Privacy Policy

PRIVACY POLICY

 

Your privacy is important to us. This privacy notice discloses the privacy practices for the services VHT provides, including at www.getmindful.com, www.vhtcx.com, and www.surveydynamix.com. This policy explains how VHT uses the personal data we collect from you when you use our websites and data, we obtain from you when you use VHT services (directly or through our partners), as well as your California Privacy Rights and your General Data Protection Regulation (GDPR) rights.

Collected information:

This notice applies to all personal information collected or submitted on the VHT websites. We are the sole owners of the information collected on this website, and we will not sell or rent this information, or share it with any third party outside of our organization other than as described in this policy. On some pages, you may request information or register to receive materials.

This notice also applies to personal information collected or submitted to VHT by our partners in the course of using VHT services. We do not sell or rent this information. When we obtain your information on behalf of a partner – for example, when you schedule a digital callback on our partner’s website through our embeddable web widget – we may share that information with our partner. When obtaining personal information from our partners, we follow their written instructions to process the information.

In the past 12 months, we have collected the following types of information:

  • Company
  • Name
  • Title
  • Country
  • Address
  • Email address
  • Phone number
  • IP address
  • Age
  • Date of birth
  • Your preferences and/or opinions
  • Information you provide to us through customer surveys
  • Details of products and services we have provided to you and/or that you have inquired about, and our response to you
  • Your browser session and geolocation data, device and network information, statistics on page views and sessions, acquisition sources, search queries and/or browsing behavior
  • Information about your access and use of our websites, including through the use of Internet cookies, your communications with our websites, the type of browser you are using, the type of operating system you are using and the domain name of your Internet service provider
  • Additional personal information that you provide to us, directly or indirectly, through your use of our websites, associated applications, associated social media platforms and/or accounts from which you permit us to collect information
  • Any other personal information requested by us and/or provided by you or a third party.

We may use non-identifying and aggregate information to better design our website and to share with partners. For example, we may tell a partner that X number of individuals visited a certain area on our website, or that Y number of men and Z number of women filled out our registration form, but we never disclose anything that could be used to identify those individuals.

Disclosure of personal information to third parties

We allow our clients access to personal information that they have stored through our services. Access to personal information stored by our customers through the services is only available to nominated users of that customer. A representative of the customer will be responsible for creating users and applying the security access profile. Passwords are encrypted when stored in our database.

We use return email addresses to answer the email we receive; such addresses are not shared with outside parties.

Unless you ask us not to, we may contact you via email in the future to tell you about new products/features or changes to this privacy policy.

We may disclose personal information to:

  • third party service providers, agents, and subcontractors for the purpose of enabling them to provide their services, including (without limitation) IT service providers, data storage, email delivery, web-hosting and server providers, debt collectors, maintenance or problem-solving providers, speech transcription, professional advisors and payment systems operators;
  • our employees, contractors and/or related entities;
  • our existing or potential agents or business partners;
  • anyone to whom our business or assets (or any part of them) are, or may (in good faith) be, transferred;
  • credit reporting agencies, courts, tribunals and regulatory authorities, in the event you fail to pay for goods or services we have provided to you;
  • courts, tribunals, regulatory authorities and law enforcement officers, as required or permitted by law, in connection with any actual or prospective legal proceedings, or in order to establish, exercise or defend our legal rights or property; and
  • when we believe it is necessary to prevent, investigate, or address possible illegal activities, including fraud, a violation of our Terms of Use, a violation of this Policy, or a threat to the physical safety of any person.

When we refer to ‘process’ in this clause and this Privacy Policy in general, we mean any operation or set of operations which is performed on personal information, whether by automated means, such as collecting, recording, organizing, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available personal information.

By providing us with personal information, you consent to the disclosure of your personal information to third parties who reside outside Australia and, if you are an individual located in the UK or EU, to third parties that reside outside the UK or EU.

