If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact us at email@example.com
- INFORMATION COLLECTION
Users of the Service may be Clients, VAs, or Agencies.
Information You Provide to Us
When you use the Service, you may provide us with information about you. This may include your name and contact information, financial information to make or receive payment for services obtained through the Virtual Buddys platform, or information to help us fill out tax forms. When you use the Service, we may also collect information related to your use of the Service and aggregate this with information about other users. This helps us improve our Services for you. You may also provide us with information about your contacts or friends if, for example, you’d like to add those contacts to a message room. Agencies may also provide us with information about VAs associated with the Agency.
- Personal Information:In the course of using the Service (whether as a Client or VA or Agency), we may require or otherwise collect information that identifies you as a specific individual and can be used to contact or identify you (“Personal Information”). Examples of Personal Information include your name, email address, company address, billing address, and phone number.
- Payment Information:If you use the Service to make or receive payments, we will also collect certain payment information, such as credit card or other financial account information, and billing address.
- Identity Verification:We may collect Personal Information, such as your date of birth or taxpayer identification number, to validate your identity or as may be required by law, such as to complete tax filings. We may request documents to verify this information, such as a copy of your government-issued identification or photo or a billing statement.
- General Audience Service:The Service is general audience and intended for users 18 and older. We do not knowingly collect Personal Information from anyone younger than age 18. If we become aware that a child younger than 18 has provided us with Personal Information, we will use commercially reasonable efforts to delete such information from our files. If you are the parent or legal guardian of a child younger than age 18 and believe that Virtual Buddys has collected Personal Information from your child, please contact us firstname.lastname@example.org
- Combination of Personal and Non-Identifying Information:Certain Non-Identifying Information would be considered a part of your Personal Information if it were combined with other identifiers in a way that enables you to be identified (for example, combining information with your name). But the same pieces of information are considered Non-Identifying Information when they are taken alone or combined only with other non-identifying information (for example, your viewing preferences). We may combine your Personal Information with Non-Identifying Information, but Virtual Buddys will treat the combined information as Personal Information.
- Collection of Third Party Personal Information:We collect the following personal information from you about your contacts or friends: First name, last name, and email address when you provide it to us for the purpose of adding your contacts to a message room.
You do not have a statutory obligation to provide us with any information, but you may have a contractual obligation to do so, and if we do not receive certain information from you, then we will not be able to provide our Service to you. If you have any questions regarding whether provision of information is mandatory and the consequences for withholding such information, please contact us using the contact information below.
Information Received from Third Parties
Information Collected Automatically
Like other online companies, we receive technical information when you use our Services. We use these technologies to analyze how people use the Service, to improve how our Site functions, to save your log-in information for future sessions, and to serve you with advertisements that may interest you.
We and our third party service providers, including analytics and third party content providers, may automatically collect certain information from you whenever you access or interact with the Service. This information may include, among other information, the browser and operating system you are using, the URL or advertisement that referred you to the Service, the search terms you entered into a search engine that led you to the Service, areas within the Service that you visited, which links you clicked on, which pages or content you viewed and for how long, other similar information and statistics about your interactions, such as content response times, download errors and length of visits to certain pages and other information commonly shared when browsers communicate with websites. We may combine this automatically collected log information with other information we collect about you. We do this to improve services we offer you, and to improve marketing, analytics, and site functionality.
The information we collect also includes the Internet Protocol (“IP”) address or other unique device identifier (“Device Identifier”) for any device (computer, mobile phone, tablet, etc.) used to access the Service. A Device Identifier is a number that is automatically assigned or connected to the device you use to access the Service, and our servers identify your device by its Device Identifier. Some mobile service providers may also provide us or our third party service providers with information regarding the physical location of the device used to access the Service.
- Web Beacons: We and our marketing partners, providers may also employ software technology known as “web beacons” and/or “tracking tags” to help us keep track of what content on our Service is effective and to serve relevant advertising to you. Web beacons are small graphics with a unique identifier that may be invisible to you, and which are used to track the online activity of Internet users. Web beacons are embedded in the web pages you review or email messages you receive. Web beacons or similar technologies may be used for a number of purposes, including, without limitation, to count visitors to our Service, to monitor how Virtual Buddys Users navigate the Service, to count how many emails that were sent were actually opened, or to count how many particular articles or links were actually viewed.
