PRIVATE POLICY



 

    A. Information We Collect

The Personal Information that we may collect broadly falls into the following categories:

(i) Information you provide to us: In the course of engaging with our Services, you may provide Personal Information about you, your platform and your Contacts. Personal Information is provided to us when you sign for and use the Services, consult with our customer service team, send us an email, or talk with one of our agents. 

 

VIRTUE Clan collects a variety of information that you provide directly to us. We process your information when necessary to provide you with the Services that you have requested when accepting our Terms of Service, or where we have obtained your prior consent, or where we have a legitimate interest to do so. For example, we may have a legitimate interest to process your information for security, testing, maintenance, promotion and enhancement purposes of the Services we provide to you, or for analytics, research and reporting purposes. Without your information, we cannot provide you with the Services you have requested or you may be limited in your use of the Services.

We will let you know prior to collection whether the provision of Personal Information we are collecting is compulsory or if it may be provided on a voluntary basis and the consequences, if any, of not providing the information. By giving us this information, you agree to this information being collected, used and disclosed as described in our Terms of Use and in this privacy policy.

This information may include:
 

  • Login information: You need a VIRTUE Membership to access a large portion of our Services as a Member. When you register for a membership or sign a contract with us, you will be asked to provide certain basic information, such as your name, email address, username, password, company name, occupation, location, and phone number (for example, if you are using two-factor authentication).

  • Billing and communications information: If you purchase our Services, you may also need to provide us with payment and billing information, such as your billing address. VIRTUE will also maintain a record of your billing transactions and purchases, and any communications and responses.

  • Information we process on your behalf: In order to launch a promotion, ad or campaign we need to use certain features of your digital media account. We use and process this information to provide the Services in accordance with your instructions.
     

(ii) Information we collect automatically: When you visit our website or interact with our social pages, we may automatically collect certain information about your device and or location. We do not use cookies to collect this information.

This information may include:
 

  • Device information: We may collect information about the device and applications you use to access the Services, such as your IP address, your operating system, your browser ID, and other information about your system and connection. We may collect information about the type of device and operating system you use. We do not ask for, access, or track any location-based information from your mobile device at any time while using our or Services.

  • Log data: Our web servers keep log files that record data each time a device accesses those servers and those log files contain data about the nature of each access, including originating IP addresses. We may also access metadata and other information associated with files that you upload into our Services.

  • Product usage data: We collect usage data about you whenever you interact with our Services, which may include the dates and times you access the Services and your activities (such as what portions of the Services are used). We also collect information regarding the performance of the Services, including metrics related to promotions and marketing campaigns that result from our Services. This information allows us to improve the content and operation of our targeting and Services, and facilitate research and analysis of the Services.

(iii) Information we collect from other sources: From time to time, we may obtain information about you from third-party sources, such as public databases, social media platforms, third-party data providers and our joint marketing partners. We take steps to ensure that such third parties are legally or contractually permitted to disclose such information to us.

  • Examples of the information we receive from other sources include demographic information (such as age and gender), device information (such as IP addresses), location (such as city and state), and online behavioral data (such as information about use of social media websites, page view information and search results and links). We use this information, alone or in combination with other information (including Personal Information) we collect, to enhance our ability to provide relevant marketing and content to you and to develop and provide you with more relevant products, features, and services.

(iv) Information from the use of our mobile apps: When you use our mobile apps, we may collect certain device and usage-related information in addition to information described elsewhere in this privacy policy.

 

     B. Use of Personal Information

We may use the Personal Information we collect through the Services or other sources for a range of reasons, including:

  • To bill and collect money owed to us by you. This includes sending you emails, invoices, receipts, notices of delinquency, and alerting you if we need a different credit card number. We use third parties for secure credit card transaction processing, and those third parties collect billing information to process your orders and credit card payments. To learn more about the steps we take to safeguard that data, see the "Our Security" section of this privacy policy.

  • To send you system alert messages. For example, we may inform you about temporary or permanent changes to our Services, such as planned outages, or send you account, security or compliance notifications, such as new features, version updates, releases, abuse warnings, and changes to this privacy policy.

  • To communicate with you about your account and provide customer support. For example, if you use our mobile apps, we may ask you if you want to receive push notifications about activity in your account. If you have opted in to these push notifications and no longer want to receive them, you may turn them off through your operating system.

  • To enforce compliance with our Terms of Use and applicable law, and to protect the rights and safety of our Members and third parties, as well as our own. This may include developing tools and algorithms that help us prevent violations. For example, sometimes we review the content of our Members’ content and campaigns to make sure they comply with the Terms of Use of the used platform and our own business. Our employees or independent contractors may review those particular promotions and campaigns. This benefits all Members who comply with our Terms of Use because it reduces the amount of spam being sent and promoted through our network and helps us maintain high deliverability.

  • To meet legal requirements, including complying with court orders, valid discovery requests, valid subpoenas, and other appropriate legal mechanisms.

  • To provide information to representatives and advisors, including attorneys and accountants, to help us comply with legal, accounting, or security requirements.

  • To prosecute and defend a court, arbitration, or similar legal proceeding.

  • To respond to lawful requests by public authorities, including to meet national security or law enforcement requirements.

  • To provide suggestions to you. This includes adding features to your VIRTUE Membership, campaigns or using data to suggest products or services that you may be interested in or that may be relevant to you or your Contacts. 

  • Combined information. We may combine Personal Information with other information we collect or obtain about you (such as information we source from our third-party partners) to serve you specifically, such as to deliver a product or service according to your preferences or restrictions, or for advertising or targeting purposes in accordance with this privacy policy. When we combine Personal Information with other information in this way, we treat it as, and apply all of the safeguards in this privacy policy applicable to, Personal Information.

  • Other purposes. To carry out other legitimate business purposes, as well as other lawful purposes about which we will notify you.

    C. Other Data Protection Rights

  • You and your Contacts may have the following data protection rights:

  • To access, correct, update or request deletion of Personal Information. VIRTUE takes reasonable steps to ensure that the data we collect is reliable for its intended use, accurate, complete and up to date. As a Member, you can manage all of your data by contacting us directly by emailing us at legal@virtuenorway.com. Our customer support will assist you with requests about access, correct, update or delete information / data.

  • In addition, individuals who are residents of the EEA can object to processing of their Personal Information, ask to restrict processing of their Personal Information or request portability of their Personal Information. You can exercise these rights by contacting us using the contact details provided in the "Contact Us" section below.

  • Similarly, if Personal Information is collected or processed on the basis of consent, the data subject can withdraw their consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your Personal Information conducted in reliance on lawful processing grounds other than consent. 

  • The right to complain to a data protection authority about the collection and use of Personal Information. For more information, please contact your local data protection authority.

  • We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection law. We may ask you to verify your identity in order to help us respond efficiently to your request.