What information do we collect? How do we collect that information?
1.a. Information voluntarily provided to us.
In short: We collect personal information that you voluntarily provide to us.
We collect Personal Information that you voluntarily provide to us when you express an interest in obtaining information about us or our products and services, when you participate in activities on our Website or otherwise when you contact us.
The Personal Information that we collect depends on the context of your interactions with us and the Website, the choices you make and the products and features you use.
We have collected within the last twelve (12) months, and may collect in the future the following categories of Personal Information from consumers listed below, for commercial and/or business purposes under the California Consumer Privacy Act of 2018 (CCPA):
- Identifiers and registration contact information: such as name, e-mail address, postal address, telephone number, account name, online identifier, Internet Protocol (IP) address, or other similar identifiers.
- Customer records information: such as name, signature, social security number, physical characteristics or description, address, telephone number, passport number, bank account number, credit or debit card number, other financial information.
- Commercial information: such as delivery information andrecords of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies and transactions made with us.
- Internet or other electronic network activity information: device information and device identifiers, browsing type and language, browsing history, search history, and information regarding a consumer’s interaction with an Internet website, application, or advertisement, and data connection and use, such as information you download.
- Geolocation data: such as city, state, zip code, etc. related to your IP address.
- Inferences on your preferences and characteristics.
- Other information: such as any other information you choose to provide us directly in relation to the use of our services, surveys we send you, etc., customer information such as questions and other messages that you send us directly through online forms, chats, e-mail, phone, or post, summaries or voice recordings of your interactions with customer service.
All Personal Information that you provide to us must be true, complete and accurate, and you must notify us of any changes to such personal information.
Privacy Shield Framework compliance:
Vates complies with the EU-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 to the United States. Vates has certified to the U.S. Department of Commerce that it adheres to the Privacy Shield Principles.
In compliance with the Privacy Shield Principles, Vates commits to resolve complaints about our collection or use of your personal information. EU individuals with inquiries or complaints regarding our Privacy Shield policy should first contact Vates at: firstname.lastname@example.org or +1 (954) 8896722.
Vates has further committed to cooperate with the panel established by the EU data protection authorities (DPAs) with regards to unresolved Privacy Shield complaints concerning data transferred from the EU.
1.b. Information automatically collected.
In Short: Some information such as your Internet Protocol (IP) address and/or browser and device characteristics is collected automatically when you visit our Website.
We automatically collect certain information when you visit, use or navigate our Website. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Website and other technical information. This information is primarily needed to maintain the security and operation of our Website, and for our internal analytics and reporting purposes.
Like many businesses, we also collect information through cookies and similar technologies.
The information we collect includes:
- Log and Usage Data:Log and usage data is service-related, diagnostic, usage and performance information our servers automatically collect when you access or use our Website and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type and settings and information about your activity in the Website (such as the date/time stamps associated with your usage, pages and files viewed, searches and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called ‘crash dumps’) and hardware settings).
1.c. Personal Information we collect from third-parties.
In Short: We protect the Personal Information obtained from third parties.
We work closely with various third parties and may receive Personal Information from them. We protect the Personal Information obtained from them in accordance with the practices and policies described herein, plus any additional obligations imposed by the third-party source of your Personal Information. The third-party sources may vary due to context, but may include the following:
- Data brokers from which we purchase data to complement the Personal Information we collect.
- Partners: (i) authentication partners: if you register or log in into our services using third party credentials (e.g. Facebook) we will import your information from such third-party source to help you create an account on our website; (ii) technical services partners that helps us without technology, and may provide us with certain data (e.g. such as mapping IP address to location data) to help us to provide our services, (iii) advertising partners, that provide us with services on our website (analytics, marketing, etc.) providing with inferences about your preferences and interests to offer you a better service and customized offerings, (iv) payment partners, if you choose to pay for a service and/or product, we may receive data from our them, to enable us to send you invoices, process your payment, (v) resellers, distributors, that deliver the product and/or service you have contracted, and therefore may supply us with data to help us provide improve our services, amongst others.
