Last Modified: July 2, 2019
Introduction
Vital Technical Marketing, Inc., dba VTM Group, (“VTM” or “We”) has developed this Privacy Policy (“Policy”) to provide information on how we handle personal information we collect through individuals who engage with us or use our services (“Services”) and the personal information we receive about individuals as a result of Services we provide to third parties, including companies or organizations of which you or your employer may be a member (“Company”). We respect your privacy and are committed to protecting it through our compliance with this Notice and our online service Causeway’s Privacy Policy, which supplements this Policy and explains how we handle personal information collected and processed from users of VTM’s Causeway site.
This Policy describes the types of information we may collect and our practices for collecting, using, maintaining, protecting, and disclosing that information. This Policy is supplemented by and includes our GDPR Compliance Policy.
This Policy may change from time to time (see Changes to Our Privacy Policy, including when required to comply with applicable laws and regulations. When we change this Policy, we will take steps to notify you by posting a notice on our website or via email.
We have recently updated this Policy in our effort to be a compliant data processor under the GDPR. Please see our section on GDPR Compliance.
What information do we collect?
We may collect the following personal information regarding you as an individual:
- Causeway access and use
Access and use of our Causeway websites as provided in the Causeway Privacy Policy.
- Responding to a request from you
When you contact us (online or offline) to request more information regarding our Services, including for support with a Service we provide you or a Company to which you are a member or interested in becoming a member, we collect information necessary to fulfill your request.
- Providing Services to Companies
In our relationship with our client Companies, the Companies may provide us with your personal information or direct us to collect and process such information from you. This information may include your business contact information, such as name, business contact details, position or title, and other information you voluntarily submit to the Company or us. In some situations, we may also collect and process payment information and conference and membership information.
Personal information of yours collected and processed as a result of VTM providing Services to a Company are subject to the Company’s policies, if any. Please direct all your privacy inquiries, including any requests to exercise your rights, to your Company’s administrator.
Accessing and Correcting Your Information
For information contained on a Causeway website, please see the Causeway Privacy Policy in regard to accessing and correcting your information here.
You can request to access or correct your personal information by emailing privacy@vtmgroup.com. If personal information of yours was collected and processed as a result of VTM providing Services to a Company, your personal information is subject to the Company’s policies, if any. Please direct all your privacy inquiries, including any requests to exercise your rights, to your Company’s administrator. If you contact us by email and your personal information was collected as a result of VTM providing Services to a Company, we can direct you to the right contact information for the Company.
What do we use your information for?
Any of the information we collect or process from you may be used in any of the following ways:
- To carry out our obligations and enforce our rights arising from our agreement to provide Services to the Company (your business contact information is a key part of the Service we provide under our agreement with Company)
- To respond to your request and personalize your experience (your information helps us to better respond to your individual and the Company’s needs)
- To improve our website (we continually strive to improve our website offerings based on the information and feedback we receive from you)
- To improve customer service (your information helps us to more effectively respond to your customer service requests and support needs)
- To send periodic emails (the email address you may provide may be used to send you information, respond to inquiries, and/or other requests or questions)
How do we protect your information?
We implement reasonable and appropriate administrative, technical, and physical security measures to maintain the safety of your personal information. Unfortunately, no security measures are guaranteed to be 100% secure, including the transmission of information via the internet. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures when you or Company transmit information to VTM.
Do we use cookies?
Cookies are small files that a site or its service provider transfers to your computer’s hard drive through your Web browser (if you allow) that enables the site or service provider systems to recognize your browser and capture and remember certain information. 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 Website.
VTM does not use cookies to track your activity while using the Website. For Causeway’s cookie policy, please go here.
Do we disclose any information to outside parties?
We do not sell or trade your personally identifiable information. We may transfer your personal information:
- To our subsidiaries and affiliates.
- To contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.
- To fulfill the purpose for which you provide it. For example, if you give us an email address to use the "email a friend" feature of our Website, we will transmit the contents of that email and your email address to the recipients.
- 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.
- To enforce or apply any agreement with Company, including for billing or collection purposes.
- If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of VTM, 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 disclose aggregated information about our users, and information that does not identify any individual, without restriction.
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 except as outlined in this Policy without your consent.
Children’s Online Privacy Protection Act Compliance
We are in compliance with the requirements of COPPA (Children’s Online Privacy Protection Act), we do not collect any information from anyone under 13 years of age. Our website, products and services are all directed and intended to people who are at least 13 years old or older, and no one under age 13 may provide any information to or on the Website. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us at privacy@vtmgroup.com.
Your Consent
By using our site and our Services, you consent to this Policy.
