Privacy Policy

INTRODUCTION.

VIPrivate Care (which includes its licensees, sublicensees and/or their respective agents (collectively “Franchisees” and together with VIPrivate Care, its subsidiaries and affiliates, collectively “VIPrivage Care”, “we”, “us” or “our”) take your privacy very seriously.  This  Privacy Policy (“Privacy Policy”) describes how we process, collect, share and otherwise use information about individuals (“Personal Information”) who use this website https://viprivatecare.com, and/or any subsidiary websites or subdomains of our subsidiaries and Licensees bearing the VIPrivate Care trademarks (collectively, “Website”, “this Website” or the “Websites”).

This Privacy Policy applies to each of the Websites and references to “this Website” refers to this Website and each of our other Websites.  Our collection, use, sharing and processing of Personal Information is also subject to the Terms of Use for our Websites located at [INSERT URL FOR TERMS OF USE] (“Terms of Use”).

For purposes of this Privacy Policy, we process your Personal Information as a “processor” and a “controller” under certain data protection laws, including, without limitation, the European Data Protection Regulation (“GDPR”).

1. ACCEPTANCE OF PRIVACY POLICY.

ALL USE OF THIS WEBSITE AND OUR OTHER WEBSITES IS GOVERNED BY THIS PRIVACY POLICY AND THE TERMS OF USE AS WE MAY UPDATE OR MODIFY THEM FROM TIME TO TIME IN OUR DISCRETION.  

PLEASE READ THIS PRIVACY 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 this Website and/or our other Websites.

BY ACCESSING OR USING THIS WEBSITE AND/OR OUR OTHER WEBSITES, on behalf of yourself and/or your company or organization, you agree and consent to our practices, as described in this Privacy Policy, regarding the collection, use, processing and disclosure of your Personal Information. You are also agreeing to comply with the requirements contained herein.

This Privacy Policy may change from time to time. Your continued use of our Websites after we make changes is deemed to be acceptance of those changes.  It is your responsibility to periodically check for updates.

2. PROCESSING ACTIVITIES COVERED.

2.1 Information to Which this Privacy Policy Applies.

This Privacy Policy applies to Personal Information collected, stored, processed, disclosed, shared and/or used  (generally, “processed”) by us when:

  • You visit our Websites that display or link to this Privacy Policy.
  • You provide information through your use of our Websites.
  • You visit our branded social media pages.
  • You or we send or receive communications, including e-mail, text and/or other electronic messages.
  • You download mobile and/or desktop applications from this Website, if any, which provide dedicated non-browser-based interaction between you and this Website.
  • You interact with our advertising and applications on third-party websites and services, if those applications or advertising include links to this Website.
  • You respond to any surveys that we might ask you to complete for research purposes or other purposes we may identify.
  • We collect such information by other means as described in this Privacy Policy.

2.2 Information to Which this Privacy Policy Does Not Apply.

This Privacy Policy does not apply to information collected by:

  • Us offline or through any other means, including without limitation, on any third party website, through your visits to our office and your attendance at events; or
  • Any third party, including through any application or content (including advertising) that may link to or be accessible from or on this Website.

2.3. Links from this Website.

This Website may contain links to other websites, applications and services maintained by third parties.  The information practices of such other services, or of social media networks that host our branded social media pages are governed by third parties’ privacy policies or statements, which we encourage you to review to better understand such third parties’ privacy practices.

3. WHAT PERSONAL INFORMATION DO WE COLLECT AND HOW WE COLLECT IT.

3.1 Personal Information We Collect Directly from You.

The information we collect from you on or through our Websites, which includes Personal Information, includes:

  • For all users – name, telephone number and email address.
  • Information that you provide by filling in forms on our Websites. This includes information provided at the time of registering to use our Website, subscribing to our service, posting material and/or User Contributions or requesting further services. We may also ask you for information when you report a problem with our Websites.
  • Records and copies of your correspondence (including e-mail addresses), if you contact us.
  • Your responses to surveys that we might ask you to complete for research purposes.
  • Details of transactions you carry out through our Websites, if any. You may be required to provide financial information before making certain uses of our Websites.
  • Your search queries on our Websites.
  • When you use and interact with this Website, we automatically collect log files and other information about your device and your usage of this Website and other details of your visits to this Website, which may include traffic data, location data, other communication data, resources that you access and use on the Websites through cookies, web beacons or similar technologies, such as Internet Protocol (IP) addresses or other identifiers, which may qualify as Personal Information (please see Section 3.2, “Automatic Data Collection Technologies We Use” below).

