(b) Except as specified herein, this policy does not apply to information you may provide to us offline.
(c) Certain features of the Covered Sites may be subject to additional privacy provisions, which will be posted on the Covered Site in connection with such features.
2. Collection of Information
(a) Information You Provide. VHMP collects Personally Identifiable Information that you voluntarily provide. For instance, when you subscribe to receive newsletters, promotional correspondence, or other services, or send us an email or feedback, you may be asked to provide information such as your e-mail address and name, and we will collect such information as well as the other information you provide us. If you post material to any blogs or forums, or participate in our social networking features or other community boards offered on our Covered Sites, that information will also be collected and may be publicly available for others to view.
(b) Cookies and other technologies.
(ii) Some of our third party partners (including advertisers and marketing services companies) may set and access cookies and similar technologies on your computer as well, or we may do so on their behalf, to help us deliver marketing messages on our sites and on other sites. We require that these third party partners provide consumers with the ability to opt out of their use of information for these purposes. You should see this icon in and around our advertisements that are delivered on other sites using information collected on our sites. Clicking this icon will provide information about the companies and data practices that were used to deliver the ad and will also describe how you may opt out of this type of advertising program. Similarly, advertising may be customized based on information obtained from your use of our mobile applications. This type of advertising involves the use of device identifiers. You can limit this type of advertising using options presented in your device setting controls that limit ad tracking or reset your advertising identifier.
(iv) Some of our emails may contain tags that allow us and our advertisers and other partners to determine the types of content that may be of interest to you. Those tags may contain Personally Identifiable Information and may be shared with others to the same extent indicated in Section 4. Those tags may not be deleted but you can opt out of receiving the emails as explained in section 5.
(c) Gifs. We may use “clear GIFs” (aka “web beacons” or “pixel tags”) or similar technologies, in the sites and applications and in our communications with you to enable us to know whether you have visited a web page or received a message. A clear GIF is typically a one-pixel, transparent image (although it can be a visible image as well), located on a web page or in an e-mail or other type of message, which is retrieved from a remote site on the Internet enabling the verification of an individual’s viewing or receipt of a web page or message. A clear gif may enable us to relate your viewing or receipt of a web page or message to other information about you, including your Personally Identifiable Information.
(d) IP Address. Your Internet Protocol (“IP”) address is usually associated with the place from which you enter the Internet, like your Internet Service Provider, your company or your university. Our server may also record the referring page that linked you to us (e.g., another Web site or a search engine); the pages you visit on our Covered Sites, the web sites you visit after this web site; the ads you see and the ads you click on our sites; other information about the type of web browser, computer, platform, related software and settings you are using; any search terms you have entered on this web site or a referral site; and other web usage activity and data logged by our web servers. We may use your IP address to help diagnose problems with our servers, gather broad demographic information, and administer our Covered Sites. We may also link this information with your Personally Identifiable Information when we feel that it is necessary to enforce compliance with our rules and policies or terms of service or to protect our Covered Sites, customers or others.
(g) Do Not Track Requests. VHMP does not act on Do Not Track requests from your browser. For more information click here.
(h) Effect of Tracking Requests. VHMP does not act on Do Not Track requests from your browser because, this way, we are able to personalize your experience on our sites and tailor content to your interests.
3. Use of Information.
(a) VHMP uses information we collect from you to provide the service you have requested. If you subscribe to our newsletter, we may also use your e-mail address to send you a confirmation notice and to deliver your newsletter. Similarly, if you enter online sweepstakes, we will also use this information to notify you if you are a winner. We might also send out e-mails to users to announce special offers, services and announcements from our Covered Sites, our partners and/or our advertisers. We also use information in connection with advertising and to serve other content, as described in section 4(d) below.
(b) We may combine and use any and all information we collect on you either online or otherwise, including from third parties, for marketing purposes.
(c) In addition, if you provide information through social media or through any other user generated submission, VHMP can edit, rewrite, use, and reuse the information, including your name, likeness, photograph, and biographical information you provide, with or without attribution, including publication on our Covered Sites, and in trade media, and advertising.
(d) We may create aggregated information from Personally Identifiable Information and may use and share such aggregated information for any purpose.