Changes to our Privacy Policy
If we decide to change this Policy, we will post those changes on this page, and/or update the Policy modification date below. If we make material changes to how we treat our users' personal data, we will notify you through a notice on the Website home page or by email to the email address specified in your account. The date the privacy policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Website and this privacy policy to check for any changes.
This Policy was last modified on July 2, 2019.
Contacting Us
If there are any questions regarding this Policy, you may contact us using the information below.
ATTN: Legal Privacy
VTM Group
3855 SW 153rd Drive
Beaverton, OR 97003
USA
privacy@vtmgroup.com
+1.503.619.0505
To register a complaint or concern please contact, us in writing, at:
Postal Service: VTM Group
3855 SW 153rd Drive
Beaverton, OR 97003
USA
Electronic Mail (email): privacy@vtmgroup.com
GDPR Compliance Policy
Last Modified: July 2, 2019
Introduction
This GDPR Compliance Policy describes how Vital Technical Marketing, Inc., dba VTM Group, in the United States (“US”) (“VTM,” “we,” or “us”) processes certain personal data that we receive in the US from the European Economic Area (“Personal Data”). This GDPR Compliance Policy supplements our Website Privacy Policy only insofar as you are an EU Data Subject as defined below, and unless specifically defined in this GDPR Compliance Policy, the terms in this GDPR Compliance Policy have the same meaning as the Website Privacy Policy.
Definitions
- “Data Protection Legislation” means the Regulation (EU) 2016/679, commonly known as the Global Data Protection Regulation or GDPR.
- “EU Data Subject” means an individual located in the European Union and the countries of Iceland, Liechtenstein and Norway and, if applicable, Switzerland.
Any term not defined herein has the same meaning as it is defined under the Data Protection Legislation if and only if it is specifically defined under the Data Protection Legislation.
Data Processor
VTM is the data processor on behalf of the Company processing data. The Company is the data controller.
Data Collection and Processing
VTM processes the personal data set out in the section of the Website Privacy Policy titled ‘What information do we collect?’ and for purposes set out in the section of the Website Privacy Policy titled ‘What do we use your information for?’.
Basis for Processing
VTM processes your personal data to fulfill its contractual obligations under VTM’s agreement with the Company, as a result of your express consent to the Privacy Policy, your implied consent in continuing to use this Website and when contacting and interacting with VTM, when we have a legal obligation to do so, and where our legitimate interests are not overridden by your fundamental rights and freedoms.
Sharing of Your Personal Data
VTM only shares your personal data with:
- Our subsidiaries and affiliates.
- Contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.
- Sub-processors authorized by the Company, including web hosting services, email and online storage services, payment processors, event registration and scheduling tools, email newsletter tools, bug-tracking and coding tools, survey tools, and webinar and online communication tools. When selecting sub-processors, we consider the personal data they will be processing and their data handling processes. Personal data is provided these sub-processors only as necessary for the purposes for which it was provided.
- To fulfill the purpose for which you provide it. For example, if you give us an email address to use the "email a friend" feature of our Website, we will transmit the contents of that email and your email address to the recipients.
- Your consent.
Your Rights
As the data controller, the Company is your point of contact to enforce your rights under the Data Protection Legislation. If you have any question who the appropriate contact would be, please feel free to contact VTM at privacy@vtmgroup.com, and we will provide the appropriate contact information.
However, to assist with the Company’s obligation of transparency, we have set forth the table below to help you enforce your rights.
- Right to access personal data about you: You can ask the Company if they are processing your personal data. If so, the Company can also provide you with a copy of that personal data.
- Right to object to processing: You may contact the Company and ask them to have us stop processing your personal data.
- Right to data portability: You may contact the Company and ask them for a copy of your personal data.
- Right to complain: You have the right to report a problem with the way we have handled your personal data with the data protection authority that is authorized to hear your concern.
- Right to object to automated decision making: As we don’t have any decisions based upon automated decision making, this right is fully met by the Company’s agreement with VTM.
- Right to rectification: All personal data can be modified by contacting the Company.
- Right to be forgotten: You may contact the Company and ask them to delete any personal information. Where possible, the Company’s administrator can delete your personal data or have it anonymized.
Privacy Shield Policy
Last Modified: July 2, 2019
This Privacy Shield Policy (“Shield Policy”) describes how Vital Technical Marketing, Inc., dba VTM Group, in the United States (“US”) (“VTM,” “we,” or “us”) collects, uses, and discloses certain personally identifiable information that we receive in the US from the European Economic Area (“EEA Personal Data”) and Switzerland (“Swiss Personal Data”). This Shield Policy supplements our Website Privacy Policy, and unless specifically defined in this Shield Policy, the terms in this Shield Policy have the same meaning as the Website Privacy Policy.
