Privacy Policy : VISO TRUST

Effective Date: August 5, 2019
Last Updated: August 5, 2019

Introduction

Valente Sherman, Inc., a California corporation (collectively referred to herein as “Valente Sherman”, “we”, “our” or “us”), recognizes the importance of protecting personal information we may collect from our users (“Users”, “you”, or “your”) who visit our web site, www.visotrust.com (the “Website”). This Privacy Policy applies to data collection by Valente Sherman and shall apply to your use of the Website and other applications including app.visotrust.com, and software, communications, capabilities and Services (“Services”) offered by us, but excluding Services that state that they are offered under a different privacy policy.

By using the Services, you signify your acceptance of this Privacy Policy. If you do not agree to this Privacy Policy, please do not use the Services.

Regardless of which country you live in, you authorize us to transfer, store, and use your information in the United States, and any other country where we operate. In some of these countries, the privacy and data protection laws and rules regarding when government authorities may access data may vary from those in the country where you live. If you do not agree to the transfer, storage and use of your information in the United States, and any other country where we operate, please do not use the Services or Services.

If you have any questions or comments about this Privacy Policy, please submit a request to [email protected].

Application of Privacy Policy

Our Privacy Policy applies to all of the Services offered by Valente Sherman and its affiliates, and Services offered on other sites, but excludes Services that have separate privacy policies that do not incorporate this Privacy Policy. Our Privacy Policy does not apply to Services offered by other companies or individuals, including products or sites that may be displayed to you, or other sites linked from our Services. Our Privacy Policy does not cover the information practices of other companies and organizations who advertise our Services, and who may use cookies, pixel tags and other technologies to serve and offer relevant ads.

Terms and Conditions

By accessing or using the Services in any manner, you also agree to be bound by Valente Sherman’s Terms of Use (the “Agreement”). Please read the Agreement carefully. If you do not accept all of the terms and conditions contained in or incorporated by reference into the Agreement, please do not use the Services.

Information We Collect

We collect information, including Personal Data, to provide better Services to all our Users. We use the term “Personal Data” to refer to any information that identifies or can be used to identify you. Common examples of Personal Data include: full name, email address, digital identity, such as a login name or handle, information about your device, and certain metadata. When you use our Services, we collect Personal Data in the following ways:

When you use our Services, we collect Personal Data in the following ways:

1. Information You Give to Us

1. Website
  You may choose to provide us with Personal Data about yourself, including your name, organization name, title, address, phone number, and email address by completing forms on our website, such as when you request information about our Services or register.
  In some instances, you may elect to provide us with location and address information. You may also provide us with Personal Data about yourself when you report a problem or have a question about our Services.
  [The Services offer interactive and social features that permit you to submit content and communicate with us. You may provide Personal Data to us when you post information in these interactive and social features. Please note that your postings in these areas of the Services may be publicly accessible or accessible to other users.]
2. Mobile Application
  Certain information is required when creating an account to use our Services on the mobile application, such as your name, email address, user name and password.
  In addition, in order to improve your experience with the Services, you may choose to provide additional information in connection with creating your security profile. You can choose not to provide certain information, but then you may not be able to register for the Services or take advantage of some features of the Services.
  In connection with the use of the Services, your mobile device may collect certain data points like activity habits. When your device syncs with Valente Sherman’s application, certain data recorded on your device is transferred from your device to our servers.

2. Information We Obtain from Your Use of Our Services

We collect certain information automatically, such as your operating system version, browser type, and internet Service provider. We also collect information about your interaction with the Services, such as creating or logging into your account, or opening or interacting with the Services on Your mobile device. When you use our Service, we automatically collect and store this information in Service logs. This includes: details of how you used our Service; Internet protocol address; cookies that uniquely identify your browser, the referring web page and pages visited. We may also collect and process information about your actual location. The information we collect automatically is statistical data and may or may not include Personal Data, but we may maintain it or associate it with Personal Data we collect in other ways or receive from third parties.

1. 1. Location Data
    If you grant us access to your location, Valente Sherman may collect information about your location when you use our Services and Services. When you use our Services via a wireless device, we may solicit your permission to collect your location data. Some features within our application may only function upon confirmation of your location, and therefore such features will not be available if you choose not to provide your location data to us. If you enable location Services for our Applications, we may collect location data periodically as you use or leave open our Application. We may associate such location data with Personal Data you provide to us. Depending on the platform you use to access our Applications (e.g., Apple’s iOS, Google’s Android), you may be able to control whether location data is collected from within “Settings” or other controls on your wireless device or the Applications.
  2. Device ID
    When using our Services, we or our Service provider may collect your unique device ID. We may use such information for internal purposes and to provide you a better experience, such as to troubleshoot application problems you may experience. We may associate device ID with Personal Data you provide to us. You may learn more about opt out of any anonymous device ID collection via the privacy settings available within your mobile device.

