Last updated: June 6th, 2018.
vSplash Techlabs, Inc. (“vSplash” “we” or “us) is committed to protecting your privacy. This Statement of Privacy applies to the vSplash website and the vSplash services platform. This statement governs the data collection, processing, and usage practices of vSplash. By using the vSplash website or its services platform, you consent to the data practices described in this statement.
Service Provider Collection/Use
vSplash collects information under the direction of its Clients. vSplash has no direct relationship with the individuals whose personal data it processes. vSplash works with its Clients to help them provide notice to their customers concerning the purpose for which personal information is collected.
vSplash collects information for our Clients. If you are a customer of one of our Clients and would no longer like to be contacted by one of our Clients that uses our services, please contact the client that you interact with directly. If you are a Client and would like to update your account, please contact us.
Service Provider, Sub-Processors/Onward Transfer
vSplash may transfer personal information to companies that help us provide our service. Transfers to subsequent third parties are covered by the provisions in this Policy regarding notice and choice and the service agreements with our Clients.
Access to Data Controlled by our Clients
vSplash has no direct relationship with the individuals whose personal data it processes. vSplash acknowledges that individuals have the right to access the personal information/data that we maintain about them. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data, should direct his query to firstname.lastname@example.org. If requested to remove data, we will respond within 30 business days
vSplash takes reasonable steps to ensure that data is reliable for its intended use, accurate, complete, and current.
Website Collection and Use Practices
vSplash collects personally identifiable information from users of its website, such as email addresses, names, company names, home, and/or work addresses, and/or telephone numbers.
In the event that you contact us for customer support through the website, we may also request that you provide additional User Information relevant to the support requested by you. Users are under no obligation to provide such information. However, we cannot guarantee that we can provide customer support in the event that relevant information related to the use of our products or services is withheld. We may retain communications relating to customer support, and/or information drawn from such communications, for statistical and/or reference.
Use and Sharing of your Personal Information
vSplash collects and uses your personal information to operate the vSplash website and deliver the services you have requested. vSplash may also use your personally identifiable information to inform you of other products or services available from vSplash and its affiliates. vSplash may also contact you via voluntary surveys to conduct research on your opinion of current services or of potential new services. You will always have the option to unsubscribe (see To Unsubscribe from vSplash below.) vSplash does not sell, rent, or lease its customer lists to third parties in which we do not have a formal agreement to provide services to vSplash, and our customers or prospects. vSplash does not share personally identifiable information except as described in this policy. vSplash may, from time to time, contact you on behalf of external business partners about offerings that may be of interest to you. In those cases, your unique personally identifiable information (email, name, address, telephone number) is not transferred to the third party. In addition, vSplash may share data with trusted partners to help us perform statistical analysis, send you email or postal mail, provide customer support, or arrange for deliveries or contact you based on your interest to receive such communications. Such third parties are prohibited from using your personal information except to provide these services to vSplash, and they are required to maintain the confidentiality of your information. vSplash does not use or disclose sensitive personal information, such as race, religion, or political affiliations, without your explicit consent.
Social Media (Features) and Widgets:
Links to Other Websites
Our site includes links to other website whose privacy practices may differ from those of vSplash. If you submit personal information to any of those sites, your information is governed by their privacy statements. We encourage you to carefully read the privacy statement of any website you visit.
With your consent, we may post your testimonial along with your name.
vSplash also collects anonymous demographic information, which is not unique to you, such as your ZIP code, age, gender, preferences, interests, and favorites using log files.
There is also information about your computer hardware, tablet hardware and software that is automatically collected by vSplash. This information can include: (1) the browser types and versions used, (2) the operating system used by the accessing system, (3) the website from which an accessing system reaches our website (so-called referrers), (4) the sub-websites, (5) the date and time of access to the Internet site, (6) an Internet protocol address (IP address), (7) the Internet service provider of the accessing system, and (8) any other similar data and information that may be used in the event of attacks on our information technology systems.
When using these general data and information, vSplash does not draw any conclusions about you. Rather, this information is needed to (1) deliver the content of our website correctly, (2) optimize the content of our website as well as its advertisement, (3) ensure the long-term viability of our information technology systems and website technology, and (4) provide law enforcement authorities with the information necessary for criminal prosecution in case of a cyber-attack. Therefore, vSplash analyzes anonymously collected data and information statistically, with the aim of increasing the data protection and data security of our enterprise, and to ensure an optimal level of protection for the personal data we process. For these purposes, we do link this automatically-collected data to personally identifiable information such as name, email address, address, and phone number.
The anonymous data of the server log files are stored separately from all personal data.
The vSplash website uses “cookies” to help you personalize your online experience. A cookie is a text file that is placed on your hard disk by a web server. Cookies are not used to run programs or deliver viruses to your computer. Cookies are uniquely assigned to you and can only be read by a web server in the domain that issued the cookie to you.
Using cookies, vSplash can provide the users of this website with more user-friendly services that would not be possible without the cookie setting.
You may, at any time, prevent the setting of cookies through our website by means of a corresponding setting of the Internet browser used, and may thus permanently deny the setting of cookies. Furthermore, already set cookies may be deleted at any time via an Internet browser or other software programs. This is possible in all popular Internet browsers. If you deactivate the setting of cookies in the Internet browser used, not all functions of our website may be entirely usable.
