“Personal Data” means any information relating to an identifiable individual. Some examples of Personal Data include names, addresses, e-mail addresses, phone numbers, photographs and online identifiers.
“Process” or “Processing” means any action that a person can take with respect to Personal Data, including collecting, using, sharing, and altering Personal Data.
2. Why We Collect Personal Data
We may collect Personal Data in order to fulfill the following purposes (the “Purposes”):
- to provide our Services to you;
- to respond to your communications with us;
- to contact you about updates to the Services, marketing and promotional offers, and service-related communications;
- for internal statistical and operational purposes to better understand how our Services are used and experienced by users;
- to improve our Services, such as through monitoring your use of our Services for security and function; and
- to carry out any other purpose which is disclosed to you and for which you consent, or as is otherwise permitted by applicable law.
3. What Personal Data We Collect
Personal Data that we may collect through your use of the Services includes, without limitation:
- information that you volunteer to us when you use the Services, such as
- personal information (first and last name, email, username, your profile photo)
- in-app messages (for example, your comments, or instant messages).
- app activity (information how you interact with the app, for example, the number of times you visit a page or sections you tap on.
- app statistics, such as crash reports or other app performance data to help us improve the app performance and/or your user experience.
- information about how you use the Services (e.g., your length of visits to our app or website, the time and frequency of your visits, the functions and features you use, and other use metrics); and
- information about your computer or mobile device, such as your Internet protocol (IP) address, device ID, browser and operating system type, resolution of your screen, language settings in your browser, referring URLs, and other technical information.
4. How We Collect Personal Data
(a) Collection through Services. We may collect Personal Data from you and any devices that you use when:
- you communicate with us; or
- you subscribe to any of our mailing lists.
For clarity, collection of certain Personal Data occurs automatically through your use of our website, such as through our implementation of cookies and web analytics further described below. You may be able to opt-out of these methods of collection as further described below. Please contact us if you have any questions about opting out of such collection.
Most web browsers allow you to modify your settings to notify you when you receive a cookie or to reject cookies entirely. Your computer also provides you with the ability to clear all cookies that have been stored onto your hard drive, should you wish to do so. However, please be aware that you may be unable to access certain parts of the Services if you block or disable our cookies. For more information about cookies, please see: https://www.allaboutcookies.org/.
(c) Analytics. We may use in-app and web analytics services (e.g., Google Analytics) in order to better understand the user experience on our website, including without limitation:
- how you reached our website;
- the website you came from;
- how long you stayed on our website;
- what pages you looked at;
- how many pages you looked at;
- what buttons you clicked;
- what browser you are using; and
- what device you are using.
Any use of analytics services by us will result in analytics providers collecting your Personal Data when you access and use our website. These third parties may set and access their own tracking technologies (including cookies and web beacons) and may otherwise collect or have access to your device identifier, site usage information, and related information about you.
If you do not wish to participate in web analytics, you may be able to download an opt-out browser add-on. Your web browser may also allow you to set a “Do Not Track” signal when you use online services. To learn more about “Do Not Track” signals, visit http://www.allaboutdnt.com/. You may also contact us at the “Contact Us” section below regarding any questions about web analytics services that we may use.
5. Grounds for Processing Personal Data
(a) General. We will not process your Personal Data without your consent, unless we are permitted or required to do so by applicable law. Your consent may be express or implied. The type of consent that we may rely on in processing your Personal Data will vary based on your reasonable expectations, the sensitivity of your Personal Data, and the circumstances surrounding the collection of your Personal Data. Express consent is when you willingly agree (e.g., orally, in writing, or electronic agreement) to the processing of your Personal Data for particular purposes. Implied consent is when: (i) you do not expressly give consent, but you rather volunteer Personal Data for obvious purposes that a reasonable person would consider appropriate in the circumstances; or (ii) you are given notice and a reasonable opportunity to opt-out of your Personal Data being processed for specified purposes, and you do not opt-out.
(b) European Union. For individuals to whom the General Data Protection Regulation (“GDPR”) applies, we may process your Personal Data on the following grounds, in addition to any other grounds that may be available pursuant to applicable law:
- Consent. Where you have given us consent through a statement or clear affirmative action agreeing to the processing of your Personal Data. For instance, by submitting your Personal Data on a form on our website for a specified purpose.
- Contract. Where processing of Personal Data is necessary to perform a contract to which you are a party with us, or which you have agreed to enter with us.
- Legal Obligation. To comply with a legal obligation to which we are subject.
