Effective date: March, 2019
Your privacy is important to us, and we want to make sure you understand exactly how we use your data when you entrust your information with us.
“Personal Data” is information relating to an identified or identifiable natural person.
- Categories of Personal Data Processed, including Personal Data Processed through Cookies
- Third-Party Recipients of Personal Data
- Cross-Border Transfers of Personal Data
- Children’s Privacy
- Retention of Personal Data
- Information Security
- Your Rights
- Your California Privacy Rights
- How to Contact Us
- Data Controller and Data Protection Officer
Categories of Personal Data Processed, including Personal Data Processed through Cookies
Personal Data that is processed when you submit a “Contact Us” form through the website: When you contact us online, we may collect Personal Data, including your name, company name, job title, business email address, and reason for contact, which may tell us that you would to learn more about VIAGIO, you are interested in a career at VIAGIO, or you have a question about our service offerings.
We may also create event logs that are useful in diagnosing performance-related issues and capturing information relating to the client support or service issue. To improve client service, subject to applicable laws, we may also record and review conversations with client support specialists, and analyze any feedback provided through voluntary client surveys. With your consent, we may log in to your account, if appropriate, to help troubleshoot and resolve your issue.
Purposes and Legal Grounds:
- If you are contacting us to ask questions about your current program or request more information about VIAGIO, we use this information to provide you with appropriate client support. If you are contacting us because you are interested in a career at VIAGIO, we use this information to provide you with relevant information about potential career opportunities at VIAGIO. We also use this information to monitor the quality and types of client support that we provide. The legal ground for processing this information for these purposes is VIAGIO legitimate interest in providing quality support to users’ requests for assistance and information. The legal ground for logging in to your VIAGIO account, if appropriate, to help troubleshoot and assist you in accessing your account, is consent, which you may withdraw.
- VIAGIO may also process the Personal Data of its website and app users for the purpose of sending you emails regarding VIAGIO events, webinars, reports, newsletters, other publications, marketing materials, and surveys. If you reside in the European Union (EU) or in any country that requires us to obtain your consent before using your Personal Data for purposes of direct marketing, we will process this information based on your opt-in consent, which you may withdraw at any time by contacting VIAGIO’s Data Protection Officer by email at help@ViagioTech.com or by writing to Data Protection Officer, Viagio Technologies, LLC, 9237 Ward Parkway, Suite 300, Kansas City, MO 64114.
Purposes and Legal Grounds:
- VIAGIO processes your email address for the purpose of permitting you to submit your job application for a potential position at VIAGIO. The legal ground for processing your email for this purpose is VIAGIO legitimate interest in permitting you to submit your job application.
Cookies are small computer files sent or accessed from your web browser on your computer’s, mobile device’s, or tablet’s hard drive that contain information about your computer, such as user ID, user settings, browsing history, and activities conducted while using VIAGIO Site. A Cookie typically contains the domain name (internet location) from which the Cookie originated, the “lifetime” of the Cookie (i.e., when it expires), and a randomly generated unique number or identifier.
Purposes and Legal Grounds:
- We use this usage data to facilitate communication between your device and our systems, store your preferences, authenticate users and detect and prevent fraud, enable certain functions of the website, administer and improve our website and applications, and analyze usage of and improve and enhance VIAGIO Sites and Apps
- If you are in the EU or another country that requires obtaining your consent before processing your usage data, we process your usage data based on the consent you provide when you click the box noting that you “agree” to the processing of your Personal Data Obtained through Cookies and Other Data Collection Tools. You may withdraw your consent by contacting our Data Protection Officer by email at help@ViagioTech.com or by writing to Data Protection Officer, Viagio Technologies, LLC, 9237 Ward Parkway, Suite 300, Kansas City, MO 64114.
- Your Control of Cookies: Web browsers allow some control of most Cookies through browser settings. Some web browsers (including mobile web browsers) provide settings that allow you to reject Cookies or that alert you when a Cookie is placed on your computer, tablet, or mobile device. You may be able to reject mobile device identifiers by activating the appropriate setting on your mobile device. Although you are not required to accept VIAGIO Cookies or mobile device identifiers, if you block or reject them, you may not have access to all features available through the VIAGIO Site or App. You will have an opportunity to manage your Cookie preferences on our websites and/or applications; except that certain Cookies are required to enable the core functionality of such websites and applications and you cannot choose to disable those Cookies.
Personal Data that is processed when complying with legal obligations and enforcing legal rights: VIAGIO will process Personal Data collected through the ViagioTech.com website as needed, to comply with legal obligations and enforce legal rights.
