The Information We Collect From You
We may collect the following personal data directly from your interactions with us:
- Your name and surname (without salutation or gender);
- Your email address (business or personal as determined by you);
- Your address (business or personal as determined by you);
- Your phone number for business purposes;
- Your landline phone number for business purposes;
- Your job title or role;
- Your company name;
- Your areas of business interest;
- Your communication preferences with Volante.
We never collect sensitive personal data such as gender, home contact details, ethnicity, religion, political affiliation or sexual preference.
How We Collect Your Information
Our direct method of collection is one of the following, and in all cases is or has been based on an indication of legitimate interest in Volante or through your use of our products and services:
- Online via Volante’s website (the “Site”)
- An enquiry directly via the Site or to a Volante employee
- Direct personal receipt of your business card
- Through an express ‘opt-in’ related to an industry event
- Registrations for Volante Webinars, marketing collateral such as White Papers, or other News and Events
- Contact with the Volante support team when using one of our products or services
We may also receive your personal data (including your name, email address, and phone number) indirectly from your organization when the organization enters into a license or other agreement with us and basic business contact data already existing in the public domain from third party contact data service providers with whom we contract.
We may also collect the following information about your use of our Site through cookies and other technologies: your domain name; your browser type and operating system; web pages you view; links you click; your IP address; the length of time you visit our Site; the actions you take on our Site; and the referring URL, or the webpage that led you to our Site. We combine this information with other information that we have collected about you, including, where applicable, your name and other personal information. Please see the section “Cookies and Other Tracking Technologies” below for more information.
The Legal Bases for Using Your Personal Information
We collect and process your information as a data controller when we have a legal basis to do so. The following legal bases pertain to our collection of data:
- Our use of your personal information is in accordance with your consent (for example, when you consent to sharing your personal information with a third party for their own marketing);
- Our use of your personal information is in our legitimate interest as a commercial organization (for example in order to make improvements to our products and services and to provide you with information you request); you have a right to object to processing as explained in the section below titled Your Legal Rights;
- Our use of your personal information is necessary to perform a contract or take steps to enter into a contract with you; and/or
- Our use of your personal information is necessary to comply with a relevant legal or regulatory obligation that we have (for example, where we are required to disclose personal information to a court or tax authority).
If you would like to find out more about the legal basis on which we process personal information, please contact us at email@example.com.
We retain your personal information for as long as necessary to fulfil the purposes described in this Policy and/or our business purposes, or as required by law, regulation, or internal policy.
How We Use Personal Data
We use and process personal data where the processing is in our legitimate interests. Our primary purpose in collecting and using personal data is to provide you with a safe, smooth, efficient, and customized experience. We collect personal data so that we can:
- Communicate with you about our products and services, including special offers that we think may be of interest to you;
- Invite you to attend industry events, webinars, and receive white papers and other articles we think may be of interest to you;
- Interact with you in the event that you contact our support, marketing, or sales teams;
- Receive feedback from you related to our products and services;
- Send invoices to you or your organization for products and services you or your organization have purchased from us;
- Meet legal requirements, including responding to subpoenas and other complying with other court orders, valid discovery requests, and other appropriate legal procedures;
- Comply with regulatory or supervisory audits and investigations;
- Provide information to our representatives and advisors, including our attorneys and accountants, to help us comply with legal, accounting, or security requirements related to our legitimate interests;
- Prosecute and defend a court, arbitration, or other legal proceeding;
- Provide data analytics reports and information related to our business interests in improving and enhancing our products and services;
- Provide the services and customer support you request;
- Resolve disputes and troubleshoot problems;
- Prevent potentially prohibited or illegal activities, and enforce our User Agreement;
- Customize, measure, and improve our services and the Site’s content and layout; and
- Share market commentary, Volante newsletters, product and service updates, and promotional offers based on your communication preferences.
