Privacy Policy

VHSL Privacy Policy

VHSL, (“we,” “our”) has created this privacy policy (this “Privacy Policy”) in order to demonstrate our firm commitment to your privacy. This document describes the practices of VHSL with respect to the collection of user information and the use, storage, protection, and disclosure of such information. VHSL complies with the EU-US Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries. If there is any conflict between the policies in this Privacy Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern.

This document only applies to user information collected from our websites (the “VHSL Websites”), including but not limited to those located at www.VHSL.org and does not address the privacy of information we obtain from places other than the VHSL Websites. Additionally, this Privacy Policy does not apply to the websites of third parties, including any third-party websites to which we may provide links on the VHSL Websites. Such third-party websites are governed by their own privacy policies and practices. In all cases, we encourage you to ask questions and to provide data only to sites whose practices and personnel you trust.

Consent, Scope, and Amendments

You accept this Privacy Policy when you sign up for, access, or use the VHSL Websites or any products, services, content, features, technologies, or functions offered through or in connection with the VHSL Websites. We may change this Privacy Policy from time to time to address new issues, to reflect changes to the VHSL Websites, and as may be necessary to remain compliant with the requirements of the Privacy Shield Framework and the Privacy Shield Principles. We will post any such changes to the VHSL Websites, and such changes will become effective upon posting. You are advised to review this Privacy Policy regularly. Your continued use of any VHSL Website following the posting of any changes to this Privacy Policy will mean that you accept such changes. If you do not agree with this Privacy Policy or any changes to this Privacy Policy, please do not access or use the VHSL Websites.

If you are using the VHSL Websites on behalf of any business, school, group or other entity, then (i) you represent and warrant that you are duly authorized by such entity to accept this Privacy Policy on such entity’s behalf, and (ii) the terms “you” and “your” will also refer to the entity that you represent and to any person using the VHSL Websites on behalf of such entity.

Information Collected and How It Is Used

We do not collect any personally identifying information about you unless you or the organization to which you belong voluntarily submits such information to us. Personally identifying information is any data that can be used to identify or contact a single person. We do not consider personally identifying information to include information that has been made anonymous so that it does not identify a specific individual.

In order to process payments, we may collect sensitive financial information such as credit card and bank account numbers. Unlike other information, we will not provide such financial information to third parties without your permission or for promotional purposes. If you do not provide required financial information, you will not be able to send or receive payments using the VHSL Websites.

Depending on the particular features you or your group use in connection with the VHSL Websites, the information we collect may include your name, address, phone numbers, email address, social security number, and date of birth. Some or all of this information may be necessary for certain applications of the VHSL Websites to perform certain functions correctly. Additionally, in connection with the

provision of our services, we may distribute this information, including your social security number, to third parties who are responsible for your compensation and for other similar purposes, including as required or requested by government agencies. Since VHSL cannot control how such third parties and others protect your social security number and other personal information, VHSL cannot and does not ensure or warrant the security or privacy of any of your personal information transferred to such third parties. If you do not want us to collect or distribute such personally identifying information to such third parties as described above, you may choose not to provide us with such information. However, we may not be able to provide you with some or all of our products and services as a result.

We may also use and distribute your personal information to enable our contracted service providers and strategic partners to support our business operations, including, without limitation, bill collection, marketing, fraud detection, product and service development, and technology services. With respect to any such third-party service provider acting as an agent on our behalf, we will ensure such party subscribes to the Privacy Shield Principles or is subject to laws providing the same level of privacy protection as required by the Privacy Shield Principles and agrees in writing to provide an adequate level of privacy protection.

From time to time, either by telephone or through mailings, we may also notify you about new products and services we are offering. Further, we may use your personal information to contact you through an VHSL sales representative to determine whether you are interested in other products or services related to VHSL. If you do not want to be contacted regarding our products and services, simply tell us when you provide us with your personal information or advise the VHSL sales representative accordingly, and you will not be contacted again for such purposes.