- Embedded Scripts:We and our marketing partners, affiliates, analytics, and service providers may also employ software technology known as an Embedded Script. An Embedded Script is programming code that is designed to collect information about your interactions with the Service, such as the links you click on. The code is temporarily downloaded onto your computer or other device and is deactivated or deleted when you disconnect from the Service.
In addition, we and our marketing partners, affiliates, analytics, and service providers may use a variety of other technologies (such as tags) that collect similar information for security and fraud detection purposes and we may use third parties to perform these services on our behalf.
HOW WE RESPOND TO DO NOT TRACK SIGNALS
Virtual Buddys does not respond to Do-Not-Track signals.
Please note that your browser setting may allow you to automatically transmit a “Do Not Track” signal to websites and online services you visit. There is no consensus among industry participants as to what “Do Not Track” means in this context. Like many websites and online services, Virtual Buddys does not alter its practices when it receives a “Do Not Track” signal from a visitor’s browser.
Work Diaries and Work View
We collect information about work for a Client, including automatically collected information about work on a particular project. If a VA enables Work Diaries, we will share Work Diaries with the relevant Client and Agency. We tell VA when we are capturing information for the Work Diary.
As part of the Service, when enabled by a VA, we collect information about a VA’s work on a project for a Client. This feature is known as Work Diary. Work Diaries include information provided by the VA, such as a memo, as well as automatically gathered information about work on a project, such as number of mouseclicks and keyboard strokes and regularly taken screenshots (which may include a webcam picture of you if you have enabled this feature in your settings).
We will share information contained in Work Diaries with the relevant Client and with any manager or administrator of any applicable VA Agency. We inform VAs each time we capture information for Work Diary. As set forth in our Terms of Service, End User License Agreement, and help pages on the Site, a VA may choose to block or delete the screen shot and associated data for a recorded work interval, but then the VA may not be paid for that work interval. Virtual Buddys may use de-identified or aggregated information from Work Diaries for statistical analysis, product development, marketing and research.
We place a premium on trust in our Service, so we may take steps to verify your identity.
Before a VA can complete registration on the Service, or at any time thereafter, we may request or re-request identity verification. Without limiting the manner in which we request identify verification, we may require VAs to participate in a video call after submitting their government issued ID to enable us to confirm that the VA is indeed the individual in the ID. We may record such video calls and take screenshots of the user during the call. Virtual Buddys may use the information obtained from Identity Verification for purposes of verifying your identity, enforcing our Terms of Service and other agreements, and preventing fraud.
VAs, Agencies, and Clients may communicate with each other through the Service. For example, VAs, Agencies, and Clients may wish to discuss Client needs and VA work proposals. If you communicate with an Agency or Client, that Agency or Client will also be a “data controller” with respect to such communications.
We display personal testimonials of satisfied customers on our Service, in addition to other endorsements. With your consent we may post your testimonial along with your name. If you wish to update or delete your testimonial, you can contact us at email@example.com
We collect feedback from Virtual Buddys Users about their experience with Virtual Buddys. Please note that any feedback you provide via the Service or feedback provided about you is publicly viewable via the Service. On very rare occasions, we may remove feedback pursuant to the relevant provisions of our Terms of Service.
- USE OF INFORMATION
We use information collected through the Service to provide and improve the Service, process your requests, prevent fraud, provide you with information and advertising that may interest you, comply with the law, and as otherwise permitted with your consent.
WE USE INFORMATION WE COLLECT:
- To provide and improve the Service, complete your transactions, address your inquiries, process your registration, verify the information you provide is valid, and for compliance and internal business purposes.
- To contact you with administrative communications and Virtual Buddys newsletters, marketing or promotional materials (on behalf of Virtual Buddys or third parties) and other information that may be of interest to you.
- To tailor content we display to you and offers we may present to you, both on the Service and elsewhere online.
- To administer and develop our business relationship with you and, if applicable, the corporation or other legal entity you represent.
- To assess your proposal to perform a freelance project for Virtual Buddys and prepare related governmental and internal statistics reports.
- To enforce and comply with the law, including to conduct an investigation, to protect the property and rights of Virtual Buddys or a third party, to protect the safety of the public or any person, or to prevent or stop activity we may consider to be, or to pose a risk of being, illegal, fraudulent, unethical or legally actionable activity. We may also use Device Identifiers to identify Virtual Buddys Users.