3.2 Automatic Data Collection Technologies We Use.

As you navigate through and interact with our Websites, we use common information collection tools to automatically collect information.  The information we collect automatically is statistical data and may include Personal Information, or we may maintain it or associate it with Personal Information we collect in other ways or receive from third parties.  It helps us to improve our Websites and to deliver a better and more personalized service, including by enabling us to estimate our audience size and usage patterns, store information about your preferences and use of our services, allow us to customize our Websites and recognize you when you return to our Websites, among other things. This information is collected through our use of cookies and other tracking technologies including:

  • Cookies. (browser cookies) are small files of letters and numbers that we store on your browser or 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 Websites.
  • Flash Cookies. Certain features of our Websites may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from and on our Websites. Flash cookies are not managed by the same browser settings as are used for browser cookies. For information about managing your privacy and security settings for Flash cookies, please see Section 5.2, “Choices about How We Use and Disclose Your Information”, below.
  • Log Files. When you access our Websites, our servers automatically record information sent from your browser, which may include your web request, Internet Protocol address, domain names, referring Uniform Resource Locator, browser type, browser language, and operating system; the date and time of your request and access; and Cookies that may uniquely identify your browser (collectively, “Usage Data”). We may combine Usage Data with Personal Information in a manner that enables us to trace Usage Data to an individual user, and may collect, use, preserve and disclose Usage Data in any manner that we may collect, use, preserve and disclose Personal Information as provided herein (whether Usage Data is combined with any Personal Information or otherwise). 
  • Web Beacons. Pages of our the Websites and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs. pixel tags and single-pixel gifs) that permit us, for example, to count users who have visited those pages or opened an e-mail and for other related Website statistics (for example, recording the popularity of certain Website content and verifying system and server integrity).
  • Social networks. We may allow you to log in to certain of our Websites using sign-in services such as Facebook. These services will authenticate your identity and provide you the option to share certain Personal Information with us such as your name and email address. If you use the social networking connection functions offered through our services, we may access your social network profile information that you have made available to be shared and to use it in accordance with this privacy policy. Please refer to the instructions governing your social network account to manage the information that is shared through your account.

3.3 Third-Party Use of Cookies and Other Tracking Technologies.

Some content or applications, including advertisements, on our Websites are served by third-parties, including advertisers, ad networks and servers, content providers and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our Websites. The information they collect may be associated with your Personal Information or they may collect information, including Personal Information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.

4. WHY WE PROCESS YOUR PERSONAL INFORMATION.

We process information that we collect from and/or about you, including Personal Information to perform services for you, to pursue our legitimate interests, and for other purposes, including:

  • To provide our Websites and their content to you and allow you to review our services, create an account or profile or register for services on the Websites. Where we do not have an account with you or provide you with any services, we process your Personal Information.
  • To provide you access to our services.
  • To provide you with information, products or services that you request from us. Where we do not have an account with you or provide you with any services, we process your Personal Information based on our legitimate interest to operate and administer our Websites and to provide you with content you access and may request.
  • To provide you with customer support and communication, and notices about your account, which may include expiration and renewal notices.
  • For analytical purposes, which may include generate and analyze statistics about your use of the Websites for operational and/or security purposes, measurement of effectiveness of our marketing activities, performance improvements, research, testing and other business purposes.
  • To notify you about changes to our Websites or services we offer or provide through one or more of the Websites.
  • To allow you to use participate in interactive features on our Websites.
  • To process your Personal Information by managing your user account for the purpose of providing services to you.
  • To promote the security of our Websites by verifying accounts and activity, investigating suspicious activities and enforcing our Terms of Use and policies to the extent necessary for our legitimate interests in promoting the safety and security of the systems and applications used by our Websites and to protect our rights and the rights of others.
  • To develop and improve our Websites.
  • To conduct marketing research, advertise to you, provide personalized information about us on and off our Websites and to provide other personalized content based upon the services we provide to you to the extent it is necessary for our legitimate interest in advertising our Websites or, where necessary, to the extent you have provided your prior consent, including without limitation, through requests made by you or use of built-in convenience features of the services we provide to you.
  • To cooperate with public and government authorities, courts or regulators in accordance with our legal obligations under applicable laws to the extent this requires the processing or disclosure of Personal Data to protect our rights or is necessary for our legitimate interest in protecting against misuse or abuse of our Websites, protecting personal property or safety, pursuing remedies available to us and limiting our damages, complying with judicial proceedings, court orders or legal processes or to respond to lawful requests.
  • 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 and third-parties’ services that may be of interest to you.