3. Social Networking

When using our Services or when using certain third-party social networking Services (for example, Facebook or Twitter) (each a “Social Network”), you may have the option to connect your Valente Sherman information with that Social Network (and its users). Information we may share with a Social Network may include, but is not limited to, technical information about your Valente Sherman activity. Information we may access about you, with your consent, from a Social Network, may include, but is not limited to, your basic Social Network information, your location data, your lists of contacts, friends and followers, and certain information about your activities on the Social Network. If you permit a connection between a Social Network and Valente Sherman, we and that Social Network may be able to identify you and to associate information received pursuant to that connection with information we already have about you. We recommend that you familiarize yourself with the privacy policy and privacy control options of any Social Network with which you choose to share information or to connect to the Services.

4. Cookies and Similar Technologies

We use various technologies to collect and store information when you use the Services, including the use of cookies or similar technologies to identify your browser or device. We also use these technologies to collect and store information when you interact with Services from our partners, such as advertising Services. Our third-party advertising and analytics partners include Google, Lead Forensics and similar partners. The technologies we use for this automatic data collection may include:

1. Cookies
  A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Services. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Services.
2. Web Beacons
  Pages of our Services or our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags and single-pixel gifs) that permit us, for example, to count users who have visited those pages or opened an e-mail and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
3. Clickstream Data
  Clickstream data is information collected by our computers when you request Web pages from the Services. Clickstream data may include information such as the page served, the time spent viewing the page, source of the request, type of browser making the request, the preceding page viewed and similar information. Clickstream data permits us to analyze how visitors arrive at the Services, what type of content is popular, what type of visitors in the aggregate are interested in particular kinds of content on the Services.
4. Mobile Device Identifiers and SDKs
  A mobile SDK is the mobile app version of a web beacon (see “Web Beacons” above). The SDK is a bit of computer code that app developers can include in their apps to enable ads to be shown, data to be collected and related Services or analytics to be performed.

5. Network Advertisers

Third party companies that manage and deliver advertisements to websites and applications are commonly referred to as “network advertisers.” A permitted network advertiser may use cookies, web beacons or similar technologies to collect information about your interaction with the Services or to tailor certain advertisements and content delivered within the Services or on other websites within such network advertiser’s ad network. These companies may also use non-cookie technologies to recognize your computer or device and/or to collect and record information about your web activity including your activities on or off of the Services. Please keep in mind that your web browser may not permit you to block the use of these non-cookie technologies, and those browser settings that block cookies may have no effect on such techniques.

6. Other Advertising
We share certain data with Social Networks to allow us to target existing users and customers with highly relevant advertising campaigns. We will not share your name, address, email address, telephone number or other Personal Data for the purpose of such campaigns. In addition to advertisements for our own Services, we may facilitate third parties to advertise their own goods or Services including through targeting those advertisements to those that might be most interested in them. If you would prefer that we not share your information with third parties for their own marketing purposes, please contact at [email protected].

How We Use Information We Collect

We use your Personal Data in ways that are compatible with the purposes for which it was collected or authorized by you, including for the following purposes:

To present, operate or improve the Service, including analysis of Service activity;
To inform you about Services and products available from Valente Sherman;
To authorize access to our Services and Services;
To provide, maintain, administer or expand the Services, performing business analyses, or for other internal purposes to support, improve or enhance our business, the Services, and other products and Services we offer;
To offer and administer programs;
To personalize the Services to your goals;
To customize or tailor your experience of the Services, which may include sending customized messages;
To administer content, promotion, sweepstakes, surveys, voting polls or other Service features;
To communicate about, and administer your participation in, special programs, surveys, contests, online campaigns, online programs, sweepstakes, and other offers or promotions, and to deliver pertinent emails;
To improve our Service and Services;
To secure our Services, including to authenticate Users;
To use statistical information that we collect in any way permitted by law, including from third parties in connection with their commercial and marketing efforts;
To use statistical information that we collect in any way permitted by law, including from third parties in connection with their commercial and marketing efforts;
To respond to and support users regarding their use of the Services and Services;
To comply with all applicable legal requirements;
To enforce our Terms and Conditions and other agreements;
To perform data analysis and testing;
To investigate possible fraud or other violations of our Terms of Use or this Privacy Policy and/or attempts to harm our Users;
To resolve disputes;
To otherwise fulfill the purpose for which the information was provided.

We use the information we collect from our Services to provide, maintain, and improve them, to develop new Services, and to protect our Company and our users.

We use information collected from cookies and other technologies, to improve your user experience and the overall quality of our Services. For example, by saving your language preferences, we will be able to have our Services appear in the language you prefer. We may use your Personal Data to see which web pages you visit at our Service, which web site you visited before coming to our Service, and where you go after you leave our Service. We can then develop statistics that help us understand how our visitors use our Service and how to improve it. We may also use the information we obtain about you in other ways for which we provide specific notice at the time of collection.

