VXONLINE LLP. and our group of companies (collectively, “VXONLINE,” “our,” “us” or “we”) recognize the importance of privacy. VXONLINE is committed to protecting the personal information of our clients and prospective clients, as well as other users of our websites and services.
Categories of Personal Information Collected. Generally, we collect the following types of personal information:
Use of Personal Information. In general, we may use and disclose the personal information we collect for the following business and commercial purposes:
Introduction and Scope
Personal Information. In this Policy, our use of the term “personal information” includes other similar terms under applicable privacy laws—such as “personal data” and “personally identifiable information.” In general, personal information includes any information that identifies, relates to, describes, or is reasonably capable of being associated, or reasonably linked or linkable with a particular individual.
Not Covered by Policy. This Policy does not apply to the Platform content or personal information that our clients collect, submit, manage, create, or record via the Platform, or the personal information we collect, access, store, use or otherwise process (collectively, “process”) via the Platform registrants, participants and other end users of client events (the “Platform Data”). VXONLINE is a processor of the Platform Data; we only use the personal information that we process as part of the Platform Data subject to our agreements with clients and their written instructions, or where otherwise required by law. This Policy also does not apply to job applicants and candidates who apply for employment through our job application portal, or to employees and non-employee workers, whose personal information is subject to different privacy notices.
Controller and Responsible Party
For the purposes of the EU General Data Protection Regulation (the “GDPR”) and other relevant applicable laws (such as the UK Data Protection Act 2018 (“UK DPA”) and the Brazilian General Data Protection Law (the “LGPD”)), VXONLINE is the controller of your personal information collected pursuant to this Policy. With respect to any Platform Data, our clients are the data controllers or businesses for their respective Platform Data, and we are a data processor or service provide, as defined under applicable privacy laws.
Information We Collect
The personal information that we collect and process will vary depending upon the circumstances. You do not have to provide us with your personal information to access much of the Site. If you choose not to disclose certain information, you can still visit our Site, but you will not be able to create an account with us, you may be unable to access certain options and services, and we may be unable to fully respond to your inquiries.
Information Collected Directly. We may collect personal information about you directly from you or from your company. For example, when you fill out a ‘Book A Demo’ form, signup for our mailing lists, register for events we host or sponsor, or otherwise provide us information through the Site, we may collect personal information such as:
Information Collected from Third Parties. We may collect personal information about you from third party sources, such as business partners, social media platforms, public sources, joint marketing partners, our resellers (so that we can deliver our Platform and related services) and third parties to whom you have expressed interest in our products and services, as well as information that you shared on social media platforms (subject to the respective platform terms and applicable laws).
Purposes and Legal Bases of Use
Certain laws, including the GDPR, require that we inform you of the legal bases for our processing of your personal information. Pursuant to the GDPR (and other similar laws), we process personal information for the following legal bases:
In addition, we may process your personal information where necessary to protect the vital interests of any individual.
Purposes for Using Personal Information. The purposes for which we may process personal information will vary depending upon the circumstances. In general, we use personal information for the business and commercial purposes set forth below, and where the GDPR or other relevant laws apply, we have set forth the legal bases for such processing in parenthesis (see above for further explanation of our legal bases):
Aggregate, De-identified or Anonymous Data. We also create and use aggregate, anonymous and de-identified data to assess, improve and develop our business, products and services, and for similar research and analytics purposes. This information is not generally subject to the restrictions in this Policy, provided it does not identify and could not be used to identify a particular individual.
Disclosures of Personal Information
In general, we disclose the personal information we collect for the business and commercial purposes explained below:
Aggregate, De-identified or Anonymous data. We may share aggregate, anonymous or de-identified data with third parties for research, marketing, analytics and other purposes, provided such information does not identify a particular individual.
Cookies and Similar Devices
We and our third-party service providers use “cookies,” pixels, java script, log files, and other mechanisms on the Site.
Cookies. A “cookie” is a small text file that may be used, for example, to collect information about website activity. Some cookies allow us to make it easier for you to navigate the Site, while others are used to enable a faster log-in process or to allow us to track your activities while using the Site. Most browsers allow you to control cookies, including whether or not to accept them, and how to remove them.
