Vector Psychometric Group Privacy Notice

At Vector Psychometric Group, maintaining the trust of our users is of the utmost importance to us. Vector Psychometric Group, LLC (“VPG”) has developed this Notice of Privacy Practices (our “Privacy Notice”) to show our commitment to fair information practices and the protection of our users’ privacy, and to describe how we collect, use, share, and disclose information about our users. Please read this Privacy Notice carefully to learn what information we collect from you when you access or use our website and services and how we use that information.

Introduction

This Privacy Notice applies to the processing of personal data that VPG receives from users of VPG’s software and services (collectively, “VPG Services”), which may include (without limitation) VPG’s website at vpgcentral.com, together with any other website that links to this Privacy Notice (collectively, our “Sites”), and any online platform, mobile applications, or other software provided by VPG (the “Software”).

This Privacy Notice explains the types of information we may collect, how we may use and disclose the information once it is collected, and, where applicable, how you can stop us from collecting, using, disclosing or continuing to hold your information. By accessing or using VPG Services, or otherwise providing your agreement to this Privacy Notice, you agree to be bound by this Privacy Notice. This Privacy Notice forms part of our Terms of Service, which describes the terms under which you use VPG Services and which are available at https://store.vpgcentral.com/conditions-of-use. This Privacy Notice should therefore be read in conjunction with those terms. If you do not agree to (or cannot comply with) all of the terms of this Privacy Notice, or with our Terms of Service, then you may not access or use VPG Services.

Please note that this Privacy Notice does not apply to information that you may provide to us, or that we may obtain, where a separate privacy policy is made available to you or in relation to services (such as websites, applications or other services that are provided to you by third parties) that do not make this Privacy Notice available, and it is your responsibility to read and confirm your agreement with the privacy policies and practices of the third parties providing those services before you provide any personal information to them.

Updates to this Privacy Notice

VPG may revise this Privacy Notice from time to time — e.g., to keep up with changes in the law, or to reflect changes in how we are doing business — in which case we will update the “Last Updated” date at the top of this Privacy Notice. If we make material changes to this Privacy Notice, we will use reasonable efforts to notify you (which may be by use of a pop-up notice on the Sites, or by other means consistent with applicable law) and will take any additional steps that may be required by applicable law. If you do not agree to an update to this Privacy Notice, you may not access or continue to use VPG Services. Your continued use of VPG Services after any revisions have been posted will constitute your acknowledgment and acceptance of the revised terms of this Privacy Notice.

What information do we collect?

User-Provided Information

During your use of any VPG Services (whether as a registered or unregistered user), you may provide us with personal information, such as your name, e-mail address, phone number, city and state (or region), information provided in emails to us, or other information that could be used to identify you as an individual or allow someone to contact you, as well as any information that relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, to you (collectively, “Personal Information”). Personal Information can be collected directly from you or indirectly as described below.

Location Data

When using VPG Services from a mobile device (a “Mobile Service”), you may share the geographic location of your device with us if you have consented to location services generally through your device’s settings or accepted our request for access to location information. Your device location may be transmitted to us whenever a Mobile Service is running (even if you are not actively using the Mobile Service or it is running in the background on your device). Your device may continue to transmit its location to us until you change your device settings.

If you set your device not to transmit location information to us, certain features of VPG Services may not be available or their functions may be limited. For example, you will have to manually enter a location when conducting a search if the results of that search are dependent in any way on your location.

Other Data

As is typical of many web sites and mobile applications, when you use VPG Services, we may collect information about your device and your usage of VPG Services including (but not necessarily limited to): your IP address (which we may associate with your domain name or that of your Internet access provider or wireless carrier, and your location); a Unique ID number associated with your device; certain other unique identifiers such as advertising identifiers; Web browser and operating system information; the language of your device; the wireless connections you are using; the referring page that linked you to us; your activities within VPG Services, including browsing and transaction history; pages, content, and links you view or click on during your use of VPG Services, and when and for how long you do so; the next website you visit after leaving our website; and, search terms you enter via VPG Services or a referral site that leads you to our website. In addition, we may deploy tracking technologies through VPG Services to collect additional information about your use of VPG Services, as set out in the “Cookies and other tracking technologies” section of this Privacy Notice.

How do we use your information?

We or our service providers may use the Personal Information we collect from or about you to perform the following functions:

• administer VPG Services and manage your account with us;
• enable you to use VPG Services and their features;
• customize VPG Services to your interests and history with us;
• localize the content and articles that are displayed to you based on your geographical location;
• conduct market research;
• improve or develop new features and offerings in VPG Services;
• tailor ads displayed to you in VPG Services and elsewhere;
• send you marketing and other communications, including information about products, services, or events that we think might be of interest to you;
• assess your level of interest in and use of VPG Services, emails, and other messaging campaigns, both on an individual basis and in aggregate;
• generate analytics reports on the usage of VPG Services; and
• respond to your requests, questions, and concerns protecting our rights and property.

