In effect as of May 25, 2018
Privacy is our bedrock; as such, we operate under a few principles:
- We will not share your personal information with anyone without your consent, except as required by law.
- We don’t ask you for personal information unless we need it.
- We don’t store your personal information unless we need it.
- Our products and services are designed to make it as clear as possible when your information is stored and/or shared.
The following provides further details on how Virtual Halo may collect, use, store, disclose and protect your personal information.
When you visit a Virtual Halo, LLC web site or application, we collect and store information about your visit. We may also engage other companies to do this on our behalf. Examples of the kind of information we, or third parties we engage, track which pages you view on our site, the site you visited just before coming to ours, keywords you used in your search, your company name and the name of your Internet service provider. We use this information to develop ideas for improving our site, our products and services and for better marketing of our products and services. We do not make any attempts to link this information with you as an individual.
There are also various forms on our web site that ask for personal information about you, such as your name, phone number, and e-mail address. If you tell us any personal information, we use it only to contact you in response to your request or to provide you with information that we think you may be interested in receiving. If you inform us that you do not want to receive any information that you have not specifically requested, we will honor your request. We will not sell or otherwise disclose your information to any other company.
At Virtual Halo our Data Privacy and Records Management Policy is a commitment to protecting the privacy of employees, client and web and social media site visitor personal data. Virtual Halo (VH) makes every reasonable effort to protect the privacy of data collected when individuals visit our sites or use our applications.
Virtual Halo employs professional security personnel and takes technical and organizational measures designed to prevent unauthorized access, use, alteration, or disclosure of privacy data collected via VH sites. We try to be both selective and proactive in checking the security background for certain external social media sites and other sites that we come in contact with but do not control. Since its inception, VH has been operating highly secured data repositories with security controls that are continuously updated to meet industry standards and address protective measures for emerging threats. Security practices are described in detail in our internal information technology (IT) policies and procedures.
As a Virtual Halo site visitor does the “GDPR”, and other similar data privacy and records management requirements apply to my data?
Companies within the EU, or who are externally located controllers and processors of the personal privacy data of EU residents in the context of collecting privacy data while soliciting and providing goods or services, will need to comply with the GDPR. Virtual Halo (VH) has adopted the GDPR as our worldwide standard for data privacy. As a VH site visitor, we do collect your business contact information. However, we may also collect or process privacy data for the purpose of providing additional services. We are very aware that combining multiple data elements, even if not considered personal data when taken alone, may result in them being considered personal privacy data when combined into a listing.
We may move your data within or to locations outside of the European Economic Area (EAA). These data transfers are legal under the GDPR as long as we adhere to the requirements for legal processing. We encrypt all data in transit and in storage.
VH has evaluated our obligations under the GDPR, in part, based on: (1) the type of visitor data that we collect via our sites and applications, and (2) the legal basis on which you rely for the protection of your data. We will exercise data privacy stewardship on all of our sites.
How will my personal information be used and shared by Virtual Halo for internal management of their sites?
The personal information we collect in our various sites allows us to:
- respond to your inquiries;
- provide the information, products and services you have requested;
- verify your identity and details of your payment method or credit card amount;
- administer our sites and provide user services;
- meet legal, regulatory and compliance requirements;
- monitor and analyze the use of any account to prevent, investigate and/or report fraud, terrorism, misrepresentation, security incidents or crime;
- gather management information to form statistical and trend analysis;
- communicate with you;
- investigate any complaints about our sites;
- personalize your experience of the sites and applications;
- contact you about our products and services which we think might be of interest to you (where we have the appropriate permissions to do so);
- employ the services of third party service providers to help us in certain areas, such as site and application hosting, maintenance and call center operation. In some cases, the third party may receive your information. However, at all times we use third parties, we will control and be responsible for the use of your information and place contractual requirements on privacy data shared with our sub-processors.
- If you provide a credit or debit card, we may also use third parties to check the validity of the sort code, account number and card number you submit in order to prevent fraud as well as to process any transaction you attempt via the website.