Clear Gifs (Web Beacons/Web Bugs)
We employ [or our third-party advertising partner employs] a software technology called clear gifs (a.k.a. web beacons/web bugs), that help us better manage content on our site by informing us what content is effective. Clear gifs are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of web users. In contrast to cookies, which are stored on a user’s computer hard drive, clear gifs are embedded invisibly on web pages, and are about the size of the period at the end of this sentence. We tie [do not tie] the information gathered by clear gifs to our customer’s personally identifiable information.
We use clear gifs in our HTML-based emails to let us know which emails have been opened by recipients. This allows us to gauge the effectiveness of certain communications, and the effectiveness of our marketing campaigns.
Third Party Tracking Technologies
vSplash websites will disclose your personal information, without notice, only if required to do so by law, or in the good faith belief that such action is necessary to: (a) conform to the edicts of the law, or comply with legal process served on vSplash or the site; (b) protect and defend the rights or property of vSplash (including enforcing this agreement); and, (c) act under exigent circumstances to protect the personal safety of users of vSplash or the public.
Access to Personally Identifiable Information
If your personally identifiable information changes, or if you no longer desire our service, you may correct, update, request deletion on our site by emailing us at email@example.com to our Privacy team. We will respond to all access requests within 30 days. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why.
If you request that your user information be deleted from our records, there may be a brief delay in our processing that request, as we will verify that the request is valid and originates from you as opposed to an unauthorized third party. If you request that your information be deleted, we reserve the right to terminate and/or limit your access to the VSplash website.
If you provide VSplash with user information, you have the following rights with respect to that information:
To exercise any of these rights, please contact us at firstname.lastname@example.org
Security of your Personal Information
No method of safeguarding information is 100% secure. vSplash uses a variety of security technologies and procedures to help protect your personal information from unauthorized access, use or disclosure. vSplash secures the personally identifiable information you provide on computer servers in a controlled, secure environment, protected from unauthorized access, use or disclosure. When sensitive personal information (such as a credit card number) is collected on our site and/or transmitted to other websites, it is protected through the use of encryption, such as the Secure Socket Layer (SSL) protocol.
The criteria used to determine the period of storage of personal data is the respective statutory retention period. After expiration of that period, the corresponding data is routinely deleted.
We will retain your information for as long as your account is active or as needed to provide you services. If you wish to cancel your account or request that we no longer use your information to provide you services, contact us at email@example.com. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
Compliance with the EU-US Privacy Shield Framework & Swiss-US Privacy Shield Framework
The data handling practices of the vSplash website and its services platform are described in the above sections. With respect to personal data received or transferred pursuant to the Privacy Shield Frameworks, vSplash is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC).
EU and Swiss individuals have the right to obtain our confirmation of whether we maintain personal information relating to you. Upon request, we will provide you with access to the personal information that we hold about you. You may also may correct, amend, or delete the personal information we hold about you. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data, should direct their query to firstname.lastname@example.org. If requested to remove data, we will respond within a reasonable timeframe.
Your right to access your personal data may be restricted in exceptional circumstances, including, but not limited to, when the burden or expense of providing this access would be disproportionate to the risks to your privacy in the case in question, or when the rights of persons other than you would be violated by the provision of such access. If we determine that your access should be restricted in a particular instance, we will provide you with an explanation of our determination and respond to any inquiries you may have.
We will also provide an individual opt-out or opt-in choice before we share their data with third parties other than our agents, or before we use it for a purpose other than which it was originally collected or subsequently authorized. To limit the use and disclosure of your personal information, please submit a written request to email@example.com.
In certain situations, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
vSplash’s accountability for personal data that it receives under the Privacy Shield and subsequently transfers to a third party is described in the Privacy Shield Principles. In particular, vSplash remains responsible and liable under the Privacy Shield Principles if third-party agents that it engages to process the personal data on its behalf do so in a manner inconsistent with the Principles, unless vSplash proves that it is not responsible for the event giving rise to the damage.
vSplash has further committed to refer unresolved privacy complaints under the Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD, operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbb.org/EU-privacy-shield/for-eu-consumers for more information and to file a complaint. This service is provided free of charge to you.
If your Privacy Shield complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See Privacy Shield Annex 1 at https://www.privacyshield.gov/article?id=ANNEX-I-introduction
Changes to this Statement
vSplash will occasionally update this Statement of Privacy to reflect company and customer feedback. vSplash encourages you to periodically review this Statement to be informed of how vSplash is protecting your information. When such a change is made, we will update the “Last Updated” date above. If we make any material changes we will notify you or our Client by email (sent to the email address specified in your account) or by means of a notice on this Site prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.
To Unsubscribe from vSplash
You may unsubscribe from vSplash marketing communications by clicking on the “unsubscribe” link located on the bottom of the company’s emails.
vSplash’s customers may send emails from our platform with vSplash’s logo to show our tools capabilities. However, vSplash does not control the email addresses directly, therefore, cannot unsubscribe you from our customers’ emails on your behalf. Please contact the sender of that email which will include proper unsubscribe links if sent via our product.
vSplash welcomes your comments regarding this Statement of Privacy. If you believe that vSplash has not adhered to this Statement, please contact vSplash at firstname.lastname@example.org. We will use commercially reasonable efforts to promptly determine and remedy the problem. vSplash is located at 1050 Wall Street West, Suite 630, Lyndhurst, NJ 07071, United States of America.