- Terms of Service
- Data We Collect
- How We Use Personal Data We Collect
- Our Legal Basis for Collecting Personal Data
- Data We Share
- Your Failure to Provide Personal Data
- Our Retention of Your Personal Data
- Your Choices and Accessing, Updating or Deleting Your Personal Data
- European Users’ Rights With Respect to Personal Data
- Changing or Deleting Your Personal Data
- Our Opt-in/Opt-out Policy
- Your Ad Choices
- Third-Party Links
- International Transfer
- How We Protect Personal Data
- Direct Marketing and “Do Not Track” Signals
- Virtual Logic 360 Customers
- How to Contact Us
Irrespective of which country you live in, you authorize us to transfer, store, and use your information in the United States, and any other country where we operate. In some of these countries, the privacy and data protection laws and rules regarding when government authorities may access data may vary from those in the country where you live. Learn more about our data transfer operations in the “International Transfer” section below. If you do not agree to the transfer, storage, and use of your information in the United States, and any other country where we operate, please do not use the Sites or Services.
Terms of Service
By accessing or using the Sites in any manner, you also agree to be bound by Virtual Logic 360’s Terms of Service (the “Agreement”). If you do not accept all of the terms and conditions contained in or incorporated by reference into the Agreement, please do not use the Sites.
Personal Data We Collect
We collect information, including personal data, to provide better services to all our Users. We use the term “Personal Data” to refer to any information that identifies or can be used to identify you. Common examples of personal data include full name, home address, email address, date of birth, digital identity, such as a login name or handle, information about your device, and certain metadata.
“Sensitive Personal Data” refers to a smaller subset of personal data which is considered more sensitive to the individual, such as race and ethnic origin, political opinions, religious or philosophical beliefs, trade-union membership, genetic or biometric information, physical or mental health information, medical insurance data, or sexual orientation. Virtual Logic 360 does not collect or use Sensitive Personal Data and asks that you do not provide Sensitive Personal Data to us.
We collect Personal Data in the following ways:
- Information You Give to Us
As you evaluate whether Virtual Logic 360 is the right solution for you, you may choose to provide us with Personal Data about yourself, including your name, email, phone number, zip or postal code, country, and user name and password, by completing forms on our website, such as when you request information about our Services. When using our Services, you may provide us with messages sent between those individuals you have authorized to use our Services. In some instances, you may elect to provide us with location and address information. You may also provide us with Personal Data about yourself when you report a problem or have a question about our services.
The Sites offer interactive and social features that permit you to submit content and communicate with other users. You may provide personal data to us when you post information in these interactive and social features. Please note that your postings in these areas of the Sites may be publicly accessible or accessible to other users.
Please note that if you do not provide us with Personal Data, your ability to use certain aspects of our products and services may be limited.
- Information We Obtain from Your Use of Our Services
We collect certain information automatically, such as your operating system version, browser type, and internet service provider. We also collect information about your interaction with the Services, such as creating or logging into your account, or opening or interacting with the Services on Your mobile device. When you use our Site, we automatically collect and store this information in service logs. This includes details of how you used our Site; Internet protocol address; and cookies that uniquely identify your browser. We may also collect and process information about your actual location. The information we collect automatically is statistical data and may or may not include Personal Data, but we may maintain it or associate it with Personal Data we collect in other ways or receive from third parties.
- Camera and Photos
When using our services, we may collect video footage or photographs of a business, office, building, and/or facility in order to create a virtual tour. Many of our services require us to collect images and other information from your device’s camera and photos.
- Device ID
When using our Services, we or our service provider may collect your unique device ID. We may use such information for internal purposes and to provide you with a better experience, such as troubleshoot application problems you may experience. We may associate Device ID with the personal information you provide to us. You may learn more about opt-out of any anonymous Device ID collection via the privacy settings available within your mobile device.
- Cookies and Similar Technologies
We and our partners use various technologies to collect and store information when you visit one of our services, and this may include using cookies or similar technologies to identify your browser or device. We also use these technologies to collect and store information when you interact with services from our partners, such as advertising services. Our third-party advertising and analytics partners include Google and similar third-party advertising or analytics, partners.
The technologies we use for this automatic data collection may include:
- Web Beacons. Pages of our services or our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us, for example, to count users who have visited those pages or opened an e-mail and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
- Clickstream Data. Clickstream data is information collected by our computers when you request Web pages from the Sites. Clickstream data may include information such as the page served, the time spent viewing the page, source of the request, type of browser making the request, the preceding page viewed, and similar information. Clickstream data permits us to analyze how visitors arrive at the Sites, what type of content is popular, what type of visitors in the aggregate are interested in particular kinds of content on the Sites.
