Effective Date: August 5, 2022
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This Privacy Policy governs our websites that display or link to this Privacy Policy (each, a “Site”), and it describes our privacy practices for the activities described in this Privacy Policy. Please read it carefully to learn how we collect, use, share, and otherwise process information relating to identified or identifiable individuals (“personal information” or “personal data”), and to learn about your rights and choices regarding such personal information. In this Privacy Policy, “we,” “us,” and “our” refer to Via Customer, Inc., 2000 Ashton Blvd Suite 100, Lehi, UT 84043and its affiliates.
By visiting or using a Site, you agree to the collection, use, and disclosure of your personal information as described in this Privacy Policy, and agree to the Via Terms of Use, which are incorporated here by reference. If you do not agree, please do not access or use the Site.
Via is the controller of your personal data as described in this Privacy Policy, unless specified otherwise. This Privacy Policy does not apply to the extent we process personal data in the role of a processor or service provider on behalf of our customers, including where we offer to our customers various products and services through which our customers (or their affiliates): (i) sell or offer their own products and services; (ii) send electronic communications to others; or (iii) otherwise collect, use, share or process personal data via our products and services.
For detailed privacy information related to a Via customer or a customer affiliate who uses our products and services as the controller, please contact our customer directly. We are not responsible for the privacy or data security practices of our customers, which may differ from those explained in this Privacy Policy.
California Notice of Collection of personal information: Via collects personal information listed below under “Information We Collect” for the purposes described below under “Information Use.” To learn more about your California privacy rights, including your right to opt-out of the sale of your personal information, please scroll down to “Your California Privacy Rights.”
QUICK GUIDE TO CONTENTS
1. ACTIVITIES COVERED
2. INFORMATION WE COLLECT
3. INFORMATION USE
4. INFORMATION WE SHARE
5. YOUR CHOICES
6. EEA & UK RIGHTS NOTICE
7. YOUR CALIFORNIA PRIVACY RIGHTS
8. CHILDREN’S PRIVACY
9. DATA SECURITY
10. INTERNATIONAL TRANSFERS
11. REVISIONS TO THIS PRIVACY POLICY
12. HOW TO CONTACT US
This Privacy Policy applies to the processing of personal data collected by us when you:
There are several ways we may obtain information about you, including through (A) information you provide to us directly; (B) information that we automatically collect; and (C) information we receive from third parties. This includes data that identifies you personally whether directly (i.e. your name) or indirectly (i.e. information about your online use).
Information You Provide
Via collects information from you when you choose to share it with us. This may include when you visit a Site, log-in at a Site, request information from us, sign up for newsletters or our email list, fill out a survey, request customer support, or otherwise communicate with or contact us. The information we collect may include your biographical information (i.e., name, address, email address, telephone or mobile number, date of birth, and gender), registration information (i.e., username), geolocation information, and additional information collected in connection with event participation (i.e., emergency contact information).
Information Automatically Collected
Whenever you visit or interact with a Site, we, as well as any third-party advertisers and/or service providers, may use cookies, web beacons, pixel tags, or other technologies to automatically or passively collect information about your online activity.
Please note that we automatically collect the following information about you:
To learn more about your advertising choices relating to the collection and use of your automatically collected information, please see the Your Choices section below.
Information Collected From Other Sources
We may acquire information about you from our partners and service providers (including, for example, business partners, analytics vendors, and advertising networks). We use the information we collect from other sources to help us maintain the accuracy of the information we collect, personalize your experience with the Site, target our communications so that we can inform you of products and services or other offers that may be of interest to you, to measure ad quality and responses, and for internal business analysis or other business purposes.
Combination of Information
We may combine the information we receive from and about you, including information you provide to us and information we automatically collect through a Site, as well as information collected offline, across other computers or devices that you may use, and from third-party sources.
Via may use the information we collect from and about you for a variety of business purposes, including:
Via may also use your information for commercial purposes, such as:
Additionally, we may use your information for other purposes disclosed at the time you provide your information or otherwise with your consent. We are committed to protecting and maintaining the privacy of your information. Therefore, we will process your data only in accordance with applicable data protection law and this Privacy Policy. We will have a lawful basis for processing your data if:
We may share the information we collect from and about you as described below.
Other: We also may share your information as disclosed to you at the time of collection.
Advertising Choices
Certain parts of a Site may require cookies, pixels, or similar technologies. For example, we may use cookies or other technologies to deliver more relevant advertising and to link data collected across other computers or devices that you may use. To learn more about the cookies in use on Sites or to exercise your preferences for the Sites, use our cookie preference tool found by clicking “Manage Cookie Preferences” in our website footer. You may also adjust your device or Internet browser settings to limit certain tracking or to decline cookies, but by doing so, you may not be able to use certain features or take full advantage of all of our offerings. Please refer to your device’s settings or your Internet browser’s “Help” section for more information on how to delete and/or disable your device or browser from receiving cookies or controlling your tracking preferences. On some Sites, our system may not respond to Do Not Track requests or headers from some or all Internet browsers.
To understand your advertising choices for receiving more relevant advertising provided on the Site or across other websites and online services, please review the information below:
Even if you opt-out, you still may receive advertising from us that is not customized for you or from companies that do not participate in the DAA or NAI.