As necessary, we may use your personal information to contact you about your account or the terms of any agreements we may have with you, including this Privacy Policy. Because such information is important to your ongoing business relationship with VHSL, you may not opt out of receiving such communications.

When requesting technical support, you may be asked to provide certain additional personal information that we deem necessary to identify you and to associate you with one of our user groups. Note that for quality and training purposes, we may monitor or record our telephone conversations with you or anyone acting on your behalf and, by contacting us, you acknowledge that your communication may be overheard, monitored, or recorded without further notice or warning. In all situations, you are not required to provide any personal information that we may request, but, if you choose not to do so, in many cases we will not be able to provide you with our products or services or respond to any queries that you may have.

We may also provide your personally identifying information to a third party in connection with any reorganization, merger, sale, assignment, joint venture, or other transfer or disposition of some or all of the assets of VHSL or its affiliated entities, and you acknowledge and agree that we can accordingly assign, sell, license, or transfer to such third party any information, including personally identifying information, that you or the organization to which you belong has provided to us. In such event, we will require such third party to agree to treat such information in accordance with this Privacy Policy and the Privacy Shield Principles.

As is true of most internet services, VHSL also automatically collects and stores certain non-personally identifying information sent to us by your computer, mobile phone, or other device whenever you access the VHSL Websites. Non-personally identifying information includes data that does not, on its own, permit direct association with any specific individual. Non-personally identifying information may include, without limitation, your IP address, operating system, Internet service provider, mobile network information, geo-location information, the type of browser, computer, or mobile device that you use, how you use the VHSL Websites, and other similar information, as well as data we have obtained from you and aggregated with other user information. VHSL collects this information to make it easier and more efficient for you to use the VHSL Websites and to allow us to understand how our users as a group use the services and resources provided on the VHSL Websites. Such non-personally identifying information is collected in a number of ways, including tracking your activities through “cookies,” your IP address or most recently visited URL, or your mobile device. (For more information on cookies, IP addresses, or mobile devices, please see the appropriate sections below.) We may eventually use such information to tailor the content, services, and advertising on the VHSL Websites to your current and future needs. We may also use such information to determine which areas of the VHSL Websites are the most commonly used, which areas need improvement, and what technologies are being used so that we may continually improve the VHSL Websites.

Cookies

When you access the VHSL Websites, we may place small data files on your computer or other device. These data files may be cookies, pixel tags, “flash cookies,” or other similar technologies (collectively, “Cookies”). Cookies make the VHSL Websites easier for you to use because they save your preferences while you are at our site (although we do not save your passwords in Cookies). They also help us better understand user behavior and facilitate and measure the effectiveness of advertisements. Cookies contain information that the server computer “knew” in the first place and are designed to only be read by the serving domain that placed them. Cookies are a standard part of Internet use and allow server computers to recognize your computer’s browser when you return to our site. For example, a Cookie may retain information regarding items that remain in your shopping cart when you leave our website, so that you do not have to start your shopping again from scratch when you return. The non-personally identifying information that we track with Cookies is anonymous and is not used to identify, or lead us back to, any particular visitor.

Most browsers are set to accept Cookies. However, you can set your browser to refuse Cookies, or to alert you when Cookies are being sent. If you elect not to accept Cookies, please note that some parts of the VHSL Websites, such as shopping, contests, or games, may not function properly, or at all, or may be considerably slower.

IP Address

An “Internet Protocol” or “IP” address is a number that is automatically assigned to your computer whenever you are using the World Wide Web. Web servers, the large computers that “serve up” web pages, automatically identify your computer by its IP address. We may use IP addresses to analyze trends, administer our site, track users’ movements, and gather broad demographic information for aggregate use. We may also use this information in connection with our marketing and advertising services. IP addresses are not normally linked to personally identifying information, which means that a user’s session will be logged but the user remains anonymous to us. To the extent IP addresses or similar identifiers are considered personally identifying information by local law or the Privacy Shield Principles, however, we will treat such identifiers as personally identifying information.