4. Disclosure of Your Information
(a) In addition to the other disclosures described in this policy, VHMP may (and you authorize us to) share or disclose Personally Identifiable Information about you to other companies or individuals in the following situations:
(i) We use third party service providers to provide products, services or functions on our behalf (such as sending emails or processing credit cards or fulfilling subscriptions), and require that these service providers maintain the confidentiality of your Personally Identifiable Information and not to use your Personally Identifiable Information for any reason except to carry out the purpose(s) for which we provide it to them.
(ii) If you have entered a contest or sweepstakes sponsored by a third party, we may share the information you provide with that third party for their use at their discretion, including direct marketing. Some of our contests and sweepstakes will ask you at the time of entry whether you would like to have your personal information shared with the sponsor, in which case we will honor your selection. Other contests will not give you that option and in that event, if you do not want your information to be shared, you should not enter the contest. The privacy policies of such third party companies apply to their use and disclosure of your information that we collect and share with them.
(iv) With any Affiliate of VHMP.
(v) In accordance with your indicated preferences (e.g., you indicated you wanted to receive promotional materials directly from a third party partner).
(vi) To a third party to promote goods and services we think would be of interest to you. You have a choice about the sharing of contact information with third parties for marketing, as described in Section 5(d).
(vii) You have furnished us Personally Identifiable Information with the intent that it be forwarded to a third party for use in connection with a specified service you are electing to participate in (examples include e-commerce partners, services to help old friends locate you online, etc.).
(b) Social Networks. If you use your login credentials from a social networking site such as Facebook or Twitter on a Covered Site, we may receive information from that social network in accordance with the terms and conditions of that social network and the controls you have set for that social network’s sharing of information.
(c) Third Party Partners. Some of our Covered Sites may partner with a retailer or other third party to offer online shopping opportunities, games, services, subscriptions and other applications on a co-branded or cross-promotional basis. Those transactions may take place on a Covered Site, or the site of the third party. In either case, Personally Identifiable Information you provide in connection with these transactions may be collected directly by, or shared by VHMP with, the third party, as well as with any participating sponsors or advertisers of such opportunities and features. Some of our Covered Sites may offer you the ability to access a third-party site with whom we have a relationship to access both sites through a co-branded registration or password; in that event, your applicable registration information may be collected directly by, or shared by VHMP with, the third-party partner. We will notify you at the point of sign up if any such co-branded registration or password practices will be in effect. These third parties’ privacy policies will apply to their use of your information.
(d) Delivery of Advertising and Other Content. In addition to ads and content that we serve you directly, we use third-party advertising companies and marketing services companies to serve ads and other content when you visit our Covered Sites and elsewhere on the internet and in other media. Both we and these companies may use information about your visits to this Covered Site, your use of our applications and elsewhere to serve ads and other content to you. In the course of doing so, a unique third-party cookie may be placed or recognized on your browser by such companies or our applications may send mobile device advertising identifiers to these companies. In addition, we and these companies may use Web beacons to help manage our online advertising and content. These Web beacons enable us and the third-party companies to recognize, for example, a browser’s cookie when a browser visits our sites and to learn which banner ads bring users to our website and to serve you ads and content that you may find of interest elsewhere on the internet and in other media. Both VHMP and these companies may use information obtained from your visits to the Covered Sites (including your status as a customer of VHMP), other websites, and information received from you offline in order to provide advertisements about goods and services and other content of interest to you across the internet and in other media. If you would like more information about this practice and to know your choices about not having this information used in this manner by our third party advertising companies please visit http://www.networkadvertising.org/choices/ or http://www.aboutads.info/choices/, or https://youradchoices.com/appchoices for mobile device advertising. The collection of information via certain ads served to users in Canada may be managed by visiting http://youradchoices.ca/choices/, and via certain ads served to users in Europe may be managed at http://youronlinechoices.com/. You can limit the use of information obtained from mobile applications for this type of advertising using options presented in your device setting controls which limit ad tracking or reset your advertising identifier.
5. EEA Visitors/Users
If you are a visitor or user from the European Economic Area, we will only collect and use your personal data (as defined under Regulation 2016/679 of the European Parliament and of the Council on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC ("GDPR")) when we have a legal basis for doing so.
