Privacy Policy

Last Updated March 2019

INTRODUCTION

Virtual Connections, LLC ("Virtual Connections", "Company" or "We") respects your privacy and is committed to protecting it through our compliance with this policy (this "Privacy Policy").

This Privacy Policy applies to personal information collected on our websites, mobile applications, including the Virtual Connections Mobile Application (the "Application"), website or cloud-based services (the "Sites"). It does not apply to any other information collected by Virtual Connections through any other means. This Policy also does not apply to any sites maintained or operated by other companies or linked to our Sites.

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, do not download, register with, or use the Sites. By downloading, registering with, or using the Sites, you agree to this Privacy Policy. This policy may change from time to time. Your continued use of the Sites after we make changes is deemed to be an acceptance of those changes, so please check the policy periodically for updates.

End Users of Virtual Connections Products and Services

Virtual Connections is a leader in helping organizations optimize their workforce and workspace through innovative SaaS-based cloud technology and other solutions. In this capacity, Virtual Connections may obtain and process on behalf of our corporate customers ("Clients") certain personal information about our Clients’ employees, representatives, consultants, contractors, agents, or other end users who are authorized to use our Services ("End User Data"). Virtual Connections is a processor or agent that processes End User Data on behalf of our Clients, which are the owners of such data under applicable data protection laws. As such, Virtual Connections assists our Clients to address data protection inquiries from end users to the extent applicable to our services, but typically does not respond directly to such inquiries from end users.

What types of Information do we collect and process about you?

We receive and store certain types of information from you when you interact with our Application and/or Sites to deliver the services you or our Clients request from us and help improve your overall online experience.

1) Information You Provide to Us

When you download, register with, or use the Sites, we may ask you provide information:

  • By which you may be personally identified, such as name, postal address, email address, telephone number, or any other information the Application and/or Sites collect that is defined as personal or personally identifiable information under applicable law ("Personal Information").
  • That is about you but individually does not identify you, such as your location and other information obtained from usage of the Application and/or Sites.
  • Information that you provide by filling in forms on the Application and/or Sites; This includes information provided at the time of registering to use the Application and/or Sites, subscribing to our service (if applicable), posting material, and requesting further services. We may also ask you for information when you report a problem with the Application and/or Sites.
  • Records and copies of your correspondences (including email addresses and phone numbers), 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 the Sites.

European Union (EU) Customers

If you are located in the EU or EEA ("EU Customer"), you have certain additional rights and protections under the law regarding the processing of your personal data.

1. Legal Basis for Processing

If you are an EU Customer, we will only process your personal data:

  • To perform our responsibilities under a contract with our Client or you (e.g. processing payments for and providing services our Client or you have requested);
  • When we have a legitimate interest in processing your personal data (e.g. to communicate with you about changes to our services, to advertise our services, and to provide, secure and improve our services); or
  • To comply with our legal or regulatory obligations.
2. Data Subject Requests

If you are an EU Customer, you have the right to access personal data we hold about you and to have certain personal data corrected or erased. You may also have the right to restrict certain processing of your data.

To make any of these requests please email our Privacy Office at the information as specified in the “How to contact us” section below. We will respond as soon as practicable and no later than one month after receipt of your request. We may request proof of identification to verify your request.

We may deny or restrict fulfillment of your request in some cases, such as when your access to data places another individual's privacy rights at risk, or the continued processing of your data is necessary to comply with a legal obligation. If so, we will notify you of the reason(s) for this denial.

3. Questions or Complaints

If you are an EU Customer and have a concern about our processing of your personal data that we are not able to resolve, you have the right to lodge a complaint with the data privacy authority where you reside. For contact details of your local Data Protection Authority, please see http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm

2) Automatic Information Collection and Tracking

When you download, access, and use the Application and/or Sites, We may use technology to automatically collect:

  • Usage Details. When you access and use the Application and/or Sites, we may automatically collect certain details of your access to and use of the Application and/or Sites, including traffic data, location data (described further below), and the resources that you access and use on or through the Application and/or Sites.
  • Device Information. We may collect information about your mobile device and internet connection, including the device’s unique device identifier, IP address, operating system, browser type, mobile network information, and the device's telephone number.
  • Stored Information and Files. The Application and/or Sites also may access metadata and other information associated with other files stored on your device. This may include, for example, photographs, audio and video clips, personal contacts, and address book information.

How we use and share your Personal Information?

We do not share your Personal Information with unaffiliated third parties for their own direct marketing purposes. Whatever the purpose may be – whether we share with service providers or other external entities – we only process and share your Personal Information to the extent reasonably necessary to fulfill your requests and meet our legitimate business and legal objectives. When we disclose Personal Information to external entities to perform support services for us, we establish by contract that they may access your Personal Information only for the purposes of performing those support services. We may combine your online information with information collected from offline or online sources, or information we already have. We may also use and disclose certain Personal Information to our affiliated companies and others for any purpose allowed by law.

Virtual Connections Business Activities

We generally process and may disclose your Personal Information to others to:

  • Provide you with specific products and services covered under the terms of a contract with one or more of our Clients, including processing transactions;
  • Perform certain requests/transactions initiated by you;
  • Respond to your questions, complaints, or reviews of our product or services;
  • Comply with applicable law, obey judicial orders, cooperate with law enforcement authorities, or prevent any suspected illegal activities;
  • Help us run our business; or
  • For any other everyday business purposes, such as product development and Application and/or Site administration.

Authorized Service Providers. We use other companies and individuals to perform certain functions on our behalf. Those functions include, without limitation, payment card processors, shipping vendors, call-center support, analyzing or hosting data on cloud-based servers and other companies that help us improve our products and services. We may disclose certain Personal Information to these companies and other individuals performing services in the United States.