We may use the information we have collected from you to enable us to display advertisements to our advertisers’ target audiences. Even though we do not disclose your Personal Information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.

5. HOW WE USE OR SHARE YOUR INFORMATION

5.1. Disclosure of Your Information.

We may disclose Personal Information that we collect or you provide as described in this Privacy Policy or the Terms of Use:

  • To our subsidiaries, affiliates and/or Licensees.
  • To contractors, service providers and other third parties we use to support our business service providers. We may share Personal Information collected through our Websites with companies that perform services on our behalf, including companies that provide website development, hosting, payment processing and billing services.
  • To fulfill the purpose for which you provide it.
  • With third-party social media networks, advertising networks and websites, which may also act as separate controllers, so that we can market and advertise on such third-party platforms and websites.
  • For the purpose of providing services, to your professional advisors including lawyers, bankers and insurers acting as joint processors or joint controllers.
  • 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. We may disclose your personal information when we believe disclosure is appropriate to comply with the law or respond to a court order or subpoena; to prevent or investigate a possible crime, such as fraud or identity theft; or to protect the rights, property or safety of ourselves or others.  We reserve the right to report to appropriate law enforcement, governmental authorities and other third parties any activities that we, in good faith, believe to be harmful or unlawful, with or without providing notice to you
  • 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 VIPrivate Care, our customers or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

We may also disclose aggregated information about you and other users that does not identify you or any other individual, without restriction.

We will not otherwise distribute, sell, rent, transfer, or otherwise disclose your Personal Information to any third party, except as provided for in this Privacy Policy or with you consent.

5.2 Choices About How We Use and Disclose Your Information.

We strive to provide you with choices regarding the Personal Information you provide to us. We have created mechanisms to provide you with the following control over your Personal Information:

  • Tracking Technologies and Advertising. You can 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, please note that some parts of this site may then be inaccessible or not function properly.
  • Disclosure of Your Information for Third-Party Advertising. If you do not want us to share your Personal Information with unaffiliated or non-agent third parties for promotional purposes, you can opt-out by unchecking the relevant box located on the form on which we collect your data (the order form/registration form). You can also always opt-out by logging into the applicable Website and adjusting your user preferences in your account profile by checking or unchecking the relevant boxes or by sending us an e-mail stating your request to info@viprivatecare.com.
  • Links to Internet or Mobile Sites. Our Websites may contain links to Internet or mobile sites not owned or operated by us, including to sites featuring companies, products, services or news that may be of interest or to pages that we maintain on YouTube, Facebook, Twitter or other social media sites.  You should review the privacy and other policies of other Internet and mobile site providers carefully, as these policies may be different than the policies of our Websites.  We assume no responsibility or liability for any third party Internet or mobile site operator’s privacy practices.
  • Promotional Offers from the Company. If you do not wish to have your e-mail address/contact information used to promote our own or third parties’ products or services, you can opt-out by unchecking the relevant box located on the form on which we collect your data (the order form/registration form) or at any other time by logging into the applicable Website and adjusting your user preferences in your account profile by checking or unchecking the relevant boxes. If we have sent you a promotional e-mail, you may send us a return e-mail asking to be omitted from future e-mail distributions. This opt out does not apply to information provided to the Company as a result of a product purchase, warranty registration, product service experience or other transactions.

We do not control third parties’ collection or use of your information to serve interest-based advertising. However these third parties may provide you with ways to choose not to have your information collected or used in this way.

5.3 Accessing, Controlling Updating, Correcting and Deleting Your Personal Information.

When you use our Websites, we work to provide you the ability to access, review, correct, edit, or remove your Personal Information and related content that you have provided to us. You can do this by logging into the Website and visiting your account profile page.  Although most changes will occur immediately, some information may stay stored on your browser’s web cache.  We take no responsibility and are not liable for information stored in your cache or on any other electronic devices through which you may access our Websites.