Where the disclosure of your personal information is solely subject to Australian privacy laws (and not subject to the Data Protection Act or GDPR), you acknowledge that some third parties may not be regulated by the Privacy Act and the Australian Privacy Principles in the Privacy Act and if any such third party engages in any act or practice that contravenes the Australian Privacy Principles, it would not be accountable under the Privacy Act and you will not be able to seek redress under the Privacy Act.

Where the disclosure of your personal information is subject to Data Protection Act or GDPR, you acknowledge that there are risks if the third party outside the UK or EU engages in any act or practice that would contravene the Data Protection Act or GDPR and where there is no adequacy decision in place with the country outside the UK or EU or appropriate safeguards in place with the third party.

How we treat personal information that is also sensitive information

Sensitive information is a sub-set of personal information that is given a higher level of protection under the Australian Privacy Principles. Sensitive information means information relating to your racial or ethnic origin, political opinions, religion, trade union or other professional associations or memberships, philosophical beliefs, sexual orientation, sexual practices or sex life, criminal records, health information or biometric information.

Our clients have complete control regarding the language and type of survey questions asked, which means that our clients may ask questions which will disclose what is considered sensitive information.

While we do not actively collect sensitive information, in the event that our clients do pose questions which result in the disclosure of sensitive information, we will keep that information secure.

Sensitive information may also be used or disclosed if required or authorized by law.

Cookies and web beacons

We may use cookies on our websites from time to time. Cookies are text files placed in your computer’s browser to store your preferences. Cookies, by themselves, do not tell us your email address or other personally identifiable information. However, they do allow third parties, such as Google and Facebook, to cause our advertisements to appear on your social media and online media feeds as part of our retargeting campaigns. If and when you choose to provide our websites with personal information, this information may be linked to the data stored in the cookie.

We use the following cookies:

  • Strictly necessary cookies. These are cookies that are required for the operation of our websites. They include, for example, cookies that enable you to log into secure areas of our websites, use a shopping cart or make use of e-billing services.
  • Functionality cookies. These are used to recognize you when you return to our websites. This enables us to personalize our content for you and remember your preferences (for example, your choice of language or region).
  • Targeting cookies. These may be set through our site by our advertising partners. They can be used by these third parties to build a profile of your interests based on the browsing information they collect from you, which includes uniquely identifying your browser and terminal equipment.
  • Analytics cookies. These cookies allow us and our partners to count visits and traffic sources, so we can measure and improve the performance of our site. They help us know which pages are the most and least popular and see how visitors move around the site. All information these cookies collect is aggregated and therefore anonymous.

How we treat personal information that is also sensitive information

Sensitive information is a sub-set of personal information that is given a higher level of protection under the Australian Privacy Principles. Sensitive information means information relating to your racial or ethnic origin, political opinions, religion, trade union or other professional associations or memberships, philosophical beliefs, sexual orientation, sexual practices or sex life, criminal records, health information or biometric information. 

Our clients have complete control in regards to the language and type of survey questions asked, which means that our clients may ask questions which will disclose what is considered sensitive information.

While we do not actively collect sensitive information, in the event that our clients do pose questions which result in the disclose of sensitive information, we will keep that information secure.

Sensitive information may also be used or disclosed if required or authorised by law. 

Security

To prevent unauthorized access, maintain data accuracy, and ensure the correct use of information, we have the appropriate physical, electronic, and managerial procedures in place to safeguard and secure the information we collect online.

We cannot guarantee the security of any information that is transmitted to or by us over the Internet. The transmission and exchange of information is carried out at your own risk. Although we take measures to safeguard against unauthorized disclosures of information, we cannot assure you that the personal information we collect will not be disclosed in a manner that is inconsistent with this Privacy Policy.

Links to other websites

Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over other websites. Therefore, we cannot be responsible for the protection and privacy of any information that you provide while visiting these sites, and such sites are not governed by this privacy statement.

You should exercise caution and look at the privacy statement applicable to the website in question.

