Vuture Global Privacy Policy

 

Who or what is Vuture?

Vuture is a multi-channel marketing automation company operating out of offices in London, New York and Sydney. It provides a SAAS platform with the ability to build and send out email marketing campaigns; create websites and secure microsites; build surveys; manage events and create print campaigns, depending on the choice of modules purchased. Integrating with most CRM systems, it tracks and records reader responses, click-throughs and email opens, tracks web visits and measures engagement. It can add activity notes to the CRM to report on user activity.

 

Introduction

Vuture respects your privacy, whether you are a Vuture customer, one of our customer’s clients or users, or simply an individual visiting one of our websites, and we are committed to protecting your privacy through our compliance with this policy.

 

This policy describes our practices in connection with information that we collect through our websites, through our web-based applications and services (collectively, our “Applications”), as well as through HTML-formatted email messages that we send to you (collectively, including the Websites and the Applications, our “Services”).

 

This policy also applies to information about you that we collect or receive:

 

  • In e-mail, text and other electronic messages between you and Vuture
  • When you interact with our advertising and applications on third-party websites and services

 

It does not apply to information collected by:

 

  • Any third party, including through any third-party application or content (including advertising) that may link to or be accessible from our Services

 

Please read this policy carefully to understand our policies and practices regarding the collection of information about you, whether via our Websites, Applications, or from other sources, and how we will treat it. If you do not agree with our policies and practices, you may choose not to use our Services. Your continued use of our Services after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

 

Your Privacy Classification

This policy classifies those accessing and using our Services as one of the following:

 

  • VISITORS: Individuals and entities that access and interact with our Websites (for instance, to read about Vuture products and services, download a whitepaper, or sign up for an online demo), as well as those whom we meet or learn about through referral, from third parties or other external sources, referred to as “Website Visitors” or simply “Visitors.” Personally identifiable information pertaining to Visitors subject to this policy is maintained in one or more Vuture marketing databases and Website analytics and management systems that are physically and logically separate from Vuture production systems and databases where Application end-user information is maintained. Vuture may use the contact information you provide as a Visitor to send you promotional materials, as further described in this policy.
  • CUSTOMERS: Individuals and entities that are Vuture’s direct customers (for example, corporate marketing departments and event planners) as well as customer personnel that are assigned a login ID and are authorised to access and use our Applications, pursuant to an active Vuture services agreement, or under a temporary evaluation license if available, are referred to as “Customers.” Personally identifiable information of Customer personnel associated with their Application accounts is treated as End-User information, and will not be used for any purpose other than providing and supporting our Applications (other than for limited exceptions described in the section below titled “How We Use Information” where applicable). Note that information relating to these same individuals who have visited and interacted with our marketing Websites (for instance, to download a whitepaper or sign up for an online demo) is treated as Visitor information.
  • END-USERS: Customers’ business contacts, which may include their own current and prospective customers, members, marketing partners, or other third party contacts that use our Applications to interact with our Customers (for example, individuals that subscribe to a mailing list, register for an event organized by a Customer, download an event-related mobile app, complete an online survey, or sign-up for tickets to a live event) are referred to as “Application End-Users” or simply “EndUsers.” Vuture does not use personally identifiable information of End-Users for any purpose other than providing and supporting the Applications (other than for limited exceptions described in the section below titled “How We Use Information” where applicable).

 

Information We Collect and How We Collect It

Vuture, and our Customers that use our Applications to send out marketing emails, organise and manage events or to provide other services, may collect several types of information from and about End-Users, including:

 

  • “Personal Information” that identifies an End-User as an individual or relates to an identifiable person. For example, this includes name, organisation, title, postal address, e-mail address, telephone number, fax number, social media account ID or other identifiers by which End-Users may be contacted online or offline.
  • “Other Information” that does not reveal a person’s identity or directly relate to an individual, on its own or in combination with other information we have collected, such as browser and device information, app usage data, information collected through cookies, pixel tags and other technologies, general geographic location, demographic information and other information provided by a person, such as dietary preferences, interests, activities, age, gender, education and occupation.

