Privacy policy

Welcome to VCV Inc.’s (“VCV”, further in text as well “we”, “our” etc.) privacy policy. VCV respects your privacy and is committed to protecting your personal data.

1. Introduction

This privacy policy tells you how VCV collects, processes and uses your personal data when you visit our website, interact with us, and use our apps and our services.

It also tells you about your privacy rights and how the law protects you.

It is important that you read this privacy policy, together with any other privacy policies we may provide, so that you are fully aware of how and why we are using your data.

This privacy policy was last updated on April 18th, 2019 and historic versions can be obtained by contacting us.

If you have any questions, or would like to exercise your privacy rights, please follow the instructions in this privacy policy. See How to contact VCV about privacy below.

2. Scope

Our website, apps and services are aimed at business users. This website is not intended for children under the age of majority in their jurisdiction and we do not knowingly collect data relating to children.

3. Personal data which we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We collect a variety of information about our users and visitors to the VCV website. This personal data falls into these categories:

  • Identity Data includes title, first name, last name, username or similar identifier and your login/password. If you interact or login to our services with us through social media such as LinkedIn, this may include your user name.
  • Contact Data includes billing address, email address and telephone numbers.
  • Financial Data includes payment card details.
  • Transaction Data includes details about payments to and from you and other details of services you have purchased from us.
  • Profile Data includes your username and password, preferences, feedback and survey responses, as well as any profile data which we have added (for example, using analytics and profiling).
  • Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
  • Usage Data includes information about how you use our website, apps and services.
  • Tracking Data includes information we or others collect about you from cookies and similar tracking technologies, such as mobile identifiers.
  • Marketing and Communications Data includes your preferences in receiving direct marketing from us and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. To provide better content and service, VCV’s website uses the Google Analytics web analytics service. Please see Google’s privacy for more information.  Google provides some additional privacy options described at http://www.google.com/policies/privacy/partners/ with respect to Google Analytics cookies. To opt out from Google Analytics, you can download a plug-in from http://tools.google.com/dlpage/gaoptout.

However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We generally do not collect any Special Categories of Personal Data about you (this includes details about your religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). But as our chatbots talk with you, they may see and collect your race or ethnicity

4. How is your personal data collected?

We use different methods to collect data from and about you including through:

  • Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms, using our services or by corresponding with us by phone, email or through chat or social media.

This includes personal data you provide when you:

  • create an account on our website;
  • use our services;
  • make inquiries or request information be sent to you;
  • sign up to receive our newsletters;
  • contact customer services.
  • Automated technologies or interactions. As you interact with us, including via the website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We may also collect Tracking Data when you use our website.
  • Third parties or publicly available sources. We may receive personal data about you from various types of third parties, including:
  • Technical Data and/or Tracking Data from analytics providers, and search information providers; and
  • Contact, Financial and Transaction Data from providers of payment and fraud prevention services.

5.  How we use your personal data

  • Where we need to perform the contract, we are about to enter into or have entered into with you. For example, when you purchase or signup to use our services, that’s a contract.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. For example, when we send you information that you have requested or to provide you with support you have requested.
  • Where we need to comply with a legal or regulatory obligation. For example, keeping records of our sales for tax compliance.

Our clients will develop the questions for the chatbot to ask job applicants and based on the applicant’s answers and the clients’ response categorizations, the chatbot determines if the applicant will move on to additional interviews.  Where our legal basis is consent, you have the right to withdraw consent any time but you may not be able to use all of our services as a result.

6. Explaining the legal bases we rely on to process personal data

The table below shows you a description of all the ways we plan to use personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Purpose/Activity Type of data Lawful basis for processing
To register you as a new customer / user Identity

Contact

Performance of a contract with you / Acceptance of ToS
To process and deliver the services including:

(a)           Manage payments, fees and charges

(b)           Collect and recover money owed to us

Identity

Contact

Financial

Transaction

Marketing and

Communications

Performance of a contract with you / Acceptance of ToS

Necessary for our legitimate interests (including to recover debts due to us)

To manage our relationship with you which will include:

(a)           Notifying you about changes to our terms or

privacy policy

(b)           Asking you to leave a review or take a survey

Identity

Contact

Profile

Marketing and

Communications

Performance of a contract with you / Acceptance of ToS

Necessary to comply with a legal obligation

Necessary for our legitimate interests (to keep our records updated and to study how customers use our

services)

To deliver direct marketing to you Identity

Contact

Profile

Usage

Marketing and

Communications

Tracking

Technical

For most direct marketing communications, we rely on consent, however there are situations in which it is in our legitimate interests to use your personal data in this way

