1. INTRODUCTION

 

This privacy policy (the “Policy”) is designed to inform users of our website, www.vitalaglobal.org (the “Site”), and other users from whom we collect personal information, about how Vitala Global Foundation (“Vitala”) collects, uses, and/or shares personal information in connection with the services that we provide.  Vitala takes individual privacy seriously and we endeavor to inform you of the uses that we have for information that we obtain from you (collectively, “Personal Information”).  We will take reasonable commercial steps to protect your privacy consistent with the guidelines set forth in this policy and with applicable federal and state laws.  In this policy, "user," “your,” or "you" refers to any individual from whom we obtain Personal Information, whether by browsing our Site, creating an account on our Site, or participating in any other activities or accessing services through us.  As the manners in which we obtain Personal Information and our uses for Personal Information may change, we encourage you to return to and reread this policy from time to time.  

 

By accessing or using our Site, you acknowledge that you have read, understand, and agree to be bound by this policy.  If you do not agree to the terms of this policy, do not use our Site.

 

2. WHAT INFORMATION DO WE COLLECT?

 

We collect two types of Personal Information from you: (1) Contact Information, and (2) Device Information.

 

CONTACT INFORMATION

 

When you write to us through our contact form here, subscribe to our newsletter here, sign up as a Site member for user-testing here, or otherwise interact with us over the Internet, via email, on the telephone, or in person, we may collect certain Contact Information from you.  Depending on the particular circumstances, this “Contact Information” may include, but are not limited to: your first and last name, email address, telephone number, or postal addresses.

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DEVICE INFORMATION

 

We may collect certain web tracking information about your device in connection with your use of and browsing of our Site.  Depending on the circumstances, this “Device Information” may include, but is not limited to: information about your web browser (e.g., browser type, domain names, access times, and operating system), Internet protocol address (“IP address“), individual web pages or products that you view, the web pages or search terms that referred you to our Site, how you interact with our Site, time zone, and/or information about the cookies installed on your device.  We may use cookies and navigational data like Uniform Resource Locators (“URLs”) to gather information regarding the date and time of your visit and the information for which you searched and viewed.

 

Cookies are small pieces of information that a website sends to your computer’s hard drive while you are viewing a website.  To provide you with a more personal and interactive experience on our Site, we may use session cookies, which expire when you close your web browser.  We may also use persistent cookies, which may remain on your computer for up to two years following your last visit to our Site, unless you remove them earlier.  Cookies can generally be removed by following Internet browser help file directions.  If you choose to disable cookies, some areas of our Site may not work properly.  For more information, visit www.allaboutcookies.org.

 

3. HOW DO WE USE YOUR INFORMATION?

 

PERSONAL INFORMATION 

 

We may generally use Personal Information for a variety of purposes including, but not limited to: providing or communicating with you regarding our services; adding you to our newsletter subscription list; granting you access to a user-testing platform; maintaining or servicing customer accounts; providing customer service; processing orders and transactions; verifying customer information; processing payments; providing analytic services; detecting security incidents that may compromise the confidentiality of Personal Information in our possession; maintaining or improving the quality or safety of our services; processing an employment application; and/or enforcing our legal rights or as required by applicable law or requested by any judicial process or governmental agency.

 

Additionally, we may use Device Information for specific purposes including, but not limited to: helping us screen for and prevent potential risk of fraud (in particular, through any IP address we collect from you); administering and optimizing our Site; making our services more useful to you; generating analytics about how our customers browse and interact with our Site; assessing the success of our marketing and advertising campaigns; and/or storing your user preferences.  We may also use Device Information in conjunction with Google Analytics to help us understand how visitors use our Site.  You can read more about how Google’s privacy policies here: 

https://www.google.com/intl/en/policies/privacy/.

 

In accordance with applicable law, Vitala will generally use only the minimum amount and scope of your Personal Information necessary to achieve the above purposes.

 

Please note that by posting or sending us messages, uploading files, inputting data, or engaging in any other form of communication through our Site, you are granting us a license to use the content of any such message, file, data, or communication.

 

AGGREGATED INFORMATION

 

We may also create usage, statistical, de-identified, anonymized, or aggregated Data (collectively, “Aggregated Data”) relating to our users and our Site for analytical and/or research purposes.  Aggregated Data includes data derived from Personal Information and data collected by Vitala from other sources that has been anonymized so that it does not relate to or identify any individual.  This data is used to understand our user base and to develop, improve, and market our Site.

