as of February 3, 2023
If you have any questions or concerns about this privacy notice or our practices with regard to your personal information, please contact us at email@example.com.
This privacy notice describes how we might use your information if you:
• Visit our website at https://www.vuleads.com
• Engage with us in other related ways ― including any sales, marketing, or events
• Or leave a review by using our Services
In this privacy notice, if we refer to:
"Website," we are referring to any website of ours that links to this policy; and "Services," we are referring to our Website, and other related services, including any sales, marketing, or events.
The purpose of this privacy notice is to explain to you in the clearest way possible what information we collect, how we use it, and what rights you have in relation to it. If there are any terms in this privacy notice that you do not agree with, please contact us or discontinue use of our Website and Services immediately.
Please read this privacy notice carefully, as it will help you understand what we do with the information that we collect from you.
1. WHAT INFORMATION DO WE COLLECT?
Personal information you disclose to us
In Short: We collect personal information that you provide to us through the Website or by using our Services.
We collect personal information that you voluntarily provide to us when you browse or register on the Website, express an interest in obtaining information about us or our Services, when you participate in activities on the Website or otherwise when you contact us.
The personal information that we collect depends on the context of your interactions with us and the Website, the choices you make and the Services and features you use. The personal information we collect may include the following:
• Personal Information Provided by You when you sign up. When you sign up on the Website, we collect your name, email address, and password. If you decide to sign up by using your Google account, we collect the information that Google sends to us, such as your name, email address. We use such information to create and maintain your user account, provide you with the requested Services, contact you (if necessary), and maintain our business records. The legal bases on which we rely are (i) performing our contractual obligations and (ii) pursuing our legitimate business interests (i.e., to administer our business). We store such information until you delete your user account.
• Payment Data. We may collect data necessary to process your payment if you make purchases, such as your name, billing address, credit card number, and the security code associated with your credit card. The payments are processed and all payment data is stored by Stripe. You may find their privacy notice link(s) here: https://stripe.com/privacy. We do not have access to your full payment details. The details that are made available to us by Stripe are your name, email, zip code, and country. The legal bases on which we rely are (i) performing our contractual obligations and (ii) pursuing our legitimate business interests (i.e., to administer our business). We store such information for the time period required by the accounting law.
• Contact information. When you contact us by email, we collect your name, email address, and any information that you provide us with in your message. We use such information to respond to your enquiry. The legal basis on which we rely is pursuing our legitimate business interests (i.e., to operate and expand our business). We store such information until you stop communicating with us. All personal information that you provide to us must be true, complete and accurate, and you must notify us of any changes to such personal information.
• Reviews. When you leave a review, we collect your name, email, title, company, social profile link, address and, any other customized information that our clients choose to request you to submit. We process such information to provide our clients with the requested services (i.e., record, publish and manage your review). The legal basis on which we rely is performing a contract with our client. We store such information until you delete your review or our client deletes your review.
Our role as a data controller and data processor
We act in the capacity of a data controller and a data processor with regard to the personal data processed through the Website and the Services in terms of the applicable data protection laws, including the EU General Data Protection Regulation (GDPR).
Our role depends on the specific situation in which personal data is handled by us, as explained in detail below:
• Data controller: We are responsible for the collection of your personal data through the the Website and the Services and their further use. We make decisions about the types of personal data that should be collected from you and purposes for which such personal data should be used. Therefore, we act as a data controller with regard to the personal data collected directly through the Solutions (e.g., when you sign up or send us an inquiry). We comply with the data controller’s obligations set forth in the applicable laws.
• Data processor: We act in the capacity of a data processor in situations when our clients use the Services to collect certain personal data from you to collect reviews (the “Service Data”). We do not own, control, or make decisions about the Service Data. We process the Service Data only in accordance with the instructions issued by a respective data controller (our client). To ensure that the Service Data is processed in accordance with the strictest data protection standards, we have drafted and offer for conclusion a data processing agreement (the “DPA”).
Information automatically collected
In Short: Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you visit our Website.
We automatically collect certain information when you visit, use or navigate the Website. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address (which may be deemed your personal information in some countries), browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Website and other technical information. This information is primarily needed to maintain the security and operation of our Website, and for our internal analytics and reporting purposes.
The information we collect includes:
• Log and Usage Data: Log and usage data is service-related, diagnostic, usage and performance information our servers automatically collect when you access or use our Website and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type and settings and information about your activity in the Website (such as the date/time stamps associated with your usage, pages and files viewed, searches and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called 'crash dumps') and hardware settings).
• Device Data: We collect device data such as information about your computer, phone, tablet or other device you use to access the Website. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model Internet service provider and/or mobile carrier, operating system and system configuration information.
• Location Data: We collect location data such as information about your device's location, which can be either precise or imprecise. How much information we collect depends on the type and settings of the device you use to access the Website. For example, we may use GPS and other technologies to collect geolocation data that tells us your current location (based on your IP address). You can control how we collect this information either by providing your consent or disabling your Location setting on your device. Note however, if you do not enable your location data, you may not be able to use certain aspects of the Services that are based on your location.