The legal basis on which we rely will depend on the type of personal data we collect and the specific context in which we are collecting it. We will make clear to you when we are collecting personal data from you, and when and as required under GDPR, we will request your affirmative consent to the collection of your personal data, prior to collecting it. We will also make clear to you when such collection of your personal data is required (for example, because we have a legal obligation to do so, or because we cannot provide a service to you without collecting your personal data), and what are the consequences of your declining to allow us to collect your personal data.
If you have any questions about our collection and use of your personal data, please contact us at email@example.com. Any requests to delete your personal data may be sent to the above email.
6. Your Choices
(a) California & Canadian Users: Your California Privacy Rights. California’s “Shine the Light” law, Civil Code section 1798.83, requires certain businesses to respond to requests from California customers asking about the businesses’ practices related to disclosing personal information to third parties for the third parties’ direct marketing purposes. Alternatively, such businesses may have in place a policy not to disclose personal information of customers to third parties for the third parties’ direct marketing purposes if the customer has exercised an option to opt-out of such information sharing. We have such a policy in place. Sections 4(d) and 4(c) explain our practices and how you can opt-out of having your information shared with third parties for the third parties’ direct or indirect marketing purposes, in accordance with such laws. In addition to reviewing Sections 4(d) and 5(d), if you wish to find out about any rights you may have under California Civil Code section 1798.83, you may contact us at firstname.lastname@example.org. Canadian residents also have certain rights to know how their information may be shared with third parties who engage in direct marketing activities. For the avoidance of doubt, these opt-out options are available for all users and are not limited to Californian and Canadian users.
(b) Mobile Opt-out. We may provide you messages, including marketing, via your wireless email address or by short message service (“SMS Service”), WAP or Mobile Services. You may opt-out of these messages from us by replying “STOP” or following the instructions provided in the message. With your permission, our apps may also send you notifications. You can choose to stop receiving these notifications using your device settings.
(c) Marketing provided by VHMP. From time to time we may send you promotional materials on behalf of VHMP and/or third parties. If you want us to stop sending you promotional materials, you may contact us at email@example.com. Marketing emails you receive from us include an unsubscribe instruction (usually found at the bottom of the email) that you may use to opt out of receiving future marketing-related emails.
(d) Marketing provided by Third Parties. From time to time we may disclose your contact information to third parties to allow them to market their products or services to you or for other marketing purposes. This may be information we received from you offline and online. If you want us to stop further sharing contact information with third parties you may contact us at firstname.lastname@example.org. In the case of information collected by our Third Party Partners, you should consult their own privacy policies to determine how your Personally Identifiable Information will be used, and follow the instructions provided to you by those Third Party Partners to unsubscribe from their messages and customize your preferences.
(e) Exceptions. If you have opted-out as described above, and thereafter you elect to use a service or promotion that requires us to contact you or share your information with a third party (e.g., you enter into a contest or sweepstakes or use an ecommerce service after opting-out), then your previous opt-out preferences will not apply to such service. The opt-outs described above apply to marketing-related communications only and we may continue to send you service related communications, including notices about your subscription.
(f) Device Settings. Our applications may provide you alerts and you can change your preferences regarding these alerts through your device settings.
7. Security of Your Personally Identifiable Information. We use industry-standard security technologies and procedures to help protect your Personally Identifiable Information from unauthorized access, use, or disclosure. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, while VHMP uses reasonable efforts to protect your Personally Identifiable Information, VHMP cannot guarantee its absolute security.
8. Kids And Parents. The Covered Sites are not intended for use by children, especially those under age 13. There are also commercially available tools to help you limits your children’s exposure to material online.
9. Non-U.S. Users. If you are located outside of the United States, please note that the information you provide to us will be transferred to and processed in the United States, where laws regarding processing of Personally Identifiable Information may be less stringent than the laws in your country. By using this Covered Site, you consent to this transfer and processing. You also consent to the adjudication of any disputes arising in connection with this Covered Site in the federal and state courts of, and in accordance with the laws of, the state of New York.
Last Update: August 6, 2018