During the past 12 (twelve) months we have disclosed the categories of Personal Information about you listed above to our affiliates, group companies, and service providers for our business and commercial purposes. We have not, however, sold your Personal Information to third parties and shall not sell your Personal Information to third parties.
1.d. Children’s information
In Short: We do not collect Personal Information from children under the age of 13 nor from the ages of 13 to 16, if we have actual knowledge that the user is less than those years of age.
Our services are not directed to children under the age of 13 years, or from ages from 13 to 16, or equivalent minimum age in the relevant jurisdiction. If you are under the age limit of 13 years, or from 13 to 16 years old, please do not use our services and do not provide us with any Personal Data or information. We will not collect, process nor sell the Personal Information of users under 13 years of age, or from 13 to 16 years, if we have actual knowledge that the user is less than those years of age.
How do we use your Personal Information?
In Short: We process your Personal Information for purposes based on legitimate business and commercial interests, the fulfillment of our contract with you and compliance with our legal obligations.
We use personal information collected via our Website for a variety of business and commercial purposes described below. We process your personal information for these purposes in reliance on our legitimate business and commercial interests, in order to enter into or perform a contract with you, with your consent, and/or for compliance with our legal obligations. We indicate the specific processing grounds we rely on next to each purpose listed below.
Such business purposes may be:
- To fulfill the purpose for which the Personal Information is provided.
- To provide you with information, products and/or services that you request from Vates.
- To communicate and respond to your requests and inquiries to Vates.
- To operate our business and provide you with our products and services: engage in transactions with clients, and process orders from our services.
- To follow up with our products and/or services after delivering them (email or phone inquiries).
- To provide consumers with e-mail alerts, event registrations, and other notices concerning Vates’s products and/or services, or events or news that might be of interest to the consumer.
- To administer and improve the functionality of our Website and its technical and functional management and present its content to our clients or others.
- To analyze, develop and improve the use and performance of our Site.
- To modify, enhance, or improve our services and/or provision of such services to our clients.
- As necessary and appropriate to protect the rights, property of Vates, our clients, or others.
- To carry out obligations and enforce our rights arising from any agreement entered between Vates and Vates’s clients or other contractual third-party, including billing and collections.
- For testing, research, analysis, and product and services development.
- To manage the security of our Website.
- To comply with applicable law and regulations to operate our business.
- To respond to law enforcement requests as required by applicable law, court order, or governmental regulations.
Such commercial purposes may be:
- To market our products and/or services and/or related products and services, and to tailor our marketing and sales activities to our clients’ interests.
The Personal Information we collect allows us to keep you posted on Vates’s latest product announcements, software updates, and upcoming events; to customize the content and advertising you see on our website personalizing your experience and allowing us to deliver the type of content and product offerings you are most interested and to send periodic emails regarding our products and/or services. If you don’t want to be on our mailing list, you can opt-out anytime by accessing the following: email@example.com.
Where do we store your Personal Information?
Your Personal Information will be stored in Vates’s databases.
Will your Personal Information be shared with anyone?
In Short: We only share information with your consent, to comply with laws, to provide you with services, to protect your rights, or to fulfill business obligations.
We may process or share your Personal Information that we hold based on the following legal basis:
- Consent:We may process your Personal Information if you have given us specific consent to use your personal information for a specific purpose.
- Legitimate Interests:We may process your Personal Information when it is reasonably necessary to achieve our legitimate business interests.
- Fulfillment of a Contract:Where we have entered into a contract with you, we may process your Personal Information to fulfill the terms of our contract.
- Legal Obligations:We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).
- Vital Interests:We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.
- Business Transfers.We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
The Personal Information that we collect may be shared with:
- Our affiliates: To provide our services and/or products.
- Our service providers: That help us conduct our business and support infrastructure, payment processors when you purchase our products and/or services.
- Advertising partners.
- Channel Partners.
- Vendors and Agent.
4.1. Transfer of your Personal Information to other countries
In some cases, our third-party service providers are located in other countries, meaning your Personal Information may be processed or stored in other countries. In certain circumstances, our service providers may be required to disclose information to government authorities, regulators, courts, or law enforcement in those countries.