 

EMAIL COMMUNICATIONS 

 

If you provide us with your email address, we may send you administrative and promotional emails, including newsletters.  If you wish to opt out of newsletters and promotional emails, you may do so by following the "unsubscribe" instructions in the email.

 

4. WHAT INFORMATION DO WE SHARE OR DISCLOSE?

 

PERSONAL INFORMATION

 

We generally will not share or disclose Personal Information with any third-parties, except in accordance with applicable law under the following circumstances:

 

• When you have consented to us sharing or disclosing your Personal Information.

 

• When the Personal Information is shared with or disclosed to a parent company, subsidiary, joint venture, or other entity under common control with us in order to achieve any of the purposes described in Section 3.

 

• Subject to the terms of a confidentiality agreement, in connection with, and for the purposes of, a business deal (or negotiation of a business deal) involving the sale or transfer of all or a part of our business or assets.  These deals may include any merger, financing, acquisition, or bankruptcy proceeding.

 

• With a third-party contractor engaged to provide management, administrative, or support services on our behalf (a "Contractor") which require the Contractor to have access to Personal Information.  In this instance, we enter into an agreement with the Contractor limiting the Contractor’s use of the Personal Information to the minimum amount necessary to perform the services; requiring the Contractor to report any suspected or actual breach of security or other incident related to the Personal Information to us; and requiring the Contractor to adhere to the same level of privacy requirements that are required of us by all applicable law.  By accessing or using our Site, you consent to our sharing your Personal Information with our Contractors and to our Contractors’ use of your Personal Information in accordance with all applicable law, this policy, and the other terms and conditions applicable to our Sites.

 

• To detect, prevent, or otherwise address security, fraud, or technical issues.

 

• To enforce our contracts and agreements (including this policy).

 

• To comply with legal obligations, processes or requests, or to protect or defend our legal rights.

 

• To ensure the personal safety of any individual, including our employees and/or agents, Site users, or members of the general public.

 

• Additionally, Device Information may be shared with Google as described in Section 3.

 

AGGREGATED INFORMATION

 

In our sole discretion, we may disclose any Aggregated Data that does not contain Personal Information to any third-parties for any reason.

 

NETWORK OPERATORS

 

Use of our Site may involve the use of third-party search engine operators or telecommunications carriers.  These operators are not our Contractors, and any information that these operators collect in connection with your use of our Site is not a part of our collected Personal Information and is not subject to this policy.  We are not responsible for the acts or omissions of these operators.

 

5. YOUR RIGHTS REGARDING YOUR INFORMATION

 

PRIVACY SETTINGS / RIGHT TO REMOVE

 

If you would like your Personal Information, or any account you have with us, to be permanently removed from our database, please contact us by email at hello@vitalglobal.org.  We may ask you to provide a copy of your driver’s license or other identifying documents to assist us in processing your request.  Vitala may still contact users who have requested that their Personal Information be permanently removed for administrative purposes.  The removal of your Personal Information may take some time to complete, consistent with applicable law.  Further, Aggregated Information is not subject to requests for removal. 

 

ACCESSING AND UPDATING THE INFORMATION

 

Vitala will, to the best of our ability and in accordance with applicable law, allow you to access, review, correct, or add to your Personal Information held in our database.  To do so, please contact us by email at hello@vitalglobal.org.

 

6. ADDITIONAL POLICIES

 

SECURITY

 

In accordance with applicable law, we have put in place appropriate, commercially reasonable physical, electronic, and managerial procedures and security precautions to protect your Personal Information.  However, no Internet transmission is completely secure, and we cannot guarantee that security breaches will not occur.  We are not responsible for the actions of hackers and other unauthorized third-parties that breach our reasonable security procedures.  This policy is not intended to confer, nor does it confer, any rights or remedies to users.

 

THIRD-PARTY ACTIVITY (INCLUDING LINKS AND COOKIES)

 

Our Site may contain links to other websites, cookies, or other materials from, or which may be operated by, parties other than Vitala.  The information practices and privacy policies of these parties may be different than ours.  Vitala is not responsible for any actions or omissions by these third-parties.  This policy applies only to Personal Information collected by Vitala.

 

DATA RETENTION

 

Unless you ask us to delete your Personal Information sooner, we will maintain it until such time that we determine, in our discretion, that (1) it is no longer necessary for any purpose for which Vitala may use it in accordance with this policy; and (2) may be destroyed or deleted in accordance with applicable law.