We do not sell or rent the personal data we collect or receive with third parties for any purpose without your explicit consent. If you do not wish to receive sales and marketing communications from Volante, you may unsubscribe by clicking on the “unsubscribe” link located at the end of any marketing communication from Volante. Unsubscribing from any marketing and sales communications will result in Volante adding your name and contact information to a “do not contact” list until such time as you re-subscribe to such marketing and sales communications. If you choose to exercise your right to be forgotten (your data deleted completely from Volante’s user database) you may make that request by sending an email to firstname.lastname@example.org requesting for your data to be deleted.
Our Disclosure of Your Data
In addition to the uses identified above, we may disclose your personal data to third parties to respond to legal requirements (including subpoenas, court orders, and requests from other authorities), enforce our policies (including any of the terms of our User Agreement), or protect any other person’s rights, property, or safety (including if we believe that you are using our products and services in an illegal or unauthorized manner).
We may also share your personal data with:
- Employees and agents of Volante in order to help detect and prevent potentially illegal acts;
- Our affiliates and subsidiaries in order to fulfill our obligations to you or your organization; such use and disclosure of your personally identifiable information will be subject to this Policy.
- Service providers under contract with us who help with our business operations, including service providers who host our data, manage our data base, process payments on our behalf, analyze visitor traffic, display advertisements, send emails on our behalf, and assist us in protecting and securing our systems;
- Other third parties for whom you explicitly give consent to share your data;
- Those serving apparently valid subpoenas, discovery requests, and other court orders; and
- Other business entities, should we plan to merge with, or be acquired by that business entity.
Without limiting the above, in an effort to respect your privacy we will not otherwise disclose your personal data except when we believe in good faith that the disclosure of information is necessary to prevent imminent physical harm or financial loss or to report suspected illegal activity, all in accordance with applicable data protections laws.
Ours is a global business and we use global cloud-based platforms. For us to provide our services to you, your personal data may be stored outside of the European Economic Area, Switzerland, and the United Kingdom. Your personal data may be accessed by Volante staff outside the European Economic Area, Switzerland, and the United Kingdom.
Where personal data is transferred outside of the European Economic Area, Switzerland, or the United Kingdom, and where the transferee is not subject to an adequacy decision by the EU Commission, we enter into EU Commission approved standard contractual clauses or Swiss standard contractual clauses, an appropriate Privacy Shield certification, or a third party service provider’s binding corporate rules.
You may obtain a copy of the relevant mechanism by contacting us on the contact details set out below.
We will always take all the steps necessary to ensure that your personal data is treated securely and in accordance with this policy.
"Do Not Track" Requests
Your Legal Rights
Depending on where you are located, you may have various data protection rights including:
- The right to access – you may have the right to request Volante to provide you with copies of your personal data collected or received by us.
- The right to rectification – you may have the right to request Volante to correct or complete any information which you believe is inaccurate or incomplete.
- The right to be informed – you may have the right to be informed about how your personal data is being used.
- The right to erasure – you may have the right to request that Volante delete your personal data, under certain conditions.
- The right to restrict processing – you may have the right to request that Volante restrict the processing of your personal data under certain conditions.
- The right to data portability – you may have the right to request that Volante transfer the personal data we have collected to another organization, or directly to you, under certain conditions.
- The right to object to automatic processing – you may have the right to restrict automatic processing of your personal information, under certain conditions.
You can control what information and communications you wish to receive from us and via what channels by clicking on the ‘Update Your Preferences’ link present at the bottom of any communication Volante sends to you. If you click on ‘unsubscribe’ at the bottom of any communication Volante sends to you, Volante will add your name and contact information to a “do not contact” list until such time as you re-subscribe to such marketing and sales communications.
In all cases, any person may request details of what data Volante holds about them or exercise any other data protection rights at any time by contacting us at email@example.com. We will respond to requests within thirty (30) days and may request additional information from you to verify the request.
Retention of Personal Data
Your Personal Information will be retained for as long as necessary to fulfil the purposes outlined in this document or to comply with applicable legal requirements.
We will retain your personal data for no longer than is necessary for those purposes. We will periodically review the personal data for deletion of the records that are no longer needed.
