VitalSmarts, L.C., a member of the TwentyEighty, Inc. family of companies, is committed to protecting the privacy of those who visit our websites and with whom we do business. As part of our normal operations, we collect different kinds of information about our website visitors. We have, however, structured our websites so that people have the option to visit without identifying themselves or revealing any personal information.
The following are things you can do while visiting our website if you prefer NOT to have information about your visit collected.
The following describes the information we collect and how that information is used to provide our visitors with the optimal online experience.
This website uses Marketo Munchkin cookies (“Marketo”). Marketo’s cookie allows us to track repeated visits to the website and link each visit to the information voluntarily provided by the visitor. For example, if the visitor is asked to provide us with name, company name and email address, we will know the identity of the visitor when they visit the site at a later date. We also use Munchkin code to track email open rates and click-through rates, allowing us to manage the email marketing experience. By using this website, you are consenting to the above use of your data.
In addition, we may use or allow third parties to serve cookies on our site – specifically we use Google Analytics and Marketo to help us monitor our website traffic and understand visitor behavior.
If you choose to provide us with your personal data, as contemplated above, in addition to using the data for the express purpose for which it was provided, we may, if permitted by applicable law, use your information to:
As a global organization offering a wide range of products and services, with business processes, management structures and technical systems that cross borders, we have implemented global policies, along with standards and procedures, for consistent protection of personal information. As a global company, we may share information about you with our subsidiaries worldwide and transfer it to countries in the world where we do business in accordance with this Privacy Notice.
Between our controlled subsidiaries, we only grant access to personal information on a need-to-know basis, necessary for the purposes for which such access is granted. In some cases, we use suppliers located in various countries to collect, use, analyze, and otherwise process personal information on our behalf.
Where appropriate, we may also share your personal information with selected partners to help us provide you, or the company you work for, products or services, or to fulfill your requests, or with your consent. When selecting our suppliers and partners, we take into account their data handling processes.
If we decide to sell, buy, merge or otherwise reorganize businesses in some countries, such a transaction may involve the disclosure of personal information to prospective or actual purchasers, or the receipt of such information from sellers. It is our practice to require appropriate protection for personal information in these types of transactions.
If you do not wish for us to use your data in the ways described above, you may follow the instructions contained in the relevant communication, update your communication preferences in your online account (if applicable), or follow the instructions below, under the heading “YOUR RIGHTS.”
Please be aware that, in certain circumstances, personal information may be subject to disclosure to government agencies pursuant to judicial proceedings, court order, or legal process. We may also share your personal information to protect our rights or property, or that of our business partners, suppliers or clients, and others when we have reasonable grounds to believe that such rights or property have been, or could be, affected.
We may place email links on this site to allow you to contact us directly via email. The information you provide is used to respond directly to your questions or comments. Those comments may be stored to improve the quality of our site and our services.
In addition, from time to time, we will purchase or rent relevant public mailing lists from reputable agencies that have obtained your prior approval to receive relevant information based on your personal preferences. Any promotional information sent to you by us will contain instructions on how to be removed from a mailing list source. We will also freely provide information about how and from whom your personal details were given to us when requested.
Our international footprint may involve the transfer of personal information between different subsidiaries, as well as to third parties located in the countries where we do business. Some countries have implemented transfer restrictions for personal information. Where required, we implement Standard Contractual Clauses approved by the EU Commission, or similar contractual clauses in other jurisdictions. This includes transfers to suppliers or other third parties.
We intend to protect your personal information and to maintain its accuracy. We implement reasonable physical, administrative and technical safeguards to help us protect your personal information from unauthorized access, use and disclosure. We also require that our suppliers protect such information from unauthorized access, use and disclosure.
We will not retain personal information longer than necessary to fulfill the purposes for which it is processed, including the security of our processing complying with legal and regulatory obligations (e.g. audit, accounting and statutory retention terms), handling disputes, and for the establishment, exercise or defense of legal claims in the countries where we do business.
Because the circumstances may vary depending on the context and the services, the information provided in Online Privacy Statement or provided in a specific notice may provide more detailed information on applicable retention terms. In the event that we process your data for marketing purposes, we will delete your data if we have not received any responses to our marketing activities for a period of three years. The deletion will occur within six months of such three-year period elapsing.
If you have a question related to this Privacy Notice, please contact us by sending an email to email@example.com. Your message should include our company name (so that we can identify which TwentyEighty company you are contacting us about) and will be forwarded to the appropriate member of our legal or compliance team.
For the purposes of the EU General Data Protection Regulation (“GDPR”), the controller of your personal information is VitalSmarts, L.C., Attn: Data Privacy Officer, 10901 W. Toller Drive, Suite 202, Littleton, Colorado 80127, United States of America.
VitalSmarts, L.C. is not the controller in situations such as personal information processed in connection with a contractual relationship. In this case, the controller of personal information is the company with which we have contracted (such as your employer) unless otherwise agreed in that contract.
You can request to access, update or correct your personal information. You also have the right to object to direct marketing. To make such a request or lodge such an objection, please send an email to firstname.lastname@example.org. Please specify our company name (so that we know which company you are contacting us about) and provide details of your request. We will contact you if we need more information to process your request.
You may have additional rights pursuant to your local law applicable to the processing. For example, if the processing of your personal information is subject to the EU General Data Protection Regulation (“GDPR”), and your personal information is processed based on legitimate interests, you have the right to object to the processing on grounds relating to your specific situation. Under GDPR you may also have the right to request to have your personal information deleted or restricted and ask for portability of your personal information. You can make these requests by sending an email to email@example.com, providing the details of your request.
In the event you consider our processing of your personal information not to be compliant with the applicable data protection laws, you can lodge a complaint directly with us by sending an email to firstname.lastname@example.org and providing specific details of the complaint, including the name of the company to which it pertains. You may also be eligible to lodge a complaint with the competent data protection authority. The names and contact details of the Data Protection Authorities in the European Union can be found at http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm.
We are concerned about the privacy of young children and do not knowingly collect any personal information from a child under the age of 13. If we learn that we have personal information on a child under the age of 13, we will delete that information from our records and systems.
We employ procedural and technical measures that are designed to help protect your personal information from loss, unauthorized access, disclosure, alteration or destruction. However, we cannot guarantee that third parties will not overcome any such measures and gain access to your information for unauthorized purposes. By using the website, you accept the risk that compromise of and unauthorized access to your information is possible. To the fullest extent permitted by law, we disclaim any warranty or guarantee that your information will be protected from misuse, appropriation, alteration, or loss.
All data submitted in our online store (if any) is submitted using secure transport technologies to provide you with the utmost in protection for your private information.
This website may contain links to other websites. Please be aware that we are not responsible for the privacy practices of such other sites. We encourage you to be aware when you leave our site and to read the privacy statements of each and every website that collects personally identifiable information. This privacy statement applies solely to information collected by this website.
We may disclose or access customer information when we believe in good faith that the law requires it, or in response to any demand by law enforcement authorities in connection with a criminal investigation or civil or administrative authorities in connection with a pending civil case or administrative investigation.
Attn: Data Privacy Officer
10901 W. Toller Drive, Suite 202
Littleton, Colorado 80127
United States of America
Please note that any requests described above to be made to email@example.com may also be made by sending a letter to the above postal address. Any such letter should include contact information – preferably an e-mail address – so that we can contact you. Requests made by standard mail will take longer to process due to the time it takes for correspondence to be exchanged.
We reserve the right to update or modify this policy at any time.