Please note that if you reside in the European Union or other regions outside the United States, information collected through our Service will be transferred to and processed in the U.S. or elsewhere. While Valur abides by the EU’s Standard Contractual Clauses governing transfers to non-EU countries, these locations may not have the same data protection laws as the country in which you initially used our Services. By using our Services, you consent to any transfer and processing in accordance with this Policy. If you have any questions, please contact us at email@example.com. For the purposes of EU data protection laws ("Data Protection Law"), Valur is a data controller of the information collected from visitors via the Site.
1. What Information We Collect and How We Use It
We collect personal and non-personal information from our Site visitors in order to provide you with a personalized, useful and efficient experience, and we collect personal and non-personal information from our Customers to provide them with our Services.
We collect this information for the following purposes:
- To provide, maintain, promote, protect, and improve the Services, to develop new ones, and to protect Valur and our users;
- To manage our organization and its day-to-day operations;
- To communicate with individuals, including via email, text message, social media and/or telephone calls;
- To market to individuals, including through email, direct mail, phone, or text message;
- To administer, improve, and personalize our Services;
- To facilitate client benefits and services, including customer support;
- To conduct research and analytics on our client base and our Services;
- To help maintain the safety, security, and integrity of our property and Services, technology assets, and business;
- To defend, protect, or enforce our rights or applicable contracts and agreements;
- To prevent, investigate, or provide notice of fraud or unlawful or criminal activity; and
- To comply with legal obligations.
The categories of information we collect can include:
Information that you provide to us
Site visitor information. We collect your personal information (e.g., name, postal address, email address) in order for you to communicate with us. We may also collect any communications that you exchange with us, as well as any information you provide if you take part in any interactive features of the Site (e.g., promotions, surveys, etc.).
User information. We collect information that Site users and our Customers provide to us when they use our Site and Services or communicate with us. For example, if a Site user chooses to complete one of our intake forms, we collect and store the information provided, which may include the user’s name, contact information, and general financial data.
Information from other sources
We use this information to operate, maintain, and provide to you the features and functionality of the Service, as well as to communicate directly with you, such as to send you email messages about products and services that may be of interest to you. We may also send you Service-related emails or messages (e.g., account verification, purchase confirmation, changes or updates to features of the Service, technical and security notices). Similarly, if you request information from us through an online contact form or if you email us, we collect the information you provide (e.g., name, telephone number, email address) so that we can respond to you. For more information about your communication preferences, see “Control Over Your Information” below.
Cookies. We, and our third party partners, automatically collect certain types of usage information when you visit our Site, read our emails, or otherwise engage with us. We typically collect this information through a variety of tracking technologies, including without limitation, cookies, web beacons, file information and similar technology (collectively, “Tracking Technologies”). For example, we collect information about your device and its software, such as your IP address, browser type, Internet service provider, platform type, device type, operating system, date and time stamp, a unique ID that allows us to uniquely identify your browser, mobile device or your account, and other such information. We also collect information about the way you use our Site—for example, the site from which you came and the site to which you are going when you leave our Site, the pages you visit, the links you click, how frequently you access the Site, whether you open emails or click the links contained in emails, and other actions you take on the Site.
Mobile device information. When you access our Site from a mobile device, we may collect unique identification numbers associated with your device or our mobile application (including without limitation, for example, a UDID, Unique ID for Advertisers (“IDFA”), Google AdID, or Windows Advertising ID), mobile carrier, device type, model and manufacturer, mobile device operating system brand and model, phone number, and depending on your mobile device settings, your geographical location data, including without limitation, GPS coordinates (e.g., latitude and/or longitude) or similar information regarding the location of your mobile device, or we may be able to approximate a device’s location by analyzing other information, like an IP address.
Analytics data. We may collect analytics data, or use third-party analytics tools, to help us measure traffic and usage trends for the Site and to understand more about the demographics of our users. Although we do our best to honor the privacy preferences of our users, we are unable to respond to Do Not Track signals set by your browser at this time.