How We Use Personal Data We Collect
We use your Personal Data in ways that are compatible with the purposes for which it was collected or authorized by you, including for the following purposes:
- To inform you about services available from Virtual Logic 360;
- To authorize access to our Sites and Services;
- To provide you with Services and Products;
- To offer and administer programs;
- To administer a content, promotion, sweepstakes, surveys, voting polls, or other Site features;
- To communicate about, and administer your participation in, special programs, surveys, contests, online campaigns, online programs, sweepstakes, and other offers or promotions, and to deliver pertinent emails;
- To send you confirmations, updates, and security alerts and support administrative messages and otherwise facilitate your use of and our administration and operation of the Services;
- For marketing purposes, including but not limited to, facilitating interest-based advertising, creating custom audiences to target online and mobile advertising, sending integrated marketing messages across channels and devices, personalizing email marketing that we sent to you, sending you other promotional materials, and notifying about special promotions, offers, events or opportunities that may be of interest to you;
- To improve our customer service, conduct customer satisfaction, market research, and quality assurance reviews;
- To respond to and support users regarding their use of the Sites and Services;
- To process applications for employment that you submit through the Sites;
- To perform data analysis and testing;
- To use statistical information that we collect in any way permitted by law, including from third parties in connection with their commercial and marketing efforts
- To comply with all applicable legal requirements;
- To otherwise fulfill the purpose for which the information was provided.
We use the information we collect from our Sites to provide, maintain, and improve them, to develop new services, and to protect our Company and our users.
We use information collected from cookies and other technologies, to improve your user experience and the overall quality of our services. We may use your Personal Data to see which web pages you visit at our Site, which website you visited before coming to our Site, and where you go after you leave our Site. We can then develop statistics that help us understand how our visitors use our Site and how to improve it. We may also use the information we obtain about you in other ways for which we provide specific notice at the time of collection.
Our Legal Basis for Collecting Personal Data
Whenever we collect Personal Data from you, we may do so on the following legal bases:
- Your consent to such collection and use;
- Out of necessity for the performance of an agreement between us and you, such as your agreement to use our Services or your request for Services;
- Our legitimate business interest, including but not limited to the following circumstances where collecting or using Personal Data is necessary for:
- Intra-organization transfers for administrative purposes;
- Product development and enhancement, where the processing enables Virtual Logic 360 to enhance, modify, personalize, or otherwise improve our services and communications for the benefit of our Users, and to better understand how people interact with our Sites;
- Communications and marketing, including processing data for direct marketing purposes, and subject to your opt-in for these purposes, and to determine the effectiveness of our promotional campaigns and advertising;
- Fraud detection and prevention;
- Enhancement of our cybersecurity, including improving the security of our network and information systems; and
- General business operations and diligence;
Provided that, in each circumstance, we will weigh the necessity of our processing for the purpose against your privacy and confidentiality interests, including taking into account your reasonable expectations, the impact of processing, and any safeguards which are or could be put in place. In all circumstances, we will limit such processing for our legitimate business interest to what is necessary for its purposes.
Personal Data We Share
Viewers of a virtual tour may sometimes opt to submit personal data to us in order to request more information about a tour from the tour creator or owner. This may take place in the context of using the “Lead Generation” feature of a tour. When such an event occurs, we receive the viewer’s personal data and disclose the Personal Data to a commercial provider (the tour creator or owner) for a business purpose. When we disclose Personal Data for these reasons, we enter into a contract that describes the purpose and requires the recipient to both keep that Personal Data confidential and not use it for any purpose except for the purposes set forth in the contract. In some cases, our commercial providers will use the Personal Data for their own purposes, and these purposes may include sending marketing communication to you.
We may also share Personal Data under the following circumstances:
- With your consent. We will share personal data with companies, organizations, or individuals outside of Virtual Logic 360 when we have your consent to do so.
- For Legal Reasons. We will share Personal Data with companies, organizations, or individuals outside of Virtual Logic 360 if we have a good-faith belief that access, use, preservation, or disclosure of the information is reasonably necessary to:
- meet any applicable law, regulation, legal process, or enforceable governmental request.
- enforce applicable Terms of Service, including investigation of potential violations.
- detect, prevent, or otherwise address fraud, security, or technical issues.
- protect against harm to the rights, property, or safety of Virtual Logic 360, our Users, or the public as required or permitted by law.