- If false or inaccurate information is provided and fraud is identified, we will follow legal processes if details will be passed to fraud prevention agencies. Law enforcement agencies may access and use this information. We and other organizations may also access and use this information to prevent fraud and money laundering, for example when:
- checking details in applications for credit and credit related or other facilities
- managing credit and credit related accounts or facilities
- recovering debt
- checking details on proposals and claims for all types of insurance
- checking details of job applicants and associates.
Where does Virtual Halo store my privacy information?
Virtual Halo primarily stores privacy data in data centers in the United States and backups of the encrypted data may also be mirrored and stored within the European Union and/or Australasia. These are certified centers: SOC 1 Type 2, SOC 2 Type 2, and ISO (International Standards Organization) 27001. (SOC – Service Organization Controls reports (1-3) of the AICPA (American Institute of Certified Public Accountants). ISO 27001 is one of the most recognized worldwide information technology security standards. SSAE 16 and ISAE 3402 – 22451 and PCI – Data 2334 Security Standard (SSAE – Statement on Standards for Attestation Engagements (#16 & 18), PCI – Payment Card Industry, Data Security Standard ((PCI-DSS)).
What constitutes personal privacy data?
Any personal information related to a natural person (called a ‘data subject’ by the GDPR) that can be used to directly or indirectly identify the person when not encrypted and used individually or in combinations to create a profile.
Personal privacy data is a very broad range of personal information and can be any information item that might be used to create a profile beyond what Virtual Halo considers basic contact information of name, address, mobile phone, email and emergency contact information. Personal privacy information would be: an identifiable photo; identifiable voice recordings; fingerprints; biometric data; home phone number, home address; numbered identifiers – bank account, credit information and credit card, passport, country identification and driver’s license numbers and social security; family member information; medical information; political opinions; sex, sexual preferences; computer IP address; data on children; travel profiles; trade union membership; criminal records; geo-coordinates of physical locations. Some countries consider some of these listed items as Sensitive Personal Identification Information (SPII).
What is the difference between a data processor and a data controller?
- A controller is the entity that determines the purposes, conditions and means of the processing of personal data. A controller can be a processor. A site owner is a controller.
- A data processor is an entity which processes personal data on behalf of the controller.
- Virtual Halo is a controller and/ or a processor at varying times in our conduct of business.
Is Virtual Halo a data processor or data controller in regard to my personal data?
Virtual Halo acts as a data controller and in some cases is also a processor (or sub-processor) for personal data provided to VH through our customers, by individuals and other third parties such as partners.
If you as a data subject provide your personal data directly to Virtual Halo (such as a site visitor, a forum or conference attendee, a site browser, etc.) VH acts as the data controller for that personal data. Note, if VH also processes that personal data in some fashion, VH also qualifies as a data processor in regard to that personal data.
Is Virtual Halo organized to manage the data processor obligations imposed by the GDPR and other similar laws and regulations?
Virtual Halo established a Data Protection and Records Management Committee and appointed Data Protection Officers (DPOs) to manage the program and comply with the GDPR. The Committee is tasked with instituting VH’s internal data privacy compliance initiatives.
For Virtual Halo, keeping site visitor data secure is a high priority. Along with ensuring data security, it is important that a site visitor’s confidence is always maintained and a high level of security around processes and protection is strongly administered.
At Virtual Halo, we strongly value and base our business on the trust that our site visitors, associates and customers have placed upon us. We will continue to earn and reinforce that trusted relationship by cooperating with requests related to our GDPR and other country data privacy obligations.
Virtual Halo, Inc. is committed to taking advanced measures to support and continuously enhance the security of our systems, to ensure that we collect and process personal data in a manner compliant with GDPR or any similar legislation.
Virtual Halo management strongly believes that information technology security/compliance is a key business service. Information security objectives and strategy must be continually aligned with VH’s business strategy and objectives.
When does Virtual Halo delete client data?