Purposes and Legal Grounds:
- VIAGIO processes such Personal Data collected through the ViagioTech.com website to enforce its rights, protect VIAGIO’s property or protect the rights, property, or safety of others, or, as needed, to support VIAGIO’s external auditing, compliance, and corporate governance functions. The legal ground for processing Personal Data for this purpose is VIAGIO’s legitimate interest in enforcing its rights, protecting its property or protecting the rights, property or safety of others, or as needed to support its external auditing, compliance, and corporate governance functions.
Third-Party Recipients of Personal Data
- Third-Party Service Providers Analyzing Usage of VIAGIO Sites and Apps: We use Personal Data collected from cookies and other data collection tools for usage analytics, fraud detection, and performance improvement for VIAGIO Sites and Apps. We may use third-party website analytics services to analyze how individuals use VIAGIO Sites and Apps, including to record mouse clicks, mouse movements, scrolling activity, and text that you type into free-form boxes. We use information collected from these third-party services to help us better understand how our users find and use VIAGIO Sites and Apps, enhance our services, and improve your user experience.
- Third Parties Assisting with Electronic Communications: Your Personal Data will be used, as needed, to manage our relationship and communicate with you by mail, telephone, email, mobile alerts, and SMS text messaging. We may share your Personal Data with service providers that assist us in communicating with you.
- Third-Party Service Providers Assisting with Print Mail Direct Marketing: Where permissible, we also may share your Personal Data with direct mail service firms that assist us in printing, addressing, and distributing printed materials and other physical marketing materials. Such firms may access name, title, company, and company address information for the purpose of printing shipping and mailing labels. VIAGIO uses this data to reach clients and prospects with non-digital marketing and product-related communications.
- Other Service Providers: We may share your information, including your Personal Data, with other service providers we use to perform the functions for which we engage them, such as hosting, data storage, and security. We may also share your Personal Data as needed to operate other related VIAGIO Sites and Apps, such as ratings and reviews websites that we operate.
- Third Parties Viewing Your Posts or Receiving Your Communications: We may use and share your Personal Data in order to perform services you request or actions you initiate, such as when you post information on message boards, forums, or on our Social Media pages. In addition, when you give us permission, we may disclose your Personal Data in order to identify you to anyone to whom you send communications through the VIAGIO Sites and Apps.
- Law Enforcement and Other Public Authorities: VIAGIO may also share the information we collect from you, as needed, to enforce its rights, protect its property or protect the rights, property or safety of others, or, as needed, to support VIAGIO’s external auditing, compliance, and corporate governance functions. VIAGIO will disclose Personal Data as it deems necessary to respond to a subpoena, binding order of a data protection authority or judge, legal process, governmental request, or any other legal or regulatory obligation. In each case, the disclosure may be to a person or entity outside of your country of residence. VIAGIO may be required to disclose Personal Data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. VIAGIO may also share Personal Data as required to pursue available legal remedies or limit damages it may sustain.
Cross-Border Transfers of Personal Data
VIAGIO controls and operates our Sites and Apps from the United States. If you are located outside of the United States, VIAGIO will transfer, store, and process your Personal Data in the United States. The data protection and privacy laws of the United States may not be as comprehensive as the laws in your country. For example, Personal Data transferred to the United States may be subject to lawful access requests by federal and state authorities in the United States.
Any transfers of Personal Data from the European Economic Area (“EEA”) to the United States are made pursuant to the EU-U.S. Privacy Shield. Viagio Technologies, LLC participates in and complies with the EU-U.S. Privacy Shield principles regarding the collection, use, sharing, and retention of Personal Data from the EEA, as described in our EU-U.S. Privacy Shield certification. VIAGIO is committed to subject to the EU-U.S. Privacy Shield principles all Personal Data received from the EU in reliance on the Privacy Shield. View the Privacy Shield list here. Learn more about the Privacy Shield here.
If you live in the EU and you have a complaint about our Privacy Shield compliance, contact our Data Protection Officer by email at help@ViagioTech.com or by writing to Data Protection Officer, Viagio Technologies, LLC, 9237 Ward Parkway, Suite 300, Kansas City, MO 64114.
If your complaint cannot be resolved through VIAGIO’s internal processes, you can refer a complaint, free of charge, to our chosen independent dispute resolution body, American Arbitration Association, and in certain circumstances, invoke the Privacy Shield arbitration process.
The ViagioTech.com website is not directed to individuals under the age of 18, and we request that individuals under 18 not provide Personal Data to VIAGIO. If we learn that we have collected Personal Data from a child under 16, we will take steps to delete the information as soon as possible.