- We attempt to notify Users about legal demands for their personal data when appropriate in our judgment unless prohibited by law or court order or when the request is an emergency. We may dispute such demands when we believe, at our discretion, that the requests are overbroad, vague, or lack proper authority, but we do not promise to challenge every demand.
- Business Transfers. If we establish a new related entity, are acquired by or merged with another organization, or if substantially all of our assets are transferred to another organization, Personal Data about our users is often a transferred business asset. In the event that Virtual Logic 360 itself or substantially all of our assets are acquired, Personal Data about our users may be one of the transferred assets.
- Aggregate Site Use Information. We may share aggregated and anonymized or pseudonymized Personal Data to third parties in order to promote or describe the use of the Sites, for research, marketing, advertising, or similar purposes.
We attempt to notify you about legal demands for your Personal Data when appropriate in our judgment, unless prohibited by law or court order or when the request is an emergency. We may dispute such demands when we believe, at our discretion, that the requests are overbroad, vague, or lack proper authority, but we do not promise to challenge every demand.
We do not share your personal data with third parties for use in affiliate or third-party marketing.
Our Retention of Your Personal Data
We may retain your Personal Data for a period of time consistent with the original purpose of the collection. We also may retain your Personal Data during the period of time needed for us to pursue our legitimate business interests, conduct audits, comply with our legal obligations, resolve disputes and enforce our agreements.
Your Choices and Accessing, Updating or Deleting Your Personal Data
You may have certain rights relating to your Personal Data, subject to local data protection law. Whenever you choose to visit our Site and use our Services, we aim to provide you with choices about how we use your Personal Data. If we have collected your Personal Data because you visited our website or contacted us, then we will facilitate your rights directly because we are the controller of your Personal Data. If we have collected your Personal Data on behalf of a customer when you have been employed by that customer, your rights are facilitated by the customer because they are the controller of your Personal Data.
Subject to applicable law, you may obtain a copy of the Personal Data we maintain about you. In addition, if you believe that Personal Data we maintain about you is inaccurate, subject to applicable law, you may have the right to request that we correct or amend the information by contacting us as indicated in the “How to Contact Us” section below. To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to the information.
- European Users’ Rights With Respect to Personal Data
Some data protection laws, including the European Union’s General Data Protection Regulation (“GDPR”), provide you with certain rights in connection with Personal Data you have shared with us when we are the data controller. If you are resident in the European Economic Area, you may have the following rights:
- The right of access. You have the right to request a copy of your Personal Data which we hold about you.
- The right of correction: You have the right to request correction or changes of your Personal Data if it is found to be inaccurate or out of date.
- The right to be forgotten: You have the right to request us, at any time, to delete your Personal Data from our servers and to erase your Personal Data when it is no longer necessary for us to retain such data. Note, however, that deletion of your Personal Data will likely impact your ability to use our services.
- The right to object (opt-out): You have the right to opt-out of certain uses of your Personal Data, such as direct marketing, at any time.
- The right to data portability: You have the right to a “portable” copy of your Personal Data that you have submitted to us. Generally, this means your right to request that we move, copy or transmit your Personal Data stored on our servers / IT environment to another service provider’s servers / IT environment.
- The right to refuse to be subjected to automated decision making, including profiling: You have the right not to be subject to a decision and insist on human intervention if the decision is based on automated processing and produces a legal effect or a similarly significant effect on you.
- The right to lodge a complaint with a supervisory authority.
You can submit these requests by emailing us at email@example.com or by contacting us at the contact information below. We will consider your request in accordance with applicable laws and our legal obligations.
- Changing or Deleting Your Personal Data
You may update, correct, or delete the Personal Data that we maintain about you by emailing us at firstname.lastname@example.org. We may retain an archived copy of your records as required by law, to comply with our legal obligations, resolve disputes, enforce our agreements, or for other legitimate business purposes.
We may contact you to request that you update your Personal Data on a regular basis to ensure its integrity for the purposes of ongoing data management.
- Our Opt-in/Opt-out Policy
We currently provide the following opt-out opportunities:
- At any time, you can follow a link provided in offers, newsletters, or other email messages (except for e-commerce confirmation or service notice emails) received from us to unsubscribe from the service.
- Your Ad Choices
As described above, we or third-party partners may place or recognize a unique cookie on your browser when you visit our Sites for the purpose of serving you targeted advertising (also referred to as “online behavioral advertising” or “interest-based advertising”). You may find more information about entities involved in online advertising and additional choices you may make, including opt-out of having your information used for internet-based advertising, through the Network Advertising Initiative (“NAI”) at the NAI Service, and the Digital Advertising Alliance (the “DAA”) at the DAA consumer choice service. Virtual Logic 360 is a participant in the online industry’s self-regulatory program administered by the DAA and has agreed to adhere to the DAA’s principles applicable to interest-based ads.
