This policy describes the information collection, use, and dissemination practices of Virtual Digital Expo, (“Virtual Digital Expo”) and applies to Virtual Digital Expo’s collection, use, storage and disclosure of information by Virtual Digital Expo on its (a) websites, including all its divisions, subsidiaries and related companies (collectively, the “Websites”), (b) on various Third Party websites, and (c) to Virtual Digital Expo ‘s other information collection, including the purchase of customer lists from Third Parties. Virtual Digital Expo is not responsible for the information collection or privacy practices of Third Party websites or applications.
CALIFORNIA RESIDENTS PRIVACY RIGHTS
Companies that collect personally identifiable information (“PII”) from California residents and disclose such information to Third Parties (including affiliated entities) for marketing purposes must, in response to a request by a consumer, either (1) provide a list detailing the categories of information shared and the entities to which such information was provided, or (2) provide a mechanism by which a consumer may opt-out of having their information shared with Third Parties. We have elected the second option and you may request that your PII not be shared with Third Parties by sending your request, including your full name, email address and postal address to: Virtual Digital Expo, 7500 W. Lake Mead Blvd., #9-463, Las Vegas, NV 89128. In accordance with California Civil Code Sec. 1789.3, California resident users are entitled to know that they may file grievances and complaints with California Department of Consumer Affairs, 400 R Street, Suite 1080, Sacramento, CA 95814; or by phone at 916-445-1254 or 800-952-5210; or by email to firstname.lastname@example.org
THE INFORMATION COLLECTION, USE AND DISSEMINATION PRACTICES OF
Virtual Digital Expo.
1. Collection of Information.
1.1 Survey Information
Virtual Digital Expo collects information from individuals by various methods, including, but not limited to, when an individual voluntarily completes a survey, order form, or a registration page either online or offline, or by means of online or offline surveys, order forms, or registration pages operated by Third Parties (collectively, a “Survey”). (As used herein, “online” means using the Internet, including the Websites, and related technologies, and “offline” means by methods other than online, including in person, in the postal mail, using telephones and cell phones, and other similar means.) In the Surveys, Virtual Digital Expo or a Third Party (a “Third Party”) may ask an individual to provide various information to Virtual Digital Expo, which may include his or her name, email address, street address, zip code, telephone numbers (including cell phone numbers and carriers), birth date, gender, salary range, education and marital status, occupation, social security number, employment information, personal and online interests, and such other information as may be requested from time to time (together, “Survey Information”). Virtual Digital Expo may also collect information concerning an individual from another source and uses that information in combination with information provided from this web site. Completing the Surveys is completely voluntary, and individuals are under no obligation to provide Survey Information to Virtual Digital Expo or Third Party, but an individual may receive incentives from Virtual Digital Expo or a Third Party in exchange for providing Survey Information to Virtual Digital Expo.
1.2 Site Membership or Registration
“Subscription” occurs when an end-user registers for Virtual Digital Expo’s and/or Third Party Advertisers’ services, either via registration at our website, via co-registration at a marketing partner’s website, or via a permission pass / opt-out / no-opt mailing Virtual Digital Expo collects personally identifiable information about our subscribers, based on: information gathered at the time of registration, subscriber interaction and response to subsequent electronic mailings and website use, information provided by marketing partners, and information appended from data aggregators. Information collected may include, but is not necessarily limited to: name, email address, postal address, gender, birth date, telephone number, activity, interests, user behavior and other demographic information. This information enables us to better tailor our content to subscribers’ needs and to help our clients to promote and sell their products and services.
1.3 Third Party List Information
Virtual Digital Expo collects information from individuals when an individual provides information to a Third Party and Virtual Digital Expo subsequently purchases, licenses, or otherwise acquires the information from the Third Party (the “Seller”). Such purchased information may include, but is not limited to, an individual’s name, email address, street address, zip code, telephone numbers (including cell phone numbers and carriers), birth date, gender, salary range, education and marital status, occupation, industry of employment, personal and online interests, and such other information as the individual may have provided to the Seller (together, “Third Party List Information”). When acquiring Third Party List Information, Virtual Digital Expo seeks assurances from the Seller that the Seller has a right to transfer the Third Party List Information to Virtual Digital Expo and that the Seller has a right to provide offers from Advertisers to the individuals whose personal information is included on the Seller’s list.