Mobile Devices

We may offer you the ability to connect to the VHSL Websites using a mobile device, either through a mobile application or via a mobile-optimized website. The provisions of this Privacy Policy apply to all such mobile access and use of mobile devices.

When you download or use our mobile applications, or access one of our mobile optimized sites, we may receive information about your location and your mobile device, including a unique identifier for your device. We may use this information to provide you with location-based services, such as advertising and other personalized content. Most mobile devices allow you to control or disable location services in the

device’s settings menu. If you have questions about how to disable your device’s location services, we recommend you contact your mobile service carrier or the manufacturer of your particular device.

Disclosure of Information

As part of the registration process, VHSL may provide you with the option of receiving information from third parties. If you select this option, VHSL will transfer your contact information to third parties. If in the future you decide you no longer want us to transfer your contact information to third parties for such purposes, you may call the VHSL Customer Support Department at 801-576-9436 to opt out. Please note that VHSL is not responsible for removing your information from third party lists or entities with which you have previously authorized VHSL to share your information. You will need to contact those third parties directly to request removal from their lists. Unless we tell you otherwise, we do not sell or rent your personally identifying information to any third parties. We will notify you at the time of data collection or transfer if your data will be shared with a third party, and you will have the option of not permitting the transfer. If you do not wish your data to be shared, you can choose not to use a particular service or not to participate in certain promotions or contests.

We may sell and rent aggregated information about our users generally to our advertisers, business partners, sponsors, and other third parties. We also may produce aggregated reports for advertisers identifying, for example, the number of users that visit our site or different areas of our site, the number of users that clicked on an advertisement, or the number of users that read a particular article. Aggregated information refers to information that cannot be directly linked to a specific individual. For example, we may know that 25,000 people visited our site today, or that 75% of those visitors were women, but we do not know their names. We may use aggregate information to customize our content and advertising, or to deliver a better experience for our visitors.

Disclosure of Information in Special Circumstances

VHSL reserves the right to disclose personal and other information in special cases when we have reason to believe that disclosing this information is necessary to identify, contact, or bring legal action against someone who may be violating the terms of any of our agreements, including, without limitation, this Privacy Policy and VHSL’ Terms and Conditions, or who may be causing injury to or interference with (either intentionally or unintentionally) VHSL’ rights or property, other VHSL users, or anyone else that could be harmed by such activities. Further, we may disclose information if we determine that, for purposes of national security, law enforcement, or other issues of public importance, disclosure is necessary or appropriate. VHSL may also disclose or access account information for administrative and other purposes that we deem necessary to maintain, service, and improve our products and services and the VHSL Websites.

Data Integrity and Access to Personal Information

VHSL shall only process personally identifying information in a way that is compatible with and relevant for the purpose for which it was collected or authorized. To the extent necessary for those purposes, VHSL shall take reasonable steps to ensure that personally identifying information is accurate, complete, current, and reliable for its intended use. You can help VHSL maintain the accuracy of your personal information by notifying us when you change your address, phone number, or email address. For other personal information that we hold, we will provide you with access for any purpose, including to request that we correct the data if it is inaccurate or delete the data if VHSL is not required to retain it by law or for legitimate business purposes. We may decline to process requests that are frivolous, vexatious, jeopardize the privacy of others, are extremely impractical, or for which access is not otherwise required by local law or the Privacy Shield Principles.

Opt Out

Users are given the opportunity, at the time that we request such information, to “opt out” of having their information used for purposes not directly related to the VHSL Websites and the products and services that we provide. For example, our download form has an “opt-in” option so users who download the trial software from us but do not want to receive any marketing materials will not receive such materials unless they select the option to do so. Users who no longer wish to receive our newsletter may remove their name from the distribution list at any time by contacting the VHSL Customer Support Department at 801-576-9436. If you have subscribed under more than one email address, you will need to unsubscribe for each of your email addresses.

