Virtuous Software Inc. (“Virtuous” or “we” or “our” or “us”) share our users’ (collectively “you” or “yours” and “users”) concerns about the privacy of personal information collected on the internet. Accordingly, this Privacy Policy (“Policy”) describes how we collect, use, and disclose information that is associated with an identified or identifiable natural person and is protected as personal data under applicable data protection laws (“Personal Data”) through:
Sites and Communications are collectively “Services”.
It does not apply to information collected by:
Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. Your use of our Services will signify and confirm your consent to the terms of this Policy. If you do not agree with this policy, do not access or use our Services or interact with any other aspect of our business.
This policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of our Services after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.
The lawful basis upon which we process your data will depend on the Personal Data collected and the nature of our use. We normally collect Personal Data in performance of a contract between Virtuous and you, in which we are the data controller, to provide you with the content available through our Services, connect you with other users, and to provide you with other information in response to any of your requests. We may also collect your Personal Data if you have provided us with consent to use your data, in which case the lawful basis is your consent, or if we have a legitimate interest in processing your personal information where the processing is not overridden by your data protection interests or fundamental rights and freedoms.
We collect the following categories of data through our Services, which may contain Personal Data. You are not required to provide any Personal Data to us, but if you do not provide certain Personal Data to us, you may not be able to use our Services and we may not be able to authenticate or assist you with your inquiries or requests.
Data We Collect Directly from You
Data We Collect from Your Use of Our Services
Data We Collect About You from Third Parties
What is a Cookie?
A cookie is a small piece of data that may be stored on your computer or mobile device. It allows a website to “remember” your actions or preferences over a period of time. We may also use other similar technologies from time to time, such as web beacons or pixel tags, to monitor internet or electronic network activity.
Why do we use cookies?
Virtuous and its third-party vendors use first-party (where we place them) and third-party cookies (where our vendors place them). Examples of the types of cookies that we use and their purposes are summarized in the chart below.
How long do cookies last?
We use two types of cookies on our Sites. “Session cookies” last as long as your online session and expire when you close your browser. “Persistent cookies” stay on your device after your browser has been closed, but generally not longer than 13 months.
How can you manage your cookie preferences?
See Managing Your Preferences, below.
We use Personal Data for the following purposes to:
We do not sell your information, and we do not share your information with third parties other than as follows:
We generally retain Personal Data for as long as needed for the specific business purpose or purposes for which it was collected. In some cases, we may be required to retain Personal Data for a longer period of time based on laws or regulations that apply to our business or for other necessary business purposes. When the purposes of processing are satisfied, we will delete or depersonalize your personal data within a reasonable time period.
We may create anonymous data from the personal information we receive about you and other individuals whose personal information we collect as set forth in this Privacy Policy. Anonymous data might include analytics information and information collected by us using cookies. We make personal information into anonymous data by excluding information (such as your name) that makes the data personally identifiable to you.
Our Sites may contain links to third party Sites and features. This Privacy Policy does not cover the privacy practices of such parties. These parties have their own privacy policies and we do not accept any responsibility or liability for their Sites, features or policies. Please read their privacy policies before you submit any data to them.
Taking into account the state of the art, the costs of implementation and the nature, scope, context and purposes of processing as well as the risk of varying likelihood and severity for the rights and freedoms of natural persons, we implement physical and technical measures designed to protect your Personal Data from unauthorized access, use or disclosure.
Virtuous Services are not intended for use by anyone younger than 13 years old. If you learn that anyone younger than 13 has used our Services or provided us with Personal Data, please contact us and we will take steps to delete such Personal Data.
We will not discriminate against you if you exercise your choices, provided that if you do not provide data to us we may not be able to provide Services to you.
There are several ways that you can manage your cookie and marketing preferences:
Our Services are generally located in the United States and we may also process your information in other jurisdictions to provide support and other similar services. If you are visiting or using our Services, please be aware that your personal data may be transferred to, and processed in, a jurisdiction other than the country in which you are resident. The data protection laws of these jurisdictions may or may not be as comprehensive or protective as those in your country.
When we engage in such transfers, we strive to use appropriate technical safeguards and use a variety of secure mechanisms, including standard contractual clauses and equivalent clauses to help protect your rights.
Certain state consumer privacy laws may provide their residents with additional rights regarding our use of their Personal Data. For example, California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Montana, New Jersey, Oregon, Tennessee, Texas, Utah, and Virginia provide (now or in the future) their state residents with rights to:
The exact scope of these rights may vary by state. To exercise any of these rights please see Who to Contact to Exercise Your Rights.
Although our Services are located in the United States, to the extent that you are accessing our services from the European Economic Area and UK, Switzerland, or the United Kingdom, you may have the following data protection rights, subject to lawful exemptions:
If you are using any of our Subscription Services, these services are made available to you through the Customer (e.g. the organization subscribing to our services), where the Data Controller is the customer and Virtuous is the Data Processor. Please direct your data privacy questions to your administrator before contacting Virtuous, as your use of the Services is subject to that organization’s policies.
For any situations where Virtuous is the Data Controller (e.g. your information was collected outside of using our Subscription Services), please contact us to have your data removed by emailing [email protected].
To the extent we are the data controller, we will verify that the information you submit (which may include first name, last name, email address, company, and country/state) matches our records before we fulfill the request. We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.
Please feel free to contact us with any comments, questions, complaints or suggestions you might have regarding our privacy practices described in this Policy. You may send us an email at: [email protected] or via mail to:
1 North 1st Street
Phoenix, AZ 85004
Attn: Virtuous Software Legal Department
We reserve the right to change, modify, add or remove portions of this Policy from time to time and will provide you with notice when significant updates are made or as required by applicable law. We recommend that you regularly revisit this Policy to learn of any such changes.