 

Vuture may also collect Personal Information and Other Information from Customers and Website Visitors. In some instances, we may combine Other Information with Personal Information (such as combining a Website Visitor’s name with information we gather about this individual’s use of the Websites). If we combine any Other Information with Personal Information, the combined information will be treated by us as Personal Information as long as it is combined.

 

We collect this information:

 

  • Directly from individuals when they provide it to us.
  • Automatically from End-Users as they use the Applications, or from Website Visitors as they navigate through the Websites, using technologies described in the section below titled “Third Party Advertisers and Analytics.” Information collected automatically may include browser and device information, details regarding use of the Services, IP addresses and information collected through cookies, web beacons and other technologies.
  • From third party sources, such as public databases, joint marketing partners, and social media platforms. For example, if a Website Visitor elects to connect his social media account to his account for our Websites, certain Personal Information from the social media account will be shared with us, which may include Personal Information that is part of the Visitor’s profile or his friends’ profiles.

 

Information Provided to Us

The information we collect through our Services may include:

 

  • Information that a person provides when utilising one of our Services, for instance, at the time an End-User subscribes to a marketing email mailing list, registers to attend an event being organised by a Vuture customer (Vuture Event Registration), uses a web chat function with our sales team, submits a request for proposal (“RFP”) to a Sales Manager, or registers with multiple mailing lists in our Preference Manager.
  • Information that Website Visitors provide by filling in forms on our Websites. This includes information provided at the time of registering to receive product information or whitepapers, attend online demos, or access other special content on our Websites. We may also ask Customers or Visitors for information when they enter a contest or promotion sponsored by us.
  • Information that Customers and End-Users provide when receiving technical or customer account support. This includes records and copies of Customer and End-User correspondence (including e-mail addresses).
  • Responses to surveys that we might ask Customers, End-Users or Website Visitors to complete for research purposes.
  • Details of transactions Customers carry out through our Applications and of the fulfillment of Customer orders.
  • Records of search queries on our Services.

 

Some of our Websites allow Visitors to create or post content on message boards, chat, profile pages and blogs and other services to which Visitors are able to post information and materials. Please note that any information posted or disclosed through these sections of our Websites will become public information, and may be available to other Website Visitors and to the general public. We urge caution to anyone deciding to disclose their Personal Information, or any other information, on our Websites.

 

Anyone submitting Personal Information relating to other people to Vuture in connection with the Services represents that they have the authority to do so and to permit us to use the information in accordance with this Privacy Policy.

 

How We Use Information

We will never sell your Personal Information to any third party!

 

We may use information that we collect or that is provided to us, including Personal Information, for any of the following purposes:

 

  • To present our Services and their contents.
  • To provide End-Users with information, products, or services they request from Vuture or our Customers using our Applications, for example by processing event registrations, or enrolling End-Users in mailing lists or programs in which they choose to participate.
  • To manage Application accounts and provide customer service.
  • To provide Customers with notices about their Vuture accounts, including expiration and renewal notices.
  • To notify Customers and End-Users about changes to our Services, any products or services we offer or provide though our Services, our terms and conditions applicable to the Services, or this Privacy Policy.
  • To communicate with Customers and Visitors by e-mail, postal mail, telephone and/or mobile devices about products or services that may be of interest and that are offered by us, our affiliated companies or other third parties.
  • To allow Customers and Visitors to participate in online product demos, surveys, and online sweepstakes or contests (including to verify participant eligibility and deliver prizes), access and download materials, and use other interactive features on our Services.
  • To better tailor Website experience to Visitors interests, Application experience to End-User or Customer interests, and display content according to user preferences.
  • To facilitate social sharing functionality.
  • To perform research and analyse use of, or interest in, our products, services or content (or products, services or content offered by others on our Website).
  • For our business purposes, such as data analysis, audits, fraud monitoring and prevention, developing new products, enhancing, improving or modifying our Services, identifying usage trends, determining the effectiveness of our promotional campaigns and operating and expanding our business activities.
  • As we believe to be necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities including public and government authorities outside your country of residence; (d) to carry out our obligations and enforce our terms and conditions applicable to the Services and other agreements, including for billing and collection purposes; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; (g) to allow us to pursue available remedies or limit the damages that we may sustain; and (h) to protect against or identify fraudulent transactions. This includes exchanging information with other companies and organisations where reasonably necessary for the purposes of fraud protection and credit risk reduction.
  • In any other way we may describe when you provide the information.
  • To fulfill any other purpose for which you provide it or with your consent.