1.4 Other Information.
Other occasions when Virtual Digital Expo obtains information from individuals include (1) when an individual is making a claim for a prize or seeking to redeem an incentive offered by Virtual Digital Expo or by a Third Party, (2) when an individual requests assistance through Virtual Digital Expo’s customer service department, (3) when an individual voluntarily subscribes to a service or newsletter; (4) when private information is provided by means of a referral by a third party to Virtual Digital Expo or a Third Party Advertiser (together, “Other Information”).
1.5 Cookies, Web Beacons, and Other Info Collected using Technology.
Virtual Digital Expo currently uses cookie and web beacon technology to associate certain Internet-related information about an individual with information about the individual in our database. Additionally, Virtual Digital Expo may use other new and evolving sources of information in the future (together, “Technology Information”).
1.6 Outside Information
Virtual Digital Expo may receive information about individuals from Third Parties or from other sources of information outside of Virtual Digital Expo including information located in public databases (“Outside Information”).
1.7 Individual Information
As used herein, Individual Information means Survey Information, Third Party List Information, Other Information, Technology Information, and Outside Information, and any other information Virtual Digital Expo gathers or receives about individuals.
1.8 No Information Collected from Children.
Virtual Digital Expo will never knowingly collect any personal information about children under the age of 18. If Virtual Digital Expo obtains actual knowledge that it has collected personal information about a child under the age of 18, that information will be immediately deleted from our database. Because it does not collect such information, Virtual Digital Expo has no such information to use or to disclose to Third Parties. Virtual Digital Expo has designed this policy in order to comply with the Children’s Online Privacy Protection Act (“COPPA”).
1.9 Credit Card Information.
Virtual Digital Expo may in certain cases collect credit card numbers and related information, such as the expiration date of the card (“Credit Card Information”) when an individual places an order from Virtual Digital Expo. When the Credit Card Information is submitted to Virtual Digital Expo, such information is encrypted and is protected with SSL encryption software. Virtual Digital Expo will use the Credit Card Information for purposes of processing and completing the purchase transaction, and the Credit Card Information will be disclosed to Third Parties only as necessary to complete the purchase transaction. Although Virtual Digital Expo takes all commercially reasonable action to protect Credit Card Information, you ultimately assume the risk of any damage or loss as a result of transmitting such information to Virtual Digital Expo, including but not limited to, identify theft, credit card fraud or credit card loss.
1.10 Links to External Websites.
2. Use of Individual Information.
2.1 Discretion of Information.
THE COMPANY MAY USE INDIVIDUAL INFORMATION FOR ANY LEGALLY PERMISSIBLE PURPOSE IN COMPANY’S SOLE DISCRETION. The following paragraphs in Section 2 describe how Virtual Digital Expo currently uses Individual Information, but Virtual Digital Expo may change or broaden its use at any time. As noted below, Virtual Digital Expo may update this policy from time to time. Virtual Digital Expo may use Individual Information to provide promotional offers to individuals by means of email advertising, telephone marketing, direct mail marketing, online banner advertising, and package stuffers, among other possible uses.
2.2 Email and Unsubscribe Policy.
Virtual Digital Expo uses Individual Information to provide promotional offers by email to individuals. Virtual Digital Expo may maintain separate email lists for different purposes. If email recipients wish to end their email subscription from a particular list, they need to follow the instructions at the end of each email message to unsubscribe from the particular list. To unsubscribe from all Virtual Digital Expo’s email lists, a person must send an email to email@example.com.
Virtual Digital Expo’s unsubscribe process impacts only the future delivery of electronic mailings disseminated by Virtual Digital Expo on its own behalf. You may still receive electronic mailings sent on behalf of Third Parties and your personal information may still be shared with Third Parties for use in offline marketing and data appends, including email appends.
