Privacy Policy

Your privacy is important to Virtual Technologies Group, LLC (“VTG,” “we,” or “us”). This Privacy Policy describes the information practices for the website operated by VTG or its affiliates, including but not limited to https://vtgus.com/ (the “Site”), including what type of information is gathered and tracked, how the information is used, and with whom the information is shared. As described below, this statement applies to your interactions with the Site as well as other interactions with VTG, such as when you agree to VTG’s Terms of Use or provide information to VTG.

BY USING THE SITE, YOU INDICATE YOUR UNDERSTANDING AND ACCEPTANCE OF THE TERMS OF THIS PRIVACY POLICY. IF YOU DO NOT ACCEPT THESE TERMS, DO NOT USE SITE.

Please carefully read this Privacy Policy as it may have changed since your last visit to the Site.  Continued use of the Site indicates your understanding and acceptance of any changes made to this Privacy Policy and posted to the Site.  This Privacy Policy does not cover the privacy practices of any third-party website to which the Site may link.  For capitalized terms not defined herein, please see the definitions provided in the VTG Terms of Use.

What information we collect: This Privacy Policy applies to all information collected by or submitted to VTG (or carefully selected third parties acting on our behalf), including personal information. “Personal information” is data that reasonably can be used to identify or describe an individual. You do not need to provide personal information to simply browse the Site.

VTG may collect personal information when:

• you contact VTG;
• you subscribe to VTG’s newsletter;
• you request information or materials;
• you participate in surveys and evaluations;
• you utilize a VTG chatbot;
• you apply for a position, or submit your resume to VTG;
• you submit any such information to VTG;
• you submit questions or comments to VTG; or
• you request access to a quote or other access to a Service.

The types of personal information collected may include (but are not limited to):

• your first and last name;
• your e-mail address;
• your telephone number;
• (for job applicants submitting electronic information) your educational background, employment experience, and job interest; and
• any other identifier that permits VTG to make physical or online contact with you.

Use of Your Personal Information:

VTG collects and uses your personal information to operate and improve the Site and deliver the Services or carry out the transactions you have requested. These uses may include providing you with more effective communication; making the Site or Services easier to use by eliminating the need for you to repeatedly enter the same information; performing research and analysis aimed at improving our offerings and technologies; and displaying content and advertising that are customized to your interests and preferences.

We also use your personal information to communicate with you. We may send certain mandatory Service communications such as welcome letters, billing information, information on technical Service issues, and security announcements with respect to the Services. We may also contact you to inform you of other products or Services available from VTG and its affiliates.

Personal information collected on the Site may be stored and processed in the United States or any other country in which VTG or its affiliates, subsidiaries or agents maintain facilities, and by using the Site or Services, you consent to any such transfer of information outside of your country.

Sharing of Your Personal Information:

VTG will not sell, rent or lease your personal information to others. VTG shares personal information with companies working on our behalf. VTG also utilizes third parties to collect information on our behalf, any information you share with these third parties is subject to their privacy policies. A list of third parties used by VTG includes (but is not limited to): HubSpot, JazzHR, and ActiveCampaign. Except as described in this statement, we will not disclose your personal information to third parties for their own marketing purposes unless you have provided consent.

Some VTG Services may be co-branded and offered in conjunction with another company. If you register for or use such Services, both VTG and the other company may receive information collected as part of the co-branded Services. If so, the privacy policy of such other company shall apply to their use of this information.

In some cases, VTG uses contractors to collect, use, analyze, and otherwise process information on its behalf. It is VTG’s practice to require such suppliers to handle information in a manner consistent with VTG’s policies. VTG may also team up with carefully selected VTG partners to participate in limited marketing campaigns solely to promote VTG’s products and Services, or the partner’s products and services, to you. You may opt-out of receiving these marketing messages at any time by following the instructions provided in the materials.

If you request something from the Site (for example, a quote, access to a Service, a callback, or specific marketing materials), we will use the information you provide to fulfill your request. To help us do this, we may share information with others, such as VTG’s business partners, financial institutions, shipping companies, and postal or government authorities (e.g., customs authorities) involved in fulfillment. As part of a transaction, we may also contact you as part of our customer satisfaction surveys or for market research purposes.

