Privacy Policy - V2 Communications

V2 Communications (“V2”) is committed to respecting the privacy rights of website visitors. The following policy describes how we collect, protect, use, and share information we receive from you.

Effective Date: July 31, 2020

This Privacy Policy explains how V2 Communications (“V2” or “we”) collects personal information through our website at https://www.v2comms.com (our “Website”) in the course of our public relations activities and when you provide us your information by telephone or email or at an in-person event or otherwise engage with us.

INFORMATION WE COLLECT AND HOW WE COLLECT IT

Information you provide to us

Certain parts of our Website may ask that you voluntarily provide us with personal information. For example, we may ask you to provide us your name, address, telephone number or email address and contact preferences when you subscribe to our newsletters or other communications, download any of our resources or contact us through the Website. If you choose to correspond with us through email or in person, we collect and retain other information that you give us, such as your name and business contact information, your email address, content of your email message, your website address and our response.

When you apply for a job with V2, we collect the employment-related information you submit, such as job preferences, work history and similar information provided in your application.

Information we collect automatically

When you interact with our Website and marketing emails, we collect certain information automatically. Some of this automatically-collected information is personal information under certain laws.

The information we collect automatically includes your IP address, browser and operating system information, clickstream data (referring website address, web pages visited, time and date of visit and links clicked), device type and ID, cookie ID, language and other technical information.

HOW WE USE INFORMATION

We use the information that we collect on or through the Website:

To respond to your requests or provide you with information that you request;
To communicate with you about updates to our services;
To maintain our Website and tailor our Website to your needs;
For data analysis, such as identifying usage trends, determining the effectiveness of our marketing and to enhance, customize and improve our Website;
To comply with and enforce applicable legal requirements;
To prevent, detect, identify, investigate, respond and protect against potential or actual claims, liabilities, prohibited behavior and criminal activity; and
To notify you about important changes to our Website and other information and resources that we think you will find valuable. You may notify us at any time if you do not wish to receive these emails by contacting us at [email protected] or clicking the “unsubscribe” link in our emails.

HOW WE SHARE YOUR INFORMATION

We disclose your personal information to:

Our vendors and business partners that or who provide data processing services to us, such as services that provide functionality on the Website or enhance the security of our Website;
An actual or proposed acquirer (and its agents and advisers) in connection with any proposed purchase, investment, merger or acquisition of all or any part of our business. We will inform the acquirer that it must use your personal information only for the purposes disclosed in this Privacy Policy; and
Any other person or entity with your consent where required or otherwise as permitted by applicable law.

We also may share personal information with any competent law enforcement body, regulatory or government agency, court or other third party if we determine disclosure is necessary (i) as a matter of applicable law or regulation, (ii) to exercise, establish or defend our legal rights or (iii) to protect your vital interests or those of any other person.

HOW WE USE COOKIES AND SIMILAR TRACKING TECHNOLOGY ON THE WEBSITE

The Website uses cookies and similar data collection technology.

Cookies generally. A cookie is a small data file that contains a unique identification number that is stored in your web browser when you surf the Internet. For example, cookies store information about your computer, the type of browser you use, how many times you visit the Website and similar technical information.

Cookies set by us are called “first party cookies.” First-party cookies enable us to track how often people are using the Website, the specific pages visited and similar actions. Cookies set by other parties are called “third party cookies.” Third-party cookies enable certain features, such as social media widgets, analytics, interactive content and (for some websites but not our Website) targeted advertising. The parties that set these third-party cookies can recognize your browser or device both when it visits the Website and when it visits other websites.

You can set your web browser to reject cookies. You do not need to have cookies turned on to use the Website. You may, however, find that some areas of the Website are slower or do not function at all if cookies are disabled. To learn more about cookies generally, visit http://www.allaboutcookies.org.

Generally, the information collected through data collection technology does not directly identify you to us personally and is aggregated with other data to create audience segments.

Why we use cookies. Some cookies – known as “essential” or “strictly necessary” cookies – are required for technical reasons in order for the Website to operate.

Analytics cookies enable us to collect information about how the Website is used and improve your experience of the Website. One of our analytics cookies is set by Google Analytics to collect aggregate information about use of the Website and report website trends to us. Google Analytics does not directly identify individual users. You can learn about Google’s practices at https://safety.google/privacy/privacy-controls/.

Advertising cookies are used to infer your interests based on your online activities and target ads that are most relevant to you based on the inferred interests. That is, when you surf the Internet, you may see different kinds of ads, such as ads next to search results. Sometimes, these ads are based on the content of the pages on which they appear and sometimes these ads are generated by matching the particular ad to your interests as inferred from your online activities collected over time. At this time, V2 does not use advertising cookies or targeted advertising in connection with the Website.