- Legitimate Interests. Where the processing of Personal Data is based on our legitimate interests, provided that these do not override your own interests and fundamental rights. We have legitimate interests in the following:
- to properly operate and deliver our Services to you;
- to understand how users engage with our Services;
- to improve our Services;
- to market our Services; and
- to provide customer service, including but not limited to, responding to inquiries and feedback.
6. Disclosure of Personal Data
(a) General. If we disclose your Personal Data to third parties, we take reasonable measures to ensure that these third parties implement appropriate technical and organizational measures in accordance with applicable privacy and data protection laws. We minimize the amount of Personal Data we disclose to what is directly relevant and necessary to accomplish the specified purpose.
(b) Provision of Services. We may disclose Personal Data as is necessary to provide our Services (including any features thereof) to you, including without limitation, by disclosing Personal Data to third party service providers in order to help us achieve the Purposes. For example, we may use third party service providers to help us: (i) with cloud data hosting (e.g., Amazon Web Services); (ii) analyze usage of our Services; (iii) track the effectiveness of our marketing strategies and communications; (iv) assist with the prevention, detection and investigation of potentially illegal acts and security breaches; and (v) collect and process error and crash reports and store data. These third parties are authorized to use your Personal Data only as necessary to provide these services to us.
(c) Corporate Transactions. We may also disclose or transfer your Personal Data to affiliates or third parties in the event of a proposed reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or equity, subject in each case to customary confidentiality agreements.
(d) Legal Disclosure. We may disclose Personal Data if we reasonably believe disclosure is in accordance with or required by any applicable law. This includes the disclosure of Personal Data where necessary for the establishment, exercise, or defense of legal claims, or as otherwise permitted by applicable law. We will have no liability associated with any such disclosures made in good faith.
(e) International Transfer and Storage. Your Personal Data may be stored and processed in any country where we have facilities or in which we engage third party service providers. By using our Services and otherwise providing us your Personal Data, you consent to the transfer of your Personal Data to countries outside of your country of residence, which may have different data protection rules than in your country. While such information is outside of the Canada, it is subject to the laws of the country in which it is held, and may be subject to disclosure to the governments, courts or law enforcement or regulatory agencies of such other country, pursuant to the laws of such country. If applicable, we will comply with the GDPR requirements providing adequate protection for the transfer of Personal Data from the European Economic Area to third country.
7. Retention of Personal Data
Our data retention periods may vary depending on the country in which you receive Services and applicable law. We will retain your Personal Data only as long as necessary to: (a) fulfill the Purposes; and (b) comply with applicable law. We will securely delete or anonymize the Personal Data once it is no longer necessary for us to hold it. We are not responsible for any liability or loss you experience as a result of such disposal of Personal Data. Subject to applicable law, if Personal Data is aggregated or anonymized so that it is no longer associated with an identified or identifiable natural person, VC may indefinitely retain it and use it for any business purpose.
8. Security of Personal Data
We protect your Personal Data using appropriate technical and organizational measures to reduce the risks of loss, misuse, unauthorized access, disclosure and alteration. However, no method of transmission over the Internet, or other method of storage, is 100% secure. Therefore, we cannot guarantee its absolute security.
9. Rights Relating to Personal Data
(a) General. You have certain rights relating to your Personal Data, subject to applicable law in each instance:
- Right to be Informed. To know how your Personal Data is collected, how it is used, and how it is disclosed and stored. This further includes:
- Right to Withdraw Consent. The right to withdraw your consent to the processing of your Personal Data at any time. Please be advised that withdrawing your consent to the processing of your Personal Data may impact the provision of the Services, such that the Services, or certain parts thereof, may not be available for access and use thereafter. For further information on this, please contact our Privacy Officer as provided in the “Contact Us” section below.
- Right to Make a Complaint. The right to make a complaint about the processing of your Personal Data.
- Right to Access. To receive a copy of your Personal Data.
- Right to Rectification. To request correction of your Personal Data.
(b) European Union. If you are an individual to whom the GDPR applies, then you have the following additional rights relating to your Personal Data, subject to applicable law in each instance:
- Right to Erasure. To request the deletion of Personal Data when: (A) you believe it is no longer necessary for the purposes collected; (B) you withdraw your consent or object to the processing of your Personal Data; or (C) your Personal Data was unlawfully processed.
- Right to Restriction of Processing. To restrict the processing of Personal Data if you dispute its accuracy or object to its processing.
- Right to Portability. To request that your Personal Data be transferred to another organization.
- Right to Information about Automated Decision Making. To receive information about the basis of any automated decision making to which you are subject (e.g., algorithms), such as the factors considered and how such factors are weighed.