• Google Analytics: We use Google Analytics, a web analytics service provided by Google LLC, registered at 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (“Google”). Google generates statistical information by means of cookies and creates reports about your use of the Website. The cookies served by Google are anonymous first-party cookies that do not allow us to identify you in any manner. The information generated by cookies will be transmitted to and stored by Google on servers in the United States. To ensure your privacy, your IP address will be anonymised and Google will not combine your IP address with other information Google holds about you. Thus, Google will not be able to identify you. In certain cases (e.g., when required by law or when third parties conduct services on behalf of Google), Google may transfer the information to third parties. For more information about Google Analytics’ privacy practices, please visit https://support.google.com/analytics/answer/6004245. If you would like to opt out from Google Analytics, you can do so by installing a Google Analytics opt-out browser add-on available at https://tools.google.com/dlpage/gaoptout?hl=en.
• Aggregated and de-identified data: In case your non-personal data is combined with certain elements of your personal data in a way that allows us to identify you, we will handle such aggregated data as personal data. If your personal data is aggregated or de-identified in a way that it can no longer be associated with an identified or identifiable natural person, it will not be considered personal data and we may use it for any business purpose.
2. HOW DO WE USE YOUR INFORMATION?
In Short: We process your information for purposes based on legitimate business interests, the fulfilment of our contract with you, compliance with our legal obligations, and/or your consent.
We use personal information collected via our Website for a variety of business purposes described below. We process your personal information for these purposes in reliance on our legitimate business interests, in order to enter into or perform a contract with you, with your consent, and/or for compliance with our legal obligations. We indicate the specific processing grounds we rely on next to each purpose listed below.
We use the information we collect or receive:
• To facilitate account creation and logon process. If you choose to link your account with us to a third-party account (such as your Google account), we use the information you allowed us to collect from those third parties to facilitate account creation and logon process for the performance of the contract. See the section below headed "HOW DO WE HANDLE YOUR SOCIAL LOGINS?" for further information.
• To post testimonials. We post testimonials on our Website that may contain personal information. Prior to posting a testimonial, we will obtain your consent to use your name and the content of the testimonial. If you wish to update, or delete your testimonial, please contact us at firstname.lastname@example.org and be sure to include your name, testimonial location, and contact information.
• Request feedback. We may use your information to request feedback and to contact you about your use of our Website.
• To enable user-to-user communications. We may use your information in order to enable user-to-user communications with each user's consent.
• To manage user accounts. We may use your information for the purposes of managing our account and keeping it in working order.
• To send administrative information to you. We may use your personal information to send you product, service and new feature information and/or information about changes to our terms, conditions, and policies.
• To protect our Services. We may use your information as part of our efforts to keep our Website safe and secure (for example, for fraud monitoring and prevention).
• To enforce our terms, conditions and policies for business purposes, to comply with legal and regulatory requirements or in connection with our contract.
• To respond to legal requests and prevent harm. If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond.
• To send you marketing and promotional communications. We and/or our third-party marketing partners may use the personal information you send to us for our marketing purposes, if this is in accordance with your marketing preferences.
• Deliver targeted advertising to you. We may use your information to develop and display personalized content and advertising (and work with third parties who do so) tailored to your interests and/or location and to measure its effectiveness. If the applicable laws requires, we will obtain your prior consent for such targeted advertising.
3. WILL YOUR INFORMATION BE SHARED WITH ANYONE?
In Short: We only share information with your consent, to comply with laws, to provide you with services, to protect your rights, or to fulfill business obligations.
We may process or share your data that we hold based on the following legal basis:
• Consent: We may process your data if you have given us specific consent to use your personal information for a specific purpose.
• Legitimate Interests: We may process your data when it is reasonably necessary to achieve our legitimate business interests.
• Performance of a Contract: Where we have entered into a contract with you, we may process your personal information to fulfill the terms of our contract.
• Legal Obligations: We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).
• Vital Interests: We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.More specifically, we may need to process your data or share your personal information in the following situations:
• Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
• Vendors, Consultants and Other Third-Party Service Providers. We may share your data with third-party vendors, service providers, contractors or agents who perform services for us or on our behalf and require access to such information to do that work. Examples include: payment processing, data analysis, email delivery, hosting services, customer service and marketing efforts. We may allow selected third parties to use tracking technology on the Website, which will enable them to collect data on our behalf about how you interact with our Website over time. This information may be used to, among other things, analyze and track data, determine the popularity of certain content, pages or features, and better understand online activity. We do not share, sell, rent or trade any of your information with third parties for their promotional purposes.
• Third-Party Advertisers. We may use third-party advertising companies to serve ads when you visit or use the Website. These companies may use information about your visits to our Website(s) and other websites that are contained in web cookies and other tracking technologies in order to provide advertisements about goods and services of interest to you.
