Your Privacy Rights

Key Terms

Definition

VPM Solutions (“We” or “us” or “our”)

Virtual Property Management Solutions, LLC

Personal Information

Any information relating to an identified or identifiable individual which may include contact data (such as name, mailing and email address, telephone number), demographic information (such as age, zip code, date of birth, and gender), and work-related information (such as experience, skill sets, certifications, or job history).

Website

Any of our websites at which you accessed this privacy policy, including www.virtualpmsolutions.com and the Platform

Applications

Our mobile application that is available for you to install or otherwise operate on your cellular phone or other device

Platform

The Website, Applications, and the services we provided through them

User

Users of the Website or Application may be Clients or Virtual Team Members as defined in the VPM Terms of Service Agreement found at https://www.vpmsolutions.com/terms-of-service

Categories of Personal Information

Personal Information Collected

Personal Identifiers 

Name, home and/or billing address, phone number, date of birth, email address, social media account information, profile data including profile pictures and video recordings for use on the Platform, professional information (such as work history), and a unique ID number that is assigned to your User Account

Sensitive Information

Social Security Number, Tax Identification Number, citizenship information, government authorized identification cards such as a passport or drivers license

Financial Information

Credit card, bank account, or other financial information provided to us by you.  Many pieces of information about your payment, such as your bank account or credit card number, are actually collected by a third-party payment processor through the Platform as described below. 

Communication

Emails or electronic correspondence that you send to us or another User or that you post to a public or private forum on the Platform. This includes the contents of any messages you send on the Platform.

Internet or other electronic network activity information

Unique device and app identifiers, browsing history or other usage data, the browser and operating system you are using, the URL or advertisement that referred you to the Website, the search terms you entered into a search engine that led you to the Website, areas within the Website or Platform that you visited, which links you clicked on, which pages or content you viewed and for how long, other similar information and statistics about your interactions, such as content response times, download errors and length of visits to certain pages and other information commonly shared when browsers communicate with website. 

Other information that can be reasonably associated with a User

User-generated content (such as job postings or applications), photographs, video recordings, examples of your work, information on work previously performed on the Platform, prior work history outside of the Platform, skill, tests or certifications taken, hourly pay rates and earnings information.

What we use your personal information for

Why

To provide products or services to you

To improve the Platform, complete your transactions, address your inquiries, process your registration, verify your information, and for compliance and internal business process. Much of our processing of Personal Information is to meet our contractual obligations to you or to take steps at your request in anticipation of entering into a contract with you. 

Communications

To respond to inquiries by you, to contact you with administrative communications from VPM Solutions including newsletters, to contact you or other Users with promotional communications and marketing materials, and other information that may be of interest to you or other Users. Such use is for our legitimate interests or those of a third party to ensure Users have accurate, updated information regarding the Platform.

To prevent and detect fraud 

For our legitimate interests or those of a third party to ensure business policies and the Terms of Use are adhered to and, for example, to minimize fraud that could be damaging for us and for you

To comply with our legal obligations  

To comply with professional, legal, and regulatory obligations that apply to our business, including gathering and providing Personal Information to auditors or regulatory organizations. This also includes our ability to conduct an investigation, to protect the property and rights of VPM Solutions or a third party, to protect the safety of the public or any person, or to prevent or stop activity we may consider to be or pose of risk of being illegal, fraudulent, unethical or legally actionable activity.

Operational reasons

For our legitimate interests or those of a third party, to, for example, improve efficiency, improve the Platform or Website, training, and quality control

Ensuring the confidentiality of commercially sensitive information

For our legitimate interests or those of a third party, i.e. to protect trade secrets and other commercially valuable information. And to comply with our legal and regulatory obligations

Statistical analysis

For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service for you at the best price

Preventing unauthorized access and modifications to systems

For our legitimate interests or those of a third party, i.e. to prevent and detect criminal activity, fraud, or other malfeasance that could be damaging for us and/or you. And to comply with our legal and regulatory obligations

Updating User records

To ensure accurate records in our Platform, for the performance of our contract with you, to take steps at your request before entering into a contract

Ensuring safe working practices, staff administration, and assessments

To comply with our legal and regulatory obligations. Also for our legitimate interests or those of a third party, e.g. to make sure we are following our own internal procedures and working efficiently so we can deliver the best service to you

Marketing 

To market our services to existing and former customers; third parties who have previously expressed an interest in our services; third parties with whom we have had no previous dealings. For our legitimate interests or those of a third party, i.e. to promote our business to potential, existing, and former customers

External audits and quality checks

For our legitimate interests or those of a third party, i.e. to maintain our accreditations so we can demonstrate we operate at the highest standards and to comply with our legal and regulatory obligations

Users

For Virtual Team Members who make their profiles publicly visible, we may share their information with Clients. For Clients who post a job, we may share your information with Virtual Team Members. 

For Clients and Virtual Team Members who have entered into a Services Contract, we may share your information to complete the transaction or resolve a claim or dispute. The receiving user is not allowed to use your information for purposes unrelated to the transaction, such as for promotional marketing unless you have consented to it.  