The Website also may from time to time use clear GIFs (also known as pixel tags or web beacons). A clear GIF is computer code that contains a unique identifier that enables us to monitor user activity and traffic of the Website. We may use GIFs to gather aggregate information on visits to the Website, track usage of Website links and assist with features of the Website.

Our Policy On Do Not Track Signals. Most web browsers incorporate a “Do Not Track” (“DNT”) or similar feature that signals to websites that a user does not want to have his or her online activity and behavior tracked. If a website that responds to a particular DNT signal receives the DNT signal, the browser blocks that website from collecting certain personal information about the browser’s user. Not all browsers offer a DNT option and DNT signals are not yet uniform. For this reason, many website operators, including V2, do not respond to DNT signals.

HOW WE PROTECT AND RETAIN INFORMATION

We use administrative, physical and technical safeguards intended to protect the personal information that we collect from and about you through the Website. Our safeguards are designed to provide a level of security appropriate to the risk of processing your personal information and include (as applicable) measures to ensure the ongoing confidentiality, integrity, availability and resilience of processing systems and a procedure for regularly testing, assessing and evaluating the effectiveness in preserving the security of personal information.

We retain personal information that we collect through the Website for as long as we have a legitimate business need to do so. When we no longer have a legitimate business need, we dispose of personal information in accordance with applicable law.

CHOICES ABOUT YOUR PERSONAL INFORMATION

If you receive marketing emails from us, you can opt out at any time by clicking the opt-out or unsubscribe link in the marketing email. Once you opt out, we will no longer send you marketing emails but still may send you emails with transactional information.

If you are a resident of California or located in the EU, please see our California Privacy Notice or Privacy Notice for Individuals Located in European Union, respectively, below to learn more about the privacy rights available to you. If you are located in a jurisdiction with data protection laws that you believe offer you privacy rights not described in this Privacy Policy, please contact us at [email protected].

CALIFORNIA PRIVACY NOTICE

The California Consumer Privacy Act of 2018 (“CCPA”) offers residents of the State of California – referred to as “Consumers” in CCPA – certain privacy rights with respect to their Personal Information. This California Privacy Notice describes the privacy rights available to California Consumers and how to exercise them.

In CCPA, “Personal Information” means information that identifies, relates to, describes, is capable of being associated with or could reasonably be linked, directly or indirectly, with a particular California Consumer or household.

California Privacy Rights

If you are a California Consumer, then CCPA gives you the following rights:

You have the right to request information about the Personal Information that we collected about you (see table below) and how and why we collect it.
You have the right to opt out of V2’s sale of your Personal Information when and if V2 sells your Personal Information. In CCPA, “sale” means transferring or making available Personal Information to third parties for monetary or other valuable consideration. WE DO NOT SELL PERSONAL INFORMATION.
You have the right to request information about our disclosure for business purposes of your Personal Information to third parties.
You have the right to request the deletion of your Personal Information.
You have the right to not be discriminated against for exercising any of these rights.

The following table lists categories of Personal Information that generally match the categories in the definition of Personal Information in CCPA. We indicate for each listed category the specific types of Personal Information in the category that we have collected within the past 12 months. We use all of the Personal Information that we collect for the purposes described in this Privacy Policy and table below.

Category of Personal Information under CCPA	Examples of Personal Information in Category Collected By V2	Why V2 Collects the Personal Information
A. Identifiers	Name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, and other similar identifiers that you choose to send it to us via email or our contact form	To provide the Website, to customize your experience and to communicate with you.
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))	Name, telephone number	To provide the Website, to customize your experience and to communicate with you.
C. Protected classification characteristics under California or federal law	NONE
D. Commercial information	Records of services purchased	To promote our services.
E. Biometric information	NONE
F. Internet or other similar network activity	Browsing history, search history, information on a consumer’s interaction with the Website	To promote our services.
G. Geolocation data	NONE
H. Audio, electronic, visual, thermal, olfactory or similar information.	NONE
I. Professional or employment-related information	Information included in your resume or application for employment or information you choose to send to us via email or our contact form	If you apply for a job with V2, we will use the information that you provide to us to review your application for employment.
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. § 1232g, 34 C.F.R. Part 99))	NONE
K. Inferences drawn from other categories (A. – L above) to create a profile about a consumer	Profile reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes	To customize your experience with the Website, to improve the Website, to develop new features and to communicate with you about features of the Website or our services that may interest you.

How to Submit Your Request to Exercise Your California Privacy Rights

Please note:

We may (and in some cases are required to) verify your identity before we can act on your request to exercise your privacy rights.
We may not honor part or all of a request you make to exercise your rights under CCPA. When this occurs, we will explain why in our response. For example, certain information we collect is exempt from this California Privacy Notice, such as publicly-available information collected from a government agency or personal information collected in connection with providing our services to you (aka B2B personal information), which is exempt until January 1, 2021.

If you are a California resident and would like to exercise one or more of your privacy rights, please:

Send an email to [email protected]. Please include “California Privacy Rights” in the subject line.
Call our toll-free number at 833-888-0623.