Purpose. We use or may use the data collected through Tracking Technologies to: (a) remember information so that you will not have to re-enter it during your visit or the next time you visit the Site; (b) provide custom, personalized content and information, including without limitation, targeted content and advertising; (c) provide and monitor the effectiveness of our Service; (d) monitor aggregate metrics such as total number of visitors, traffic, usage, and demographic patterns on our Site; (e) diagnose or fix technology problems; and (f) otherwise plan for and enhance our Service.
Declining to Accept Tracking Technologies. If you would prefer not to accept cookies, most browsers will allow you to: (i) change your browser settings to notify you when you receive a cookie, which lets you choose whether or not to accept it; (ii) disable existing cookies; or (iii) set your browser to automatically reject cookies. Please note that doing so may negatively impact your experience using the Site, as some features and services on our Site may not work properly. Depending on your mobile device and operating system, you may not be able to delete or block all cookies. You may also set your e-mail options to prevent the automatic downloading of images that may contain technologies that would allow us to know whether you have accessed our e-mail and performed certain functions with it.
3. How and With Whom We Share Personal Information
We may share the information we collect from our Site and Services for the following purposes:
- We may share your personal information with third-party service providers or business partners who help us deliver or improve our Service or who perform services on our behalf, such as providing users with legal or accounting services, identifying and serving targeted advertisements, processing payments, sending postal mail, providing back-office services, or measuring Site traffic. Note that individuals can opt in or opt out by logging into the Service and updating the communication preferences section of their settings page.
- We may aggregate, or strip information of personally identifying characteristics, and then share that aggregated or anonymized information with third parties, including without limitation, to publish research reports.
- We may share or disclose your personal information if we determine, in our sole discretion, that we are required to do so under applicable law or regulatory requirements, or if we reasonably believe disclosure is necessary to prevent harm or financial loss, or in connection with preventing fraud or illegal activity, and/or to enforce our Terms of Service.
4. Control Over Your Information
Email Communications. From time to time, we may send you emails regarding updates to our Site, products or services, notices about our organization, or information about products/services we offer (or promotional offers from third parties) that we think may be of interest to you. If you wish to unsubscribe from such emails, simply click the “unsubscribe link” provided at the bottom of the email communication or respond with "unsubscribe". Note that you cannot unsubscribe from certain Services-related email communications (e.g., account verification, confirmations of transactions, technical or legal notices). For users in the European Economic Area (including the EU, the United Kingdom, Iceland, Liechtenstein, and Norway) and Switzerland (the “EEA”), we will send you marketing communications only with your prior consent. Please see the section “GDPR: Information for EEA Users” below.
5. Third Party Tracking and Online Advertising
We may share, or we may permit third party online advertising networks, social media companies and other third party services, to collect, information about your use of our Site over time so that they may play or display ads that may be relevant to your interests on our Site as well as on other websites or apps, or on other devices you may use. Typically, though not always, the information we share is provided through cookies or similar tracking technologies, which recognize the device you are using and collect information, including without limitation, hashed data, click stream information, browser type, time and date you visited the Site, and other information. This information is used to display targeted ads on or through our Site or on other websites or apps, including without limitation, on Facebook. We or the online advertising networks use this information to make the advertisements you see online more relevant to your interests. As noted above, depending on your browser or mobile device, you may be able set your browser to delete or notify you of cookies and other tracking technology by actively managing the settings on your browser or mobile device. You may also be able to limit interest-based advertising through the settings on your mobile device by selecting “limit ad tracking” (iOS) or “opt-out of interest based ads” (Android). To learn more about interest-based advertising and how you may be able to opt-out of some of this advertising, you may wish to visit the Network Advertising Initiative’s online resources at http://www.networkadvertising.org/choices, and/or the Digital Advertising Alliance’s resources at www.aboutads.info/choices, and you may also adjust your ad preferences through your settings on Facebook and the other websites or apps we may use to display targeted ads. You may also be able to opt out of some – but not all – interest-based ads served by mobile ad networks by visiting http://youradchoices.com/appchoices and downloading the mobile AppChoices app. You may also manage certain advertising cookies by visiting the EU-based Your Online Choices at http://www.youronlinechoices.eu. If you have any questions about opting out of the collection of cookies and other tracking/recording tools, you can contact us directly at firstname.lastname@example.org.