We use your Personal Information for the purposes described above:
- To Honor Our Contractual Commitments to You. Much of our processing of Personal Information is to meet our contractual obligations to our investors, or to take steps at Users’ request in anticipation of entering into a contract with them.
- For Our Legitimate Interests. In many cases, we handle Personal Information on the grounds that it furthers our legitimate interests in commercial activities, such as the following, in ways that are not overridden by the interests or fundamental rights and freedoms of the affected individuals:
- Providing our Site and Service.
- Analyzing and improving our business.
- Communications, including marketing and responding to your inquiries about our services.
- Addressing information security needs and protecting our Users, Virtual Buddys, and others.
- Managing legal issues.
- To Comply with Legal Obligations. We need to use and disclose Personal Information in certain ways to comply with our legal obligations.
- DATA RETENTION
Unless you request that we delete certain information we retain the information you submit to verify your identity for 30 days and we retain other information we collect for at least 6 months. Your information may persist in copies made for backup and business continuity purposes for additional time. If you choose to provide us with Personal Information, we encourage you to routinely update the data to ensure that we have accurate and up-to-date information about you.
- INFORMATION SHARING AND DISCLOSURE
- Information about VAs Shared with Clients, Agencies, Virtual Buddys Payroll Vendors, and Partners of The Virtual Buddys Foundation Initiative: We share information regarding VAs who have entered into a contract with a Client or who have elected to participate in Virtual Buddys Payroll, including information in Work Diaries and work history, with Clients, Agencies and Virtual Buddys Payroll vendors. Note that if a VA is suspended from the Virtual Buddys Service, we may share that information with Clients for whom that VA has worked or submitted proposals for work. We may also share information with Agencies to whom VAs are associated for a particular work project. If you choose to view a job post or submit a proposal for work as a VA via the Service, we may share relevant information with the applicable Client(s), including, but not limited to, the information contained in your VA Profile. If you choose to participate in The Virtual Buddys Foundation Initiative as a VA, we may share information relevant to your participation in the program with partners of Virtual Buddys who provide support to VAs through that program.
- Information about Clients and Agencies Shared with VAs: If you have entered into a service contract or agreed to use Virtual Buddys Payroll with another user, we may provide him/her with your name, company address, billing address, or tax ID or VAT number in order to complete the transaction or to facilitate the resolution of a claim or dispute. The user receiving your information is not allowed to use it for purposes unrelated to the transaction, such as to contact you for marketing purposes, unless you have expressly consented to it.
- Service Providers: We may employ third party companies and individuals to facilitate our Service, to provide the Service on our behalf, to perform Service-related services (e.g., without limitation, maintenance services, database management, web analytics and online advertising, payment processing, fraud detection and improvement of Virtual Buddys’s features) or to assist us in analyzing how our Service is used. These third parties may have access to your Personal Information in order to perform these tasks on our behalf.
- Legal and Investigative Purposes: Virtual Buddys will share information with government agencies as required by law in response to lawful requests by public authorities, including to meet national security or law enforcement requirements and, including without limitation, in connection with reporting earnings. We cooperate with government and law enforcement officials and private parties to enforce and comply with the law. We will disclose information about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal process (including but not limited to subpoenas), or, at the request of governmental authorities or other third parties conducting an investigation where we determine in our sole discretion the disclosure is necessary to (a) protect the property and rights of Virtual Buddys or a third party, (b) protect the safety of the public or any person, or (c) prevent or stop activity we may consider to be, or pose a risk of being, illegal, fraudulent, unethical or legally actionable activity.
- Internal and Business Transfers: Virtual Buddys may share information, including Personal Information, with its parent company SLK GLOBAL PTY LTD., and any current or future subsidiaries or affiliates, primarily for business and operational purposes. We may sell, transfer, or otherwise share some or all of our assets, including your Personal Information, in connection with a merger, acquisition, reorganization or sale of assets (including, in each case, as part of the due-diligence process with any potential acquiring entity) or in the event of bankruptcy.
- Sweepstakes, Contests, and Promotions:We may offer sweepstakes, contests, and other promotions (any, a “Promotion”) that may require registration. By participating in a Promotion, you are agreeing to the official rules that govern that Promotion, which may contain specific requirements of you, including, except where prohibited by law, allowing the sponsor(s) of the Promotion to use your name, voice, likeness, or other indicia of persona in advertising or marketing associated with the Promotion. If you choose to enter a Promotion, your Personal Information may be disclosed to third parties or the public in connection with the administration of such Promotion, including, without limitation, in connection with winner selection, prize fulfillment, and as required by law or permitted by the Promotion’s official rules, such as on a winner’s list.