Analytics Choices
If you wish to prevent your data from being used by Google Analytics, Google has developed the Google Analytics opt-out browser add-on available here.
Direct Marketing Choices
To opt-out of direct marketing communications, you may:
If you receive marketing communications from one or more Via affiliates, you must opt-out individually from each of the affiliates from which you are receiving brand-specific marketing communications.
We respect your privacy rights and provide you with reasonable access and rights to the personal data that you may have provided through your use of the Site. If you live in the European Economic Area (“EEA”) or United Kingdom (“UK”) and wish to access, amend, delete, or transfer any personal data we hold about you, you may contact us as set forth in the “Contact Us” section. In some cases, you may also update your registration information or preferences by accessing your account settings page on Sites.
At any time, you may object to the processing of your personal data in our legitimate interests, except if otherwise permitted by applicable law. If you believe there has been a violation of your privacy rights, please contact us as set forth in the “Contact Us” section below. You also have a right to lodge a complaint with your local data protection authorities.
You may decline to share certain personal data with us, in which case we may not be able to provide to you some of the features and functionality of the Site.
We will retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. In some circumstances we may anonymize your personal data (so that it can no longer be associated with you) for analytics purposes, in which case we may use this information indefinitely without further notice to you.
Your Rights
If you are a California resident, you may take advantage of the following rights:
To make a request, please contact us by email at privacy@viacustomers.com, or at (385) 287-6959. If you send a written request, you must put the statement “Your California Privacy Rights” in the subject field. We are not responsible for notices that are not labeled or sent properly, or do not have complete information. We may take steps to verify your identity before responding to your requests to know or delete your personal information by asking questions about your interactions with us.
You have the right to use an authorized agent to submit your requests. Please direct your agent reach out by email at privacy@viacustomers.com, or at (385) 287-6959. Authorized agents must submit proof of the consumer’s signed authorization to make a request. We may require you to verify your identity directly with us prior to fulfilling your authorized agent’s request.
If you exercise any of the foregoing rights, we will not discriminate against you, including by denying access to our products or services or restricting your access to products or services of a certain quality or price level.
CCPA Disclosures
Pursuant to the California Consumer Privacy Act (CCPA), and in addition to the disclosures elsewhere in this Privacy Policy, this section describes the types of personal information that we collected, disclosed for business purposes, or sold to third parties in the last 12 months.
Biographical information / identifiers, characteristics of protected classifications under California or federal law (i.e., gender, age), internet or other electronic network activity information, geolocation information, visual information, and inferences drawn from the above. For more information about the information that we collect, please see “Information We Collect,” above. The sources of the information are the consumer, our business customers and partners, analytics providers, advertising partners, social networks, service providers, and third party photographers.
In the last 12 months, Via has disclosed the following categories of personal information to its service providers, contractors, and vendors for business purposes: Biographical information / identifiers, characteristics of protected classifications under California or federal law (i.e., gender, age), internet or other electronic network activity information, geolocation information, education information, visual information, and inferences drawn from the above. To learn more, please see “Information We Share” above.
The CCPA also provides California residents with the right to opt out of the “sale” of personal information. Based on the definition of “sell” under the CCPA and under current regulatory guidance, we do not sell personal information.
Please note that we also do not knowingly sell the personal information of minors under 16 years of age without legally required affirmative authorization.
Protecting children’s privacy is important to us. We do not direct the Site to, nor do we knowingly collect any personal information from, children under the age of sixteen. If we learn that a minor has provided personal information through the Site, we will use reasonable efforts to remove such information from our files.
We have taken certain physical, administrative, and technical steps to safeguard the information we collect from and about our customers and Site visitors. While we make every effort to help ensure the integrity and security of our network and systems, we cannot guarantee our security measures.
Your personal data may be collected, transferred to, and stored in the United States by us and by our affiliates and third-parties that are based in other countries.
Therefore, your personal data may be processed outside your jurisdiction, including in countries and jurisdictions that are not subject to an adequacy decision by the European Commission or your local legislature or regulator, and that may not provide for the same level of data protection as your jurisdiction. We ensure that the recipient of your personal data offers an adequate level of protection and security, for instance by entering into the appropriate back-to-back agreements and, if required, standard contractual clauses or an alternative mechanism for the transfer of data as approved by the European Commission (Art. 46 GDPR) or other applicable regulators or legislators. Where required by applicable law, we will only share, transfer or store your personal data outside of your jurisdiction with your prior consent.
To find out more about how we safeguard your information (including the mechanism(s) involved) in relation to transfers outside the EEA, please contact us via the details provided in the “Contact Us” section below.
We reserve the right, at our sole discretion, to change, modify, add, remove, or otherwise revise portions of this Privacy Policy at any time. When we do, we will post the change(s) on the Site. Your continued use of the Site following the posting of changes to these terms means you accept these changes. If we change the Privacy Policy in a material way, we will provide appropriate notice to you.
If you have any questions or concerns about this Privacy Policy or the practices described herein, you may contact us at legal@viacustomers.com or by mail to:
Via Customers, Inc.
2000 Ashton Blvd #100
Lehi, UT 84043
Attention: Legal