 

DO NOT TRACK

 

We do not respond to Do Not Track (DNT) signals or requests.  DNT is a web browser setting that informs a website that you do not want to be tracked.

 

AMENDMENTS 

 

Vitala will review this policy from time to time and may modify or amend it as necessary to comply with applicable law.  We may also update the Policy to reflect changes to our practices or for other operational reasons.  If we make any material changes to how Personal Information is collected, used, disclosed, or transferred, we will notify you of these changes by modifying the version of this policy, which is available for your review on our Site.  Accordingly, we encourage you to review this policy from time to time.  Notwithstanding any modifications we may make, all Personal Information will be treated in accordance with the version of the Policy that is/was in effect at the time the Personal Information was collected, unless we obtain your consent otherwise.   

 

COMPLAINTS

 

In the event you wish to submit a complaint about how we have processed any Personal Information, or to contact us for any other related reasons, please contact us by email at hello@vitalglobal.org.  We will deal with your complaint or request as soon as possible, and without prejudice to you.  In addition to submitting a complaint to us, you may of course also file any complaint with a relevant government agency or authority in the state or jurisdiction in which you live or work.

 

ACCESSIBILITY

 

Any person with a disability that prevents or restricts them from accessing this policy through Vitala’s website may request a copy in an alternative format by contacting us by email at hello@vitalglobal.org.

 

CHILDREN

 

The Children’s Online Privacy Protection Act imposes certain requirements on website operators that have actual knowledge that they collect Personal Information from children under 13 years of age.  Vitala does not knowingly collect or maintain Personal Information from persons under 13 years of age, and no part of our Site is directed at persons under 13.  If you are under 13 years of age, please do not use our Site.  If Vitala learns that Personal Information of persons less than 13 years of age has been collected without verifiable parental consent, Vitala will delete the Personal Information.

 

WEBSITE VISITORS FROM OUTSIDE THE UNITED STATES

 

Vitala and its servers are located in Canada and Israel and operate in the United States, subject to the applicable state and federal laws of the United States.  Those who choose to access our Site do so on their own initiative and at their own risk, and are responsible for complying with all local laws, rules, and regulations.  We may limit our Site’s availability, in whole or in part, to any person, geographic area or jurisdiction we choose, at any time and in our sole discretion.  We do not represent or warrant that our Site, or any part thereof, is appropriate or available for use in any other jurisdiction.  If you choose to access or use our Site, you consent to the use and disclosure of information in accordance with this policy and subject to such laws.

 

7. NOTICE FOR RESIDENTS OF THE EUROPEAN ECONOMIC AREA, UNITED KINGDOM, OR SWITZERLAND

 

We do not market our services to residents of Europe, the United Kingdom (UK), or Switzerland, and are not subject to Regulation 2016/679 of the European Parliament and of the Council of April 27, 2016, on the protection of natural persons with regard to the processing of Personal Information and free movement of Personal Information, known as the General Data Protection Regulation (“GDPR”).  If you reside in the European Economic Area (“EEA”), UK, or Switzerland, please be aware that if you voluntarily provide us with any Personal Information, that information will be transferred from your location to data centers located in the United States for processing, and this transfer will be deemed to have been made with your consent.

 

Although we are not subject to the GDPR, we will generally make commercially reasonable efforts to honor your data privacy rights upon request, subject to certain limitations.  If you reside in the EEA, UK, or Switzerland, you have the right, as applicable under the GDPR, to the following:

 

• Request an accounting of Personal Information that we possess that pertains to you in an electronically portable format.  

• Request that we correct or update Personal Information that pertains to you.

• Request that we delete Personal Information that pertains to you. 

• Fully or partially withdraw your consent to the collection, processing, and/or transfer of your Personal Information.

 

If you believe we are unlawfully possessing your Personal Information, you have the right to complain to your local data protection supervisory authority.  You can find contact details here: https://edpb.europa.eu/about-edpb/board/members_en.

 

To request an accounting of your Personal Information, a correction or update to your Personal Information, deletion of your Personal Information, or to withdraw your consent to the collection, processing, and/or transfer of your Personal Information, please contact us by email at hello@vitalglobal.org.  Once we receive your request, we will no longer process your Personal Information for the above purposes unless there are legitimate grounds for further processing which override your interests, rights, and freedoms, or for the establishment, exercise, or defense of legal claims.

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Privacy Policy updated September 2023