When your Personal Information is transferred internationally to third parties located in territories which may not offer an equivalent level of protection to privacy as that applicable within your country of residence (Personal Data collected within the European Economic Area (EEA), for example, may be transferred to be processed by third countries located outside the EEA), we ensure that the transfer of your Personal Data is carried out in accordance with applicable privacy laws and that appropriate technical and organizational security measures are taken. We will take all the necessary steps to verify that your Personal Data receives an adequate or substantially equal (where required by local law) level of protection.
- Legal basis for processing your Personal Data.
In Short: We rely on various legal bases to collect and process the Personal Information that we collect.
We rely on the following legal bases to collect and process your Personal Information:
- Consent: where you have provided your consent for the processing of your Personal Information for a specific purpose.
- Performance of a contract: where processing is necessary for the performance of a contract with you, or taking steps prior to entering a contract with you.
- Legal obligation: where we have a legal obligation to process your Personal Data for example when responding to a public or governmental authority, courts, or regulators, according to a legal obligation under applicable law-.
- Legitimate interest: to satisfy a legitimate interest, for example when it is not required by law but it clearly benefits you.
What are cookies and how do we use them or other tracking technologies?
Cookies are small files that a site or its service provider transfers to your computer’s hard drive through your Web browser (if you give permission to the browser) that enables the site’s or service provider’s systems to recognize your browser and capture and remember certain information. Cookies can gather information about the use of a website or enable the website to recognise the user as an existing customer when they return to the website at a later date. This file is neither a virus nor spyware.
- Understand and save your preferences for future visits.
- Compile aggregate data about site traffic and site interactions in order to offer better site experiences and tools in the future. We may also use trusted third-party services that track this information on our behalf.
There are different categories of cookies:
We may also use Web Beacons, which are very small graphic images or objects embedded in our web page or e-mail) to collect information about your online actions, visits to our website, and activity.
How to manage cookies.
- In your Web Browser
- In your mobile device
In your mobile device, your operating system (OS) offers options for avoiding personalized advertising (both in IOS and Android) to limit the use of information with the use of apps to generate advertisements based on your interests and tastes. Please be aware that advertisers and our partners may also use their own cookies and beacons, and we do not hold control of the information they collect. You will need to refer to their Privacy Policies. These third parties may use the information collected to serve more relevant advertisements. To configure your cookie controls and reject advertising cookies, follow the instructions on your device.
How long do we keep your information?
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
How do week keep your information safe?
In Short: We aim to protect your personal information through a system of organizational and technical security measures.
We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your Personal Information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security, and improperly collect, access, steal, or modify your Personal Information. Although we will do our best to protect your personal information, transmission of personal information to and from our Website is at your own risk. You should only access the Website within a secure environment.
In Short: You have rights regarding the Personal Information that we collect. You can request access, rectification, erasure, etc. of the Personal Information collected.
9.1. Rights under Argentina’s Personal Data Protection Act N° 25.326 (PDPA)
- Require us to inform you about the Personal Data we hold about you;
- Require us to access the Personal Data we hold about you;
- Require us to rectify the Personal Data we hold about you;
- Require us to update the Personal Data we hold about you;
- Require us to delete Personal Data (including where our processing activity is based on their consent);
Your exercise of some of these rights is subject to certain exemptions (e.g. the right for you to request us to delete your Personal Data when we have a legal obligation to retain such data, or such deletion affects a third party. In those cases we are not allowed to proceed with the aforementioned request).
If you exercise any of these rights we will check your entitlement and respond to you within ten (10) days when you require access to your Personal Data or five (5) days when you require any rectification, update, or deletion.
According to the section 14, paragraph 3 of Act 25.326 the right to access your Personal Data at intervals of not less than six months is free of charge, unless there is a specified legitimate interest agreed upon by the interested party. You can access said Personal Data by submitting an email to firstname.lastname@example.org or calling at the following number +1 (954) 8896722.