We occasionally hire other companies to provide limited services on our behalf, such as providing customer support, processing transactions, or performing statistical analysis of our Services. Such companies will be permitted to obtain only the personal information they need to deliver the service. They are required to maintain the confidentiality of the information and are prohibited from using it for any other purpose.

Mobile information will not be shared with third parties/affiliates for marketing/promotional purposes.

We may access or disclose your personal information if we believe such action is necessary to: (a) comply with the law or legal process served on VTG; (b) protect and defend the rights or property of VTG (including the enforcement of our agreements); or (c) act in urgent circumstances to protect the personal safety of users of the Site, the Services, or members of the public.

Your Choices:

VTG provides a number of ways for you to ‘opt out’ of receiving additional information from us or having us provide your personal information to our partners and providers. We may offer you these choices at the time you give us your information.

If you do not wish to continue receiving certain marketing materials (e.g., e-mail messages), you can opt-out of receiving these materials by following the unsubscribe instructions provided in the materials. This option does not apply to communications primarily for the purpose of administering orders, contracts, support, product safety warnings, software updates, or other administrative and transactional notices.

How to Update Your Information:

To update your contact information, please email us at jholoquist@westhill.law

Safeguarding Your Personal Information:

We recognize industry standards and employ security safeguards to protect information from unauthorized access and misuse. We use the most accurate and current information you provide in order to process your request. Furthermore, whenever you transmit sensitive information, such as credit card information, to us through the Site, we may provide you access to a third party server that allows encryption across the Internet. Browsers offer varying degrees of security, particularly in regard to encryption. Even the same version of a browser can come with different levels of encryption. For your protection, make sure your browser is set and configured to support Secure Socket Layer (SSL) 2.0/3.0 and employs 128-bit encryption. All acceptable browsers do provide detailed information on security levels in “Properties” or “Document Information” from the browser’s menu bar. See your browser’s “Help” tab or documentation for more information.

Enforcement:

VTG regularly reviews its compliance with this Privacy Policy. Please feel free to direct any questions or concerns regarding this statement or VTG’s treatment of personal information by contacting us at the link or address indicated below.

Cookies and Browser Information:

VTG uses cookies for a variety of purposes. A “cookie” is a name for tokens of information that our web site may provide to your browser while you are at those Site. We use cookies to help us keep track of the items that you place in your shopping cart or to better understand web site usage in the aggregate so that we know what areas of the Site users prefer. If you simply want to browse, you do not have to accept cookies from the Site. Most browsers are defaulted to accept and maintain cookies. If you do not want websites to be able to use cookies, you can alter the configuration of your browser to not accept cookies. Unless you have adjusted your browser settings so that it will refuse cookies, our system will issue cookies when you direct your browser to our Site. Third party vendors, including Google, may use cookies to serve ads to you while you are using the Site based on your prior visits You can learn more about Google’s advertising practices and how to opt out of Google’s use of cookies by reviewing the Google advertising policy. Should you decide, however, that you would like to purchase any Services with VTG and you have modified your browser settings not to accept cookies, you will need to re-set your browser to accept the cookies that we send it. Otherwise, you may not be able to purchase or obtain access to the Services.

With or without cookies, our web site keeps track of usage data, such as the source address from which a page request originates (i.e., your IP address, domain name), date and time of the page request, the referring web site (if any), and other parameters in the URL (e.g., search criteria). We use this data to better understand web site usage in the aggregate so that we know what areas of our web site users prefer (e.g., based on the number of visits to those areas). This information is stored in log files and is used for aggregated and statistical reporting. It is not attributed to you as an individual.

Links to Other Site:

The Site may provide links to third-party websites, such as those of our business partners and online advertisers. You should review their privacy policies to learn more about what, why, and how they collect and use personally identifiable information.

For Questions or Concerns:

If you have questions or concerns regarding this Privacy Policy, you should first contact jholoquist@westhill.law. VTG’s principal business address is located at: 1605 Indian Wood Circle, Maumee, OH 43537.

