Privacy policy

We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are, how and why we collect, store, use, and share your personal information. It also explains your rights in relation to your personal information and how to contact us or supervisory authorities in the event you have a complaint

We collect, use and are responsible for certain personal information about you. When we do so we are subject to various laws in the United States and the General Data Protection Regulation which applies across the European Union (including in the United Kingdom which has separate data protections that require substantially the same requirements), and we are responsible as “controller” of that personal information for the purposes of those laws.

It would be helpful to start by explaining some key terms used in this policy:

We, us, our	VBOUT Inc., a Delaware corporation established on May 29, 2014 and existing under the laws of the State of Delaware, United States
Personal information	Any information relating to an identified or identifiable individual
Special category personal information	Personal information revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membership Genetic and biometric data Data concerning health, sex life or sexual orientation

• Your name and contact information, including email address and telephone number and company details
• Information to enable us to check and verify your identity, e.g., your date of birth
• Your gender information, if you choose to give this to us
• Location data, if you choose to give this to us
• Your billing information, transaction and payment card information, if you chose to give this to us
• Your personal or professional interests based on behavioral analytics/ inferences
• Your professional online presence, e.g., LinkedIn profile
• Your contact history, purchase history and saved items
• Information from accounts you link to us, e.g., Facebook
• Information to enable us to undertake credit or other financial checks on you, if relevant to your transaction
• Information about how you use our website, IT, communication and other systems
• Your responses to surveys, competitions and promotions
• Other categories of information and data points such as: referral sources, device ID, browser type, device operating system, visitor IP address, website visits, mouse clicks and coordinates, session IDs and duration, browser ID and hash, Twilio SMS replies, Twilio phone recording, form submissions, and engagement with messaging.
• Cookies are small text files that we send to Customer’s computer or mobile device. They are unique to their account or their browser. We uses sessions cookies to improve the overall experience of the user by memorizing their login credentials or tracking the pages throughout the duration of time the user spends on the website. We, and our partners, use cookies and similar technologies on our Websites and Services that help us collect information, to analyze trends, administer the website, track users’ movements around the website, and to gather demographic information about our use base as a whole.You can control the use of cookies at the individual browser level, but if you choose to disable cookies, it may limit your use of certain features or functions on our website. The Websites and Services may also include cookies and similar tracking technologies from Third Parties, which may collect other information about Customers through the Websites and Services, as well as through other websites and online services.
• VBOUT’s use and transfer to any other app of information received from Google APIs will adhere to Google API Services User Data Policy, including the Limited Use requirements.

This personal information is required to provide services products and services to you. If you do not provide personal information we ask for, it may delay or prevent us from providing services to you.

We collect most of this personal information directly from you—in person, by telephone, text or email and/or via our website, mainly through information you provide. Additionally, you may decide to sign up for Client services or newsletter or products and provide us with an email address, a phone number, a password, a domain and/or any other details of similar accounts. Furthermore, if you purchase our services, you may be required to provide us with billing information, home or working address as well as credit card and banking information.

In such cases, our servers collect information automatically when you access or use our website or our services and collect them in log file format. Information may include the Internet Protocol (IP) address, the address of the web page you have visited before using our website or our services, the type of browser and its configuration, the date and time you have accessed our services, information about browser settings and plugins, as well as language preferences and cookie information.

We may also collect information:

• From a third party with or without your consent, e.g., in limited circumstances, Personal Information may be enhanced through a data enrichment program which matches, ensures accuracy, confirms, supports, validates and or supplements data already provided to us by you.
• From cookies on our website—for more information on our use of cookies, please see our cookies policy.
  Via our IT systems.
• Information provided to us by you from user inputs.

Under data protection law, we can only use your personal information if we have a proper reason for doing so;

• To comply with our legal and regulatory obligations;
• For the performance of our contract with you or to take steps at your request before entering into a contract;
• For our legitimate interests or those of a third party –or–
• Where you have given consent.

A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.

The table below explains what we use (process) your personal information for and our reasons for doing so:

What we use your personal information for	Our reasons
To provide services to you	For the performance of our contract with you, or to take steps at your request before entering into a contract
To prevent and detect fraud against you or Vbout	For our legitimate interests or those of a third party, i.e., to minimize fraud that could be damaging for us and for you
Ensuring business policies are adhered to, e.g., policies covering security and internet use	For our legitimate interests or those of a third party, i.e., to make sure we are following our own internal procedures so we can deliver the best service to you
Operational reasons, such as improving efficiency, training and quality control	For our legitimate interests or those of a third party, i.e., to be as efficient as we can so we can deliver the best service for you at the best price
Ensuring the confidentiality of commercially sensitive information	For our legitimate interests or those of a third party, i.e., to protect trade secrets and other commercially valuable information To comply with our legal and regulatory obligations
Statistical analysis to help us manage our business, e.g., in relation to Personal Information is used by our Clients, who the Data Subject provides Personal Information to through our systems. These Clients use Personal Information for the reasons provided to the Data Subject directly by the Client. These Clients are subject to their own compliance requirements. However, we do not use this Personal Information for any additional purposes.	For our legitimate interests or those of a third party, i.e., to be as efficient as we can so we can deliver the best service for you at the best price.
Preventing unauthorized access and modifications to systems	For our legitimate interests or those of a third party, i.e., to prevent and detect criminal activity that could be damaging for us and for you To comply with our legal and regulatory obligations.
Preventing unauthorized access and modifications to systems Updating and enhancing customer records	For the performance of our contract with you or to take steps at your request before entering into a contract To comply with our legal and regulatory obligations For our legitimate interests or those of a third party, e.g., making sure that we can keep in touch with our customers about existing orders and new products.
Statutory returns	To comply with our legal and regulatory obligations
Ensuring safe working practices, staff administration and assessments	To comply with our legal and regulatory obligations For our legitimate interests or those of a third party, e.g., to make sure we are following our own internal procedures and working efficiently so we can deliver the best service to you.
Marketing our services to: —existing and former customers; —third parties who have previously expressed an interest in our services; —third parties with whom we have had no previous dealings.	For our legitimate interests or those of a third party, i.e., to promote our business to existing and former customers
External audits and quality checks, e.g., for ISO or Investors in People accreditation and the audit of our accounts	For our legitimate interests or a those of a third party, i.e., to maintain our accreditations so we can demonstrate we operate at the highest standards To comply with our legal and regulatory obligations

We may use your personal information to send you updates (by email, text message, telephone or post) about our services, including exclusive offers, promotions or new services.

We have a legitimate interest in processing your personal information for promotional purposes (see above “How and why we use your personal information”). This means we do not usually need your consent to send you promotional communications. However, where consent is needed, we will ask for this consent separately and clearly.

We will always treat your personal information with the utmost respect and never sell it with other organisations outside the Vbout group for marketing purposes.

You have the right to opt out of receiving promotional communications at any time by:

• contacting us at support@vbout.com
• using the ‘unsubscribe’ link in emails or ‘STOP’ number in texts

We may ask you to confirm or update your marketing preferences if you instruct us to provide further services in the future, or if there are changes in the law, regulation, or the structure of our business.

We routinely share personal information with:

Companies within the Vbout group;

• Third parties we use to help deliver our services to you, e.g., payment service providers, warehouses and delivery companies;
• Other third parties we use to help us run our business, e.g., marketing agencies or website hosts;
• Third parties approved by you, e.g., social media sites you choose to link your account to or third-party payment providers;
• Our bank(s);

We only allow our service providers to handle your personal information if we are satisfied they take appropriate measures to protect your personal information. We also impose contractual obligations on service providers relating to ensure they can only use your personal information to provide services to us and to you. We may also share personal information with external auditors, e.g., in relation to ISO accreditation and the audit of our accounts.

We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.

We may also need to share some personal information with other parties, such as potential buyers of some or all of our business or during a re-structuring. Usually, information will be anonymised but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.

We will not share your personal information with any other third party.

We acknowledge and accept liability for the protection of your personal data during any onward transfers to third parties. This means that should there be any breach or misuse of your data as a result of its transfer to third-party entities, our organization will be held responsible for taking appropriate remedial actions and addressing any damages or losses that may arise.

Information may be held at our offices and those of our group companies, third party agencies, service providers, representatives and agents as described above (see above: “Who we share your personal information with”).

Some of these third parties may be based outside the European Economic Area. For more information, including on how we safeguard your personal information when this occurs, see below: “Transferring your personal information out of the EEA”.

We will keep your personal information while you have an account with us or we are providing services to you. Thereafter, we will keep your personal information for as long as is necessary:

• To respond to any questions, complaints or claims made by you or on your behalf;
• To show that we treated you fairly;
• To keep records required by law.

We will not retain your personal information for longer than necessary for the purposes set out in this policy. Different retention periods apply for different types of personal information.

To deliver services to you, it is sometimes necessary for us to share your personal information outside the European Economic Area (EEA), e.g.:

• With our offices outside the EEA;
• With your and our service providers located outside the EEA;
• If you are based outside the EEA;
• Where there is an international dimension to the services we are providing to you.

These transfers are subject to special rules under European and UK data protection law.

The following countries to which we may transfer personal information have been assessed by the European Commission as providing an adequate level of protection for personal information: None.

Except for the countries listed above, these non-EEA countries do not have the same data protection laws as the United Kingdom and EEA. We will, however, ensure the transfer complies with data protection law and all personal information will be secure. Our standard practice is to use standard data protection contract clauses that have been approved by the European Commission. To obtain a copy of those clauses http://vbtstaging.vbout.com/data-protection-agreement.

If you would like further information please contact us or our Data Protection Officer (see ‘How to contact us’ below).

VBOUT complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce.  VBOUT has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union and the United Kingdom in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF.  VBOUT has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF.  If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern.  To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit https://www.dataprivacyframework.gov/.

VBOUT is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC). This means that the FTC has the authority to oversee and enforce our compliance with privacy obligations and regulations.