The tools provided at the DAA opt-out page and the NAI opt-out page are provided by third parties, not Virtual Logic 360. Virtual Logic 360 does not control or operate these tools or the choices that advertisers and others provide through these tools.
The Sites may contain links to web pages operated by parties other than Virtual Logic 360. We do not control such websites and are not responsible for their contents or the privacy policies or other practices of such websites. Our inclusion of links to such websites does not imply any endorsement of the material on such websites or any association with their operators. Further, it is up to the User to take precautions to ensure that whatever links the User selects or software the User downloads (whether from this Site or other websites) is free of such items as viruses, worms, trojan horses, defects, and other items of a destructive nature. These websites and services may have their own privacy policies, which the User will be subject to upon linking to the third party’s website. Virtual Logic 360 strongly recommends that each User review the third party’s terms and policies.
How We Protect Personal Data
Virtual Logic 360 maintains administrative, technical, and physical safeguards designed to protect the User’s Personal Data and information against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure, or use. We implement appropriate technical and organizational measures to ensure a level of security appropriate to the risk, taking into account technological reality, cost, the scope, context, and purposes of processing weighted against the severity and likelihood that the processing could threaten individual rights and freedoms. For example, we use commercially reasonable security measures such as encryption, firewalls, and Secure Socket Layer software (SSL) or hypertext transfer protocol secure (HTTPS) to protect Personal Data.
Although we take reasonable steps designed to protect your Personal Data, please be advised that no security system or means of transmitting data over the Internet can be guaranteed to be entirely secure (including without limitation with respect to computer viruses, malicious software, and hackers attacks). We cannot and do not guarantee or warrant the security of your Personal Data or any information you disclose or transmit to us. We are not responsible for the acts of those who gain unauthorized access, and we make no warranty, express, implied, or otherwise, that we will prevent such access, and we are not responsible for any damages or liabilities relating to any such incidents to the fullest extent permitted by law. Where required under law, we will notify you of any such loss, misuse, or alteration of Personal Data that may affect you so that you can take the appropriate actions.
The Site is not intended for use by children. We do not intentionally gather Personal Data about visitors who are under the age of 13 (or a minor in the jurisdiction in which you are accessing our Sites or Services). If a child has provided us with Personal Data, a parent or guardian of that child may contact us to have the information deleted from our records. If you believe that we might have any information from a child under age 13 in the applicable jurisdiction, please contact us at email@example.com. If we learn that we have inadvertently collected the Personal Data of a child under 13, or equivalent minimum age depending on the jurisdiction, we will take steps to delete the information as soon as possible.
- Children’s Online Privacy Protection Act (COPPA)
Virtual Logic 360 will never knowingly request, obtain, use, or disclose Personal Data or private content from anyone under the age of 13 without parental consent.
Customers who are individuals 18 years of age or older must inform us if you intend to allow persons under the age of 13 to use your subscription and you must acquire parental consent and provide documentation of this consent to us. Only the parent or legal guardian may grant consent. If we receive documentation of parental consent, we may receive Personal Data about children under the age of 13 listed on your subscription account in order to provide our Services to them. Virtual Logic 360 DOES NOT SHARE CHILDREN’S PERSONAL DATA WITH THIRD PARTIES. If you are a parent or legal guardian of a user under 13 you may, at any time, revoke your consent to allow your student to use the Programs under your subscription, refuse to allow Virtual Logic 360 to further use or collect your student’s Personal Data, or direct Virtual Logic 360 to delete all identifiable information regarding your student that you have provided. To do so, please contact us at the contact information below. However, if you do any of the foregoing, your child or student will not be able to use the Programs.
- The Family Educational Rights and Privacy Act (FERPA)
FERPA gives parents certain rights with respect to their children’s education records. These rights transfer to the student when he or she reaches the age of 18 or attends a school beyond the high school level. Virtual Logic 360 helps our school customers be compliant with FERPA. Specifically:
- Any sensitive online information is transmitted over secure channels;
- All student data are stored in ways that are not publicly accessible;
- Security audits are regularly performed to ensure data integrity;
- Virtual Logic 360 does not share information with third parties that could be used to identify students without consent from the student’s parent, guardian, or school.
