Effective as of May 24, 2018
V2 respects your privacy.
We may also gather generic information automatically to help gauge the effectiveness of our websites, and various promotions aimed at generating traffic to specific areas of our website. This generic information does not include any information that can be used to identify the user but does provide us with what websites were visited and for what duration, the number of pages viewed by a visitor, originating traffic sources, browser technical information, and country of origin. This information is not shared or sold to a third party and is used solely by V2 to improve the content of our websites for our visitors.
“Personal data” means any information relating to an identified or identifiable natural person. An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person (Article 4 of the EU General Data Protection Regulation (GDPR)).
V2 is a Data Processor, working at the request and on behalf of our clients, who are Data Controllers. V2 regularly designs and hosts online registration, survey and polling pages on behalf of our clients. Each page is created unique and to the exact requests of our client; each page collects specific demographic data about registrants as requested by that client. As a part of our service, V2 routinely provides this demographic data at the request of that specific client. Any demographic information processed by V2 on behalf of a client is the property of that client. V2 employees and agents do not view or share this information except as required to adequately provide services to that client. V2 will not sell or provide any information to a third party, or other clients that may employ the services of V2.
With respect to the use of any Personal Data in order to provide services to our Clients, V2 will comply with all applicable Laws relating to privacy and data protection as well as any specific Client instructions regarding Personal Data. With respect to any Personal Data that is subject to EU Data Protection Directive 95/46/EC (or any superseding legislation) (the “Directive”), the V2 shall (1) process any personal data transferred to or collected by V2 on behalf of our clients only as a Data Processor on behalf of the Client, and (2) implement appropriate technical and organizational security measures to protect such personal data from unauthorized access, use, loss, damage or destruction.
V2 maintains a quarterly data deletion cycle where all client data that is older than 12 months is automatically and permanently deleted. This data includes but is not limited to: name, email, company, title, mailing address, as well as other Personal Data and demographic categories that are collected as a part of V2 registration, polling and survey pages. At the request of a client, V2 may adjust the frequency and/or timeline to deletion of data that we store on behalf of our clients. If you as an individual believe that V2 may have processed your data at the request and on behalf of our client, you may submit a DSR (data Subject Rights) request to firstname.lastname@example.org. Please include the name(s) of our clients whom you believe your data may have been gathered on behalf of.
Third Party Disclosure
We do not sell, trade, or otherwise transfer to outside parties your personally identifiable information. This does not include website hosting partners and other parties who assist us in operating our website, conducting our business, or servicing you, so long as those parties agree to keep this information confidential. We may also release your information when we believe release is appropriate to comply with the law, enforce our site policies, or protect ours or others’ rights, property, or safety.
Third Party Links
We do not include or offer third party products or services on our website.
California Do Not Track Disclosures
- We honor do not track signals and do not track, or plant cookies when a Do Not Track (DNT) browser mechanism is in place.
Fair Information Practices, Data Breach Notification
The Fair Information Practices Principles form the backbone of privacy law in the United States and the concepts they include have played a significant role in the development of data protection laws around the globe. Understanding the Fair Information Practice Principles and how they should be implemented is critical to comply with the various privacy laws that protect personal information.
For European customers and per GDPR regulation, we agree to immediately notify you of any data breach involving data collected, stored and uploaded on the Site within 24 hours of detection of a breach. For customers outside of Europe and who are exempt from GDPR regulation, we will do our best effort to notify you of any data breach involving data collected, stored and uploaded on the Site. We take these actions in best effort and intention, and to remain in compliance with any and all regulation regarding data breaches, but in no way shall these notifications be viewed or understood to be an admission of neglect or fault by us for any possible causes or outcomes of any data breach.
Blog, Visitor Submission Forms
V2 hosts Visitor Submission Forms (“Contact us” forms), and may from time to time host Blogs or search field topics that may gather visitor demographic data, such as name, and email. V2 may use this information to provide updates about our website and our services. V2 will not resell or provide this information to any third party vendors.
Exceptions to this policy
In extreme circumstances, at the sole discretion of V2 and/or as requested by law enforcement authorities or government officials, V2 may release demographic information to law enforcement authorities or other government officials in connection with an investigation of any matter that is illegal, to prevent or combat fraud, or any circumstance that could expose V2 to liability.
V2 welcomes your questions and comments regarding this statement of privacy. Please contact us at email@example.com or via posted mail at: V2, LLC, Attn: Privacy, 4224 NE Halsey Street, Suite 320, Portland, OR, 97213.