VanBo, LLC Privacy Notice
Updated September 6th, 2019
Introduction and Overview
VanBo, LLC (VanBo, Us, or We) recognizes how important your data is to you, and we are committed to helping you protect it. This notice sets out the practices for vanbo.tech, and any application or service we offer.
How We May Receive Your Information
VanBo may receive your data in multiple ways – through meetings at events where you give us your business card or when you ask us to contact you via our “Contact Us” forms. We may also receive information about you from other sources such as publicly available databases or third parties from whom we have purchased data.
The Information We Collect
Except as explained in this notice below regarding a Change of Ownership or Business Transaction, we do not sell or rent your information to anyone and will remove it upon your request via an approved method as listed in “How You Can Access Your Data.” The personally identifiable information (PII) or personal data we gather includes:
- Your first and last name
- Email address
- Phone number
- Postal address, if necessary to fulfill your request
- Your IP Address, geolocation information based upon that IP Address, and time zone
- Your behaviors and preferences in browsing our website or using our services
Our mobile applications collect the following additional data:
- Mobile device operating system version and hardware model
- Network information such as network type and carrier
- Information about the services you connect to within the application, such as courseware and offline learning activities
- How you use the application during your current session and over time, including what courses you complete, pass/fail rate, and whether you are accessing your transcripts and certificates.
Non-personally identifiable information we collect can include many things, and we again do not rent or sell any of the following types of data collected with third parties.
- Browser type
- Operating system
- The date and time of your visit, along with the time you spend visiting our websites
- Pages you visit on our websites
- Any return visits you may make
We also collect non-personal data about you using cookies. These cookies are small text files created by a web server, delivered through your browser, and stored on your device. Please read our “Cookies, Online Tracking, and Similar Technology” section for further details.
How and When Your Information Is Gathered
We collect this information under the following circumstances:
- You agree to allow third-party sites to share your contact information with us
- You communicate with us regarding our content
- You subscribe to our products or services
- You subscribe to our mailing list and/or newsletters
- You purchase our solutions and services, and when you access and use our websites
- We conduct our administrative and business functions about your use of our site
- You complete a job application or send in a resume for an available job
Why We Collect Data
We collect your personal data for certain legitimate business purposes, such as the ones listed below and any similar:
- To establish, maintain, and manage our business relationships
- Where the processing enables us to enhance, modify, personalize, or otherwise improve our services and communications for the benefit of our customers
- Process and respond to privacy concerns or complaints
- To enhance the security of our network and information systems
- To better understand how visitors interact with our services
- To determine the effectiveness of promotional campaigns and advertising
- To determine suitability for an open job posting
Reuse of Your Personal Information
We will not reuse personal data for a new purpose other than the original one(s) for which it was collected, unless one or more of the following apply:
- The new use is compatible with the original one, meaning you should reasonably expect a similar use;
- We have notified you of the new use and given you an opportunity to object to it; or
- The new use is otherwise permitted or required by law.
Retention, Destruction, and Disclosure of Your Personal Data
We retain your personal data for as long as necessary to fulfill the purposes for which it was collected, or for the reasons listed below and any similar reasons:
- To protect the rights and safety of our customers and third parties, as well as our own.
- To meet legal requirements, including complying with court orders, valid discovery requests, valid subpoenas, and other appropriate legal mechanisms.
- To provide information to representatives and advisors, including attorneys and accountants, to help us comply with legal, accounting, or security requirements.
- To prosecute or defend a court, arbitration, or any other legal proceeding.
- To respond to lawful requests by public authorities, including to meet national security or law enforcement requirements.
Depending on the purpose, retention periods will vary. The criteria we use to determine retention periods include whether:
- We are under a legal, contractual, or other obligation to retain personal data pursuant to data retention laws, as part of an investigation or for litigation purposes
- Personal data is needed to provide our solutions and services business including performance improvement and to maintain accurate business and financial records
- If you have consented to us retaining your personal data for a longer period, we will retain that data in line with your consent.
If we must disclose your data to a third party, we will do so only under the following circumstances:
- If required to fulfill your requests for our services including but not limited to online backups, email integration, online training, or other services you wish to procure from VanBo
- We are required to do so by law, court order or legal process
- In response to lawful requests by public authorities, including to meet national security or law enforcement requirements
- Under the discovery process in litigation
- To enforce our policies or contracts
- To collect amounts owed to us
- When we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation or prosecution of suspected or actual illegal activity
- Or, if we, in good faith, believe that disclosure is otherwise necessary or advisable. In addition, from time to time, server logs may be reviewed for security purposes including, for example, to detect unauthorized activity on the services. In such cases, server log data containing Personal Data may be shared with law enforcement bodies so that they may identify users in connection with their investigation of the unauthorized activities.
Please see “How You Can Access Your Data” below if you should wish to be forgotten so that we may properly destroy the data we hold.