Service Providers

We may use service providers and individuals to facilitate payment processing, tax reporting, fraud detection, image verification, document verification, web analytics, and other services. These service providers may include analytics companies, advertising partners, payment processors, identity verification companies, security companies, hosting companies, generative AI partners, or other merchants. These third parties may have access to your Personal Information to perform these tasks on our behalf. 

Legal and investigative purposes

We will share information with government agencies as required by law including, without limitation, in response to lawful requests by public authorities to meet national security or law enforcement requirements and in connection with reporting earnings. We cooperate with government and law enforcement officials and private parties to enforce and comply with the law. We will disclose information about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal process (including but not limited to subpoenas), or, at the request of governmental authorities or other third parties conducting an investigation where we determine in our sole discretion the disclosure is necessary to (a) protect the property and rights of VPM Solutions or a third party, (b) protect the safety of the public or any person, or (c) prevent or stop activity we may consider to be, or pose a risk of being, illegal, fraudulent, unethical or legally actionable activity.

Business Transfers

We may sell, transfer, or otherwise share some or all of our assets, including your Personal Information, in connection with a merger, acquisition, reorganization or sale of assets or in the event of bankruptcy. 

Non-identifying Information and De-Identified Information

We may share aggregated non-identifying information and we may otherwise disclose non-identifying information, including hashed information, or de-identified information to third parties and for our own marketing uses. 

Right to Access

The right to be provided with a copy of your personal information (the right of access)

Right to Rectification

The right to require us to correct any mistakes in your personal information

Right to Erasure

The right to require us to delete your personal information—in certain situations

Right to Restriction of Processing

The right to require us to restrict processing of your personal information—in certain circumstances, e.g. if you contest the accuracy of the data

Right to Data Portability

The right to receive the personal information you provided to us, in a structured, commonly used, and machine-readable format and/or transmit that data to a third party—in certain situations

Right to Object

The right to object:

• at any time to your personal information being processed for direct marketing (including profiling);

• in certain other situations to our continued processing of your personal information, e.g. processing carried out for the purpose of our legitimate interests.

Right Not to be Subject to Automated Individual Decision-Making

The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you

Disclosure of Personal Information We Collect About You

California residents have the right to request that we disclose the following information to you about our collection and use of your personal information over the past twelve (12) months. We may ask you to provide certain information to identify yourself so that we may compare it with our records to verify your request. Upon verification, we will disclose to you:

• The categories of personal information we have collected about you.

• The categories of sources for the personal information we have collected about you.

• The specific pieces of personal information we have collected about you.

• Our business or commercial purpose for collecting or “selling” your personal information as defined by the CCPA.

• The categories of third parties to whom we have sold or shared your personal information, if any, and the categories of personal information that we have shared with each third-party recipient.

Please note that we are not required to:

• Retain any personal information about you that was collected for a single one-time transaction if, in the ordinary course of business, that information about you is not retained;

• Reidentify or otherwise link any data that, in the ordinary course of business, is not maintained in a manner that would be considered personal information; or

• Provide the personal information to you more than twice in a 12-month period.

Right to Opt-Out of “Sale” or “Sharing” of Personal Information

California residents have the right to opt-out of the “sale” or “sharing” of their personal information as defined by the CCPA by contacting us at info@vpmsolutions.com with the subject line “CCPA”. Please note that we do not knowingly “sell” the personal information of any individuals under the age of 18.

Where we are “sharing” your personal information with third parties for the purposes of cross-context behavioral advertising or profiling, you may opt-out of such sharing at any time by submitting a request

Right to Deletion

California residents have the right to request that we delete any of the personal information collected from you and retained by us, subject to certain exceptions. We may ask you to provide certain information to identify yourself so that we may compare it with our records in order to verify your request. Once your request is verified and we have determined that we are required to delete the requested personal information in accordance with the CCPA, we will delete, and direct our service providers to delete your personal information from their records. Your request to delete personal information that we have collected may be denied if we conclude it is necessary for us to retain such personal information under one or more of the exceptions listed in the CCPA.

Please note that we may not delete your personal information if it is necessary to:

• Complete the transaction for which the personal information was collected, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between you and us;

• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity;

• Debug to identify and repair errors that impair existing intended functionality;

• Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law;

• Comply with the California Electronic Communications Privacy Act;

• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when our deletion of the information is likely to render impossible or seriously impair the achievement of such research, provided we have obtained your informed consent;

• Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us;

• Comply with an existing legal obligation; or

• Otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information.

Right to Correct

Under the CCPA, as amended by the CPRA, California residents have the right to request that we correct any inaccurate personal information we maintain about you, taking into account the nature of the personal information and the purposes for which we are processing such personal information. We will use commercially reasonable efforts to correct such inaccurate personal information about you.

Right to Limit Use of Sensitive Personal Information

California residents may have the right to request that businesses limit the use of any sensitive personal information to those uses which are necessary to perform the Services or for other specifically-enumerated business purposes under the CCPA, as amended by the CPRA. Please note that we do not use sensitive personal information other than as necessary to perform the Services or as specifically permitted under the CCPA.

Protection Against Discrimination

You will not receive any discriminatory treatment by us for the exercise of your privacy rights conferred by the CCPA.