vCita, Inc. (“vCita”) respects the privacy of users (a “User” or “Users”) and experts (an “Expert” or “Experts”) alike. This policy explains vCita’s privacy practices in connection with the use of the web-application (the “Web-App”) operated by vCita for Expert and Users and the services rendered through the Web-App by Expert to User (the “Services”). It also describes the ways vCita collects and uses personal information of Users and Experts and the rights and options available to Users and Experts with respect to their information. We may refer to Users and Experts together as “You”.
This policy is incorporated into the vCita-Expert Services Agreement between vCita and Expert (the “Expert Agreement”). Capitalized terms not defined herein shall have the meaning ascribed to them in the Expert Agreement.
What personal information does the Expert provide to vCita?
As an Expert, when you register to the Web-App, you may be asked to provide vCita an active e-mail address and other contact and personal details (or other allowed identification means), and to select a password. vCita may ask you to provide additional payment and transaction related personal information, to the extent required.
Please bear in mind that false, incorrect, incomplete, or outdated information may prevent you from registering and using the Services or the Web-App, or impair vCita’s ability to provide you with the Services or the Web-App and to contact you.
What Internet traffic does vCita collect?
vCita’s Web-App provides a comprehensive solution to Users and Experts, which enables them to contact each other, schedule an appointment, form a contract, pay and receive fees, interact and manage their engagement by using the Web-App. The Web-App is installed on vCita’s servers, and when you use the Web-App, the information routed via the Web-App is accessible to vCita.
When you use the Services or the Web-App, vCita will collect information, such as session durations, page impressions, Internet protocol (IP) addresses, the domain name that served you to access the Services or the Web-App, and content types and origins.
vCita will also store information related to online data or metadata that is routed through vCita’s servers, such as web pages’ addresses, structures, data fields and images.
The stored data will be attributed to you in person, only to the extent necessary for the use of the Web-App or the Services, as set in the following chapter. In all other cases, vCita will anonymize the data and will not knowingly use the data to personally identify you.
Further information may be collected when you and vCita exchange communications, for example, when you submit an inquiry to the customer support at: email@example.com.
Does vCita collect location based information?
vCita does not actively collect any personal information that is based on your geographical location, except for the country that you reside in when accessing the Services or the Web-App. However, certain location based information may be stored on vCita’s servers, for example if you use the Services or the Web-App to access geographic based services. vCita will use such information subject to this policy and will anonymize such data as soon as it is no longer necessary for the performance of the Services by Expert or the use of the Web-App.
What does vCita do with your personally identifiable information?
vCita may use personally identifiable information for the following purposes:
- to provide and operate the Services or the Web-App;
- to send you updates and notices and to provide you with information related to the Services or the Web-App, provided that vCita will not share your e-mail address or any other personally identifiable information with online advertisers and advertising networks, without your explicit consent;
- to enforce the Expert Agreement;
- to contact you as and when vCita believes it to be necessary;
- to comply with any applicable law and assist law enforcement agencies as required;
- in any case where vCita believes that the use of the information is necessary to prevent imminent physical harm or damage to property;
- to collect fees and debts, and to prevent fraud, misappropriation, infringements, identity thefts and any other misuse of the Services or the Web-App; and
- to take any action in any case of dispute, or legal proceeding of any kind between you and vCita, or between you and other users or third parties with respect to, or in relation with the Services or the Web-App.
As a vCita user, your personal information may be maintained, processed and stored by vCita, our affiliates, and our service providers in the United States or other jurisdictions. vCita adheres to the Safe Harbor Privacy Principles according to the U.S.-EU Safe Harbor Framework and the U.S.-Swiss Safe Harbor Framework. The Safe Harbor program is intended to provide equivalent protections for personal data as exist in the EU and Switzerland. For more information about the Safe Harbor and to view our certification, visit the U.S. Department of Commerce’s Safe Harbor website at http://export.gov/safeharbor/.
If you have any questions about our Safe Harbor participation, please contact us using the information below. If you believe that vCita has not satisfactorily addressed your data privacy concerns related to the U.S.-EU Safe Harbor Privacy Principles or the U.S.-Swiss Safe Harbor Privacy Principals, and without prejudice to any other remedy you may enjoy, you may obtain dispute resolution services through The DMA Safe Harbor Program.
In relation to information of users collected and stored through the vCita Web-App (“Clients’ Data”), vCita serves as a data “Processor” (due to the technical hosting thereof) and not as a data “Controller” (as both such capitalized terms are defined in the European Data Protection Directive). The Experts controlling and operating the vCita Web-App shall be considered the controllers of such Clients’ Data and are responsible for complying with all laws and regulations as may be applicable to the collection and control of such Clients’ Data including privacy or data protection laws of all relevant jurisdictions. vCita cannot provide legal advice to Experts, but vCita recommends that all Experts that create and maintain websites using vCita platform should maintain clear and comprehensive privacy policies complying with the applicable laws and regulations.