We cannot delete your Personal Information except by also deleting your user account.  Under certain privacy laws you may have a right to access your Personal Information that we hold about you, however, your rights to access your Personal Information are not absolute. We may decline to process requests that are unreasonably repetitive or systematic, require disproportionate technical effort, jeopardize the privacy of others, or would be extremely impractical. In some instances, a request that requires disproportionate technical effort to accommodate may be processed for an additional fee.  You authorize us to use and disclose, in accordance with this Privacy Policy and the Terms of Use, any new or modified information that you provide. Please note our data retention practices identified below.  In addition, we may not accommodate a request to access or change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect. If we deny your request for access to, or refuse a request to correct Personal Information, we shall explain why.

For your information, removal of your Personal Information may impact our ability to provide you or your ability to use our services.

If you delete your User Contributions from our Websites, copies of your User Contributions may remain viewable in cached and archived pages, or might have been copied or stored by other Website users.

5.4 Choices for Personal Information.

We will ask for your consent prior to collecting or using Personal Information for any purpose other than those described in this Privacy Policy or other supplementary privacy notices. You may be given the option to opt out of some of our data-collection practices. If we propose to use Personal Information for any purpose other than those described in this Privacy Policy or other supplementary privacy notices, we will provide you with an effective way to opt out of such use. Please note that declining to submit Personal Information for any Service may prevent us from being able to provide that Service to you.

5.5 Opt-Out/Changing Your Account.

You may unsubscribe or opt out of any of our email lists, electronic newsletters, bulletins, guides or marketing campaigns at any time by following the instructions included in such email or other communication by emailing to info@viprivatecare.com.

If you wish to change the status of your profile, you may so do by us by contacting by emailing us at info@viprivatecare.com If you no longer wish to use our services or maintain your profile as active, upon your request, we will, as soon as practicable and in accordance with all applicable laws, deactivate your profile and login information. After we have deactivated your profile, information about profile may remain on the Website and/or in our databases and we may continue to use log information in accordance with this Privacy Policy. We may also retain your information to comply with any applicable laws, prevent fraud, resolve disputes, troubleshoot problems, assist with any lawful investigations, enforce our Terms of, or to take any other actions permitted by law.

6. STORAGE AND INTERNATIONAL TRANSFER OF PERSONAL INFORMATION.

The information that we collect from you may be transferred to, and stored at, a destination outside of your country of domicile. It may also be processed by employees, subcontractors and sub-processors (“Our Providers”) operating outside of your country of domicile who work for us, or on our behalf. Our Providers may be engaged in, among other things, the fulfilment of any requests and the provision of support services. By submitting your Personal Information, you agree to this transfer, storing or processing. We take steps we believe reasonably necessary so that your Personal Information is treated securely and in accordance with this Privacy Policy.

Please note, not all countries provide the same level of data protection.  In this event, we will ensure that the recipient of your Personal Information offers an adequate level of protection in the country in which it is processed, for instance by entering into standard contractual clauses for the transfer of data as approved by the European Commission with respect to the GDPR or other applicable requirements, or we will ask you for your prior consent to such international data transfers.

7. DATA RETENTION AND SECURITY

7.1 Data Retention.

We retain your Personal Information and information stored and collected through our Websites for as long as we have a business or tax need or as applicable laws, regulations, or government orders require. When your information is no longer necessary or relevant for the identified purpose or to fulfill a legal or business requirement, we will use reasonable commercial efforts to securely dispose of and destroy your information collected through the Website.

After expiry of the applicable retention periods, your Personal Information will be deleted. If there is any information that we are unable, for technical reasons, to delete entirely from our systems, we will put in place appropriate measures to prevent any further use of such Information.

7.2 Data Security.

We follow generally accepted standards, including organizational, technical and physical measures to help safeguard against the accidental or unlawful destruction, loss, alteration and unauthorized disclosure of, or access to, the Personal Information we process or use. We are not responsible for circumvention of any privacy settings or security measures contained on this Website.

You are solely responsible for protecting your password, limiting access to your devices and signing out of our Websites after your sessions. Any transmission of Personal Information is at your own risk. If you have any questions about the security of our websites, please contact us by using the information in the “Contact Information” section, below

While we follow generally accepted standards to protect Personal Information, no method of storage or transmission is 100% secure. The safety and security of your Personal Information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Websites, you are responsible for keeping this password confidential. You agree to notify us immediately of any unauthorized access to or use of your user name or password or any other breach of security. You also agree to exit from your account at the end of each session.  We have the right to disable any user name, password or identifier, whether chosen by you or provided by us, at any time in our sole discretion for any or no reason, including, if, in our opinion, you have violated any provision of this Privacy Policy or the Terms of Use.