Location-based services. We offer to our Clients the ability to use location-based tracking on some mobile technologies as part of Virtual Connections’s Services. To provide location-based services on these Virtual Connections products, we and our partners and licensees may collect, use, and share precise location data, including the real-time geographic location of your device. Where available and enabled within the Virtual Connections product configuration, location-based services may use GPS, Bluetooth, and your IP Address, along with crowd-sourced Wi-Fi hotspot and cell tower locations, and other technologies to determine your devices’ approximate location.

Sale of the Business. If we sell all or part of our business, Personal Information may be transferred to the purchaser in connection with that transaction. We will use reasonable efforts to include contractual provisions that require the purchaser to treat your Personal Information consistent with the terms of this Privacy Policy.

Other Disclosures. We may otherwise disclose Personal Information as permitted or required by law, when we believe in good faith it is necessary for safety purposes, required for legal reporting, or to protect our legal rights or enforce our End User Terms of Use, SaaS Software License or any applicable rules, or to protect the rights of others. We may also disclose Personal Information to our auditors, legal advisors, or to respond to a subpoena. We may also aggregate information that we gather about you (e.g. traffic patterns, services usage) and provide these statistics to others in aggregate form.

Data Security

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration and disclosure.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) login credentials including a password for access to certain parts of the Sites, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

Unfortunately, the transmission of information via the Internet and mobile platforms is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted through the Application and/or Sites. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures we provide.

How do we protect international transfers of Personal Information?

Virtual Connections is based in the United States. If you are located in a jurisdiction outside the United States, the data protection laws in the United States may not be considered to provide an adequate level of protection under your local data protection laws. If you are a user of the Application and/or Sites and prefer not to have your Personal Information transferred to the United States, do not use the Application and/or Site. Otherwise, by using the Application and/or Sites or providing any information, you consent to the transfer of Personal Information to the United States and any other destinations outside of your home country.

If you are located in jurisdictions outside the United States, what are your rights concerning your Personal Information?

Some non-United States jurisdictions maintain local data protection regulations that confer some data protection rights on individuals. Virtual Connections will address such rights as required by applicable laws. Note, if you are an employee or contractor to our Clients, and we obtain access or otherwise process End User Data about you in that context, you should contact your employer/customer who will be in the best position to respond to your inquiry. If you wish to exercise any of these rights, please contact us as specified in the "How to contact us" section below.

European Union (EU) Customers

If you are located in the EU or EEA ("EU Customer"), you have certain additional rights and protections under the law regarding the processing of your personal data.

1. Legal Basis for Processing

If you are an EU Customer, we will only process your personal data:

  • To perform our responsibilities under a contract with our Client or you (e.g. processing payments for and providing services our Client or you have requested);
  • When we have a legitimate interest in processing your personal data (e.g. to communicate with you about changes to our services, to advertise our services, and to provide, secure and improve our services); or
  • To comply with our legal or regulatory obligations.
2. Data Subject Requests

If you are an EU Customer, you have the right to access personal data we hold about you and to have certain personal data corrected or erased. You may also have the right to restrict certain processing of your data.

To make any of these requests please email our Privacy Office at the information as specified in the “How to contact us” section below. We will respond as soon as practicable and no later than one month after receipt of your request. We may request proof of identification to verify your request.

We may deny or restrict fulfillment of your request in some cases, such as when your access to data places another individual's privacy rights at risk, or the continued processing of your data is necessary to comply with a legal obligation. If so, we will notify you of the reason(s) for this denial.

3. Questions or Complaints

If you are an EU Customer and have a concern about our processing of your personal data that we are not able to resolve, you have the right to lodge a complaint with the data privacy authority where you reside. For contact details of your local Data Protection Authority, please see http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm

How long do you retain my Personal Information?

Depending on the product or service, we will retain your Personal Information only for the period necessary to fulfill the purposes outlined in this Privacy Policy or as set out in our Client agreement, unless a longer retention period is required or permitted by a law that applies to us.

What about Minors and Children Under 13?

We are in compliance with the requirements of COPPA (Childrens Online Privacy Protection Act). We do not knowingly collect any Personal Information from children under the age of 13 or knowingly track the use of our Application and/or Sites by minors. Our Application, products and services are all directed to people who are at least 13 years or older.

California Online Privacy Protection Act Compliance

Because we value your privacy we have taken the necessary precautions to be in compliance with the California Online Privacy Protection Act. We therefore will not distribute your personal information to outside parties without your consent. As part of the California Online Privacy Protection Act, all users of our site may make any changes to their information at any time by changing their information in their Application and/or Site settings.

How can you contact us to file a complaint, ask questions, or send us comments about this Privacy Policy?

If you have any questions, have a complaint, or wish to send us comments about this Privacy Policy or exercise any rights, e-mail us info@worldwideassist.net or call 867-888-3388 or write to us. We will investigate your complaint and use reasonable efforts to respond to you as soon as possible.

Our address is:

Virtual Connections LLC
Attn.: Privacy Office
1220 Venice blvd apt 305
Venice, CA 90291

How will you know if we amend this Privacy Policy?

We may amend this Privacy Policy at any time. If we make any material change in how we collect, use, disclose, or otherwise process Personal Information, we will prominently post an updated Privacy Policy on our Sites. Any material changes to this Privacy Policy will be effective ten (10) days after our posting of the updated Privacy Policy. Where required to do so by law, we may seek your prior consent to any material changes we make to this Privacy Policy.