Last updated December 1, 2020
Thank you for choosing to be part of our community at Virtual Guardian. We are committed to protecting your personal information and your right to privacy. If you have any questions or concerns about this privacy notice, or our practices with regards to your personal information, please contact Virtual Guardian at info@virtualguardian.org.
When you use the Virtual Guardian mobile/desktop application, as the case may be (the "App") and more generally, use any of our services (the "Services", which include the App and desktop), we appreciate that you are trusting Virtual Guardian with your personal information. We take your privacy very seriously. In this privacy notice, we seek to explain to you in the clearest way possible what information we collect, how we use it and what rights you have in relation to it. We hope you take some time to read through it carefully, as it is important. If there are any terms in this privacy notice that you do not agree with, please discontinue use of our services immediately.
This privacy notice applies to all information collected through our App and desktop site.
Please read this privacy notice carefully as it will help you understand what Virtual Guardian do with the information that Virtual Guardian collect.
TABLE OF CONTENTS
1. WHAT INFORMATION DO WE COLLECT?
2. HOW DO WE USE YOUR INFORMATION?
3. WILL YOUR INFORMATION BE SHARED WITH ANYONE?
4. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
5. DO WE USE GOOGLE MAPS?
6. HOW LONG DO WE KEEP YOUR INFORMATION?
7. HOW DO WE KEEP YOUR INFORMATION SAFE?
8. WHAT ARE YOUR PRIVACY RIGHTS?
9. CONTROLS FOR DO-NOT-TRACK FEATURES
10. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
11. DO WE MAKE UPDATES TO THIS NOTICE?
12. HOW CAN YOU CONTACT VIRTUAL GUARDIAN ABOUT THIS NOTICE?
1. WHAT INFORMATION DO WE COLLECT?
Personal information you disclose to Virtual Guardian, in short: We collect information that you provide to Virtual Guardian.
We collect personal information that you voluntarily provide to Virtual Guardian when you register on the App/desktop site, express an interest in obtaining information about Virtual Guardian or the products and services that Virtual Guardian offers or otherwise when you contact Virtual Guardian.
The personal information that we collect depends on the context of your interactions with Virtual Guardian and the App/Desktop Site, the choices you make and the products and features you use. The personal information we collect may include the following:
Personal Information Provided by You. names; phone numbers; email addresses; mailing addresses; usernames; passwords; contact or authentication data; health & medical information; support needs; progression data; incident & accident information; assessment information; Timetable; and other similar information.
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 App/Desktop Site.
We automatically collect certain information when you visit, use, or navigate the Virtual Guardian App/Desktop Site. 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 who and when you use our App/Desktop Site and other technical information. This information is primarily needed to maintain the security and operation of the Virtual Guardian App/Desktop Site, 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 the Virtual Guardian App/Desktop Site and which we record in log files. Depending on how you interact with the Virtual Guardian App/Desktop site. This log data may include your IP address, device information, browser type and settings and information about your activity when using the App/Desktop Site (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).
Device Data. We collect device data such as information about your computer, phone, tablet, or other device you use to access the Virtual Guardian App/Desktop Site. Depending on the device used, this device data may include information such as your IP address (or proxy server), device application identification numbers, location, browser type, hardware model Internet service provider and/or mobile carrier, operating system configuration information.
Location Data. Virtual Guardian may collect information data such as information about your device's location, which can be either precise or imprecise. How much information we collect depends on the type of settings of the device you use to access the Virtual Guardian App/Desktop Site. For example, we may use GPS and other technologies to collect geolocation data that tells Virtual Guardian your current location (based on your IP address). You can opt out of allowing Virtual Guardian to collect this information either by refusing access to the information or by disabling your Locations settings on your device. Note however, if you choose to opt out, you may not be able to use certain aspects of the Services.
Information collected through the Virtual Guardian App/Desktop Site, in short: Virtual Guardian may collect information regarding your geolocation, mobile device, push notifications, when you use the Virtual Guardian App/Desktop Site.
If you use the Virtual Guardian App/Desktop Site, we also collect the following information:
• Geolocation Information. Virtual Guardian may request access or permission to and track location-based information from your mobile device, either continuously or while you are using the Virtual Guardian App/Desktop Site, to provide certain location-based services. If you wish to change the access or permissions, you may do so in your device's settings.
• Mobile Device Access. Virtual Guardian may request access or permission to certain features from your mobile device, including your mobile device's camera, microphone, reminders, and other features. If you wish to change the access or permissions, you may do so in your device's settings.