If you have any questions about the security of our Websites, please contact us by using the information in the “Contact Information” section, below.

8. YOUR RIGHTS.

8.1. Your Rights.

You have certain rights relating to your Personal Information, subject to local data protection laws. Depending on the applicable laws, these rights may include:

  • Right to Access. Making a request to access your Personal Information at any time.
  • Right to Correct or Rectify. Request correction of the Personal Information that we hold about you.
  • Right to Erase/Delete. Request erasure/deletion/removal of your Personal Information. Please Note: we may not always be able to comply with your request for erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
  • Right to Object. Object to processing of your Personal Information where we are relying on a legitimate interest (or those of a 3rd party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms.
  • Right to Restrict Our Processing. Request restriction of processing of your Personal Information.
  • Right to Transfer. Request the transfer of your Personal Information to you or directly to another controller. This right only applies to automated information which you initially provided consent for us to use or where we used the Personal Information to perform a contract with you.
  • Right to Withdraw Consent. Withdraw consent at any time where we are relying on your consent to process your Personal Information. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent.

California residents are entitled once a year, free of charge, to request and obtain certain information regarding our disclosure, if any, of certain categories of Personal Information to third parties for their direct marketing purposes in the preceding calendar year. We do not share Personal Information with third parties for their own direct marketing purposes. California residents who have profiles on our Websites and are under the age of 18 are entitled, in accordance with California law, to request and obtain removal of content and information that they themselves post on the our Websites.

8.2. How to Exercise Your Rights.

To exercise your rights, please contact us by using the information in the “Contact Information” section, below. We try to respond to all legitimate requests within a month and will contact you if we need additional information from you in order to honor your request. Occasionally it may take us longer than [a month], taking into account the complexity and number of requests we receive.

To discontinue your account and/or request return or deletion of your Personal Data and other information associated with your account, please contact us by using the information in the “Contact Information” section, below.

8.3. Marketing Messages.

Generally we do not rely on consent as a legal basis for processing Personal Information except in relation to sending direct marketing communications via email or text message.

You may receive marketing communications from us if you provided us with your details when you registered for any services, seminar, promotional or networking event or attended a course and you have given us consent to send you marketing. We may also use your identity, contact details, technical data, usage data and profile data to form a view and decide which services may of interest or relevant for you.  

9. MISCELLANEOUS.

9.1 Changes To Our Privacy Policy.

We reserve the right, at any time, to change, modify, or revise this Privacy Policy and the privacy and security practices discussed herein. We will post any revised version of the Privacy Policy on our Websites. If we make any significant, material changes to the Privacy Policy, we will modify the date on which this Privacy Policy was last revised as set forth at the top of this Privacy Policy. You are responsible for periodically visiting our Websites and this Privacy Policy to check for any changes.  Continued use of our Websites and our services following such changes constitutes your acknowledgment of them and agreement to be bound by their terms and conditions.

9.2 Children’s Privacy.

We are committed to protecting the privacy of children and encourages parents and guardians to take an active role in their children’s online activities and interests. Our Websites are not directed to children or designed to attract them. You must be at least 16 years of age to use our Websites and Services. We do not knowingly collect, use, or disclose Personal Information about users that are under 16 years of age. If we later learn that a user is under 16 years of age, we will remove that user’s Personal Information from our databases and prevent the user from further using our Websites and services. If you are a user who is identified in this manner, we may require you to submit suitable proof of age, such as a copy of government-issued identification, in order to continue using the our Websites.

9.3 Monitoring and Enforcement.

In accordance with applicable laws, you may request access and raise concerns or complaints regarding your Personal Information processed by us with by contacting us by email at info@viprivatecare.com.

If you file a complaint, we will investigate the matter or suspected failure to comply with this Privacy Policy. It is our practice to respond to you within [45] days of receiving the complaint. We will take all appropriate action to remedy any such issues.

Contact Information.

To ask questions or comment about this Privacy Policy and our privacy practices, contact us at info@viprivatecare.com.

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