Cookies, Online Tracking, and Similar Technology
To make our websites and applications work properly, we sometimes place small data files called cookies on your device. A cookie is a small individualized text file that a website saves on your computer or mobile device when you visit the site. It enables our website to remember your actions and preferences (such as language, font size and other display preferences) over time, so you don’t have to keep re-entering them whenever you come back to the site or browse from one page to another.
Our services also contain cookie technology from third party analytics providers such as Google Analytics, through which such providers collect information about your online activities across our websites to help us compile aggregated statistics about the effectiveness of marketing campaigns or other business operations. We use the data gathered by the cookies to assist us in the following methods:
- Improve your browsing experience
- Customizing our interactions with you
- Storing and managing your preferences and settings
- Compiling statistical data
- Analyzing the performance and usability of our services
- Measuring website traffic patterns
- Determining which areas of our websites have been visited
The third-party analytics engines on our web sites transfer data about your utilization of our website, user agent, etc., to those third-party providers.
Your Choices Around These Technologies
We are committed to providing you with meaningful choices about the information collected by the use of our services, but our services do not currently recognize or respond to browser-initiated Do Not Track signals or other similar tracking mechanisms unrelated to cookies. You may opt out of all marketing from us by reaching out to firstname.lastname@example.org
Data Security and Integrity
We take precautions to protect your information both online and offline, with a variety of physical, administrative and technical safeguards which are in place. Wherever we collect information, that information is encrypted and transmitted to us in a secure way, as well as being encrypted for as long as we retain the information. You can verify this by looking for the closed lock in your browser (usually found in the address bar). You can also see the “https” at the beginning of the web address. However, please note that no method of transmission over the Internet, or method of electronic storage, is 100% secure.
Accountability for Onward Transfers
We will not transfer your personal data to any third parties without notifying you via written contact and ensured that they have at least the same level of privacy protection as we employ. We will only transfer data to our agents, subsidiaries or third-party service providers to provide services to you or perform activities on VanBo’s behalf and only for a purpose which is consistent with this notice.
If you are a resident of any country in the European Union, your data may be stored in the US, using appropriate data transfer mechanisms based upon the Privacy Shield Principles.
How You Can Access Your Data / Individual Rights
We are subject to a variety of different laws which may provide you rights to your personal data. For example, for EU data, transferred to the United States pursuant to Privacy Shield, the Privacy Shield Principles provide for the right to access your personal data, including limiting its use and disclosure.
There are additional rights under the European Union’s General Data Protection Regulation which may apply to you. If you wish to correct, update, block, or delete personal data which we maintain, please let us know by sending an email to email@example.com.
We will respond to your request without undue delay, but not longer than 30 days from the date of your request. We may ask you to verify your identity before we can process your request, and if your request is denied we will explain why in a written response.
Links to third party websites
Our websites may contain links to sites and/or applications operated by third parties. We make no representations or warranties in relation to the privacy practices of any third-party site or application and we are not responsible for any third-party content or privacy statements. Your use of such sites and applications is subject to the relevant third-party privacy notices.
Change of Ownership or Business Transition
Should we have any change to our business, such as a merger, acquisition, or sale of our company, your personal information as we have it stored may be transferred in accordance with applicable privacy laws. In the event of a business change as described, we may disclose your data to the prospective seller or buyer of such business or assets, subject to their entering into appropriate confidentiality undertakings (such as non-disclosure agreements) prior to the effective date of said change.
The services provided by us are not directed to children under the age of 13, and we do not knowingly collect any information from anyone under the age of 13. We recommend that persons over 13 but under 18 years of age ask their parents for permission before using any of the services we provide or sending any information about themselves to anyone over the internet.
Your California Privacy Rights
If you are a resident of California, the “Shine the Light” law (California Civil Code Section 1798.83) permits you to request certain information regarding the disclosure of your personal information by us to third parties for the third parties’ direct marketing. To make such a request, please email firstname.lastname@example.org, or reach out to us by mail as listed at the end of this notice.
EU-US Privacy Shield
VanBo does not intend to do business at this time outside of the United States. At such time as we conduct business outside the US borders, we will adhere to all privacy requirements of the countries we do business in.
How to contact us
If you have any questions about how we handle your data or if you have a privacy concern please contact our Data Privacy Officer. In compliance with the Privacy Shield Principles, we are committed to resolving complaints about your privacy and our collection or use of your personal data.
Mail: VanBo, LLC
ATTN: DATA PRIVACY OFFICER
N63W23565 Silver Spring Dr #108
Sussex, WI 53089
Changes to our Privacy Notice
We will review this notice periodically and may modify it at our discretion. The date at the top of this page will reflect the latest update. We encourage you to review this notice on a regular basis to stay informed about how we are working to keep your data safe.