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    Your Privacy Rights

    This privacy notice was last updated on 07/03/24

    Please read this Privacy Policy carefully as it contains important information on who VPM Solutions is, and how and why we collect, store, use, and share your personal information collected from our Websites and Applications. It also explains your rights regarding your personal information and how to contact us in the event you have a complaint. The Privacy Policy is to be read in conjunction with our Terms of Use.

     

    1. Definitions.

    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

     

    1. Personal Information We Collect About You.

     

    When you use the Platform, you may provide us with information about you. This may include your name and contact information, financial information to make or receive payment for services obtained through the VPM Solutions Platform, or information related to taxes. When you use the Platform, we may also collect information concerning your use of the Platform and aggregate this with other Users which helps us improve the Platform for you.

    Depending on our relationship with you, we may collect the following categories and types of Personal Information from and about you:

     

    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.



    1. How Your Personal Information is Collected.

    We collect most of this personal information directly from you. For example, when you contact us through our Website, sign up for an Account, or send us other Communications. However, we may also collect information:

    • When you create a profile on the Platform;

    • When you submit documents or records;

    • When you communicate with another User or VPM Solutions;

    • When you install and/or operate an Application on your device;

    • When you apply for or post a job opportunity on the Platform; and

    • From cookies and similar online tracking and analytic technology on our website.

    We may also collect information about your visit to the Website or on the Platform, including the pages you view, the links you click, and other actions taken. We may also collect standard information that your browser sends to every website you visit, such as your IP address, browser type and language, access times, and referring website addresses. We may, in the future, include other optional requests for information from you to help us tailor the Website or Platform by delivering more personal information to you. 

     

    1. Information collected by our desktop applications (Mac, Windows, and Linux):

    While a Virtual Team Member is working on a project for a Client, we may also collect screenshots, applications currently being worked on, web URLs visited, time you are active, the operating system you are using, whether or not you have an input device such as a monitor, whether your mouse is actively moving or not, the names of projects or tasks being worked on, the amount of time worked on those tasks, the browser version you are using, and whether your keyboard is being typed on. VPM Solutions may share this information with the relevant Client.

    Note: VPM Solutions does not utilize a keylogging program.

     

    1. Information Collected Automatically

    VPM Solutions uses technologies, such as cookies or similar, to analyze trends, traffic to our Website, track users movement around the Website, Platform and Applications, and to gather demographic information about our user base as a whole. This technology may include cookies, web beacons, and embedded scripts. We may use other technologies that collect similar information for security and fraud detection and we may use third-parties to perform these services on our behalf. You are given the option to consent to the collection and use of your data in this manner prior to it being collected. 

     

    1. Analytics Providers

    VPM Solutions uses Google Analytics to provide us with information regarding traffic on the Website and Platform. For more information about how Google uses data when you use our site, visit www.google.com/policies/privacy/partners. Users may download the Google Analytics Opt-out Browser Add-on at: https://tools.google.com/dlpage/gaoptout.

     

    1. How and Why We Use Your Personal Information.

    We may use the information you provide about yourself to fulfill your requests for services and programs offered by us, to respond to your inquiries about our offerings, and to offer you other services, programs and products that we believe may be of interest to you. We use your personal information:

    • Where you have given consent, including where you have consented to provide your information to another User in connection with a job opportunity on our Platform.

    • To develop and administer our business relationship with you or an entity you represent;

    • To comply with our legal and regulatory obligations;

    • For our legitimate interests or those of a third party. A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests. For example:

      • Providing our Website and Platform

      • Detecting security incidents, protecting against malicious, fraudulent, deceptive, or illegal activity and prosecuting those responsible for that activity

      • Measuring interest and engagement in our Platform and Website

      • Developing new products, features, and services

      • Ensuring internal trust & safety

      • Authenticating and verifying identities

      • Debugging the Website and Platform

      • Enforcing our agreements and policies

      • Analyzing and improving our business

      • Communications, including marketing and responding to your inquiries about our services

      • Managing legal issues

    • If you register an Account as a Virtual Team Member, Clients have access to your Personal Information listed in your profile and you may receive emails, SMS, or phone calls directly from them. 

    The table below explains what we use, or process, your personal information for and our reasons for doing so:

     

    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

     

    1. Promotional Communications.

    We may use your Personal Information to send you promotional and administrative updates (by email, text message, telephone, or post) about our products and services. You have the right to opt-out of receiving promotional communications from us at any time by:

    • Using the “unsubscribe” link in emails or “STOP” number in texts; or

    • Updating your preferences in your Account settings or, with respect to Applications, through the settings of your Application.