You should also note that unsubscribing from Virtual Digital Expo’s electronic mailings will not automatically unsubscribe the subscriber’s information from any Third Party associates and licensees of the data. Since Third Party associates and licensee partners maintain separate databases from Virtual Digital Expo, and you will need to unsubscribe from each source individually, if desired. This allows you the freedom to pick and choose which subscriptions to maintain and which to discontinue.
2.3 Content of Email Messages.
In certain commercial email messages sent by Virtual Digital Expo, an Advertiser’s name will appear in the “From:” line but hitting the “Reply” button will cause a reply email to be sent to Virtual Digital Expo. The “Subject:” line of Virtual Digital Expo email messages will usually contain a line provided from the Advertiser to Virtual Digital Expo.
2.4 Solicited Email.
Virtual Digital Expo only sends email to individuals who have agreed on the Websites to receive email from Virtual Digital Expo or to individuals who have agreed on Third Party websites to receive email from Third Parties. As such Virtual Digital Expo does not send unsolicited email messages. As a result, statutes requiring certain formatting for unsolicited email are not applicable to Virtual Digital Expo’s email messages.
2.5 Targeted Advertising.
Virtual Digital Expo uses Individual Information to target advertising to an individual. When an individual is using the Internet, Virtual Digital Expo uses Technology Information (see also Section 2.7 below) to associate an individual with that person’s Individual Information, and Virtual Digital Expo attempts to show advertising for products and services in which the person has expressed an interest in the Surveys, indicated an interest by means of Technology Information, and otherwise. Virtual Digital Expo may, at its discretion, target advertising by using email, direct mail, telephones, cell phones, and other means of communication to provide promotional offers.
2.6 Direct Mail and Telemarketing.
Virtual Digital Expo uses Individual Information to advertise, directly or indirectly, to individuals using direct mail marketing or telemarketing using telephones and cell phones.
2.7 Use of Technology Information.
Virtual Digital Expo uses Technology Information (1) to match a person’s Survey Information and Third Party List Information to other categories of Individual Information to make and improve profiles of individuals, (2) to track a person’s online browsing habits on the Internet, (3) to determine which areas of Virtual Digital Expo’s websites are most frequently visited. This information helps Virtual Digital Expo to better understand the online habits of individuals so that Virtual Digital Expo can target advertising and promotions to them.
2.8 Profiles of Individuals.
Virtual Digital Expo uses Individual Information to make a profile of an individual. A profile can be created by combining Survey Information and Third Party List Information with other sources of Individual Information such as behavioral and other information obtained from public databases. Virtual Digital Expo may also publish personal information in the form of a testimonial if such information is sent to Virtual Digital Expo by you.
2.9 Storage of Individual Information.
Virtual Digital Expo stores the Individual Information in a database on our computers. Our computers have security measures (such as a firewall) in place to protect against the loss, misuse, and alteration of the information under Virtual Digital Expo’s control. Not withstanding such measures, Virtual Digital Expo cannot guarantee that its security measures will prevent our computers from being illegally accessed, and the Individual Information on them stolen or altered.
3. Dissemination of Individual Information.
3.1 Sale or Transfer to Third Parties.
Virtual Digital Expo MAY SELL OR TRANSFER INDIVIDUAL INFORMATION TO THIRD PARTIES FOR ANY PURPOSE IN Virtual Digital Expo’S SOLE DISCRETION.
3.2 Order Fulfillment.
Virtual Digital Expo will transfer Individual Information to Third Parties when necessary to provide a product or service that a person orders from such Third Party while using Virtual Digital Expo websites or when responding to offers provided by Virtual Digital Expo.
3.3 Legal Process.
Virtual Digital Expo may disclose Individual Information to respond to subpoenas, court orders, and other legal processes.
3.4 Summary Data.
Virtual Digital Expo may sell or transfer non-individualized information, such as summary or aggregated anonymous information about all persons or sub-groups of persons.
Individuals have access to their Individual Information collected to provide an opportunity for an individual to correct, amend, or delete such information. Access can be obtained by contacting firstname.lastname@example.org. Virtual Digital Expo may also grant advertising clients and email services providers’ access to an individual’s email address to verify the origin of the Individual Information collected.