(Please see ​Advertising, marketing and your communications preferences below)

To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) Identity

Contact

Technical

Tracking

Performance of a contract with you / Acceptance of ToS

Necessary for our legitimate interests (for running our business, provision of

administration and IT services, network security, to prevent fraud and in the context of a business

reorganization            or           group

restructuring exercise)

To deliver the services where you engage in a chatbot interview Identity

Contact

Profile

Usage

Technical

Tracking

Special (race, ethnicity) if your video function is on

Performance of a Contract with you / Acceptance of ToS

Consent

To use data analytics to

improve         our         website,

services,

marketing, customer relationships and

experiences

Technical  Tracking

Usage

Necessary for our legitimate interests (to define types of customers for our services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
In order to resolve legal claims or disputes involving you or us All relevant data categories, depending on the nature of the allegation or claim Necessary to bring or defend a claim

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using / processing your data.

If you need any assistance / clarifications / more details, pls., see below how to contact VCV about privacy.

7. Advertising, marketing and your communications preferences

We may use your Identity, Contact, Technical, Tracking, Usage and Profile Data to form a picture of what we think you may want or need, or what may be of interest to you. This is how we decide which services and offers may be relevant for you and tell you about them. This is what we call direct marketing.

We may carry out direct marketing by email, phone, text or post. For example, you might have the newsletter hit your inbox.

On our website, we always try hard to make it really clear what we are doing and what communications you will be sent, whether it’s you deciding to sign up to the newsletter or as part of creating an account or the purchase journey – and you have a right at any time to change your mind and say no thank you and opt out (but we’d be really sorry to see you go, so please gives us a chance by fine tuning your preferences before really leaving us!). The easiest way to opt out is to use the unsubscribe link at the bottom of the communication.

Of course, there are lots of different ways you’ll see advertisements for VCV on other sites, and not all of these are based on using personal data – sometimes we just buy good old-fashioned advertising space in the real world and websites and social media. If you see VCV’s advertisements on websites, these may not be directed specifically at you, we might just have bid for the space. But here’s some things we may do that may be specifically directed at you:

  • emails, for example the newsletter;
  • text messages, for example with discount codes;
  • promotions by post, such as great money off shipping offers, or from our trusted retail partners; and/or
  • phone calls, to tell you something that might be relevant to you and your business.

We also work with partners to try and promote the reach of our advertisements and use analytics and retargeting for this reason. We use Tracking Data to deliver relevant online advertising, including via websites and social media.

Tracking Data, and in particular — cookies, help us to deliver website advertising that we believe is most relevant to you and to potential new customers of VCV.

Cookies can also tell us if you have seen a specific advertisement, and how long it has been since you have seen it. This is helpful, because it means we can control the effectiveness of our advertisements and control the number of times people might be shown our advertisements (you know, before we risk become annoying). Cookies also help us understand if you’ve opened a marketing email because we don’t want to send you things you don’t read.

If you want more information about Tracking Data, in particular — cookies, see Cookies below.

Almost all the cookies that relate to advertising are part of the third — party online advertising networks. If you’d like to read about how you can control which advertisements you see online, see opt-out programs established by the Digital Advertising Alliance (United States), the Digital Advertising Alliance of Canada and the European Interactive Digital Advertising Alliance. We do not control cookies which are set by advertising networks.

8. Cookies

You can see from Advertising, marketing and your communications preferences above, that cookies are a tool which we (and everyone one else who operates online) uses for advertising. That is just part of why cookies are used. Generally, they are clever.

Cookies help our website and apps work better and provide lots of help in the background to make the process of being a VCV user a lot easier. You’d miss a lot of these things if they were gone – like it being easy to log in and move from page to page.

Other cookies collect information about how visitors use our website, for instance which pages visitors go to most often, and if they get error messages from web pages. These cookies don’t collect information that identifies a visitor. All information these cookies collect is aggregated and used to improve how our website works.

There are also cookies that allow our website to remember choices you make (such as your user name, language or the region you are in) and provide enhanced, more personal features.

There are cookies that collect information about your browsing habits in order to make advertising delivered to you more relevant to you and your interests (see Advertising, marketing and your communications preferences above). They are usually placed by advertising networks with our permission. They remember that you have visited a website and this information is shared with other organizations such as advertisers. Quite often targeting or advertising cookies will be linked to site functionality provided by the other organization.

