law, you have the following rights in respect of your personal data that we hold: (i) Right of access; (ii) Right of portability; (iii) Right to rectification; (iv) Right to erasure; (v) Right to restriction; (vi) Right to withdraw consent; and (vii) Right to object.

You also have the right to lodge a complaint to your local data protection authority. Information about how to contact your local data protection authority is available here.

If you wish to exercise one of these rights, please submit a request by:

• Emailing support@virtualvalue.com with the subject line "European Rights Request".

Due to the confidential nature of data processing we may ask you to provide proof of identity when exercising the above rights.