- Right not to be Subject to Automated Decision Making. To not be subject to decisions based solely on automated processing that produce legal effects concerning you or similarly significantly affect you, unless this is necessary pursuant to a contract between us.
- Right to Object to Processing Activities. To object to the processing of your Personal Data based on your legitimate interests.
If you want to learn more about any rights under the GDPR, you can visit the European Commission’s page on Data Protection at https://ec.europa.eu/info/law/law-topic/data-protection_en.
(c) California Residents. This section applies to our collection and use of “Personal Information”, as defined under the California Consumer Privacy Act (2018), as amended (the “CCPA”), if you are a resident of California.
- Your Rights. As a resident of California, you have certain rights with respect to your Personal Information, subject to applicable law in each instance:
- Right to Know. To request information on the categories of Personal Information that we collected in the previous twelve (12) months, the categories of sources from which the Personal Information was collected, the specific pieces of Personal Information we have collected about you, and the business and/or commercial purposes for which such Personal Information is collected and shared. You also have the right to request information on the categories of Personal Information which were disclosed for business and/or commercial purposes, as well as the categories of third parties to whom disclosure was made in the twelve (12) months preceding your request for your Personal Information.
- Right to Delete. To request us to delete Personal Information that we collected from you.
- Right to Opt-Out. To opt-out of the “sale” of your Personal Information to third parties, as such term is defined in the CCPA. For certainty, we do not sell your Personal Information.
- Right to Non-Discrimination. To not receive discriminatory treatment when you exercise your California privacy rights (e.g., denial of goods or services, provision of a different level, quality or price for goods or services). However, notwithstanding the foregoing, different service levels and prices may be provided if such difference is reasonably related to the value provided by the Personal Information.
- Right to Correct. To correct any inaccuracies in the Personal Information collected from you.
- Right to Limit. To limit the use and disclosure of your sensitive personal information (e.g., social security number, genetic data, etc.) to limited purposes, such as providing you with the services you requested.
|Category of personal information
|We Disclosed for a Business Purpose
|Category of 3rd Parties to whom Disclosed
Examples: name, postal address, unique personal identifier, online identifier, IP address, email address, driver’s license number, etc.
|Performance of the Services; Security; Improvement of the Services
|Categories of Personal Information in Cal. Civ. Code 1798.80(e)
Examples: name, signature, bank account number, credit card number, other financial information.
|Characteristics of Protected Classifications under California or US Federal Law
Examples: gender, age, race, medical condition, marital status.
Examples: purchase history and billing and transaction information.
Examples: physiological, biological, or behavioral characteristics (including DNA, fingerprints, images, voice recordings).
|Internet or Other Electronic Network Activity Information
Examples: information regarding a consumer’s interaction with a website, application or advertisement, including browsing history and search history.
|Improvement of the Services
|Service Providers enabling such collection
Examples: physical location.
Examples: call and video recordings, profile photos).
|Professional or employment-related information
Examples: job history, resume.
|Non-public educational information as defined in the Family Educational Rights and Privacy Act (20 U.S.C. §1232g and 34 C.F.R. Part 99).
Examples: student education records.
|Inferences drawn from Personal Information
Examples: consumer preferences, characteristics, psychological trends, behavior.
|Improvement of the Services
|Service Providers enabling such collection
(d) Exercising Your Rights. If you would like to exercise your any of your Personal Data rights, please refer to our “Contact Us” section below. When doing so, please tell us which right you wish to exercise and provide us with contact information to direct our response. Response procedures may vary depending on the laws applicable to you. Your use of the Services may be affected depending on the nature of the rights you seek to exercise.
Subject to applicable law: (i) we may verify your identity before fulfilling requests to exercise any rights; and (ii) we may request additional information if we cannot initially verify your identity, or if we require such additional information in order to properly assess your request. Any Personal Data you disclose to us for purposes of verifying your identity and/or exercising your rights will solely be used for the purpose of verification and processing of your request.
10. Communications with Us
To opt-out of receiving certain communications from us through your use of the Services (the “Communications”), you may either contact us as provided in the “Contact Us” section below, or, if applicable, click “Unsubscribe” if such function is supported in the particular Communication. Please note that certain Communications may be necessary for the proper functioning and use of the Services, and opting out of those Communications may prevent the proper functioning and use of the Services.
11. Personal Data About Other Individuals
Before providing any Personal Data on behalf of another person, you confirm that you have received all necessary authorizations to do so.
13. Contacting Us