Our Services may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility for them. Please check these policies before you submit any personal data to these websites.
Third-Party Ad Networks
Users may opt out of many third-party ad networks. For example, you may go to the Digital Advertising Alliance (DAA) Consumer Choice Page for information about opting out of interest-based advertising and their choices regarding having information used by DAA companies. You may also go to the Network Advertising Initiative (NAI) Consumer Opt-Out Page for information about opting out of interest-based advertising and their choices regarding having information used by NAI members. If you are in the EU, you may opt-out of certain third party cookies that we and other websites may use for targeted advertising through the European Interactive Digital Advertising Alliance (EDAA) Your Online Choices Page or www.aboutads.info.
Opting out from one or more companies listed on the DAA Consumer Choice Page, the NAI Consumer Opt-Out Page, or the EDAA’s Your Online Choices Page will opt you out from those companies’ delivery of interest-based content or ads to you, but it does not mean you will no longer receive any advertising through our Site or on other websites. You may continue to receive advertisements, for example, based on the particular website that you are viewing (i.e., contextually based ads). Also, if your browsers are configured to reject cookies when you opt out on the DAA, NAI, or EDAA websites, your opt out may not be effective.
California Privacy Rights
If you are a California resident you may have additional rights to data protection and privacy under the California Consumer Privacy Act (“CCPA”). Under the CCPA, you have the right to request that businesses (as defined in the CCPA) disclose certain information to you about business’ collection and use of your personal information during the preceding 12 month period. Additionally, you also have the right to request that the business delete your personal information, subject to certain exceptions. If the business sells personal information you have a right to request that your personal information not be sold. A business cannot discriminate against you for exercising any of your rights under the CCPA.
In connection with its business operations, Volante believes that it is acting as a “service provider” rather than a “business”, although many of the banks and financial institutions to whom we provide products and services may be considered “businesses” under the CCPA. [Substantially all][All] personal information collected by our clients is encrypted or otherwise deidentified (as defined in the CCPA) before it is processed by our products and services and Volante does not have any access to personally identifiable information. If Volante receives personally identifiable information, Volante’s receipt and use of any consumer personal data is performed on behalf of its clients for purposes of providing our products and services to those clients. If you have any questions about what personal data may be collected and how it is used in connection with Volante’s products and services, or any other questions about your CCPA rights, please direct those questions directly to your bank or other financial institution.
In the event that you provided your personal data directly to Volante through your use of the Site or our products and services, and you would like to exercise your rights under the CCPA, please contact us at firstname.lastname@example.org. We may need to verify your identity before we can respond to your request. Volante does not, and has never, sold the personal data we collect to any third party.
In the event that you choose to exercise your rights under the CCPA, Volante will not discriminate against you by charging you different prices or provide you with a different quality of products or services. Some of the services Volante provides, including access to your Site account, are contingent on your providing Volante or its client your personal data, including, but not limited to, account login and financial information connected with the financial payment being processed by our products or services. We believe that the benefit of the features are reasonably related to the value of the personal data that you provide.
Neither our Site nor our products or services are directed to children, and you may not use our Site, products, or services if you are under the age of 13. You must be old enough to consent to the processing of your personal data in your country.
We have adopted a procedure to receive and respond to complaints and inquiries about our policies and practices relating to the handling of personal data. We will investigate all complaints in respect of personal data. If a complaint is justified, we will take appropriate measures, including, as necessary, amending our policies and practices. Any inquiries or complaints regarding this Policy or our practices relating to the handling of personal data should be addressed to Vice President- Compliance, email@example.com.
For further information on our privacy policies and practices relating to the handling of personal data, if you have a concern about the way in which we have handled personal data, or to exercise any of your data rights, contact us by postal mail to Harborside 5, 185 Hudson Street #1605, Jersey City, NJ 08550, USA or by email to firstname.lastname@example.org.
Our Data Protection Officer can be contacted at: email@example.com.