Clear GIFs, Pixel Tags and Other Technologies. Clear GIFs are tiny graphics with a unique identifier, similar in function to cookies. In contrast to cookies, which are stored on your computer’s hard drive, clear GIFs are embedded invisibly on web pages. We may use clear GIFs (also referred to as web beacons, web bugs or pixel tags), in connection with our services to, among other things, track the activities users of our services, help us manage content, and compile statistics about usage of our services. We and our third party service providers also use clear GIFs in HTML emails to our customers, to help us track email response rates, identify when our emails are viewed, and track whether our emails are forwarded.
Log Files. Most browsers collect certain information, such as your IP address, device type, screen resolution, operating system version, and internet browser type and version. This information is gathered automatically and stored in log files.
Do-Not-Track Signals. The Site does not respond to do-not-track signals. You may, however, disable certain tracking as discussed above (e.g., by disabling cookies). This may affect the viewing experience of the platform.
VXONLINE is headquartered in the Singapore and has operations and service providers in the Singapore. As such, we and our service providers will not transfer your personal information to other jurisdictions outside of Singapore, that may not provide equivalent levels of data protection as your home jurisdiction. We will take steps to ensure that your personal information receives an adequate level of protection in the jurisdictions in which we process it, including through appropriate written data processing terms and/or data transfer agreements.
Protection of Children’s Personal Information
VXONLINE does not publish content that is targeted at children. The Site is not intended for minors (defined by Singaporean Law) under the age 16. We do not knowingly or specifically collect information about minors under the age of 16. If you believe we have unintentionally collected such information, please notify us as set out in the Contact Us.
Wherever your personal information may be held within VXONLINE or on its behalf, we take reasonable steps to protect the personal information that you share with us from unauthorized access or disclosure, including, without limitation, restricting access to certain portions of our website through access controls, and using firewalls. Regardless of the precautions taken by us, VXONLINE cannot ensure or warrant the security of any information you transmit to us, and you transmit such information at your own risk. You are responsible for all actions taken with your User ID and password, if any. Therefore, we recommend that you do not disclose your password to anyone. If you lose control of your password, you may lose substantial control over your personally identifiable information and may be subject to legally binding actions taken on your behalf.
Your Choices and Rights
Access, Amend and Correct. If you wish to access personal information that you have submitted to us, to request the correction of any inaccurate information you have submitted to us, or to request deletion of your information, please send your request by email. We will review your request and make reasonable efforts to respond to it as soon as practicable. We may ask you for additional information so that we can confirm your identity.
Direct Marketing. You may always opt-out of direct marketing emails. If you would like to unsubscribe from VXONLINE email subscriptions or otherwise change your email preferences with VXONLINE, please follow the instructions in any VXONLINE promotional email that we send to you. We may continue to send you transactional or service-related communications, such as service announcements and administrative messages.
Complaints. We will take steps to try to resolve any complaint you raise regarding our treatment of your personal information. You also have the right to raise a complaint with the privacy regulator in your jurisdiction.
As a general rule, we retain your personal information for six months from the date of our last interaction with you to fulfil the purposes for which it was collected or as necessary to comply with our legal obligations, resolve disputes, maintain appropriate business records, and enforce our agreements. In general, for example, we will retain relevant contact information of clients, prospective clients and Site visitors for three years from the date of our last interaction with you and in compliance with our obligations under applicable laws. Our clients instruct us on how long to retain Client Data, which we handle as a data processor. We may retain personal information for longer where required by our regulatory obligations, professional indemnity obligations, or where we believe necessary to establish, defend, or protect our legal rights and interests or those of others.
Changes to the Policy
VXONLINE may update this Policy to reflect new or different privacy practices or to reflect changes in industry standards or legal requirements. Revisions will be posted on our website. This statement of privacy is for the information of our users and does not constitute a contract or modification of any contract. When changes are made to this Policy, VXOnline may not make prior notice. We encourage you to periodically review this Policy for the latest information on our privacy practices.