The Agency of Access to Public Information, in its function of Controlling Entity of Act 25.326, has the attribution to attend any complaints or reports related to the infringement of personal data regulations”.
According to section 19 of act 25.326, the rectification, update or erasure of Personal Data that is inexact or incomplete is free of charge.
9.2. Rights under GDPR, CCPA and Privacy Shield Framework.
Under current privacy laws and regulations, the General Data Protection Regulation (GDPR), CCPA and the Privacy Shield Framework, you possess certain rights in relation to your Personal Information, as follows:
9.2.1. Under the GDPR:
If you are a resident from the European Economic Area (EEA) or the UK, you have the following rights regarding your Personal Information:
- Right of access: you have the right to be informed and request access to the Personal Data we have collected and process about you.
- Right to rectification: you have the right to request the rectification of inaccurate Personal Data concerning you, which must be duly amended or updated without undue delay.
- Right to erasure: you have the right to request we delete your Personal Data.
- Right to restriction of processing: you have the right to request us to stop processing either all or some of your Personal Data, temporarily or permanently.
- Right to data portability: you have the right to request a copy of your Personal Data in electronic format and the right to transmit your data to another controller.
- Right to object: you have the right, at any time, to object to us processing your Personal Data on grounds relating to your particular situation, and the right to object to your Personal Data being processed for direct marketing purposes.
- Right not to be subject to automated decision making: you have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.
To exercise any of the aforementioned rights, please email us at email@example.com.
To opt-out of our marketing mails, please contact us at firstname.lastname@example.org.
9.2.2. Under the CCPA:
If you are a resident of the state of California, USA, please be advised that you may exercise the following additional rights, under the CCPA. Under the CCPA, you have the right to request information about our data collection, namely, how we gather it, how we share it, how we sell it, when and how disclose your information and when and how we delete it.
Right to Know:
You have the right to know the specific pieces of information we collect, use, disclose or sell, and have collected, used, disclosed, or sold, covering the 12-month period preceding our receipt of your information request. In particular, you can ask us to disclose:
- The specific pieces of your Personal Information we collect or have collected.
- The categories of Personal Information we have to collect or have collected about you;
- The categories of sources from which we collect or have collected your Personal Information;
- The categories of your Personal Information that we sell, or have sold, disclose, or have disclosed for a business purpose;
- The categories of third parties to whom we sell or have sold, disclose, or have disclosed your Personal Information.
- The business or commercial purpose for which we have to collect, sell, or have collected or sold your Personal Information;
You can make a request to know up to twice a year, free of charge.
Right to Delete:
You also have the right to request that we delete Personal Information, subject to certain exceptions according to applicable law, for instance when we are legally obligated to keep the information. You may exercise your right by using our Contact Form and typing in the message box “I want to permanently delete my data” or emailing us at email@example.com.
Right to Receive a Copy:
You have the right to request a copy of the Personal Information we have collected about you. You may exercise your right by using our Contact Form and typing in the message box “I want to receive a copy of my Personal Information” or emailing us at firstname.lastname@example.org.
Right to opt-out of the Sale of Your Personal Information:
You have the right to opt-out of the sale of the Personal Information we have collected about you. After you make said request we can no longer sell or share your personal information, unless you later authorize us to do so again.
Right to Correct:
You have the right to request that we correct inaccurate Personal Information that we have collected about you.
Right To Limit Use and Disclosure of Sensitive Personal Information:
You have the right to request that we limit the use and disclosure of sensitive personal information (for example your social security number, financial account information, your precise geolocation data, or other generic data).
Right to non-discrimination:
You have the right not to be discriminated against by us; namely, by us denying you goods or services, charging you a different price or rate for our goods and services, amongst others, resulting from your exercise of any of your consumer rights under the CCPA.
9.2.3. Under the Privacy Shield Framework:
Vates can be subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC). As an individual, under certain conditions, you can contact us to invoke binding arbitration.
We will post any changes to this policy on this page and we will also contact you via your contact information, for example by email. Each version of this policy is identified at the bottom of the page by its effective date.
How to contact us