WHAT INFORMATION MAY BE COLLECTED?
During your use of the network (whether as a registered or unregistered user), you may provide us with personal information, such as your name and e-mail address, or other information that could be used to identify you as an individual or allow someone to contact you, as well as any information associated with such information (collectively, “Personal Information”). Personal Information includes both things that specifically identify you (like your real name) and things that don’t specifically identify you, but might be connected back to you (like the IP address of your computer or the device identifier of your smartphone).
When using the network from a mobile device (a “Mobile Service”), you may share the geographic location of your device with us. Your device location may be transmitted to us whenever a Mobile Service is running (even if you are not actively using the Mobile Service or it is running in the background on your device). Your device may continue to transmit its location to us until you change your device settings.
If you set your device not to transmit location information to us, certain features of the network may not be available or their functions may be limited. You should also know that turning off location sharing only prevents your device from sharing its precise location. Your network service provider may still provide general location information (based on access points you’ve connected to, for example). The information provided varies by network service provider. You should check with your network service provider to find out what information is provided and if there are ways for you to limit it.
Service Usage Information
As is typical of many web sites and mobile applications, when you use the network, we may collect information about your device and your usage of the network including:
- Your IP address (which we may associate with your domain name or that of your Internet access provider or wireless carrier, and your location);
- Unique ID number associated with your device;
- Other unique identifiers such as advertising identifiers (e.g., “ad-ID” or “IDFA”);
- Web browser and operating system information;
- Language of your device;
- Wireless connections you are using;
- Referring page that linked you to us;
- Your activities, including browsing and transaction history;
- Pages, content, and ads you view or click on during your use of the network, and when and for how long you do so;
- The next web site you visit after leaving our web site; and
- Search terms you enter on the network or a referral site.
HOW IS YOUR INFORMATION USED?
We or our service providers may use the information we collect from or about you to perform the following functions:
administer the network and your account with us;
enable you to use the network and their features;
customize the network to your interests and history with us;
localize the content and articles that are displayed to you based on your geographical location;
conduct market research;
improve or develop new features and offerings in the network;
tailor ads displayed to you in the network and elsewhere;
send you marketing and other communications, including information about products, services, or events that we think might be of interest to you;
assess your level of interest in and use of the network, e-mails, and other messaging campaigns, both on an individual basis and in aggregate;
generate analytics reports on the usage of the network; and
respond to your requests, questions, and concerns protecting our rights and property.
We may also use Personal Information to meet our internal and external audit requirements and for information security purposes. Where permissible under applicable law, your Personal Information may be used for other purposes, which will be disclosed to you at the time when your information is collected. There may be instances, however, when we will use your Personal Information for purposes that were not disclosed at the time of the data collection; for example, when doing so is necessary to comply with a legal obligation or requirement. We may use Personal Information to (a) respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, which may include such authorities outside your country of residence; (b) enforce our terms and conditions; and (c) protect our rights, privacy, safety, or property, or those of other persons.
Some of the uses specified above are necessary for the performance of a contract between us, or for the provision of a service requested by you. In other cases, the uses are based on our legitimate interests such as marketing the network to people who have expressed an interest in them or similar services.
HOW DO WE SHARE THE INFORMATION WE COLLECT?
We may share your information:
with our lawyers, auditors, and other professional advisors, third party advertising companies (including exchanges and brokers) and third party providers of services such as cloud storage, customer relationship management systems, travel and expense management, analytics databases, who need your information to provide services to us (or on our behalf);
when we believe in good faith that disclosure is necessary to protect our rights or property, protect your safety or the safety of others, investigate fraud, or respond to a government agency, law enforcement, judicial or public authority, or other legal request, or to comply with the law;
in connection with a proposed corporate change or dissolution, including for example a merger, acquisition, reorganization, consolidation, bankruptcy, liquidation, sale of assets or wind down of business.
We may share non-personally identifiable information about usage of the network (including aggregate data) with others, for their own use, in a de-identified form.
In addition, what you voluntarily post to public areas of our Service may be available to other Service users.
Transfers outside the European Economic Area (“EEA”)
with our offices outside the EEA;
with service providers located outside the EEA;
if you are based outside the EEA;
where we consider that the transfer is necessary for exercising, establishing or defending legal rights including, as appropriate, providing information to respond to a government, law enforcement, judicial or other legal request, or otherwise to comply with applicable law.
Non-EEA countries might not have the same legal framework for data protection as the EEA countries. In particular, the United States, which is the most common destination of our transfers of Personal Information outside the EEA, is not considered to provide a level of personal data protection equivalent to that of the EEA. We will, however, ensure the transfers comply with EU data protection law. Our standard practice is to use standard data protection contract clauses approved by the European Commission as the basis for such data transfers. You may read more about this on the European Commission Justice website at (http://ec.europa.eu/justice/data-protection/international-transfers/adequacy/index_en.htm).
If you would like further information, please see “Contact us” section below.
HOW DO WE SECURE YOUR PERSONAL INFORMATION?
We use reasonable technical, administrative and physical security measures to protect Personal Information collected via the network. We cannot guarantee that any information, during transmission through the Internet or while stored on our systems or otherwise in our care, will be absolutely safe from unauthorized access or use (e.g., by hackers). You use the network, and send us information, at your own risk.
If you correspond with us by e-mail, text message, or using a “Contact us” feature on our Service, a third party could view the information you send in transit by such means. We have no liability relating to disclosure of your information due to errors, omissions or unauthorized acts or failures to act by third parties during or after transmission.