4. WHO WILL YOUR INFORMATION BE SHARED WITH?
In Short: We only share and disclose your information with the following third parties that agree to ensure an adequate level of protection to your personal data. If we have processed your data based on your consent and you wish to revoke your consent, please contact us using the contact details provided in the section below titled "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?".
• Advertising, Direct Marketing, and Lead Generation
Crisp, Sendinblue and Mailchimp
• Allow Users to Connect to Their Third-Party Accounts
• Cloud Computing Services
• Communicate and Chat with Users
• Data Backup and Security
• Functionality and Infrastructure Optimization
• Invoice and Billing
• Retargeting Platforms
Facebook Custom Audience and Google Ads Remarketing
• Social Media Sharing and Advertising
LinkedIn social plugins, Facebook social plugins and Twitter social plugins
• User Account Registration and Authentication
• Web and Mobile Analytics
• Website Performance Monitoring
• Video hosting
5. HOW DO WE HANDLE YOUR SOCIAL LOGINS?
In Short: If you choose to register or log in to our services using a social media account, we may have access to certain information about you.
Our Website offers you the ability to register and login using your third-party social media account details (like your Google logins). Where you choose to do this, we will receive certain profile information about you from your social media provider. The profile information we receive may vary depending on the social media provider concerned, but will often include your name, email address, friends list, profile picture as well as other information you choose to make public on such social media platform.
We will use the information we receive only for the purposes that are described in this privacy notice or that are otherwise made clear to you on the relevant Website. Please note that we do not control, and are not responsible for, other uses of your personal information by your third-party social media provider. We recommend that you review their privacy notice to understand how they collect, use and share your personal information, and how you can set your privacy preferences on their sites and apps.
6. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?
In Short: We may transfer, store, and process your information in countries other than your own.
Our servers are located in France. If you are accessing our Website from outside France, please be aware that your information may be transferred to, stored, and processed by us in our facilities and by those third parties with whom we may share your personal information (see "WILL YOUR INFORMATION BE SHARED WITH ANYONE?" above), in France, and other countries.
If you are a resident in the European Economic Area (EEA) or United Kingdom (UK), then these countries may not necessarily have data protection laws or other similar laws as comprehensive as those in your country. We will however take all necessary measures to protect your personal information in accordance with this privacy notice and applicable law. In case it is necessary to make an international transfer from the EEA or UK, we will make sure that the jurisdiction in which the recipient third party is located guarantees an adequate level of protection for your personal data or we conclude an agreement with the respective third party that ensures such protection (e.g., a data processing agreement based pre-approved standard contractual clauses).
7. HOW LONG DO WE KEEP YOUR INFORMATION?
In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this privacy notice unless otherwise required by law.
We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements). No purpose in this notice will require us keeping your personal information for longer than the period of time in which users have an account with us.
When we have no ongoing legitimate business need to process your personal information, we will either securely delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
8. DO WE COLLECT INFORMATION FROM MINORS?
In Short: We do not knowingly collect data from or market to children under 18 years of age.
We do not knowingly solicit data from or market to children under 18 years of age. By using the Website, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Website. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at email@example.com.
9. WHAT ARE YOUR PRIVACY RIGHTS?
In Short: In some regions, such as the European Economic Area (EEA) and United Kingdom (UK), you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time.
In some regions (like the EEA and UK), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; and (iv) if applicable, to data portability. In certain circumstances, you may also have the right to object to the processing of your personal information. To make such a request, please use the contact details provided in section 12 of this privacy notice. We will process your request within 30 calendar days and act upon any request in accordance with applicable data protection laws.
If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time. Please note however that this will not affect the lawfulness of the processing before its withdrawal, nor will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.
If you are a resident in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: https://ec.europa.eu/justice/data- protection/bodies/authorities/index_en.htm. Information about the UK Information Commissioner’s Office is available at https://ico.org.uk.
If you are a resident in Switzerland, the contact details for the data protection authorities are available here: https://www.edoeb.admin.ch/edoeb/en/home.html.
Requests regarding the Service Data. If we receive a request from a data subject asking to exercise data subject’s rights with regard to the Service Data, we will forward such a request to the respective data controller (our client).
If you would at any time like to review or change the information in your account or terminate your account, you can contact us using the contact information provided.
Opting out of email marketing
If you receive our email marketing, you can unsubscribe from our marketing email list at any time by clicking on the unsubscribe link in the emails that we send or by contacting us using the details provided below. You will then be removed from the marketing email list — however, we may still communicate with you, for example to send you service-related emails that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes.
10. CONTROLS FOR DO-NOT-TRACK FEATURES
Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.
11. DO WE MAKE UPDATES TO THIS NOTICE?
In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.
We may update this privacy notice from time to time. The updated version will be indicated by an updated "Revised" date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.
12. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
If you have questions or comments about this notice, you may email us at firstname.lastname@example.org or by post to:
1A allée du Grand Cerf,
59910, Bondues, France