Links to Other Sites

Users will find advertising or other content on the VHSL Websites that may link to the sites and services of our partners, suppliers, advertisers, sponsors, licensors, and other third parties. In many cases, the links represent cooperative projects or are mutual links established with persons or entities connected with our site. We do not control the content or links that appear on these third-party sites. In addition, these third-party sites or services, including their content and links, may be constantly changing. These third-party sites and services may have their own privacy policies and customer service policies, or no policy at all. We encourage you to review the privacy policies of any third party site or service before providing any of them with your personal information.

Minors

The VHSL Websites are not designed for children age 13 or younger. Accordingly, we do not knowingly collect, use, or disclose personally identifying information from children age 13 or younger. In the event we learn that we have collected such information, we will take steps to delete the information as soon as possible.

Security

Protecting your privacy and your information is a priority at VHSL. We do not rent or sell the personal financial information you provide to us. We use industry-standard methods to protect your personally identifying information from unauthorized access. Among other techniques, we usually store such information on a computer behind a “firewall” in a secure location, and we take measures to restrict the number of employees internally who can access such data. When our registration or order form asks users to enter sensitive information (such as a credit card number), that information is encrypted and protected using industry-standard encryption technology, such as 128-bit encryption SSL (Secure Socket Layers). In addition, as an added security measure, if you use a credit card to make a purchase on our site, an VHSL representative may call you to verify the transaction.

While we use SSL encryption to protect sensitive information online, we also take steps to protect user information off-line. Access to all of our users’ information, not just the sensitive information mentioned above, is restricted in our offices. Only employees who need the information to perform a specific job (for example, our billing clerk or a customer service representative) are granted access to personally identifying information. Furthermore, employees are kept up-to-date on our security and privacy policies and practices, and such policies and practices are strictly enforced. Finally, the servers on which we store personally identifying information are kept in a secure environment.

Of course, there is no such thing as “perfect security” on the Internet, and no data transmission can be guaranteed to be secure. As a result, while we strive to protect your personal information, VHSL cannot and does not ensure or warrant the security of any information you transmit to us or put on our website, and you do so at your own risk.

Passwords

Your VHSL account information is password protected so that only you are authorized to access this personal information. We strongly recommend that you do not divulge your password to anyone. VHSL will not ask for your password in an unsolicited phone call or in an unsolicited email.

Retention of User Information

We may retain your personal information for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law.

Privacy Shield Framework

VHSL complies with the EU-US Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries. VHSL has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the policies in this Privacy Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification page, please visit https://www.privacyshield.gov/.

In compliance with the EU-US Privacy Shield Principles, VHSL commits to resolve complaints about your privacy and our collection or use of your personal information.

VHSL has further committed to refer unresolved privacy complaints under the EU-US Privacy Shield Principles to BBB EU PRIVACY SHIELD, a non-profit alternative dispute resolution provider located in the United States and 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. The services of BBB EU PRIVACY SHIELD are provided at no cost to you. As further explained in the Privacy Shield Principles, a binding arbitration option will also be made available to you in order to address residual complaints not resolved by any other means.

VHSL’ accountability for personal data that it receives under the Privacy Shield Framework and subsequently transfers to a third party is described in the Privacy Shield Principles. In particular, VHSL 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 Privacy Shield Principles, unless VHSL proves that it is not responsible for the event giving rise to the damage.

VHSL is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission (FTC).

Enforcement and Additional Information

VHSL uses a self-assessment approach to ensure compliance with this Privacy Policy and periodically verifies that this Privacy Policy is accurate, comprehensive for the information intended to be covered, prominently displayed, completely implemented and accessible, and in conformity with local law and the Privacy Shield Principles. We encourage interested persons to raise any concerns using the contact information provided below, and we will investigate and attempt to resolve any complaints and disputes regarding the use and disclosure of personally identifying information in accordance with local law and the Privacy Shield Principles.

To access your information, ask questions about our privacy practices, or issue a complaint, please contact us at:

VHSL

1642 State Farm Blvd.
Charlottesville, VA 22911
Telephone: (434) 977-8475

If a complaint or dispute cannot be resolved through our internal process, we agree to dispute resolution using the Council of Better Business Bureaus, Inc. (“CBBB”) as a third-party resolution provider.