Virtual Halo deletes client data, including backups based on our records management schedule. In some cases that can be shortly after you leave one of our sites. Web and social media privacy information is deleted after you finish browsing or have opted out of receiving our communications or you have been unresponsive to our inquiry messages for a period of time. If you acknowledge our site or application use rules to continue browsing or you agree when specifically requested to opt-in your information is transferred to our secure customer relations management database. In some cases we are legally and/ contractually required to keep some data for more extended periods of time consistent with the lawful processing provisions of the GDPR. Data is held in various categories in our records management deletion schedules. These data retention categories range from nearly immediate up to seven (7) years unless there is a longer legal requirement. For more information about data retention times please contact us.
Does Virtual Halo provide clients with the option to delete client data?
Virtual Halo supports the deletion of client data; however, such a request needs to be in writing and needs to be done in conjunction with VH’s Technical Support team in the event it is not a temporary storage item like non-persistent web and social media cookies.
What are Virtual Halo site cookie policies?
The types of cookies Virtual Halo and others may place on your device are described below.
- VH will read or set only the types of cookies that are strictly necessary for quality browsing or specifically allowed by your browser preference settings.
- VH only places cookies that set your preferred language, deliver specific content based on visit history, and give access to various sections of the sites.
- Cookies set by our sites will remain on your device, but VH will not access or use those non-strictly-necessary cookies. You may remove them using functionality provided by your browser. Please note that cookies are specific to the browser or device you use, as well as to the domain, and you will therefore have to configure your preferences again if you change your browser or devices, or visit a different domain.
- Any specific questions regarding these cookie settings may be sent to email@example.com
How do you use Web Beacons?
Some of our web pages may contain electronic images known as web beacons (sometimes known as clear gifs) that allow us to count users who have visited these pages. Web beacons collect only limited information which includes a cookie number, time and date of a page view, and a description of the page on which the web beacon resides. We may also carry web beacons placed by third party advertisers. These beacons do not carry any personally identifiable information and are only used to track the effectiveness of a particular campaign.
How do you use Social Media Widgets?
How do you use Blog Information?
Should you choose to add a comment to any posts that we have published on our sites for example in a blog, the name and email address you enter with your comment will be saved to the site’s database, along with your computer’s IP address and the time and date that you submitted the comment. This information is only used to identify you as a contributor to the comment section of the respective blog post and is not passed on to any of the third-party data processors. Only your name will be shown on a site that is public-facing. Your posted comment(s) and its associated personal data will remain on this site until we see fit to either 1) remove the comment, or 2) remove the blog post. Should you wish to have the comment and its associated personal data deleted, please email us with your contact information using the email address that you commented with.
If you are under 18 years of age we request you obtain parental consent before posting a comment on our blog and sites.
NOTE: You should avoid entering personally identifiable information to the actual comment field of any blog post comments that you submit on this site.
How do you use Contact Forms and Email Links?
Should you choose to contact us using a contact form on our sites or an email link, the data you supply will be stored in our customer relationship management database or may be passed on to be processed by a third-party data processor(s). We do retain information from data requests in our customer relationship management system. Collated and transferred data is encrypted before being sent across the internet. We do not sell personal information.
How do you use information we provide to you?
As a compliance philosophy Virtual Halo makes every effort to apply a data minimization approach in our privacy data gathering and storage activities. We do collect and hold some personal information you give us. These are the general types of information we may collect from you:
Registration and Profile Information
We try to gather only the most necessary information for the involved inquiry or purpose. When you enter or register to use our site, our services, to receive information, to participate in our events, and create or update your forum profiles, we may collect various kinds of information about you. For example, we may collect: your name; postal address; phone number; fax numbers and email address; your log-in ID and password; your title; company; and other business related or event specific profile information you provide; demographic information; and information linked with your profile such as comments you may post. We need this information to be able to respond to you, secure the site and provide services as applicable.