• Mobile Device Data. Virtual Guardian will automatically collect device information (such as your mobile device ID, model and manufacturer), operating system, version information and system configuration information, device and application identification numbers, browser type and version, hardware model Internet service provider and/or mobile carrier, and Internet Protocol (IP) address (or proxy server). If you are using the Virtual Guardian App/Desktop Site, the Virtual Guardian App/Desktop site may also collect information about the phone network associated with your mobile device, your mobile device's operating system or platform, the type of mobile device you use, your mobile device's unique device ID and information about the features of the Virtual Guardian App/Desktop Site you accessed.
• Push Notifications. Virtual Guardian may request to send you push notifications regarding your account or certain features of the Virtual Guardian App/Desktop Site. If you wish to opt-out from receiving these types of communications, you may turn them off in your device's settings.
The information is primarily needed to maintain the security and operation of the Virtual Guardian App/Desktop Site, for troubleshooting and for our internal analytics and reporting purposes.
2. HOW DO WE USE YOUR INFORMATION?
In Short: We process your information for purposes based on legitimate business interests, the fulfilment of our contract with you, compliance with our legal obligations, and/or your consent.
Virtual Guardian will use your personal information collected via the Virtual Guardian App/Desktop Site for a variety of business purposes described below. We process your personal information for these purposes in reliance on our legitimate business interests, 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.
We use the information we collect or receive:
• To facilitate account creation and logon process. If you choose to link your account with Virtual Guardian to a third-party account (such as your Google or Facebook account), we use the information you allowed Virtual Guardian to collect from those third parties to facilitate account creation and logon process for the performance of the contract.
• To post testimonials. We post testimonials on our Virtual Guardian App/Desktop Site that may contain personal information. Prior to posting a testimonial, we will obtain your consent to use your name and the consent of the testimonial. If you wish to update, or delete your testimonial, please contact Virtual Guardian at info@virtualguardian.org and be sure to include your name, testimonial location, and contact information.
• Request feedback. We may use your information to request feedback and to contact you about your use of our Virtual Guardian App/Desktop site.
• To enable user-to-user communications. We may use your information to enable user-to-user communications with each user's consent.
• To manage user accounts. We may use your information for the purposes of managing our account and keeping it in working order.
• To send administrative information to you. We may use your personal information to send you product, service, and new feature information and/or information about changes to our terms, conditions, and policies.
• To protect our services. We may use your information as part of our efforts to keep our Virtual Guardian App/Desktop site safe and secure (for example, for fraud monitoring and prevention).
• To enforce our terms, conditions, and policies for business purposes, to comply with legal and regulatory requirements or in connection with our contract.
• To respond to legal requests and prevent harm. If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond.
• For other business purposes. We may use your information for other business purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Virtual Guardian App/Desktop site, products, marketing and your experience. We may use and store this information in aggregated and anonymized form so that it is not associated with individual end users and does not include personal information. We will not use identifiable personal information without your consent.
3. WILL YOUR 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 fulfil business obligations.
We may process or share your data that we hold based on the following legal basis:
• Consent: We may process your data if you have given Virtual Guardian specific consent to use your personal information in a specific purpose.
• Legitimate Interests: We may process your data when it is reasonably necessary to achieve our legitimate business interests.
• Performance of a Contract: Where Virtual Guardian has entered into a contract with you, Virtual Guardian may process your personal information to fulfil the terms of the 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: Virtual Guardian 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.
More specifically, we may need to process your data or share your personal information in the following situations:
• Business Transfers. Virtual Guardian 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.
• Other Users. When you share personal information (for example, by posting comments, contributions or other content to the Virtual Guardian App/Desktop Site) or otherwise interact with public areas of the App/Desktop Site, such personal information may be viewed by all users and may be publicly made available outside the App/Desktop site in perpetuity. Similarly, other users will be able to view descriptions of your activity, communicate with you within our Virtual Guardian App/Desktop Site, and view your profile.
4. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
In Short: Virtual Guardian App/Desktop site may use cookies and other tracking technologies to collect and store your information.
Virtual Guardian App/Desktop site may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information. Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Notice.
5. DO WE USE GOOGLE MAPS?
In Short: Yes, we use Google Maps for the purpose of providing better service.
The Virtual Guardian App/Desktop Site uses Google Maps APIs which are subject to Google's Terms of Service. You may find the Google Maps APIs Terms of Service here. To find out more about Google’s Privacy Policy, please refer to this link. We obtain and store your device ('cache'), your location. You may revoke your consent anytime by contacting Virtual Guardian at the contact details provided at the end of this document or through our website.
6. HOW LONG DO WE KEEP YOUR INFORMATION?
In Short: We keep your information for as long as necessary to fulfil the purposes outlined in this privacy notice unless otherwise required by law.
We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements). No purpose in this notice will require Virtual Guardian keeping your personal information for longer than six (6) months past the start of idle period of the user's account.
When Virtual Guardian 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.
7. HOW DO WE KEEP YOUR INFORMATION SAFE?
In Short: We aim to protect your personal information through a system of organisational and technical security measures.