We will ask for your consent before using information for a purpose other than those set out in this Privacy Policy.

Our Legal Basis for Collecting Personal Data

Whenever we collect Personal Data from you, we may do so on the following legal bases:

Your consent to such collection and use;
Out of necessity for the performance of an agreement between us and you, such as your agreement to use our Services or your request for Products;
Our legitimate business interest, including but not limited to the following circumstances where collecting or using Personal Data is necessary for:
- Intra-organization transfers for Partner data for administrative purposes;
- Product development and enhancement, where the processing enables Valente Sherman to enhance, modify, personalize, or otherwise improve our Services and communications for the benefit of our users, and to better understand how people interact with our Services;
- Communications and marketing, including processing data for direct marketing purposes, and subject to your opt-in for these purposes, and to determine the effectiveness of our promotional campaigns and advertising;
- Fraud detection and prevention;
- Enhancement of our cybersecurity, including improving the security of our network and information systems; and
- General business operations and diligence;

Provided that, in each circumstance, we will weigh the necessity of our processing for the purpose against your privacy and confidentiality interests, including taking into account your reasonable expectations, the impact of processing, and any safeguards which are or could be put in place. In all circumstances, we will limit such processing for our legitimate business interest to what is necessary for its purposes.

Information We Share

We do not share Personal Data with companies, organizations and individuals outside of the Organization unless one of the following circumstances applies:

With your consent. We will share Personal Data with companies, organizations or individuals outside of Valente Sherman when we have your consent to do so.
For external processing. We provide Personal Data to our affiliates or other trusted businesses or partners to process it for us, based on our instructions and in compliance with our Privacy Policy and any other appropriate confidentiality and security measures. These third parties include payment processors, such as financial institutions and their vendors and contractors that process transactions, marketing partners, and similar partners. It is our policy to only share Personal Data with contractors, Service providers and other third parties who are bound by contractual obligations to keep Personal Data confidential and use it only for the purposes for which we disclose it to them. Under certain circumstances, you may avoid having us share your information with our business partners and vendors by not granting us permission to share your information. Not granting us permission to share your information with our business partners or vendors may limit your access to their Services through the Services.
For Legal Reasons. We will share Personal Data with companies, organizations or individuals outside of Valente Sherman if we have a good-faith belief that access, use, preservation or disclosure of the information is reasonably necessary to:
- meet any applicable law, regulation, legal process or enforceable governmental request.
- enforce applicable Terms of Use, including investigation of potential violations.
- detect, prevent, or otherwise address fraud, security or technical issues.
- protect against harm to the rights, property or safety of Valente Sherman, our Users or the public as required or permitted by law.
We attempt to notify Users about legal demands for their Personal Data when appropriate in our judgment, unless prohibited by law or court order or when the request is an emergency. We may dispute such demands when we believe, in our discretion, that the requests are overbroad, vague or lack proper authority, but we do not promise to challenge every demand.
Business Transfers. If we establish a new related entity, are acquired by or merged with another organization, or if substantially all of our assets are transferred to another organization, Personal Data about our users is often a transferred business asset. In the event that Valente Sherman itself or substantially all of our assets are acquired, Personal Data about our users may be one of the transferred assets.
Non-Personal and Aggregate Service Use Information. Valente Sherman may compile and share your information in aggregated form (i.e., in a manner that would not personally identify you) or in de-identified form so that it cannot reasonably be used to identify an individual (“De-Identified Information”). We may disclose such De-Identified Information publicly and to third parties, for example, in public reports about exercise and activity, or to Valente Sherman Partners under agreement with us. Valente Sherman may also disclose De-Identified Information for general research purposes and in research collaborations with third parties, such as universities, hospitals or other laboratories to determine the prevalence of particular conditions among Users or to determine whether a User might be suitable for research or clinical trials. Valente Sherman may also use De-Identified Information for commercial collaborations with private companies for purposes such as product design or enhancement of Services.

Your Failure to Provide Personal Data

Your provision of Personal Data is required in order to use certain parts of our Services and our programs. If you fail to provide such Personal Data, you may not be able to access and use our Services and/or our programs, or parts of our Services and/or our programs.

Our Retention of Your Personal Data

We may retain your Personal Data for a period of time consistent with the original purpose for collection. For example, we keep your Personal Data for no longer than reasonably necessary for your use of our programs and Services and for a reasonable period of time afterward. We also may retain your Personal Data during the period of time needed for us to pursue our legitimate business interests, conduct audits, comply with our legal obligations, resolve disputes and enforce our agreements.

