Effective Date: September 16, 2019
Collection of Information
Information Provided by Our Business Customers. In the course of providing telephone town hall, streaming, polling and other services to our business customers, our business customers provide us with personally identifiable information about their members, constituents, customers, etc., including contact information such as name, phone number, email address and physical address.
Information That We Collect from You. When you directly access or use our Services, we may collect two types of information: (1) personally identifiable information; and (2) information that is not personally identifiable. Personally identifiable information includes information that identifies you personally, alone or in combination with other information available to us.
As part of the standard operation of our Services, we may collect personally identifiable information. When you use some of our Services, you are not required to provide any personally identifiable information. If you choose to sign up for a telephone town hall, channel or other event on or through our Services (“Event(s)”), then you will need to provide us with personally identifiable information, including your contact information such as your name, phone number and email address.
You may also volunteer your personally identifiable information through the Services. If you participate in a telephone town hall, streaming event or poll, or contact us via email, text message, telephone or otherwise, we may keep your message, email address, contact and other information. Information provided in your message will be treated consistently with other personally identifiable information.
As part of the standard operation of our Services, we also collect non-personal information about you, including your device identifiers, browser type, operating system, IP address and the domain name from which you accessed the Services. In addition, we may collect information about your browsing behavior, such as the date and time you visit the Services, the areas or pages of the Services that you visit, the amount of time you spend viewing the Services, the number of times you return to the Services, the referring web page, pages visited, location, your mobile carrier, device and application ID’s and other click-stream data.
We use persistent and session cookies, web beacons and various technologies to collect and track the non-personal information described above and to better understand how you interact with the Services. Most Internet browsers automatically accept cookies. You are free to decline cookies, but by doing so you may not be able to use certain features of the Services.
We may keep track of how you interact with links posted on or through the Services, including those of our customers that host or sponsor Events or channels, advertisers on the Services and third-party service providers, by redirecting clicks or through other means.
We use clear gifs (aka web beacons), which are tiny graphic images, in our web pages and emails. These help us measure the effectiveness of our campaigns by telling us whether the messages have been received, opened or otherwise acted upon.
We may tailor content for you, such as suggestions for Events or channels that may be of interest to you, based on, among other things, your visits to third-party websites that integrate our buttons or widgets. When these websites first load our buttons or widgets for display, we receive information, including the web page you visited and a cookie that identifies your browser.
The Services do not support “Do Not Track” requests sent by your web browser or other similar mechanisms.
Use of Information
We use the information we collect from and about you as described in the “Collection of Information” section above and to provide the best service we can, including to: (1) contact you about Events or channels you have signed up for, Events or channels you may be interested in, or to provide information about the Services or your use of the Services; (2) provide you with customized content, advertising, promotions and offers from us and from our customers that host or sponsor Events or channels, advertisers on the Services and third-party service providers and advertising partners (“Partner(s)”); (3) administer the Services, monitor their usage and diagnose problems with the Services; (4) remember you when you return to the Services, so that you don’t have to re-submit information and preferences; (5) improve our Services; (6) protect the security or integrity of the Services and our business; and (7) provide services to our business customers.
When you sign up for an Event or a channel, you authorize us to share your information with the applicable Partner(s). If you cancel a sign up for an Event or a channel, we will use reasonable efforts to notify the Partner(s) that you have cancelled, but we are not responsible or liable in any way if the Partner(s) continue to contact you.
You always have the ability to opt out of receiving future phone calls, emails, text messages or other notifications from us. Please see the section on “Your Choices” below for details.
Sharing and Disclosure of Information
We may disclose to our Partners personal information that we collect from you on their behalf (as described above in the “Collection of Information” section”) so that they can provide you with customized content, advertising, promotions and offers.
We also may share aggregate, non-personally identifiable information with third parties for research and other purposes.
We offer certain choices to you regarding our email marketing communications.
You may opt out of receiving future email communications from us or our Partners by cancelling a sign up for an Event or a channel by following the instructions under the “My Vekeo” tab in the main menu on the Vekeo website. You may also opt out of receiving phone calls, emails or texts from us by following any instructions provided in such phone call, email or text or by sending us an email with the relevant information at firstname.lastname@example.org.
If you opt out of receiving future communications from one or more of our Partners, we are not responsible if the Partner(s) continue to contact you. If you cancel a sign up for an Event or a channel, we will use reasonable efforts to notify the Partner(s) that you have cancelled, but we are not responsible or liable in any way if the Partner(s) continue to contact you. It is your responsibility to follow any instructions provided by a Partner to be removed from that Partner’s communications.