4. Privacy Practices of Third Parties.
4.1 Advertiser cookies and web beacons.
Advertising agencies, advertising networks, and other companies (together, “Advertisers”) who place advertisements on the Websites and on the Internet generally may use their own cookies, web beacons, and other technology to collect information about individuals. Virtual Digital Expo does not control Advertisers’ use of such technology and Virtual Digital Expo has no responsibility for the use of such technology to gather information about individuals.
The Websites and email messages sometimes contain hypertext links to the websites of Third Parties. Virtual Digital Expo is not responsible for the privacy practices or the content of such other websites. Linked websites may contain links to websites maintained by Third Parties. Such links are provided for your convenience and reference only. Virtual Digital Expo does not operate or control in any respect any information, software, products or services available on such Third Party websites. The inclusion of a link to a web site does not imply any endorsement of the services or the site, its contents, or its sponsoring organization.
4.3 Affiliated Companies.
Virtual Digital Expo may disclose, transfer, and sell Individual Information to entities affiliated with Virtual Digital Expo in Virtual Digital Expo’s discretion.
5. Unsubscribe Procedures.
If you wish to discontinue receiving email messages from Virtual Digital Expo, you have several options:
Unsubscribe from one email list.
Collection of your Personal Information
Our website, available at the domain name upon which this Notice appears (“Site”) provides a service intended to direct users, who complete an enquiry through our Site or related online platforms, to a service provider that may be able to assist them with a particular type of claim (“Service Providers”).
As the purpose of our Site is to direct you to an appropriate Service Provider, the information that you complete will be passed on in this way; you can be assured that with all third parties necessary to operate our business, we or where relevant Virtual Digital Expo, have adopted approved model data protection clauses in our arrangements with them, to ensure they meet the same high standards required in relation to the processing of your personal information under applicable data protection laws.
You have a choice whether to provide any information to us, except where this is necessary to fulfil any contract – such as in relation to the provision of our services (albeit recognising that such a decision may mean that we are unable to provide our services as you expect), or where we are required to do so by applicable law or a Government agency or law enforcement.
The purpose of our service is to help direct you to a relevant Service Provider for your needs. Virtual Digital Expo assists us in this respect and where a suitable provider is identified, your information will be transferred securely to that relevant Service Provider.
We may on occasion have the need to transfer your data to suppliers located outside of the European Economic Area (“EEA”), including in the USA. We will only do so where the legal regimes of those territories outside of the EEA offer an equivalent standard of data protection to our own.
Our Data Protection Obligations
All information provided to us through this Site will be treated as confidential and we will not abuse this trust by providing all or any part of your information to others, except for Service Providers, unless you have consented to this or where this is in our legitimate interests, further outlined below. Except as outlined above, your information will not be sold, licensed, loaned or otherwise distributed to any other organisation unless we are required to do so by applicable law. Subject to any overriding obligation to which we are subject, you have the right to object to the processing of your personal information, by a simple request that we stop such processing.
Why we Process your Personal Information
Our use of your personal information will at all times be in accordance with applicable data protection laws; we rely on the following grounds justifying our processing of personal data:
Where information is obtained through or as a result of your use of our Site, we will only use this information for the following purposes:
Managing Your Preferences
You have the right to manage your preferences in relation to the kinds of information that we collect and the manner in which your information is processed – you can update these preferences at any time through our site; you can also withdraw your consent, either as a whole or in relation to particular kinds of information or delivery methods.
You may ask us to erase information that we hold about you, except where there is some other reason requiring us to maintain the information, such as for insurance purposes, for example. We monitor and will also delete information and data that we hold, where we reasonably consider this no longer to be required.
If you have accepted the relevant cookies, we may collect, store and process non-personal information about you automatically as a result of your use of this site, such as the type of internet or mobile browser that you are using to gain access and any website from which you linked to us, but you cannot be identified from this information. We will only use such non-personal information to help provide an effective and more relevant website offering.