We retain your Personal Data even after your business relationship with us ends if reasonably necessary to comply with our legal obligations (including law enforcement requests), meet regulatory requirements, resolve disputes, maintain security, prevent fraud and abuse, enforce our Terms of Use, or fulfill your request to “unsubscribe” from further messages from us. We will retain De-Identified Information after your account has been closed.

Your Choices and Accessing, Updating or Deleting Your Personal Data

Subject to applicable law, you may obtain a copy of Personal Data we maintain about you or you may update or correct inaccuracies in that information by contacting us. To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to the information. In addition, if you believe that Personal Data we maintain about you is inaccurate, subject to applicable law, you may have the right to request that we correct or amend the information by contacting us as indicated in the How to Contact Us section below.

You may update or correct information about yourself by making changes to your profile by emailing us at [email protected]. If you completely delete all such information, then your account may become deactivated. We may retain an archived copy of your records as required by law, to comply with our legal obligations, to resolve disputes, to enforce our agreements or for other legitimate business purposes.

We may contact you to request that you update your Personal Data on a regular basis to ensure its integrity for the purposes of ongoing data management.

Email Communications

By providing an email address on the Valente Sherman Services, you agree that we may contact you in the event of a change in this Privacy Policy, to provide you with any Service-related notices, or to provide you with information about our events, invitations, or related educational information.

Third Party Links

The Services may contain links to webpages operated by parties other than Valente Sherman. We do not control such websites and are not responsible for their contents or the privacy policies or other practices of such websites. Our inclusion of links to such websites does not imply any endorsement of the material on such websites or any association with their operators. Further, it is up to you to take precautions to ensure that whatever links you select or software you download (whether from this Service or other websites) is free of such items as viruses, worms, trojan horses, defects and other items of a destructive nature. These websites and Services may have their own privacy policies, which you will be subject to upon linking to the third party’s website. We strongly recommend that you review the third party’s terms and policies.

International Transfer

We are committed to complying with applicable laws, regulations and mandatory government standards regarding the protection of Personal Data. Countries where we process data may have laws which are different, and potentially not as protective, as the laws of your own country. If we transfer your Personal Data out of your jurisdiction, we will implement suitable safeguards and rely on legally-provided mechanisms to lawfully transfer data across borders to ensure that your Personal Data is protected.

How We Protect Personal Data

Valente Sherman maintains administrative, technical and physical safeguards designed to protect the User’s Personal Data and information against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use. We implement appropriate technical and organizational measures to ensure a level of security appropriate to the risk, taking into account technological reality, cost, the scope, context and purposes of processing weighted against the severity and likelihood that the processing could threaten individual rights and freedoms. We use commercially reasonable security measures such as encryption, firewalls, and Secure Socket Layer software (SSL) or hypertext transfer protocol secure (HTTPS) to protect Personal Data.

If Valente Sherman collects account information for payment or credit, Valente Sherman will use the information only to complete the task for which the account information was offered.

Children

The Service is not intended for use by children. We do not intentionally gather Personal Data about visitors who are under the age of 13. If a child has provided us with Personal Data, a parent or guardian of that child may contact us to have the information deleted from our records. If you believe that we might have any information from a child under age 13 in the applicable jurisdiction, please contact us at [email protected]. If we learn that we have inadvertently collected the Personal Data of a child under 13, or equivalent minimum age depending on jurisdiction, we will take steps to delete the information as soon as possible.

Direct Marketing and “Do Not Track” Signals

Valente Sherman does not track its users over time and across third party websites to provide targeted advertising and therefore does not respond to Do Not Track (DNT) signals. However, some third-party sites do keep track of your browsing activities when they serve you content, which enables them to tailor what they present to you. If you are visiting such sites, your browser may include controls to block and delete cookies, web beacons and similar technologies, to allow you to opt out of data collection through those technologies.

California residents are entitled to contact us to request information about whether we have disclosed Personal Data to third parties for the third parties’ direct marketing purposes. California users may request further information about our compliance with this law by e-mailing us at the address listed in the “How to Contact Us” section.

Changes to this Privacy Policy

Our Privacy Policy may change from time to time. We will not reduce your rights under this Privacy Policy without your explicit consent. We will post any privacy policy changes on this page and, if the changes are significant, we will provide a more prominent notice (including, for certain Services or programs, email notification or privacy policy changes). We will also keep prior versions of this Privacy Policy in an archive for your review.

Revisions:

August 5, 2019

How to Contact Us

If you need to contact us regarding security or privacy, including reporting any known or suspected security incidents or vulnerabilities please do so at [email protected].

If you have any specific questions about this Privacy Policy, you can contact us via email or phone or by writing to us at the address below:

Send e-mail to: [email protected]

Send mail to our address:
VISO TRUST (DBA)
Valente Sherman, Inc.
PO BOX 193152
San Francisco, CA 94119-3152
[email protected]
www.visotrust.com