Individuals should be aware that under certain conditions, they may have the opportunity to invoke binding arbitration to resolve disputes or issues related to our data practices. This means that if a resolution cannot be reached through our internal processes or through other dispute resolution mechanisms, an individual may seek a final and binding decision through arbitration.

Access	The right to be provided with a copy of your personal information (the right of access)
Rectification	The right to require us to correct any mistakes in your personal information
To be forgotten	The right to require us to delete your personal information—in certain situations
Restriction of processing	The right to require us to restrict processing of your personal information—in certain circumstances, e.g., if you contest the accuracy of the data
Data portability	The right to receive the personal information you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations
To object	The right to object: —at any time to your personal information being processed for direct marketing (including profiling); —in certain other situations to our continued processing of your personal information, e.g., processing carried out for the purpose of our legitimate interests.
Not to be subject to automated individual decision-making	The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you

For further information on each of those rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights under the General Data Protection Regulation.

If you would like to exercise any of those rights, please:

–and–

• Let us have enough information to identify you (e.g., your full name, address and customer or matter reference number)
• Let us have proof of your identity and address (a copy of your driving license or passport and a recent utility or credit card bill)
• Let us know what right you want to exercise and the information to which your request relates

Your Rights Under the CCPA. You have the right under the California Consumer Privacy Act of 2018 (CCPA) and certain other privacy and data protection laws, as applicable, to exercise free of charge:

Disclosure of Personal Information We Collect About You	You have the right to know: The categories of personal information we have collected about you; The categories of sources from which the personal information is collected; Our business or commercial purpose for collecting or selling personal information; The categories of third parties with whom we share personal information, if any; and The specific pieces of personal information we have collected about you. Please note that we are not required to: Retain any personal information about you that was collected for a single one-time transaction if, in the ordinary course of business, that information about you is not retained; Reidentify or otherwise link any data that, in the ordinary course of business, is not maintained in a manner that would be considered personal information; or Provide the personal information to you more than twice in a 12-month period.
Personal Information Sold or Used for a Business Purpose	In connection with any personal information we may sell or disclose to a third party for a business purpose, you have the right to know: The categories of personal information about you that we sold and the categories of third parties to whom the personal information was sold; and The categories of personal information that we disclosed about you for a business purpose. You have the right under the California Consumer Privacy Act of 2018 (CCPA) and certain other privacy and data protection laws, as applicable, to opt-out of the disclosure of your personal information. If you exercise your right to opt-out of the disclosure of your personal information, we will refrain from selling your personal information, unless you subsequently provide express authorization for the sale of your personal information.
Right to Deletion	Subject to certain exceptions set out below, on receipt of a verifiable request from you, we will: Delete your personal information from our records; and Direct any service providers to delete your personal information from their records. Please note that we may not delete your personal information if it is necessary to: Complete the transaction for which the personal information was collected, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between you and us; Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity; Debug to identify and repair errors that impair existing intended functionality; Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law; Comply with the California Electronic Communications Privacy Act; Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when our deletion of the information is likely to render impossible or seriously impair the achievement of such research, provided we have obtained your informed consent; Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us; Comply with an existing legal obligation; or Otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information.
Protection Against Discrimination	You have the right to not be discriminated against by us because you exercised any of your rights under the CCPA. This means we cannot, among other things: Deny goods or services to you; Charge different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties; Provide a different level or quality of goods or services to you; or Suggest that you will receive a different price or rate for goods or services or a different level or quality of goods or services. Please note that we may charge a different price or rate or provide a different level or quality of goods and/or services to you, if that difference is reasonably related to the value provided to our business by your personal information.

We have appropriate security measures in place to prevent personal information from being accidentally lost, used or accessed in an unauthorized way. We limit access to your personal information to those who have a genuine business need to access it. Those processing your information will do so only in an authorized manner and are subject to a duty of confidentiality. We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

All information is stored securely and accessed by authorized personnel only. VBOUT implements and maintains appropriate technical, security and organizational measures to protect Personal Information against unauthorized or unlawful processing and use, and against accidental loss, destruction, damage, theft or disclosure.

If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.

If you would like to exercise any of your rights as described in this Privacy Policy, please:

• Email us at support@vbout.com.
  Please note that you may only make a CCPA-related data access or data portability disclosure request twice within a 12-month period.
  If you choose to contact directly by email you will need to provide us with:
• Enough information to identify you (e.g., your full name and address);
• Proof of your identity and address (e.g., a copy of your driving license or passport and a recent utility or credit card bill); and
• A description of what right you want to exercise and the information to which your request relates.

We are not obligated to make a data access or data portability disclosure if we cannot verify that the person making the request is the person about whom we collected information, or is someone authorized to act on such person’s behalf.

Any personal information we collect from you to verify your identity in connection with you request will be used solely for the purposes of verification.

We hope that we can resolve any query or concern you raise about our use of your information.

The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live, or where any alleged infringement of data protection laws occurred. To submit a complain or file a case, please visit JAMS.

This privacy notice was published on June 27, 2018, and last updated on August 22, 2023.

We may change this privacy notice from time to time – when we do, we will inform you via our website.

If you would like this notice in another format (for example: audio, large print, braille) please contact us (see “How to contact us” above).