- THIRD PARTY ANALYTICS PROVIDERS, AD SERVERS AND SIMILAR THIRD PARTIES
We may work with advertising agencies and vendors who use technology to help us understand how people use our Site. These vendors may use technologies to serve you advertisements that may interest you. You can choose to opt out of receiving interest-based advertising.
Virtual Buddys works with (or may in the future work with) network advertisers, ad agencies, analytics service providers and other vendors to provide us with information regarding traffic on the Service, including pages viewed and the actions taken when visiting the Service; to serve our advertisements on other websites, within mobile apps and elsewhere online; and to provide us with information regarding the use of the Service and the effectiveness of our advertisements. Our service providers may collect certain information about your visits to and activity on the Service as well as other websites or services, they may set and access their own tracking technologies on your device (including cookies and web bacons) and may use that information to show you targeted advertisements. Some of these parties may collect Personal Information when you visit the Service or other online websites and services. We may also share certain Non-Identifying Information with these parties, including Hashed Information, in connection with the services they provide to us. If you choose to opt out, please note you will continue to receive generic ads.
While we may use a variety of service providers to perform advertising services, some of these companies are members of the Network Advertising Initiative (“NAI”) or the Digital Advertising Alliance (“DAA”) Self-Regulatory Program for Online Behavioral Advertising.
- YOUR CHOICES AND RIGHTS
You have certain choices regarding how we may communicate with you.
Registered Virtual Buddys Users may update their choices regarding the types of communications you receive from us through your online account. You also may opt-out of receiving marketing emails from us by following the opt-out instructions provided in those emails. Please note that we reserve the right to send you certain communications relating to your account or use of the Service (for example, administrative and service announcements) via email and other means and these transactional account messages may be unaffected if you opt-out from receiving marketing communications. You may opt-out of receiving text messages by replying “STOP” to any text message received. Registered Virtual Buddys Similarly, registered Virtual Buddys Users who access the Service by using certain desktop browsers may, with permission, receive push notifications. Notification preferences can be modified in the settings menu forthe applicable browser.
All Users may request access to or correction of any Personal Information we have about them or close their account and/or request deletion of all Personal Information we have about them. In certain jurisdictions, Users may have certain rights with regard to their Personal Information. We will honor User requests to the extent we can reasonably do so and as required by law, but some information will remain on the Services, such as information you posted publicly.
Upon request Virtual Buddys will provide you with information about whether we hold any of your personal information. You are responsible for maintaining the accuracy of the information you submit to us, such as your contact information. You may access, correct, or request deletion of your personal information by making updates to that information or by contacting Virtual Buddys through your online account. If you request to access all personal information you’ve submitted, we will respond to your request to access within 30 days or as otherwise required by law. If your information is deleted, then your account may become deactivated. If your account is deactivated or you ask to close your account, you will no longer be able to use the Service. If you would like to close your account in our system, you can do so through the Virtual Buddys Service.
Depending on where you are located, you may have certain rights with regard to your Personal Information (including, in certain cases, under the Privacy Shield, described below). For example, if you are located in the ACCropean Economic Area (“ACC”), in addition to the rights described above, you may contact us at the contact information provided below to (1) request a restriction on the processing of your Personal Information, (2) object to the processing of your Personal Information, or (3) exercise other rights with respect to your Personal Information. If you are a California resident, you may have other rights. Virtual Buddys uses automated means to calculate the Job Success Score of VAs. If you believe that our services have miscalculated your Job Success Score or you would like to exercise any other rights with regard to your Personal Information, please email us at firstname.lastname@example.org for assistance. We may be able to assist you by conducting a manual review of your Job Success Score, such as by assessing whether the information you’ve provided us is accurate. While we strongly encourage you to first raise any questions or concerns about your Personal Information directly with us, you have a right to lodge a complaint with the relevant supervisory authority and to seek judicial remedy.
In addition, the rights described above may be limited, for example, if fulfilling your request would reveal personal information about another person, or if you ask us to delete information we are required by law to keep or have compelling legitimate interests in keeping (such as for fraud prevention purposes). Your Personal Information may remain in our archives and information you update or delete, or information within a closed account, may persist internally for our administrative purposes, to the extent permitted by law. Bear in mind that neither you nor Virtual Buddys can delete all copies of information that has been previously shared with others on the Service.