Children’s Privacy 

VHT’s websites and services are not intended for use by children, including those under the age of 13. VHT does not sell the personal information of consumers, including consumers under 16 years of age.

How to Contact Us

If you have any questions about our privacy policies, would like to correct factual errors, or if you would like to be removed from our database, please email us at to vhtcompliance@vhtcx.com. To protect your privacy and security, we may take reasonable steps to verify your identity before making any corrections or deletions.

 

Your California Privacy Rights

California residents have the right to know about the personal information we collect, disclose, sell, or share which is discussed above. California residents also have the right to request that VHT disclose the personal information we collect, use, disclose and sell. The terms in this Your California Privacy Rights section shall have the same meaning as they do in the California Consumer Privacy Act of 2018 (CCPA), as amended by the California Privacy Rights Act of 2020.

Access. California residents may request the categories of personal information we have collected about them, the categories of sources from which the personal information is collected, the business or commercial purpose for collecting or selling personal information, the categories of third parties with whom we share personal information, and the specific pieces of personal information we have collected about them.

Deletion. California residents may request that VHT delete personal information VHT has collected from the consumer. In response to such a request, and upon verification of the requesting party’s identity, VHT will deidentify the personal information as permitted by law.

Correction. California residents may request that VHT correct inaccurate personal information VHT has collected about the consumer. We will take reasonable steps to correct any information found to be inaccurate, incomplete, misleading or out of date.

Opt-Out of Sale or Sharing of Personal Information. California residents have the right to opt out of the sale or sharing of their personal information. VHT does not sell or share personal information other than as described herein.

Non-Discrimination. California residents have the right not to receive discriminatory treatment by VHT for the exercise of the privacy rights conferred by the CCPA.

If you would like to make a request to exercise a California right, please send an email to vhtcompliance@vhtcx.com or call us at 866-670-2223. To protect your privacy and security, we may take reasonable steps to verify your identity before we can fulfill it, including those submitted by your authorized agent. When you submit a California-Rights request with relevant personal information, VHT shall:

(i) reasonably respond to your request; and
(ii) promptly fulfill your request or, in cases where VHT denies such a request, offer an explanation for the denial.

Your European Privacy Rights

If you reside in a jurisdiction that has adopted the General Data Protection Regulation (GDPR), such as the EU or UK, you are entitled to the following:

Access. You may request copies of your personal data. We may charge you a small fee for this.

Correction. You may request that VHT correct any information you believe is inaccurate. You also have the right to request VHT to complete information you believe is incomplete.

Erasure. You may request that VHT erase your personal data, under certain conditions.

To restrict processing. You may request that VHT restrict the processing of your personal data, under certain conditions.

To object to processing. You may object to VHT’s processing of your personal data, under certain conditions.

Data portability. You may request that VHT transfer the data that we have collected to another organization, or directly to you, under certain conditions.

EU Representative.
We have appointed IT Governance Europe Limited to act as our EU Representative. If you wish to exercise your rights under the EU General Data Protection Regulation (GDPR), or have any queries in relation to your rights or privacy matters generally please email our Representative at eurep@itgovernance.eu or post your request or query to:

EU Representative, IT Governance Europe, Third Floor, The Boyne Tower, Bull Ring, Lagavooren, Drogheda, Co. Louth, A92 F682

When contacting our Representative please ensure you include our company name in any correspondence you.

UK Representative.
We have appointed GRCI Law Limited to act as our UK Representative. If you wish to exercise your rights under the UK General Data Protection Regulation (GDPR), or have any queries in relation to your rights or privacy matters generally please email our Representative at ukrep@grcilaw.com or post your request or query to:

UK Representative, Unit 3, Clive Court, Bartholomew’s Walk, Cambridgeshire Business, Park, Ely, Cambridgeshire, CB7 4EA, UK

When contacting our Representative please ensure you include our company name in any correspondence.
Last Updated: March 11, 2022

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