Access and Correction of Your Information
To access or correct your personally identifiable information, please send us an email at email@example.com or contact us by mail at 1805 Shea Center Drive, Suite 160, Highlands Ranch, Colorado 80129.
We have the right, but not the obligation, to: (1) retain and use your personally identifiable information for as long as needed to provide you access to or use of our Services; (2) retain and use your personally identifiable information for as long as needed to provide services to our business customers; (3) retain and use your personally identifiable information as necessary to comply with our legal obligations, resolve disputes and enforce our agreements; and (4) retain and use non-personally identifiable information.
Your personally identifiable information will be stored in our databases or databases maintained by our third-party storage/service providers. Most of these databases are stored on servers located in the United States, but some may be located outside of the United States.
We take reasonable physical, electronic, contractual and administrative steps to protect the confidentiality, security and integrity of your personally identifiable information. However, no method of transmission over the Internet or method of electronic storage is completely secure, and we cannot guarantee its absolute security. You agree to notify us immediately at firstname.lastname@example.org of any actual or suspected unauthorized use or breach of security with respect to our Services.
EU-U.S. Privacy Shield
This section of our Privacy Statement applies to personal information transferred to Company from organizations in the EEA.
Company has partnerships with certain organizations in the EEA (“EEA Partners”) that provide us with personal information to enable us to provide our Services to individuals in the EEA. We do not disclose personal information obtained from our EEA Partners to any third parties. If we plan to use personal information from an EEA Partner in a manner that is materially different from the purposes for which it was originally collected, or that you subsequently authorized, we will provide you with an opportunity to approve of such uses. Company acts as a data processor for our EEA Partners and, in this role, processes data on their behalf and at their instruction for purposes that they determine. Accordingly, contact the EEA Partner to whom you provided your personal information to learn about the choices they offer you to limit the use and disclosure of your personal information, and how to exercise those choices. Company does not otherwise knowingly collect personal information of individuals in the EEA.
Company complies with the EU-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union to the United States. Company has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this Privacy Statement and the Privacy Shield Principles, the Privacy Shield Principles will govern. To learn more about the Privacy Shield program, and to view our certification, please visit www.privacyshield.gov.
In compliance with the Privacy Shield Principles, Company commits to resolve complaints about our collection or use of your personal information. European Union individuals with inquiries or complaints regarding our Privacy Shield policy should first contact Company at email@example.com. Company has further committed to refer unresolved Privacy Shield complaints to JAMS, an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint from us, or if we have not resolved your complaint in a reasonable amount of time, please contact or visit JAMS at www.jamsadr.com/eu-us-privacy-shield for more information or to file a complaint. The services of JAMS are provided at no cost to you. Please note that if your complaint is not resolved through these channels, under limited circumstances, a binding arbitration option may be available before a Privacy Shield Panel. To find out more about the Privacy Shield’s binding arbitration scheme, please see https://www.privacyshield.gov/article?id=ANNEX-I-introduction.
Company generally does not transfer personal data that we receive under Privacy Shield. In some instances, however, we may transfer such data to a third-party service provider for processing; if we do so, we will remain responsible if the third party processes your personal information in a manner inconsistent with the Privacy Shield Principles, unless we are not responsible for the event giving rise to the damage.
The Federal Trade Commission has jurisdiction over Company’s compliance with the Privacy Shield.
Individuals from the EU may contact our EU representative regarding any data protection and privacy requests:
We do not direct our Services to, nor do we knowingly collect any personally identifiable information from, children under 13 years of age. If you become aware that your child has provided us with personally identifiable information without your consent, please contact us at firstname.lastname@example.org. If we become aware that a child under 13 has provided us with personally identifiable information, we take commercially reasonable steps to remove such information and terminate the child’s signups.
Changes to this Privacy Statement
We may change this Privacy Statement from time to time in our sole discretion without notice to you. When we do, we will post the change(s) on the Services. By continuing to access or use our Services after those changes have been posted, you agree to be bound by the revised Privacy Statement.
If you have any questions about this Privacy Statement, our practices, our Services, or dealings with the Company, please send us an email at email@example.com or contact us by mail at 1805 Shea Center Drive, Suite 160, Highlands Ranch, Colorado 80129.