If you create an account on the network, you are responsible for maintaining the strict confidentiality of your account password, and you shall be responsible for any activity, including disclosure of your Personal Information, that occurs using your account credentials, whether or not you authorized such activity. Please notify us of any unauthorized use of your password or account or any other breach of security.
We have procedures in place to deal with any suspected data security breach. If we believe that the security of your Personal Information in our care may have been compromised, we will endeavor to notify you of that development promptly taking into consideration the circumstances within 72 hours. If we have your e-mail address, we may notify you by e-mail. Where legally required to do so, we also will notify any applicable regulator.
COOKIES AND OTHER TRACKING TECHNOLOGIES
We, and/or our service providers or partners on our behalf, may use tracking technologies which may run on your device when you use the network. The circumstances in which we may deploy tracking technologies include:
HTML5 may be used to store information on your computer or device about the network usage activities. This information can be retrieved by us to determine how the network are being used by our visitors, how the network may be improved, and to customize the network for our users.
These tracking technologies may be deployed by us and/or our service providers or partners on our behalf. These technologies enable us to assign a unique number to your computer or device, and relate information about your use of the network to other information about you, including your Personal Information. These technologies also enable us to recognize you when you access the network using different web browsers or devices.
You can manage website cookies in your browser settings. You always have the choice to have your device warn you each time a cookie is being sent or change these settings by accepting, rejecting, or deleting cookies. If you choose to change your settings, you may find that certain functions and features will not work as intended on the network. All browser settings are slightly different, so to manage cookies, you should refer to the relevant settings within your browser. If you would like to obtain more detailed information about types of cookies, how they are used, and how you can manage your cookie preferences you may want to visit: www.aboutcookies.org or www.allaboutcookies.org. Please click below for detailed information on how to disable and delete cookies in some commonly used browsers:
Mozilla Firefox®: https://support.mozilla.org/en-US/kb/delete-cookies-remove-info-websites-stored
Microsoft® Internet Explorer: https://support.microsoft.com/en-us/help/17442/windows-internet-explorer-delete-manage-cookies#ie=ie-11
Google Chrome™: https://support.google.com/accounts/answer/61416?hl=en
LINKS AND CONNECTIONS TO THIRD PARTY SERVICES
We may also include tools in the network that allow you to share or publicly post content from the network to your profile on a third party social network. You may choose to share information about your activities on the Service with such third party platforms and its users, including publishing your information about what content you may have viewed on the network. If you visit a Service while logged into certain social media platforms, the social media platform may be able to identify your browser and associate the technical information provided by your web browser with other information that they have already collected about you, which may result in their ability to identify you. In addition, when you choose to share information about your activities on the network with certain social media platforms, VNN may send technical information about you to that platform as well as information about what content you are viewing.
Third-Party Ad Servers and Networks
We use third-party advertising companies to serve ads when you visit the network.
For more information about third-party advertisers and how to prevent them from using your information, visit the Digital Advertising Alliance’s site at http://www.aboutads.info/choices/ or the Network Advertising Initiative’s site at http://www.networkadvertising.org/choices/. However, if you opt-out we may still suggest offerings (including content sponsored by third-parties) to you on our Service based on your history or your account preferences.
DO NOT TRACK DISCLOSURES
Some web browsers may transmit “do-not-track” (“DNT”) signals to mobile applications with which the user communicates. We currently do not change our tracking practices (which are explained in more detail under “Service Usage Information” above) in response to DNT settings in your web browser.
Our third party partners, such as web analytics companies and third party ad networks, may collect information about you and your online activities over time and across the network and other online properties. These third parties may not change their tracking practices in response to DNT settings in your web browser and we do not obligate these parties to honor DNT settings. We utilize Google Analytics for our web analytics and you can opt out of your usage data being included in our Google Analytics reports by visiting https://tools.google.com/dlpage/gaoptout.
YOUR RIGHTS RELATING TO YOUR PERSONAL INFORMATION
You may review, update or correct certain of the Personal Information that is stored in your user account in the network (if you have one) by using the “Contact Us” information below. We may ask you to verify your identity and to provide other details before we are able to provide you with any information, correct any inaccuracies, or delete any information. Your right to delete information is subject to our records retention policies.
You can opt out of our promotional e-mails by clicking the opt-out/unsubscribe link within the e-mail you receive. Please understand that it may take us a few days to process any opt out request and that even if you opt out of receiving promotional correspondence from us, we may still contact you in connection with your relationship, activities, transactions, and communications with us.
In some jurisdictions, including in the countries of the European Economic Area, you have the right, in certain circumstances, to (i) require us delete your Personal Information, (ii) require us to restrict processing of your Personal Information (for example, if you contest the accuracy of that information), (iii) receive a copy of the Personal Information you provided to us in a structured, commonly used, and machine-readable format and/or instruct us to transmit that data to a third party; and (iv) object to our continued processing of your Personal Information, for direct marketing (including profiling) or other purposes. You can exercise these rights free of charge by contacting us using the details in the “Contact us” section below.
The network is not aimed at children. If, however, we collect and use information about children, we will comply with industry guidelines and applicable laws.
If you have any questions or comments regarding our privacy practices, you may contact us at:
We hope that can resolve any query or concern you may raise about our use of your information.
Individuals located in the EEA have the right to lodge a complaint with a supervisory authority of the EEA state where you work or live or where any alleged infringement of data protection laws occurred. A list of the supervisory authorities can be found here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm
Effective Date: 1 July 2018