We have implemented appropriate technical and organisational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your 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 unauthorised third parties will not be able to defeat our security, and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Virtual Guardian App/Desktop site is at your own risk. You should only access the Virtual Guardian App/Desktop site within a secure environment.
8. WHAT ARE YOUR PRIVACY RIGHTS?
In Short: In some regions, such as the European Economic Area, you have rights that allow you greater access and control over your personal information. You may review, change, or terminate your account at any time.
In some regions (like the European Economic Area), you have certain rights under applicable data protection laws. These may include the right
(i) to request access and obtain a copy of your personal information
(ii) to request rectification or erasure
(iii) to restrict the processing of your personal information; and
(iv) if applicable, to data portability. In certain circumstances, you may also have the right to object to the processing of your personal information. To make such a request, please use the contact details provided below. We will consider and act upon any request in accordance with applicable data protection laws.
If Virtual Guardian is relying on your consent to process your personal information, you have the right to withdraw your consent at any time. Please note however that this will not affect the lawfulness of the processing before its withdrawal, nor will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.
If you are resident in the European Economic Area and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority.
You can find their contact details here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.
If you are resident in Switzerland:
the contact details for the data protection authorities are available here: https://www.edoeb.admin.ch/edoeb/en/home.html.
If you have questions or comments about your privacy rights, you may email Virtual Guardian at info@virtualguardian.org.
Account Information
If you would at any time like to review or change the information in your account or terminate your account, you can:
• Log in to your account settings and update your user account.
Upon your request to terminate your account, we will deactivate and/or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our Terms of Use and/or comply with applicable legal requirements.
Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Virtual Guardian App/Desktop Site. To opt-out of interest-based advertising by advertisers on our Virtual Guardian App/Desktop site visit http://www.aboutads.info/choices/.
Opting out of email marketing: You can unsubscribe from the Virtual Guardian marketing email list at any time by clicking on the unsubscribe link in the emails that we send or by contacting Virtual Guardian using the details provided below. You will then be removed from the marketing email list – however, we may still communicate with you, for example to send you service-related emails that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes. To otherwise opt-out, you may:
9. CONTROLS FOR DO-NOT-TRACK FEATURES
Most web browsers and mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognising and implementing DNT signals has been finalised. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.
10. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
In Short: Yes, if you are a resident of California, you are granted specific rights regarding access to your personal information.
California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits Virtual Guardian users who are Californian residents to request and obtain information from Virtual Guardian, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year.
If you are a California resident and would like to make such a request, please submit your request in writing to Virtual Guardian using the contact information provided below.
If you are under 18 years of age, reside in California, and have a registered account with the Virtual Guardian App/Desktop Site, you have the right to request removal of unwanted data that you publicly post on the Virtual Guardian App/Desktop Site. To request removal of such data, please contact Virtual Guardian using the contact information provided below and include your email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Virtual Guardian App/Desktop Site, but please be aware that the data may not be completely or comprehensively removed from all our systems (e.g. backups, etc.).
CCPA Privacy Notice
The California Code of Regulations defines a "resident" as:
(1) every individual who is in the State of California for other than a temporary or transitory purpose and
(2) every individual who is domiciled in the State of California who is outside the State of California for a temporary or transitory purpose
All other individuals are defined as "non-residents."
If this definition of "resident" applies to you, certain rights and obligations apply regarding your personal information.
What categories of personal information do we collect?
We have collected the following categories of personal information in the past twelve (12) months:
Category Examples Collected
A. Identifiers Contact details, such as real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address and account name
NO
B. Personal information categories listed in the California Customer Records statute Name, contact information, education, employment, employment history and financial information
YES
C. Protected classification characteristics under California or federal law Gender and date of birth
NO
D. Commercial information Transaction information, purchase history, financial details and payment information
NO
E. Biometric information Fingerprints and voiceprints
NO
F. Internet or other similar network activity Browsing history, search history, online behavior, interest data, and interactions with our and other websites, applications, systems and advertisements
NO
G. Geolocation data Device location
NO
H. Audio, electronic, visual, thermal, olfactory, or similar information Images and audio, video or call recordings created in connection with our business activities
NO
I. Professional or employment-related information Business contact details in order to provide you our services at a business level, job title as well as work history and professional qualifications if you apply for a job with us
NO
J. Education Information Student records and directory information
NO
K. Inferences drawn from other personal information Inferences drawn from any of the collected personal information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics
NO
We may also collect other personal information outside of these categories in instances where you interact with Virtual Guardian in-person, online, or by phone or mail in the context of:
• Receiving help through the Virtual Guardian customer support channels
• Participation in customer surveys or contests; and
• Facilitation in the delivery of our Services and to respond to your inquiries
How do we use and share your personal information?