 

We may also use contact information of Customers and Visitors to contact them via email, telephone or direct mail about products and services that may be of interest to them. Where required, we will seek and obtain recipients’ express authorisation before we send marketing emails. If you do not want us to use your information in this way, please adjust your email preferences on the profile page that is accessible by clicking the unsubscribe link provided at the bottom of emails you receive from us. For more information, see Choices About How We Use and Disclose Your Information below.

 

Third Party Sub-processors and Service Providers

Vuture uses certain third parties to help with the business administration and other activities related to the services provided. Some of these third parties are based in the EEA and some are based outside the EEA.

 

If the Visitor, User or Customer is located in the EEA, by using Vuture’s Services they consent to the transfer of their personal data to the servers of Vuture’s third party service providers. In particular, Vuture’s third party service providers that may keep personal data with servers not located in the EEA are the following:

 

  • Freshdesk: Vuture uses Freshdesk as Vuture’s ticketing service and help desk software. Freshdesk, Inc., is located at 311 California Street, San Francisco, CA 94104, USA and hosts and processes data in the US, EEA and possibly in other countries, has been awarded with the TRUSTe’s Privacy seal and has certified that it adheres to the relevant US-EU and US-Swiss Privacy Shield Principles of the Government of the United States. See Freshdesk's Privacy Policy for further details.

 

 

Disclosure of Your Information

We may disclose aggregated information about users of our Services, and information that does not identify any individual, without restriction.

 

If you choose to use our Services to transact business with Customers (for example, subscribe to a mailing list, register for an event or respond to an online survey), any information you provide in connection with that transaction will be transferred to, and under the control of, the Customer. Customers will also have access to information (including Personal Information and Application usage data) related to how End-Users interact with the Applications that they use to organise and manage mailing lists and events. Although our own use and disclosure of your information will be in compliance with this Privacy Policy, Vuture cannot and does not take responsibility for the privacy practices of Customers.

 

We may disclose Personal Information that we collect or you provide as described in this Privacy Policy:

 

  • To our subsidiaries and affiliates for the purposes described in this Privacy Policy. Vuture is the party responsible for the management of the jointly-used Personal Information.
  • To contractors, service providers and other third parties as reasonably necessary or prudent to provide, maintain and support our Services.
  • To a third party in the event of a merger, divestiture, restructuring, reorganisation, dissolution or other sale or transfer of some or all of Vuture’s assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which Personal Information held by Vuture about our Website Visitors, Customers and End-Users is among the assets transferred.
  • To fulfill the purpose for which information is provided. Here are some examples:
    • If End-Users provide an email address when registering for an event or subscribing to a mailing list, customers will use the e-mail address to send the End-User information and announcements relating to that event or mailing.
  • As we believe to be necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities, including public and government authorities outside your country of residence; (d) to carry out our obligations and enforce our terms and conditions applicable to the Services and other agreements, including for billing and collection purposes; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, and/or that of our affiliates, our customers, you or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain. This includes exchanging information with other companies and organisations where reasonably necessary for the purposes of fraud protection and credit risk reduction.
  • For any other purpose disclosed by us when you provide the information or with your consent.

 

Third Party Services

This Privacy Policy does not address, and we are not responsible for, the privacy, information or other practices of any third parties, including any non-customer third party operating any site or service to which the Services link. The inclusion of a link on the Services does not imply endorsement of the linked site or service by us or by our affiliates.

 

Please note that we are not responsible for the collection, usage and disclosure policies and practices (including the data security practices) of other non-customer organisations, such as Facebook, Apple, Google, Microsoft, BlackBerry, or any other company, including app developers, app providers, social media platform providers, operating system providers, wireless service providers or device manufacturers, including any Personal Information you disclose to other organisations through or in connection with the Applications.