Retention of Personal Data
We will retain your Personal Data in our records for no longer than is necessary for the purposes for which it was originally collected. When such information is no longer needed for the purposes for which it was originally collected, we will securely delete all of your electronic Personal Data, and securely dispose of any hard copy Personal Data, except for what is needed to comply with our legal obligations. See section below under “Your Rights” for additional information pertaining to the right of erasure, as well as other data subject rights.
VIAGIO has an information security program that implements technical, physical, and organizational measures designed to assist in maintaining the security and confidentiality of Personal Data; safeguarding against anticipated threats to the confidentiality, integrity, and availability of Personal Data; and protecting your Personal Data against loss, misuse, unauthorized alteration or destruction, and unauthorized access or disclosure.
However, whenever Personal Data is processed, there is a risk that such data could be lost, misused, modified, hacked, breached, and/or otherwise accessed by an unauthorized third party. No system or online transmission of data is completely secure. In addition to the technical, physical, and organizational measures that VIAGIO has in place to protect your Personal Data, you should use appropriate security measures to protect your Personal Data. If you believe that your account or any information you provided to us is no longer secure, notify our Data Protection Officer immediately by email at help@ViagioTech.com.
If you reside in the EU, you have the right under the General Data Protection Regulation to request access to and rectification or erasure of your Personal Data, data portability, restriction of processing of your Personal Data, the right to object to processing of your Personal Data, the right to withdraw your consent, and the right to lodge a complaint with a supervisory authority.
If you reside in the EU, you may opt out of usage of your Personal Data for purposes materially different than those for which your Personal Data was originally collected or subsequently authorized. You also may opt out of disclosures of your Personal Data, if any, to third-party controllers. But if you do not want your Personal Data disclosed to the client for which a survey is being conducted, you may not be eligible to participate in the survey. If we collect any sensitive Personal Data (e.g., health data) from you, we will obtain your opt-in consent before disclosing such data to a third party or using your Personal Data for a purpose other than that for which it was originally collected or subsequently authorized.
If you live in the EU, and if you wish to exercise any of these rights, contact our Data Protection Officer by email at help@ViagioTech.com or by writing to Data Protection Officer, Viagio Technologies, LLC, 9237 Ward Parkway, Suite 300, Kansas City, MO 64114.
If you reside outside of the EU, you may have similar rights under your local laws. If you do not live in the EU but you think you have any of these data subject rights under your local laws, please contact our Data Protection Officer by email at help@ViagioTech.com or by writing to Data Protection Officer, Viagio Technologies, LLC, 9237 Ward Parkway, Suite 300, Kansas City, MO 64114.
To the extent that the personal data VIAGIO Sites and Apps collects is considered to be HR data (e.g. recruitment information), the independent recourse mechanism is the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues.
In compliance with the Privacy Shield Principles, VIAGIO commits to resolve complaints about our collection or use of your personal information. EU individuals with inquiries or complaints regarding our Privacy Shield policy should first contact our Data Protection Officer by email at help@ViagioTech.com or by writing to Data Protection Officer, Viagio Technologies, LLC, 9237 Ward Parkway, Suite 300, Kansas City, MO 64114.
VIAGIO has further committed to cooperate with the panel established by the EU data protection authorities (DPAs) with regard to unresolved Privacy Shield complaints concerning human resources data transferred from the EU in the context of the employment relationship.
Your California Privacy Rights
Do Not Track. VIAGIO does not track its customers over time and across third-party websites and online services (e.g., mobile apps), and therefore does not respond to Do Not Track (DNT) signals. However, some third-party sites and apps may track your browsing activities when they provide you content, which enables them to tailor what they present to you. Third parties may collect Personal Data relating to your online activities over time and across different websites and apps when you use our services.
How to Contact Us
If you have questions about privacy, need assistance with accessing or updating your Personal Data, or have complaints relating to the processing of your Personal Data, contact our Data Protection Officer by email at help@ViagioTech.com.
You can also write to us at:
Viagio Technologies, LLC.
Attn: Data Protection Officer
9237 Ward Parkway
Kansas City, MO 64114
Data Controller and Data Protection Officer
VIAGIO is the controller of the Personal Data that is collected through the ViagioTech.com website. You can contact VIAGIO’s Data Protection Officer by email at help@ViagioTech.com or by writing to Data Protection Officer, Viagio Technologies, LLC, 9237 Ward Parkway, Suite 300, Kansas City, MO 64114.