    We may ask you to confirm or update your preferences if you instruct us to provide further products and/or services in the future, or if there are changes in the law, regulation, or the structure of our business.

     

    1. Who We Share Your Personal Information With.

    We do not sell your Personal Information for monetary consideration. However, we may use technologies on our Platform for the purposes of payment, marketing, or advertising. We may also share information we have collected about you, including Personal Information, as disclosed at the time you provide your information, with your consent, as otherwise described in this Privacy Policy or for the following purposes:

     

    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. 

     

    1. “Do Not Track” Notice

    Our website does not monitor, recognize, or honor any opt-out or do not track mechanisms, including general web browser “Do Not Track” settings and/or signals.

     

    1. Personal Information We Sold or Disclosed for a Business Purpose.

    In the preceding 12 months, we have not sold Personal Information to any third-party.

    In the preceding 12 months, we have disclosed for a business purpose to one or more third parties the following categories of Personal Information:

    • Personal Identifiers;
    • Communications with another User of the Platform; 

    • Payment Information collected by our third-party payment processor Service Provider; and,

    • Internet or other electronic network activity information

     

    1. Where Your Personal Information is Held.

    Information is held at our offices and those of our Service Providers, representatives, and agents as described above (see above: “Who We Share Your Personal Information with”) or on computer servers used or maintained by those entities. 

    12.1 Cross-Border Data Transfers

    Because we are a U.S. company, we process and store your information in the United States and our Service Providers may process and store it elsewhere. We may transfer your personal information to a third party that is located in a jurisdiction other than the one from which we collected your personal information, including to countries that have not been deemed to have an adequate level of protection for the rights and freedoms of data subjects. If we do transfer your personal information to another jurisdiction, we will do so following provided that the data recipient is subject to contractual agreements imposing obligations on it to ensure appropriate technical and organizational are implemented and maintained at all times to prevent the unauthorized and unlawful processing of personal information, and the accidental loss or destruction of, or damage to, personal information, consistent with our obligations under applicable data protection laws. We will use appropriate legal transfer mechanisms, including Standard Contractual Clauses, where required by law.

     

    1. Retention of Personal Information.

    Unless we delete your information subject to a legitimate request, we reserve the right to keep your personal information indefinitely, including while you have an account with us or while we are providing products and/or services to you. We will also keep your personal information for as long as is necessary:

    • To respond to any questions, complaints, or claims made by you or on your behalf;

    • To show that we treated you fairly; or

    • To keep records required by law.

     

    1. EU Data Subject’s Rights Under the GDPR.

    If you are a data subject in the European Union, you may have the following rights under the GDPR:

     

    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



    1. Notice for California Residents.

    If you are a resident of California, you may have the right under the California Consumer Privacy Act (CCPA)/California Privacy Rights Act (CPRA) and certain other privacy and data protection laws, as applicable, to exercise free of charge:

    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.



    1. How to Exercise Your Rights.

    Registered Account Users may delete their account and control their data options on the settings of the Application. California and European users may exercise their rights at:

    • On our website at www.vpmsolutions.com; 

    • Via email at info @vpmsolutions.com; or

    • Call us, toll-free, at (800) 759-0279;  

     

    Please note that you may only make CCPA-related data access or data portability disclosure request twice within a 12-month period.

    If you choose to contact us directly (i.e., outside of logging in to your account on our website), you will need to provide us with:

    • Enough information to identify you (e.g., your full name, address);

    • Proof of your identity and address (e.g., a copy of your driving license or passport and a recent utility or credit card bill); and

    • A description of what right you want to exercise and the information to which your request relates.

    We are not obligated to make a data access or data portability disclosure if we cannot verify that the person making the request is the person about whom we collected information or is someone authorized to act on such person’s behalf. Any personal information we collect from you to verify your identity in connection with your request will be used solely for the purposes of verification.

     

    1. Security

    VPM Solutions takes reasonable steps to help protect and secure the information it collects and stores about Users. We maintain reasonable administrative, technical, and physical safeguards designed to protect personal information that we receive against accidental, unlawful, or unauthorized destruction, loss, alteration, access, disclosure or use.

     

    1. Changes to This Privacy Notice.

    VPM Solutions reserves the right to modify this Privacy Policy at any time. We will occasionally update this Privacy Policy to reflect changes in our services and customer feedback. When we post changes to this Privacy Policy, we will revise the “last updated” date at the bottom of this statement. It is your responsibility to check periodically for changes.

     

    1. How to Contact Us.

    You may contact us at info@vpmsolutions.com or by filling out the form here.