 

Cookies and Similar Technologies

We and our service providers may collect information about Website Visitors' online activities over time and across our Websites, third-party websites or other online services, and we may collect similar information about the online activities of Customers and End-Users within our Applications. As you navigate through and interact with our Websites and Applications, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions and patterns, including:

 

  • Details of your visits to our Services, such as the date and time you access our Services, length of time you spend on our Services, websites you visited before or after our Services, the resources and content that you access and use on the Services, and whether your interaction with our Services results in your requesting information about Vuture or making a purchase.
  • Information about your computer and internet connection, such as your Media Access Control (MAC) address, computer type (Windows or Macintosh), screen resolution, language, Internet browser type and version and the name and version of the Services (such as the Application) you are using. The technologies we use for this automatic data collection may include:
    • Cookies (or browser 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 or receive certain parts of our Services. Unless you have adjusted your browser settings so that it will refuse cookies, our system will issue cookies when you direct your browser to our Websites or receive our Services.
    • Session Cookies and Persistent Cookies. A “session” cookie lasts for a single browser session only and is deleted when the user closes the web browser. A “persistent” cookie remains on the user’s device (even while powered off) until it expires or is deleted. A persistent cookie will be reactivated when a user returns to the website which posted the cookie. Cookies cannot read or access other cookies or any data from a user’s hard drive. Cookies alone will not personally identify a user, however a cookie may recognize a user’s individual web browser or device through an IP Address, browser version, operating system and other information, and end users of our Services who log in to their Vuture accounts may be individually identifiable to particular Services using session cookies.
    • Web Beacons. Pages on our Services and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags and single-pixel gifs). Web beacons differ from cookies in that the information is not stored on your hard drive, but invisibly embedded on web pages or in email. Web beacons permit us to track online movements of web users -- 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). This enables Vuture to provide a website experience more tailored to your preferences and interests.

 

At this time we do not respond to browser ‘do not track’ signals, as we await the work of interested stakeholders and others to develop standards for how such signals should be interpreted. You can learn about how you can adjust your browser’s settings to limit or disable cookies and other tracking technologies by visiting the section below titled “Choices about How We Use and Disclose Your Information.”

 

For more information on the details of our cookies, refer to the helpdesk article: Web Tracking Privacy Compliance.

 

Advertising and Analytics

When you access and use the Services and other websites, we may serve you advertisements regarding goods and services that may be of interest to you (or in some cases, to users who our service providers deem to have characteristics similar to our customers) based on information relating to your access to and use of the Services and other websites. To do so, we or our service providers may place or recognize a unique cookie on your browser (alone or in conjunction with web beacons, pixel tags or other tracking technologies).

 

We use third party analytics providers, including Quantcast, Google and others, to collect information about your use of the Services and to help us improve how the Services work. The information allows us to see the overall patterns of usage on the Services, helps us record any difficulties you have with the Services, shows us whether our advertising is effective or not, and allows us to use responses to advertisements to optimize ad performance. Google Analytics, Adobe and Mixpanel use cookies and other, similar technologies to collect information about the Services used and to report website trends to us, without identifying individual End-Users or Visitors to us. See below for more information, or to opt out of these practices:

 

 

Choices About How We Use and Disclose Your Information

We strive to provide you with choices regarding the Personal Information you provide to us. We have created mechanisms to provide you with the following control over your information:

 

  • Tracking Technologies and Advertising. You may set your web browser to restrict or to entirely block cookies, to configure cookie notification settings and/or to delete cookies already present on the browser or device. Information on how to do this should be provided in the web browser’s help/reference section. Visitors who block cookies may be able to access a Website but will not be able to use some of the content, applications and services available on that site. Limiting or restricting certain types of cookies may also prevent a Customer or End-User from using certain portions of the Applications, depending on how the browser settings are configured. For example, emails cannot be tracked or secure areas cannot be accessed.
  • Promotional Offers from Vuture. If you do not wish for Vuture to use your email address to send you promotional messages, or would like us to prevent a Customer from using the Applications to send you emails to promote its own or third parties’ products or services, you can (i) opt out by checking the relevant box located on the form on which your data is collected (or, in some jurisdictions, by failing to opt in), (ii) adjust your email preferences on the profile page which is accessible by clicking the unsubscribe link provided at the bottom of emails you receive from us (or from our Customer), or (iii) at any other time by sending an email stating your request to abuse@vutu.re. We will try to comply with your request(s) as soon as reasonably practicable. Please also note that if you, as a Website Visitor or Customer, opt out of receiving marketing-related emails from us (or as an End-User opt out of receiving marketing-related emails from one of our Customers), we may still send you important administrative messages, and you cannot opt out from receiving administrative messages.