If this California Privacy Notice and any provision in the rest of our Privacy Policy conflict, then this California Privacy Notice controls for the processing of Personal Information of California Consumers.

A different California law permits California residents to request a notice disclosing the categories of personal information about you that we have shared with third parties for their direct marketing purposes during the preceding calendar year. We do not share with third parties for their direct marketing purposes any of the personal information about you that we collect.

PRIVACY NOTICE FOR INDIVIDUALS LOCATED IN EUROPEAN UNION

In this Privacy Notice for Individuals Located in the European Union (“EU Notice”), “personal data” means any information about an identified or identifiable individual person.

The data controller (i.e., the person or entity that determines the purpose and means of processing) for the personal data that V2 collects directly from or about you (and not on behalf of our clients) is:

V2 Communications

Attn: Legal

500 Harrison Avenue,

Boston, MA 02118

When we are the data controller of personal data, we need to inform individuals in the European Union (“EU”) about the legal bases for our processing of their personal data. Our legal bases depend on the context in which the personal data is collected and processed. Generally, we only collect personal data when we need the personal data to perform a contract with an individual in the EU, when we have consent to do so or when the processing is in our legitimate business interests and not overridden by the privacy or other fundamental rights and freedoms of individuals in the EU.

When V2 is acting as a controller and processes your personal data in reliance on our legitimate interests (or those of any third party), this interest is typically to provide our Website and communicate with you, such as when we respond to your queries, to improve our Website and for our marketing activities. We may have other legitimate interests and we will make clear our legitimate interests at the relevant time when necessary.

In some cases, we also may have a legal obligation to collect personal data from or about certain individuals. If we ask you to provide personal data to comply with a legal obligation or to perform a contract with you, we will make this clear at the relevant time and advise you whether providing your personal data is mandatory and the possible consequences if you do not provide your personal data.

If you have questions or need further information about the data controller of your personal data or the legal bases on which your personal data is processed, please contact us using the contact details provided below.

If you would like to review, correct, update, suppress, restrict or delete personal data that you have previously provided to us or if you would like to receive an electronic copy of your personal data for purposes of transmitting it to another organization (when this right to portability is provided to you by law), please submit your request by contacting us by email at [email protected] with the subject line of “EU Privacy” or by mail at:

V2 Communications

Attn: Legal

500 Harrison Avenue

Boston, MA 02118

In your request, please make clear the personal data to which your request relates. For your protection, we may need to verify your identity before fulfilling your request. We will comply with your request as soon as reasonably practicable and within the time periods required by applicable law.

We often need to retain certain personal data for recordkeeping purposes and/or to complete any transaction that you began prior to requesting a change or deletion. We also may not allow you to review certain personal data for legal, security or other reasons.

If you are an individual located in the EU, you have the right to lodge a complaint with a data protection authority about how we process your personal data. Please see https://ec.europa.eu/info/law/law-topic/data-protection/reform/what-are-data-protection-authorities-dpas_en for more information.

International Transfers of Personal Data

Our servers are located in the United States, which may be outside the jurisdiction where personal data is collected. Also, some of the third-party service providers with which we may share personal data are located in and may transfer personal data to various jurisdictions. These other jurisdictions may have data protection laws that are different from the laws of your place of residence (and, in some cases, not as protective).

We use appropriate safeguards to ensure that your personal data is protected in accordance with this EU Notice and applicable law. These safeguards include implementing the European Commission’s Standard Contractual Clauses for transfers of personal data with our clients based in the EU.

LINKS TO OTHER WEBSITES

The Website may include links to third-party websites, applications, widgets and other online services that are not operated by us. When you use a third party website or service linked to the Website, you are subject to its privacy practices and policies, not ours. This Privacy Policy applies only to information collected by V2 through the Website.

CHILDREN’S PRIVACY

The Website is not intended for use by minors (i.e., a child under the age of majority in a particular jurisdiction). V2 does not knowingly collect personal information from minors. Consistent with the requirements of applicable law, if we learn that a minor has improperly provided us with personal information, we will use that information only to respond directly to that minor (or his or her parent or legal guardian) to inform the minor that he or she cannot use the Website and subsequently will delete that information.

UPDATES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time in response to changing legal, technical or business developments. When we update our Privacy Policy, we will post the updated version and change the Effective Date above. If we make material changes that affect your privacy rights, we also will take appropriate measures to inform you in advance so that you have an opportunity to review the revised Privacy Policy before it becomes effective. If your consent is required by applicable privacy laws, we will obtain your consent to the updates before the revised Privacy Policy applies to you.

QUESTIONS?

If you have any questions about this Privacy Policy, please contact us by email at [email protected] or by mail at:

V2 Communications

Attn: Legal

500 Harrison Avenue,

Boston, MA 02118