Changes to VTG Privacy Statement:

VTG reserves the right to change this policy from time to time. If we do make changes, the revised Privacy Policy will be posted on this site.

NOTICE TO CHILDREN UNDER THE AGE OF 18 AND THEIR PARENTS OR LEGAL GUARDIANS:

THE SITE IS INTENDED FOR ADULTS. WE DO NOT KNOWINGLY OR INTENTIONALLY COLLECT PERSONAL INFORMATION FROM ANYONE UNDER THE AGE OF 18. IF YOU ARE UNDER THE AGE OF 18, PLEASE DO NOT PROVIDE ANY PERSONAL INFORMATION TO VTG. IF YOU KNOW OF ANYONE UNDER THE AGE OF 18 WHO HAS PROVIDED US WITH INFORMATION, PLEASE CONTACT US IMMEDIATELY AND WE WILL REMOVE THE INFORMATION.

SPECIFIC PROVISIONS FOR CALIFORNIA RESIDENTS

This section of the Privacy Policy applies only to individuals who reside in California. The California Consumer Privacy Act of 2018 (“CCPA”) provides additional rights to know, delete and opt out, and requires businesses collecting or disclosing Personal Information to provide notices and means to exercise rights. For Purposes of this section, “Personal Information” has the definition set forth in the CCPA.

California Notice of Collection

In the past twelve (12) months, we or our service providers have collected the following categories of information enumerated in the CCPA in connection with the Site:

• First and last name, billing or other physical address (including street name, city/town, state/province, postal code, and country of origin), e-mail address, and telephone number;

• Information and Services considered, accepted, rejected, and other use data;

• Any other identifier that permits VTG to make physical or online contact with you;

• Internet activity, including history of visiting and interacting with the Site, browser type, browser language and other information collected automatically; and

• Any other information you have chosen to provide to us through the Site.

Right to Know and Delete

If you are a California resident, you have the right to delete Personal Information we have collected about you and you have the right to know certain information about our data practices in the preceding twelve (12) months. In particular, you have the right to request the following:

• Categories of Personal Information we have collected about you;

• Categories of sources from which the Personal Information was collected;

• Categories of Personal Information about you we disclosed for a business purpose or sold;

• Categories of third parties to whom the Personal Information was sold or disclosed for a business purpose;

• Business or commercial purpose for collecting or selling the Personal Information; and

• Specific pieces of Personal Information we have collected about you.

To exercise any of these rights, please submit a request to us at jholoquist@westhill.law. In the request, please specify which right you are seeking to exercise and the scope of the request. We will confirm receipt of your request within ten (10) days. We may require specific information from you to help us verify your identity and process your request. Please note that, in many instances, VTG does not collect types of information that enable us to identify you. As such, if we do not have information that permits us to verify your identity, we may deny your requests to know or delete. You can request access only twice within a twelve (12) month period.

Right to Opt Out

Under the CCPA, you have the right to opt out of the sale of your Personal Information to third parties at any time. VTG does not “sell” your Personal Information as it is currently defined under the CCPA. You may contact us by emailing us at jholoquist@westhill.law if you have any questions or concerns.

Authorized Agent

You can designate an authorized agent to submit requests on your behalf. However, we will require written proof of the agent’s permission to do so and verify your identity directly.

Right to Non-Discrimination

You have the right not to receive discriminatory treatment by us for the exercise of any of your rights.

California Do-Not-Track Notice

We may collect information about your online activity while using our Site and after you leave our Properties. VTG does not support Do Not Track signals, and therefore we do not respond to such signals.

Notice to International Residents:

The Site is primarily operated and managed on servers located and operated within the United States. In order to receive information about VTG or participate in the Services of VTG, you may be sending your PII outside of the country where you reside or are located, including to the United States. Accordingly, if you reside or are located outside of the United States, your PII may be transferred outside of the country where you reside or are located, including to countries that may not or do not provide the same level of protection for your PII. We are committed to protecting the privacy and confidentiality of PII when it is transferred.