When you use our website, your device or browser may send cookies from the third — parties, for example when using embedded content and social network links. It’s important for you to know that we have no access to or control over cookies used by these companies or third-party websites. We suggest you check the third-party websites for more information about their cookies and how to manage them.

You can see more information about the cookies we use as provided above Google Analytics link and here link to Yandex Metrics.

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

9. Disclosures of your personal data

We may share your personal data with the parties set out below for the purposes set out in this privacy policy. We may also share your personal data if the law otherwise allows / requests it.

We may share personal data with the following categories` third parties:

  • Suppliers and service providers (such as technology service providers such as our hosting provider, payment processing and fraud prevention providers);
  • auditors and professional advisers like bankers, lawyers, accountants and insurers;
  • our clients seeking to hire individuals- so they will be able to see your resume or CV videos on our website;
  • government, regulators and law enforcement.

For example, we share personal data with the following specific third parties:

We also share data with the third — parties connected to advertising, retargeting and analytics. Please see Section 8 Cookies above.

We may also share data with the third — parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

10. Payment information

VCV uses the third party payment processor to process payments made for services via the Website. All online payments will be conducted in accordance with Payment Card Industry (PCI) data security standards and your billing information (which is only used by these payment processors for the purpose of performing fraud protection) is encrypted before being communicated to them. Subject to the below exceptions, your credit card details are communicated directly from your browser to these payment processors — VCV does not see your full Permanent Account Number (PAN). This means that the payment form is either off-site or displayed in a frame on the payment page.

11. International transfers

The information you enter on the website, apps or services or otherwise provide to VCV may be transferred outside of your country to the United States of America and other jurisdictions which does not offer an equivalent level of protection as in other parts of the world (i.e., as in the European Union). In particular, you are advised that the United States of America uses a sectoral model of privacy protection that relies on a mix of legislation, governmental regulation, and self-regulation. The European Union’s General Data Protection Regulation (“GDPR”) allows for transfer of personal data from the European Union to a third country in certain situations. By agreeing to the terms of use and this Privacy Policy, you agree to the transfer of all such information to the United States of America which may not offer an equivalent level of protection to that required in other countries, particularly the European Union, and to the processing of that information by VCV on its servers located in the United States of America as described in this Privacy Policy. In our discretion, we may adopt other means, such as entering into Model Contract Clauses, or enter into different certification programs under applicable law for ensuring adequate safeguards.

12. Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed, such as encryption, firewalls, password protection, third party audits and other internal restrictions. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

13. Data retention and minimization

We will only keep your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting, or law requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for a certain period of time after they stop being customers for tax purposes.

In some circumstances you can ask us to delete your data; see Your legal rights below for further information.

In some circumstances we may anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

14. Your legal rights

If the General Data Protection Regulation applies to you because you are a citizen of European Union, you have the rights under data protection laws in relation to your personal data:

  • The right to be informed – that’s an obligation on us to inform you how we use your personal data (and that’s what we’re doing in this privacy policy);
  • The right of access – that’s your right to get to know what personal data we hold about you and how and for what purpose those data are being processed;
  • The right to rectification – that’s your right to make us to correct your personal data that may be incomplete or inaccurate;
  • The right to erasure – that’s also known as the ‘right to be forgotten’ where in certain circumstances you can ask us to delete the personal data we have about you (unless there’s an overriding legal reason we need to keep it);
  • The right to restrict processing – that’s a right for you in certain circumstances to ask us to suspend processing personal data;
  • The right to data portability – that’s a right for you to ask us for a copy of your personal data in a common format (for example, a .csv file);
  • The right to object – that’s a right for you to object to us processing your personal data (for example, if you object to us processing your data for direct marketing); and
  • Rights in relation to automated decision making and profiling – that’s a right you have for us to be transparent about any profiling we do, or any automated decision making.

These rights are subject to certain rules around when you can exercise them. You can see a lot more information on them, if you are interested, on the UK Information Commissioner’s Office website.

If you wish to exercise any of the rights set out above, please contact us (see Section 15 How to contact VCV about privacy).

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact DPO using the details in Section 15 How to contact VCV about privacy below.

You have the right to make a complaint at any time to the Information Commissioner’s Office (“ICO”), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

15.  How to contact VCV about privacy

If you have any questions about this privacy policy, or would like to exercise any of your rights, please email us at support@vcv.ai

If you need help about our services, or this website generally, please contact us support@vcv.ai

16. A little request from VCV to you

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us. You can do this by updating your account. Thank you.

17. Changes to this privacy policy

We may update our privacy policy from time to time. Be sure to check in and have read every now and then. Thank you.