Important notice about privacy of persons under the age of 18
The Services and the Web-App are not intended for use by persons under the age of 18. If you are not 18 years old or older, then you may not use any of the Services or the Web-App and must not provide any of your personal details.
vCita strongly encourages parents to monitor their children’s use of the Web. vCita will delete a child’s personally identifiable information if a parent so requests by sending an e-mail to firstname.lastname@example.org. If vCita learns that a child under the age of 18 years has provided personally identifiable information to vCita without verifiable parental consent, vCita will use commercially reasonable efforts to delete such information from vCita’s databases.
How does vCita share your personally identifiable information with others?
vCita does not sell, rent or lease your personally identifiable information to third parties. vCita may share personally identifiable information with others in any of the following instances, or otherwise subject to your explicit consent:
- to operate the Services or the Web-App, including to store and process your information through a third party hosting services and to process payments;
- to contact you. For example, vCita may use a third party’s mailing platform to send you messages and updates from time to time;
- if vCita believes that you have breached the Expert Agreement or any other agreement with vCita, or abused your rights to use the Services or the Web-App, or performed any act or omission that vCita believes to be violating any applicable law, rules, or regulations. vCita may share your information with law enforcement agencies, governmental agencies and other competent authorities as well as with other third parties, as may be required;
- if vCita is required, or believes that it is required by law to share or disclose your information;
- in any case of dispute, or legal proceeding of any kind between you and vCita, or between you and other users or third parties with respect to, or in relation with the Services or the Web-App (including a dispute between User and Expert);
- in any case where vCita believes that sharing information is necessary to prevent imminent physical harm or damage to property;
- if vCita organizes the operation of the Services or the Web-App within a different framework, or through another legal structure or entity, or if vCita is acquired by, or merged with another entity, provided, however, that those entities agree to be bound by the provisions of this policy, with respective changes taken into consideration; and
- vCita may also share personally identifiable information with sub-contractors and other companies or organizations connected, or affiliated with vCita, such as subsidiaries, sister-companies and parent companies.
How does vCita use aggregated information?
vCita may also use anonymous, statistical or aggregated information to properly operate the Services or the Web-App, to improve the quality and functionality of the Services or the Web-App, to enhance your experience, to create new services, including customized services, to change or cancel existing content or services and for other internal and statistical purposes.
vCita may share, publish, post, disseminate, transmit or otherwise communicate or make available such information, to suppliers, business partners, sponsors, affiliates and any other third party, at vCita’s sole discretion, provided, however, that vCita will not knowingly, or intentionally use the information to reveal your identity without your consent.
How can you access your personal information?
If you are an Expert and registered to the Web-App, then you may access your personal account and edit or amend your personal information at any time using the designated user interface in the Web-App. If you find that the information on your personal account is not accurate, complete or updated, then you may make all necessary changes to correct it. Otherwise, both Experts and Users may contact us at email@example.com.
Which ‘opt out’ and deletion options are available to you?
At any time you may opt out of vCita’s mailing lists, by sending vCita a removal request to: firstname.lastname@example.org. It may take up to ten (10) business days for your opt-out request to take effect.
If you wish to delete your personally identifiable information that is stored in vCita’s database, you may send a request to delete information to: email@example.com. vCita will inform you whether it can accept your request. vCita may refuse your request, for example, if vCita believes that removal of certain information may jeopardize certain activities of the Services or the Web-App, or harm other users. In any case, vCita may keep any aggregated or anonymized information for statistical, marketing and other purposes, indefinitely.
How does vCita secure your personal information?
vCita and third parties on its behalf implement information security systems and procedures to secure your personal information. While such systems and procedures reduce the risk of security breaches, they do not provide absolute security. Therefore, vCita cannot guarantee that the Services or the Web-App will be immune from any wrongdoings, malfunctions, unlawful interceptions or unauthorized access to the information stored therein and to other information security risks, or that your private communications on or through the Services or the Web-App will remain private.
We restrict access to personal information you provided vCita to our employees, contractors, vendors and agents who need to know that information for the purposes described in this policy. These individuals are obligated to keep your personal information confidential and they may be subject to penalties, termination of relations and criminal prosecution, if they fail to comply with such obligations.
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Where is my personal information processed?
vCita may store and process the information through a third party’s hosting services in the USA or in other jurisdictions, at its discretion. If you are in the European Economic Area, or in any other jurisdiction that regulates the transfer of personal information outside that jurisdiction, then you hereby grant vCita your explicit and unambiguous consent to transfer your personal information to the USA or to any other jurisdiction where vCita’s hosting services operate, for the purposes described in this policy.
vCita is doing its utmost to comply with this Policy. If you have any questions, concerns or complaints regarding this policy and the enforcement thereof, please refer them to: firstname.lastname@example.org. After receiving your complaint, vCita may contact you to better understand your concerns and will make all efforts to promptly answer your question, or resolve your complaint to your full satisfaction.
vCita may change and update the terms of this policy from time to time. Changes will take effect seven (7) days after their initial posting on the Website or the Web-App, unless vCita amends the policy to comply with legal requirements. In the latter cases the amendments will become effective as required, or ordered.
Last Updated: October 28, 2015