If a school customer requests that student data be sent to a third party, Virtual Logic 360 will: (i) send the data to the school customer directly to transfer to the third party or (ii) send the data directly to the third party designated by the school customer if requested by that customer, provided the school agrees that school customer is solely responsible for the use, storage, and maintenance of such information by such third party. For more information on how we protect the information entrusted to us by our school customers, please contact us at firstname.lastname@example.org.
Direct Marketing and “Do Not Track” Signals
Do Not Track (“DNT”) is the concept that has been promoted by regulatory authorities, in particular by the U.S. Federal Trade Commission (FTC), for the Internet industry to develop and implement a mechanism to allow internet users to control the tracking of their online activities across websites. Virtual Logic 360 does not track its users over time and across third-party websites to provide targeted advertising and therefore does not respond to DNT signals. However, some third-party sites do keep track of your browsing activities when they serve you content, which enables them to tailor what they present to you. If you are visiting such sites, your browser may include controls to block and delete cookies, web beacons, and similar technologies, to allow you to opt-out of data collection through those technologies.
California residents are entitled to contact us to request information about whether we have disclosed Personal Data to third parties for the third party’s direct marketing purposes. We do not disclose Personal Data to third parties for third parties direct marketing purposes. California users may request further information about our compliance with this law by e-mailing us at the address listed in the “How to Contact Us” section. In your request, please attest to the fact that you are a California resident and provide a current California address for our response. Please be aware that not all information sharing is covered by the California privacy rights requirements and only information on covered sharing will be included in our response. We reserve our right not to respond to requests submitted to addresses other than the addresses specified in this paragraph.
Virtual Logic 360 Customers
- Virtual Logic 360 Customer Information. We collect information about individuals within our Virtual Logic 360 Customers organization (“Customer Information”). Customer Information may include information related to the Customer’s account, name, work e-mail address, work phone number, job title, or similar kinds of information. We use Customer Information to support the Customer account, maintain our business relationship with the Customer, respond to customer inquiries, or perform accounting functions. Virtual Logic 360 Customers may update personal data and passwords by logging into the Virtual Logic 360 Platform and updating their accounts. Virtual Logic 360 Customers may contact Virtual Logic 360 support in order to delete their information. In some cases, we may not be able to delete Customer Information, and in such cases, we will tell you why.
- Information about our Customers’ Contacts. We collect information about any contacts, such as their users and others, that may be uploaded into the Virtual Logic 360 Platform (“Information about our Customers’ Contacts”). Information about our Customer’s Contacts may include name, e-mail address, phone number, job title, or similar kinds of information. We use information about our Customer’s Contacts for the purposes of providing Services to such contacts. Virtual Logic 360 Customers may update or delete Information about their contacts in the Virtual Logic 360 Platform. Virtual Logic 360 Customers may also contact Virtual Logic 360 support in order to update and delete such information. In some cases, we may not be able to delete such information, and in such cases, we will tell you why.
- Archival Information. We collect communications information for archival purposes on behalf of, and as directed by, our Virtual Logic 360 Customers (“Archival Information”). Archival Information includes data about our Virtual Logic 360 Customers and the third parties they correspond with. We do not control or monitor the information our Virtual Logic 360 Customers collect and store through our services, or their privacy practices or policies. It is our Customer’s obligation to obtain all necessary consents and to comply with all applicable laws with respect to the Customer’s communications and use of our services. Our Customer’s privacy policies or practices apply to Archival Information, the purposes for which the Customer collects Archival Information, how the Customer may use Archival Information and what choices the individual may have with respect to Archival Information. Individuals must contact the applicable Customer in order to correct, amend, or delete their information, or to opt-out of any collection, uses, or disclosure of their information by our Customer.
- Automatically Collected Information. We collect information automatically about how our Virtual Logic 360 Customers use our services (“Automatically Collected Information”). We do this via data collection technologies such as cookies, web beacons, gifs, or other tracking technologies. We collect this information in order to monitor, support, and improve our services or to provide Virtual Logic 360 Customers with certain customized features. We may use Automatically Collected Information to tell us how our Virtual Logic 360 Customers use our services, to improve our services, or develop new products, services, or features. We may combine this information with other information we collect.
We treat Customer Information, Information about our Customer’s Contacts, Archival Information, and Automatically Collected Information as the confidential and proprietary information of our Virtual Logic 360 Customers, subject to the terms of the Virtual Logic 360 Terms of Service and any other service agreement between Virtual Logic 360 and the Virtual Logic 360 Customer.
If you have any questions about these polices, please contact us by email at email@example.com