6. Data Protection and Security
Deactivating your account or deleting your personal data. Except as described in the “Customer Data” section above, you can choose to deactivate your account so that you are no longer included in the Service. You may also request that we delete information about you. You can request deactivation or deletion by contacting us using the information listed in the “Contact Us” section below.
Data retention. Following termination or deactivation of your user account, Valur may retain your information for a commercially reasonable time for record keeping, audit or other purposes. Any Business Content, including without limitation any Customer Data that we have access to, shall be retained, stored, and deleted according to our agreement with our business customer, including without limitation the Terms of Service. For individuals based in the EEA we store personal data for as long as necessary to fulfill the purposes for which we collect the data, except if required otherwise by law.
Keeping information safe. Valur cares about the security of your information and uses industry standard, commercially reasonable physical, technical and organizational measures designed to preserve the integrity and security of all information we collect. However, no security system is impenetrable and we cannot guarantee the security of our systems 100%. In the event that any information under our control is compromised as a result of a breach of security, we will take reasonable steps to investigate the situation and where appropriate, notify those individuals whose information may have been compromised and take other steps, in accordance with any applicable laws and regulations.
7. Links to Third-Party Websites and Services
8. Children’s Privacy
Valur’s Site and Services are intended for use strictly by adults. We do not knowingly solicit or collect personal information from children under the age of 13. If we learn that any personal information has been collected inadvertently from a child under 13, we will delete the information as soon as possible. If you believe that we might have collected information from a child under 13, please contact us at email@example.com.
10. Your California Privacy Rights
If you are a California resident, California Civil Code Section 1798.83 permits you to request information regarding the disclosure of personal information to third parties for their direct marketing purposes during the immediately preceding calendar year. You may make one request each year by emailing us at firstname.lastname@example.org.
11. GDPR: Information for EEA Users
Legal basis for processing in the EU
In the EU, the purposes for which we process your personal data are:
- Where we need to perform the contract we are about to enter into or have entered into with you for the Service;
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests; and
- Where we need to comply with a legal or regulatory obligation in the EU.
Please contact us at email@example.com if you need details about the specific legal basis we are relying on to process your personal data where more than one legal basis has been set out.
What rights do I have?
If you are located in the EU, you have the following rights under the General Data Protection Regulation (GDPR) in respect of your personal data that we hold:
a) Right of access. The right to obtain access to your personal data.
b) Right to rectification. The right to obtain rectification of your personal data without undue delay where that personal data is inaccurate or incomplete.
c) Right to erasure. The right to obtain the erasure of your personal data without undue delay in certain circumstances, such as where the personal data is no longer necessary in relation to the purposes for which it was collected or processed.
d) Right to restriction. The right to obtain the restriction of the processing undertaken by us on your personal data in certain circumstances, such as where the accuracy of the personal data is contested by you, for a period enabling us to verify the accuracy of that personal data.
e) Right to portability. The right to portability allows you to move, copy or transfer personal data easily from one organization to another.
f) Right to object. You have a right to object to processing based on legitimate interests and direct marketing.
As a Valur user, we rely on your consent as a lawful basis for processing personal data to provide you with access to our Services, to enable the Services to function as expected, to communicate with you in response to customer service inquiries, to deliver service-related emails, and to deliver marketing or promotional communications.
How may I exercise my individual rights?
Valur account holders and users may exercise their rights regarding their personal data as follows:
- You can access your personal data through your account settings on the Valur Site or by contacting us to request a personal data report at firstname.lastname@example.org;
- You may withdraw your consent to receive cookies by adjusting your browser settings;
- You may withdraw your consent to receive marketing or promotional communications at any time by clicking the “unsubscribe” link found within email updates from Valur and changing your contact preferences;
- Except as described in the section “Customer Data” above, you can request deletion of your data as described in the section “De-Activating Your Account or Deleting Your Personal Data.”
You also have the right to lodge a complaint to your local data protection authority. Further information about how to contact the appropriate data protection authority is available at http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm. We encourage you to first reach out to us by using the contact details set out below so that we can have an opportunity to address your concerns directly, and so that we may find a solution together before you lodge a complaint.
12. Contact Us
Last updated: March 1, 2021