We take a number of steps to protect your data, but no security is guaranteed.
Virtual Buddys takes commercially reasonable steps to help protect and secure the information it collects and stores about Virtual Buddys Users. All access to the Site is encrypted using industry-standard transport layer security technology (“TLS”). When you enter sensitive information (such as tax identification number), we encrypt the transmission of that information using secure socket layer technology (“SSL”). We also use HTTP strict transport security to add an additional layer of protection for our Virtual Buddys Users. But remember that no method of transmission over the Internet, or method of electronic storage, is 100% secure. Thus, while we strive to protect your Personal Information, Virtual Buddys cannot ensure and does not warrant the security of any information you transmit to us.
- INTERNATIONAL TRANSFER OF PERSONAL INFORMATION
Because we are an Australian. company, we process and store your information in the Australia and our service providers may process and store it elsewhere.
When we transfer Personal Information from territories in the ACC or with similar laws to our affiliates or service providers in the Australia and elsewhere outside the ACC, we rely on approved data transfer mechanisms, including standard contractual clauses approved by the ACC Commission and the Privacy Shield, as described below. You may request a copy of the standard contractual clauses relevant to your Personal Information, if any, using the contact information below.
- PRIVACY SHIELD NOTICE
Virtual Buddys and its affiliates Virtual Buddys Inc. have certified that their Australian. operations adhere to the ACC. Privacy Shield Frameworks (“Privacy Shield”) with respect to the Personal Information that they receive in reliance on the Privacy Shield.
When Virtual Buddys or one of its affiliates receives Personal Information under the Privacy Shield and then transfers it to a third party service provider acting as an agent on their behalf, Virtual Buddys or its affiliate may have certain responsibility under the Privacy Shield if both (i) the agent processes the information in a manner inconsistent with the Privacy Shield and (ii) Virtual Buddys or its affiliate is responsible for the event giving rise to the damage.
Covered ACC residents should contact Virtual Buddys at the contact information below regarding Virtual Buddys’s or its affiliates’ compliance with the Privacy Shield. Virtual Buddys will attempt to answer your questions and satisfy your concerns in a timely and complete manner as soon as possible. If, after discussing the matter with Virtual Buddys, your issue or complaint is not resolved, Virtual Buddys and the above-named affiliates have agreed to participate in the Privacy Shield independent dispute resolution mechanisms listed below, free of charge to you. PLEASE CONTACT VIRTUAL BUDDYS FIRST.
For other Personal Information Virtual Buddys or its affiliates receive under the Privacy Shield, Virtual Buddys and its affiliates have committed to refer unresolved privacy complaints under the ACC.
- LINKS TO OTHER SITES
Our Service contains links to other websites. If you choose to click on a third party link, you will be directed to that third party’s website. The fact that we link to a website is not an endorsement, authorization or representation of our affiliation with that third party, nor is it an endorsement of their privacy or information security policies or practices. We do not exercise control over third party websites. These other websites may place their own cookies or other files on your computer, collect data or solicit Personal Information from you. We encourage you to read the privacy policies or statements of the other websites you visit.
Phishing websites imitate legitimate websites in order to obtain personal or financial information. Identity theft and the practice currently known as “phishing” are of great concern to Virtual Buddys. In addition, if you believe you have received an email or had a similar interaction with a third party pretending to be Virtual Buddys, please report it at email@example.com
- CHANGES TO THIS POLICY
- CONTACTING US
If you would like to exercise any of these rights, please submit a request through the Data Request Form available in our website or email us at firstname.lastname@example.org You will be required to verify your identity before we fulfill your request. You can also designate an authorized agent to make a request on your behalf. To do so, you must provide us with written authorization or a power of attorney, signed by you, for the agent to act on your behalf. You will still need to verify your identity directly with us.
Certain information may be exempt from such requests under applicable law. For example, we need certain types of information so that we can provide the Service to you. If you ask us to delete it, you may no longer be able to access or use the Service.
The ACC sets forth certain obligations for businesses that “sell” personal information. Based on the definition of “sell” under the ACC and under current regulatory guidance, we do not believe we engage in such activity and have not engaged in such activity in the past twelve months.