The VCS Platform is a tool used by businesses (including direct customers of VCS and customers who access the Platform through a VCS reseller) and their employees, agents and authorized users (the “Business Customers”) to deliver webinars and other content to registrants, attendees, participants, and other end users (the “End Users”). Collectively, End Users and Business Customers are “Platform Users”.
This Policy applies to the personal information that VCS’s Business Customers submit to us via the Platform, as well as the personal information we collect, access, store, use or otherwise process (collectively, “process”) via the Platform on behalf of Business Customers, including the Registrant Information, Other Information and User Communications (each defined below), as well as other personal information we process from End Users of the Platform (together the “Platform Data”).
Controller and Responsible Entity:
With respect to the Platform Data, VCS is a “data processor” or “service provider” under applicable data protections laws. As a data processor or service provider, we will only process the Platform Data pursuant to our client’s instructions, as set forth in our applicable client agreements, and as otherwise required by applicable privacy and data protection laws. This Policy does not apply to processing of Platform Data or any other personal information collected via the Platform by clients, which is subject to their own policies and practices.
With respect to the Platform Data we process that is subject to EU and Swiss data protection laws, VCS has certified its adherence to and will comply with the EU-U.S. and Swiss-U.S. Privacy Shield Principles, which can be found at www.privacyshield.gov/ (collectively, “Privacy Shield Principles”). You can review the Privacy Shield Principles, learn more about Privacy Shield, and view our Privacy Shield certification at www.privacyshield.gov/. VCS’s commitments under the Privacy Shield are subject to the investigatory and enforcement powers of the United States Federal Trade Commission. Please note: On July 16, 2020, the European Court of Justice invalidated the EU-US Privacy Shield Program as an adequacy mechanism for transfers of personal data to the United States. VCS will continue to comply with its Privacy Shield commitments for so long as it remains an active participant in the program. In addition, we will work with clients to implement additional adequacy measures where necessary under applicable data protection laws in the European Economic Area (EEA) and the United Kingdom (UK), such as the EU standard contractual clauses for the transfer of personal data to processors established in third countries.
2. Data Collected:
Information Collected Directly:
End User Information. To access webinars, virtual environments and other events administered by Business Customers via the Platform as an End User, you may be required to register. While our Business Customers determine what information to collect from End Users, the requested personal information typically includes name, email address, telephone number, company name and job title as well as information about your company such as country and industry sector.
User Communications. When you send email or other communication to VCS or another user, we may retain those communications in order to process your enquiries, respond to your requests and to improve our services.
Affiliated Sites. We may offer services in connection with other websites or suppliers. Personal information that you provide to those sites may be sent to us in order to deliver these services. We process such information in accordance with this Policy.
Other Information. VCS’s Business Customers may request additional information, like surveys or polls, be filled out in some webinars or virtual environments. Business Customers are responsible for configuring the Platform to collect such personal information.
Information Collected Automatically:
Log Information. When you use VCS, our servers record, in a server log, information that your browser sends whenever you visit a website. Server logs may include information such as your web request, Internet Protocol address, browser type, browser language, the date and time of your request and one or more cookies that may uniquely identify your browser.
Aggregate and De-Identified Information:
VCS may process (i.e., collect, use and disclose) aggregate de-identified information, and other information that is not personally identifiable, for research, analytics and other purposes, provided such information does not identify, and could not reasonably be used to identify a particular Business Customer or End User
3. Use of Information:
VCS uses the personal information we collect via the Platform to provide our services to Business Customers, including to operate and improve the Platform and our services, to provision Platform Users’ accounts, to carry out the transactions Platform Users request via the Platform, and to respond to Platform User requests.As noted above, VCS is a data processor of the personal information collected via the Platform. Business Customers are data controllers with respect to Platform User personal information; this Policy does not apply to the processing (including collection, use and sharing) of Platform User personal information by Business Customers.
Business Customers may use the personal information they collect via the Platform for additional purposes, such as to deliver targeted content within the Platform, to contact End Users about their use of the Platform, for marketing and promotional purposes, and for other purpose; you should review their privacy policies for more information about how they collect, use and share the personal information collected via the Platform.
4. Sharing of Information; Onward Transfers:
As noted, Platform User information, including End User personal information, is shared with the Business Customer upon whose behalf the information was collected or Platform is being operated; this Policy does not apply to the processing (including collection, use and sharing) of Platform User personal information by Business Customers, and we are not responsible for such processing.
VCS will not share personal information about Platform Users with third parties except to provide the products or services you have requested, with consent, or under the following circumstances:
Third parties who process personal information on our behalf must agree to use such personal information only for the purpose for which it is provided by us and they must contractually agree to provide adequate protections for personal information; VCS will continue to be liable for any onward transfers of personal information to such third parties.
We may also disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements, as well as where is necessary to satisfy any applicable law, regulation, legal process or enforceable government request, to enforce our User Agreement and investigate violations thereof, to prevent, detect and address fraud, security or technical issues, or to protect against harm to the rights and property of VCS. If we are acquired by or merged with another company, if substantially all of our assets are transferred to another company (including as due diligence and for other purposes prior to the closing of such a transaction), or as part of a bankruptcy proceeding, we may transfer the information we have collected (including personal information) to the acquiring company.
5. Accessing, Amending and Limiting Use of Your Personal Information
Individuals have the right to access the personal information that is maintained about them, and in some cases to limit use and disclosure of such information. Registered Platform Users may log into their accounts to view and amend certain personal information in their profile. EU and Swiss End Users who would like to request access to, to limit use of, or to limit disclosure of their personal information collected via the Platform by a Business Customer should contact that Business Customer directly; EU and Swiss End Users may also make such requests by contacting us at [email protected] and providing the name of the Business Customer. We will refer such requests to that Business Customer and will support them as needed in responding to your request.
To secure your personal information access to your data is password protected, and sensitive information is protected by encryption when it is exchanged between your Web browser and our Website. It is your responsibility to keep your password confidential and not to share this information with anyone. While we will implement the security measures detailed above, transmission of information via the internet is not completely secure and therefore transmission via the internet is at your own risk.
7. Complaints and Disputes
Individual Platform Users who have any questions, complaints, or disputes regarding this Policy or the manner in which VCS handles or protects personal information may contact us at [email protected] We will promptly investigate and attempt to resolve any complaints and disputes and will respond within 45 days of receiving any such complaint.
For EU and Swiss Platform Users whose complaint cannot be resolved through this process, VCS agrees to participate in a dispute resolution process administered by JAMS. For information about how to initiate a Privacy Shield claim with JAMS, go here. If neither VCS nor JAMS resolves your complaint, you may be able to engage in binding arbitration through a Privacy Shield arbitration panel (for more information, go here).
VCS may update this Policy from time-to-time, so please review it frequently. In the event we make material changes in the way we treat user personal information, we will notify you by email.
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