VTM complies with the EU-U.S. Privacy Shield Framework and Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States. VTM has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/
Personal Data Collection and Use
Our Website Privacy Policy describes the categories of EEA and Swiss Personal Data that we may receive in the US as well as the purposes for which we use that EEA and Swiss Personal Data. We process EEA and Swiss Personal Data for the following primary purpose: to fulfill our contractual obligations and carry out our rights under our agreement with the company or organization through which you are accessing this Website (“Company”). Other purposes for which we process EEA and Swiss Personal Data include those set out in ‘What do we use your information for?’. VTM will only process EEA and Swiss Personal Data in ways that are compatible with the purposes that VTM collected it for, or for purposes the individual later authorizes. Before we use your EEA and Swiss Personal Data for a purpose that is materially different than the purposes we collected it for or that you later authorized, we will provide you with the opportunity to opt out. VTM maintains reasonable procedures to help ensure that EEA and Swiss Personal Data is reliable for its intended use, accurate, complete, and current.
We do not collect any category of sensitive EEA and Swiss Personal Data.
Data Transfers to Third Parties
Third-Party Agents or Service Providers. We may transfer EEA and Swiss Personal Data to our third-party agents or service providers who perform functions on our behalf. Where required by the Privacy Shield, we enter into written agreements with those third-party agents and service providers requiring them to provide the same level of protection the Privacy Shield requires and limiting their use of the data to the specified services provided on our behalf. We take reasonable and appropriate steps to ensure that third-party agents and service providers process EEA and Swiss Personal Data in accordance with our Privacy Shield obligations and to stop and remediate any unauthorized processing. Under certain circumstances, we may remain liable for the acts of our third-party agents or service providers who perform services on our behalf for their handling of EEA and Swiss Personal Data that we transfer to them. We may use Google Analytics to analyze traffic and usage of our services. You can find out more information about Google Analytics cookies here: https://policies.google.com/technologies/partner-sites. To opt-out of Google Analytics relating to your use of our Sites, you can download and install the Browser Plugin available via this link: https://tools.google.com/dlpage/gaoptout?hl=en.
If we transfer your EEA and Swiss Personal Data to one of our affiliated entities within our corporate group, we will take steps to ensure that your EEA and Swiss Personal Data is protected with the same level of protection the Privacy Shield requires.
Disclosures for National Security or Law Enforcement. Under certain circumstances, we may be required to disclose your EEA and Swiss Personal Data in response to valid requests by public authorities, including to meet national security or law enforcement requirements.
Security
VTM maintains reasonable and appropriate security measures to protect EEA and Swiss Personal Data from loss, misuse, unauthorized access, disclosure, alteration, or destruction in accordance with the Privacy Shield.
Access Rights
You may have the right to access the EEA and Swiss Personal Data that we hold about you and to request that we correct, amend, or delete it if it is inaccurate or processed in violation of the Privacy Shield. These access rights may not apply in some cases, including where providing access is unreasonably burdensome or expensive under the circumstances or where it would violate the rights of someone other than the individual requesting access. If you would like to request access to, correction, amendment, or deletion of your EEA and Swiss Personal Data, you can submit a written request to the contact information provided below. We may request specific information from you to confirm your identity. In some circumstances we may charge a reasonable fee for access to your information.
Questions or Complaints and Independent Recourse Mechanism
In compliance with the Privacy Shield Principles, VTM commits to resolve complaints about our collection or use of your personal information. EU and Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should first contact VTM at:
ATTN: Legal Privacy
VTM Group
3855 SW 153rd Drive
Beaverton, OR 97003
USA
privacy@vtmgroup.com
+1.503.619.0505
VTM has further committed to refer unresolved Privacy Shield complaints to through an alternative dispute resolution provider located in the United States. If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.
Binding Arbitration
You may have the option to select binding arbitration for the resolution of your complaint under certain circumstances, provided you have taken the following steps: (1) raised your complaint directly with VTM and provided us the opportunity to resolve the issue; (2) made use of the independent dispute resolution mechanism identified above; and (3) raised the issue through the relevant data protection authority and allowed the US Department of Commerce an opportunity to resolve the complaint at no cost to you. For more information on binding arbitration, see US Department of Commerce's Privacy Shield Framework: Annex I (Binding Arbitration).
Contact Us
If you have any questions about this Shield Policy or would like to request access to your EEA and Swiss Personal Data, please contact us as follows:
ATTN: Legal Privacy
VTM Group
3855 SW 153rd Drive
Beaverton, OR 97003
USA
privacy@vtmgroup.com
+1.503.619.0505
Changes to This Policy
We reserve the right to amend this Shield Policy from time to time consistent with the Privacy Shield's requirements.
Last Modified: July 2, 2019