ADDITIONAL INFORMATION FOR SITE USERS IN THE EUROPEAN ECONOMIC AREA AND UNITED KINGDOM:

VTG is headquartered in the United States and has operations and service providers in the United States and throughout the world. As such, we and our service providers may transfer your Personal Information to, or access it in, jurisdictions that may not provide levels of data protection equivalent to those in your country of residence. By using our Services, or otherwise interacting with us, regardless of where you live or where you provide information to us, you consent to our use and our service providers’ use of your Personal Information worldwide and to the transfer of your Personal Information to countries outside of your country of residence, including the United States. In certain circumstances, courts, regulatory agencies, law enforcement agencies, or security authorities in those other countries may be entitled to access your Personal Information.

VTG is aware of the July 16, 2020, ruling by the European Court of Justice invalidating the EU-US Privacy Shield Framework. Accordingly, VTG will take adequate measures designed to protect the transfer of Personal Information of individuals in the European Economic Area (EU Member States, Iceland, Liechtenstein, and Norway) (“EEA”), such as relying on the European Commission-approved Standard Contractual Clauses (“SCCs”) as a legal mechanism for such transfer, or other adequate transfer mechanism as required under relevant data protection laws, as well as additional safeguards, where appropriate. A copy of these clauses may be obtained by contacting us at the email address listed below.

For transfers to or from the United Kingdom (“UK”), we make use of the SCCs, as adapted for the UK. For individuals located in the EEA or the UK, the terms “PII” and “Personal Information,” as used in this Privacy Policy, are equivalent to “personal data” under applicable European and UK data protection legislation.

If you are located in the EEA, the UK, or Switzerland, you have certain rights and protections under applicable law regarding the processing of your Personal Information, as defined by the General Data Protection Regulation (“GDPR”), and this section applies to you.

Legal Basis for Processing

When we process your Personal Information, we will do so in reliance on the following lawful bases:

• To perform our responsibilities under our contract with you (e.g., providing the Services you requested).
• When we have a legitimate interest in processing your Personal Information to operate our business or protect our interests (e.g., to provide, maintain, and improve our Services, conduct data analytics, and communicate with you).
• To comply with our legal obligations (e.g., to maintain a record of your consent and track those who have opted out of non-administrative communications).
• When we have your consent to do so (e.g. when you opt-in to receive non-administrative communications from us). When consent is the legal basis for our processing of your Personal Information, you may withdraw such consent at any time.

Data Retention

We store Personal Information associated with your account for as long as your account remains active. In some cases, we retain Personal Information for longer if doing so is reasonably necessary to comply with our legal, regulatory, or other compliance obligations. We store other data for as long as necessary to carry out the purposes for which we originally collected it and for other legitimate business purposes, including to meet our legal, regulatory, or other compliance obligations.

Your Rights

For Site Users in the European Union, according to the GDPR, you have the following statutory rights:

• Information. At the point where Personal Information is collected from the data subject, as defined by the GDPR, or obtained from another source, there is a requirement to inform the data subject about VTG’ use of that Personal Information and the rights of data subjects over it. Compliance with this right is provided within this Privacy Policy.

• Access. You have the right to obtain confirmation as to whether or not Personal Information concerning you is being processed, and, where that is the case, all necessary information to make the process transparent. You also have the right to obtain a copy of your Personal Information being processed.

• Rectification. You have the right to require rectification of inaccurate data about you.

• Erasure. You have the right to ask for the deletion of your data in certain circumstances.

• Restrict processing. You have the right to restrict processing of data under certain specified circumstances.

• Data portability. You have the right to request for the receipt or the transfer to another organization, in a machine-readable form, of your Personal Information.

• Object to processing. You have the right to ask us to stop using all or some of your Personal Information under certain specified circumstances.

• Right to withdraw consent. When you have given your explicit consent for the processing of your data, you can withdraw it at any time without justification. The withdrawal of consent will not affect the lawfulness of processing based on consent before its withdrawal.

If would like to exercise your rights, please let us know by sending an email to jholoquist@westhill.law.

You also have the right to lodge a complaint with your local Data Protection Authority or to the Data Protection Authority where the alleged infringement took place.