More information about our data collection and sharing practices can be found in this privacy notice.
You may contact Virtual Guardian by email at info@virtualguardian.org, or by referring to the contact details at the bottom of this document.
If you are using an authorised agent to exercise your right to opt-out, we may deny a request if the authorised agent does not submit proof that they have been validly authorised to act on your behalf.
Will your information be shared with anyone else?
Virtual Guardian may disclose your personal information with our service providers pursuant to a written contract between Virtual Guardian and each service provider. Each service provider is a for-profit entity that processes the information on our behalf.
We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be "selling" of your personal data.
Virtual Guardian has not disclosed or sold any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months. Virtual Guardian will not sell personal information in the future belonging to website visitors, users and other consumers.
Your rights with respect to your personal data
Right to request deletion of the data - Request to delete
You can ask for the deletion of your personal information. If you ask Virtual Guardian to delete your personal information, we will respect your request and delete your personal information, subject to certain exceptions provided by law, such as (but not limited to) the exercise by another consumer of his or her right to free speech, our compliance requirements resulting from a legal obligation or any processing that may be required to protect against illegal activities.
Right to be informed - Request to know
Depending on the circumstances, you have a right to know:
• whether Virtual Guardian collects and uses your personal information;
• the categories of personal information that Virtual Guardian collects;
• the purposes for which the collected personal information is used;
• whether Virtual Guardian sells your personal information to third parties;
• the categories of personal information that Virtual Guardian sold or disclosed for a business purpose;
• the categories of third parties to whom the personal information was sold or disclosed for a business purpose; and
• the business or commercial purpose for collecting or selling personal information.
In accordance with applicable law, we are not obligated to provide or delete consumer information that is de-identified in response to a consumer request or to re-identify individual data to verify a consumer request.
Right to Non-Discrimination for the Exercise of a Consumer's Privacy Rights
We will not discriminate against you if you exercise your privacy rights.
Verification process
Upon receiving your request, Virtual Guardian will need to verify your identity to determine you are the same person about whom we have the information in our system. These verification efforts require Virtual Guardian to ask you to provide information so that Virtual Guardian can match it with the information you have previously provided Virtual Guardian. For instance, depending on the type of request you submit, Virtual Guardian may ask you to provide certain information so that Virtual Guardian can match the information you provide with the information Virtual Guardian already have on file, or Virtual Guardian may contact you through a communication method (e.g. phone or email) that you have previously provided to Virtual Guardian. Virtual Guardian may also use other verification methods as the circumstances dictate.
Virtual Guardian will only use personal information provided in your request to verify your identity or authority to make the request. To the extent possible, Virtual Guardian will avoid requesting additional information from you for the purposes of verification. If, however, if Virtual Guardian cannot verify your identity from the information already maintained by Virtual Guardian, Virtual Guardian may request that you provide additional information for the purposes of verifying your identity, and for security or fraud-prevention purposes. Virtual Guardian will delete such additionally provided information as soon as we finish verifying you.
Other privacy rights
• you may object to the processing of your personal data
• you may request correction of your personal data if it is incorrect or no longer relevant, or ask to restrict the processing of the data
• you can designate an authorized agent to make a request under the CCPA on your behalf. Virtual Guardian may deny a request from an authorised agent that does not submit proof that they have been validly authorised to act on your behalf in accordance with the CCPA.
• you may request to opt-out from future selling of your personal information to third parties. Upon receiving a request to opt-out, we will act upon the request as soon as feasibly possible, but no later than 15 days from the date of the request submission.
To exercise these rights, you can contact Virtual Guardian by email at info@virtualguardian.org, or by referring to the contact details at the bottom of this document. If you have a complaint about how we handle your data, we would like to hear from you.
11. DO WE MAKE UPDATES TO THIS NOTICE?
In Short: Yes, Virtual Guardian will update this notice as necessary to stay compliant with relevant laws.
Virtual Guardian may update this privacy notice from time to time. The updated version will be indicated by an updated “Revised” date and the updated version will be effective as soon as it is accessible. If Virtual Guardian make material changes to this privacy notice, Virtual Guardian may notify you either by prominently posting a notice of such changes or by directly sending you a notification. Virtual Guardian encourage you to review this privacy notice frequently to be informed of how we are protecting your information.
12. HOW CAN YOU CONTACT VIRTUAL GUARDIAN ABOUT THIS NOTICE?
If you have questions or comments about this notice, you may email Virtual Guardian at info@virtualguardian.org:
HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?
Based on the applicable laws of your country, you may have the right to request access to the personal information Virtual Guardian collect from you, change that information, or delete it in some circumstances. To request to review, update, or delete your personal information, please submit a request to info@virtualguardian.org. Virtual Guardian will respond to your request within 30 days.