Under GDPR (which, in this Privacy Notice, means EU Data Protection Regulation 2016/679 and laws implementing or supplementing GDPR as the data protection or privacy laws of any other country), the nature of the processing that we undertake does not require us to appoint a formal Data Protection Officer (DPO); however, we may maintain equivalent standards and the nominated representative for the purposes of compliance with our data protection obligations is our founder/owner.
Technical and Organisational Measures and Security
The protection of our clients’ personal information is important to us and therefore we have and maintain appropriate technical and organisational measures to achieve these aims. These seek to protect personal information that we process from and against unauthorised or unlawful use, or accidental loss, damage or destruction and we review these measures, on a regular basis to ensure that they are appropriate.
These include encrypted access to our systems, only accessible by our personnel, utilising secure and regularly-updated passwords and access to and processing of information though our site, using secure HTTPS. We do not however process any bank or card details through our site; instead using an established third party provider to take payments online.
In relation to data security, you accept the risk that data transmitted to us through this site via electronic means may be intercepted before reaching us or may be accessed by unauthorised third parties, or exploited unlawfully. We do not assume any responsibility for guarding against the acts of third parties and shall not be liable for any direct, indirect or consequential losses or damages incurred or suffered as a result.
Sharing your Personal Information
We will never share your personal information with others for commercial gain or in ways that you would not reasonably expect of us.
Although we will share the personal information provided through our Site to relevant Service Providers and others, as explained above, we will not share your personal information with anyone else, unless we have your explicit consent to do so or where we have a legal obligation to do so.
In addition, we may process your information where we are required or permitted to do so under applicable law, where required to do so by any Government agency or law enforcement, where it is necessary in connection with the sale or potential sale of our business or where we conclude that we have and can show one or more legitimate interests for doing so.
Linking to Other Sites
To add value to visitors’ experiences when using this Site, we may provide links to other websites or resources for you to access at your sole discretion, but you agree that we shall not be responsible or liable to you in respect of the availability or content of, or consequences of you linking to, any such external site; although we welcome links to this Site, we shall be entitled to demand that such links are broken if we consider the content or nature of the linking site to be unsuitable or unprofessional, as we see fit.
How long we Store Personal Data
We maintain the data that we collect in providing our services only for a limited time, to fulfil our obligation to send your enquiry data to Virtual Digital Expo, for the purposes of selecting relevant Service Providers, after which our need to use and process your personal data is completed; following this processing, your data will generally be erased or securely destroyed within a relatively short period of time, unless we determine that there is a legitimate interest in holding such data for longer.
Where we are able to fulfil a request to delete and erase your personal information, we will fulfil that request, unless there is some other obligation to which we are subject requiring us to retain your data, in which case we will retain it only for so long as is necessary to meet that other legal obligation.
Your Rights and how to Exercise Them
You may request a copy of the information that we hold about you (known as a Subject Access Request). In addition, under the GDPR, you may exercise the following rights:
Please contact us via a simple request, where you wish to exercise any of your above rights or if you wish to file a complaint about our collection, processing or use of your personal information.
Right to Object to Processing
Whatever justification we rely on, under GDPR you have a right to object to our processing of your personal information, unless we have a separate legal or regulatory obligation to do so, in which case our processing will only be limited to the extent to which we need to process your information. However, except for this, you may confirm your objection to the extent and kinds of processing being undertaken, by sending us a simple request, updating your preferences.
Your Information and Keeping it Up-to-Date
You have the right to request details of the information that we hold about you. Should you wish to be provided with these details, please contact us with a simple request. We wish to keep any information that we hold about you accurate and up to date and therefore please contact us if the information we hold about you needs updating. If you have any questions or concerns regarding your privacy, or if you experience difficulties in accessing or viewing this Site, please contact us using the details mentioned above.
Changes to this Privacy Notice
We may change or modify this Privacy Notice at any time and we recommend that you check the latest version of this notice each time that you access the Site. The date of the most recent update will appear below. Any significant changes to this notice may be confirmed through direct communication with you, where we consider that such changes should specifically be brought to your attention.