 

Accessing and Correcting Your Information

If you are a registered user of one of our Services, you can review and change your Personal Information and/or email marketing preferences by logging into the Services and visiting your preference page. For example, Users of our Event Management application may update or correct their Personal Information, other profile settings and user preferences by using the Preference Manager within the “My Account” section of the App.

 

You may also send us an e-mail at privacy@vutu.re to request access to, correct or delete any Personal Information that you have provided to us. In your request, please make clear what Personal Information you would like to have changed, whether you would like to have the Personal Information that you have provided to us suppressed from our database, or otherwise let us know what limitations you would like to put on our use of your Personal Information that you have provided to us. For your protection, we may only implement requests with respect to the Personal Information associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

 

Please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting such change or deletion. There may also be residual information that will remain within our databases and other records, which will not be removed.

For a list of all your rights, please refer to the ICO website: https://ico.org.uk/for-organisations/data-protection-reform/overview-of-the-gdpr/individuals-rights/.

 

Children Under the Age of 13

Our Services are not intended for children under 13 years of age. We do not knowingly collect Personal Information from children under 13. If you are under 13, do not (i) use or provide any information on these Services or on or through any of its features, (ii) register to use any of our Services, (iii) make any purchases through our Services, (iv) use any of the interactive or public comment features of our Services or provide any information about yourself to us, including your name, address, telephone number, e-mail address or any screen name or user name you may use. If you believe we might have any information from or about a child under 13, please contact us using one of the means provided below (see Contact Information).

 

Privacy Shield & Dispute Resolution

Vuture has certified its adherence to the U.S.-EU Privacy Shield Framework and the U.S.-Swiss Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of Personal Information from organisations in European Union member countries and Switzerland. To learn more about the Privacy Shield program, and to view Vuture’s certification, please visit https://www.privacyshield.gov.

 

As part of our participation in the Privacy Shield, we have agreed to TRUSTe dispute resolution for disputes relating to our compliance with the Privacy Shield Framework. If you have any complaints regarding our compliance with the Privacy Shield you should first contact us (as provided below). If contacting us does not resolve your complaint, you may raise your complaint with TRUSTe by Internet here. Please click here for fax and postal mail information. TRUSTe's Dispute Resolution process is only available in English. For human resources data we have agreed to cooperate with Data Protection Authorities.

 

You can also report Privacy Right concerns to the ICO here: https://ico.org.uk/concerns/.

 

Cross-Border Transfer

The Services are controlled and operated by us from the United Kingdom, and are not intended to subject us to the laws or jurisdiction of any state, country or territory other than that of the United Kingdom. Your Personal Information may be accessed by Vuture personnel providing Services in any country where we have facilities or in which we engage service providers, and by using the Services you consent to the transfer of information to countries outside of your country of residence, including the United Kingdom, which may have different data protection rules than those of your country.

 

Data Security

We seek to use reasonable organisational, technical and administrative measures to protect Personal Information within our organisation. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please immediately notify us of the problem by contacting us in accordance with the "Contact Information" section below.

 

For more information on Vuture Security, refer to http://vutu.re/technology/security.aspx

 

Retention Period

We will retain your Personal Information for the period necessary to fulfil the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law. Vuture customers can define their own data retention policies in the Application.

 

Changes to Our Privacy Policy

We may change this Privacy Policy. Please take a look at the “Last Modified” section at the top of this page to see when this Privacy Policy was last revised. Any changes to this Privacy Policy will become effective when we post the revised Privacy Policy on the Services. Your use of the Services following these changes means that you accept the revised Privacy Policy.

 

Contact Information

To ask questions or comment about this privacy policy and our privacy practices, contact us at:

 

Vuture Privacy Representative

3rd floor, Crowne House

56-58 Southwark Street

London SE1 1UN, United Kingdom

privacy@vutu.re

 

Please note that email communications are not always secure, so please do not include credit card information or sensitive information in your emails to us.

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