Information We Automatically Collect
- When you visit our site or use Virtual Halo site services, as do many companies, some information is collected and recorded automatically such as your computer’s operating system, Internet Protocol (IP) address, access times, browser type and language, and the website you visited before our corporate sites, so we are aware of transfers and linking for security due diligence (blocking and enhancing) of our site and to protect you the user. This is logged automatically and stored in log files. We also collect information about your usage and activity on our corporate sites. We may tie your IP address to information we automatically collect on our corporate sites. We may also tie information we automatically collect with personal information, such as your login ID and information you give us for a registration. We use our own products, and products of third parties acting on our behalf, to analyze, optimize, securely protect and improve our site.
- VH will also collect information on your usage to ensure the security of the data we collect on behalf of our clients. You cannot opt-out of this collection and processing as it is necessary to ensure the security of the service we provide for our sites and for our clients.
- Virtual Halo may also use device-recognition technologies combined with other identifiers to create cross-browsers and cross-devices identities to provide you with better services and security.
In Virtual Halo Commitment to data protection what steps have been taken to protect my data?
Virtual Halo initiated a data privacy data management compliance review and update effort beginning in December 2017 to ensure alignment with the May 2018 requirements of the European Union (EU) General Data Protection Regulation (GDPR) and other similar privacy data regulatory obligations coming into force around the world. These efforts are companywide, ongoing and driven by a chartered committee sponsored by senior corporate leaders. We meet regulatory requirements, to include these examples:
- We have not identified any information technology shortfalls in data privacy transmission and storage encryption.
- The standing Data Privacy and Records Management Committee currently meets bi-monthly.
- An internal informational data portal about data privacy is available for associates.
- Privacy data owners’ storage information submissions are being continuously catalogued and are annually updated.
- The annual review of the initial data privacy impact risk assessments of the catalogued submissions from data owners is an ongoing Committee activity.
- We have standard contract language amendments for subcontractors/processors in-place.
- A new Company master policy on data privacy and records management supporting our due diligence and transparency requirements for the new privacy protection laws is in effect.
- We have an approved charter for the permanent standing Committee to administer the ongoing post May 2018 data privacy records management program to meet the GDPR.
- We conduct associate data privacy awareness training annually.
- If you need additional elaboration on Committee actions please contact us at: firstname.lastname@example.org
- In addition to efforts by the Committee, Virtual Halo employs security professionals and takes technical and organizational measures designed to prevent unauthorized access, use, alteration, or disclosure of privacy data collected via VH sites. Further, VH has more than 40 years of experience in operating highly-secured solutions with security controls that are continuously updated to meet industry standards and address emerging threats. This is described in detail in our information technology policies and procedures.
- We encrypt our data in transit and in storage.
- In our delivery of training activities and consulting services we are sometimes contractually required to conduct business operations processing wherein we collect client employee, vendor and client customer privacy data on behalf of our clients and for our internal services processes. We also may collect limited categories of privacy data from individuals that visit our web and social media sites. This information is stored in secure sites.
- We use or intermittently use contracted assistance to process VH payroll, human resources and related associate services and in doing so we necessarily disclose personal information to accomplish these processing operations.
- We acknowledge that individuals have the right to inquire about and access their data
- Virtual Halo is required to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
- We make efforts to limit the collection, use and disclosure of personal data to help protect personal privacy. We will discuss with you your specific request to limit use of your data if you choose to restrict the use of privacy data. We most likely cannot make exceptions for required legal, regulatory, contractual and personal public safety contact information erasure requests. The discussions will include the alternate processes and consequences of the alternative processing methods available to accomplish the same necessary services affected by your request, up to and including deleting data if that is an option.
- Virtual Halo is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC).
- An individual has the possibility, under certain conditions, for the individual to invoke binding arbitration when seeking more restrictive data privacy remedies from Virtual Halo.
- Virtual Halo understands that it may not be absolved of liability in cases of onward transfers of privacy data to third parties.
Virtual Halo, LLC
7424 W Plank Rd
Peoria, IL 61604 USA
Updated: May25, 2018