We may also use Personal Information to meet our internal and external audit requirements and for information security purposes. Where permissible under applicable law, your Personal Information may be used for other purposes, which will be disclosed to you at the time when your information is collected. There may be instances, however, when we will use your Personal Information for purposes that were not disclosed at the time of the data collection; for example, when doing so is necessary to comply with a legal obligation or requirement. We may use Personal Information to: (a) respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, which may include such authorities outside your country of residence; (b) enforce our Terms of Use and other policies; and (c) protect our rights, privacy, safety, or property, or those of other persons. We may also use Personal Information in connection with a proposed corporate change or dissolution, including for example a merger, acquisition, reorganization, consolidation, bankruptcy, liquidation, sale of assets or wind down of business.

We may retain information about you for as long as it is necessary for us to fulfill the purposes described in this Privacy Notice. In order to comply with our obligations under applicable law, collect amounts owed to us, resolve disputes, enforce our legal rights, or otherwise make internal use of information in a lawful manner that is reasonably aligned with the expectations of the user or compatible with the context in which the information was provided, and to undertake any investigations necessitated by the foregoing, some of your information may be retained in our systems even after you opt out or request that your information be deleted.

How do we share information we collect?

We may share your information:

• with our lawyers, auditors, and other professional advisors, third party advertising companies (including exchanges and brokers) and third-party providers of services such as cloud storage, customer relationship management systems, travel and expense management, analytics databases, who need your information to provide services to us (or on our behalf);
• when we believe in good faith that disclosure is necessary to protect our rights or property, protect your safety or the safety of others, investigate fraud, or respond to a government agency, law enforcement, judicial or public authority, or other legal request, or to comply with the law;
• when you have given us your consent or otherwise authorized us to use your Personal Information, or when such use is necessary in order for us to provide you with VPG Services that you have requested;
• in connection with a proposed corporate change or dissolution, including for example a merger, acquisition, reorganization, consolidation, bankruptcy, liquidation, sale of assets, or wind down of business, where our accumulated customer information may be treated as a business asset and, as with other business assets, this information may be subject to transfer to or acquisition by a third party in connection with the corporate change;
• with our third-party promotional and marketing partners, including, without limitation, businesses participating in our various programs; and
• with our parent companies, subsidiaries, affiliates, joint ventures, or other companies under common control in order to support marketing, sale and delivery of any service.

We may analyze your information in aggregate form to operate, maintain, manage, and improve VPG Services. We may share non-personally identifiable information about usage of VPG Services (including aggregate data) with third parties, including our affiliates, agents, and business partners, for their own use, in a de-identified form.

In addition, if VPG Services include any public areas that allow for user posts or contributions, then what you voluntarily post to or contribute using those public areas of VPG Services may be available to other users and may be collected by VPG.

VPG Services may allow access to third party content and services and may contain links, banners, widgets, or advertisements that lead to third-party websites. We are not responsible for these other websites or services, and so their posted privacy policies (not this Privacy Notice) will govern the collection and use of your information through them. We encourage you to read the privacy statements of services visited through VPG Services or websites visited after leaving VPG Services to learn about how your information is treated by others.

How do we secure your Personal Information?

We use reasonable technical, administrative and physical security measures designed to protect Personal Information collected via VPG Services. We cannot guarantee that any information, during transmission through the Internet or while stored on our systems or otherwise in our care, will be absolutely safe from unauthorized access or use (e.g., by hackers). You use VPG Services, and send us information, at your own risk.

If you correspond with us by e-mail, text message, or using a “Contact us” feature on VPG Services, a third party could intercept the information you send in transit, and you should therefore take special care in deciding what information you send. We have no liability relating to disclosure of your information due to errors, omissions or unauthorized acts or failures to act by third parties during or after transmission.

If you create an account on VPG Services, you are responsible for maintaining the strict confidentiality of your account password, and you will be responsible for any activity, including disclosure of your Personal Information, that occurs using your account credentials, whether or not you authorized such activity. Please notify us of any actual or suspected unauthorized use of your password or account or any other breach of security of which you are aware.

We have our headquarters in the United States. The Personal Information we or our service providers collect may be stored and processed in servers within or outside of the United States and wherever we and our service providers have facilities around the globe, and certain information may be accessible by persons or companies outside of the United States who provide services for us. Accordingly, we and our service providers may transfer your Personal Information to, or access it in, jurisdictions that may not provide equivalent levels of data protection as your home jurisdiction. We will take reasonable steps to ensure that your Personal Information receives an adequate level of protection in the jurisdictions in which we process it. If you are located in the United Kingdom (“UK”), European Economic Area (“EEA”), or Switzerland, our relevant data processing agreements and other contracts include, incorporate or contain provisions that are based on the Standard Contractual Clauses issued by the European Commission in order to provide adequate protection for the transfer of Personal Information to countries outside of the UK, EEA, or Switzerland. We may also need to transfer your information to other group companies or service providers in countries outside the EEA. This may happen if our servers or suppliers and service providers are based outside the UK, EEA, or Switzerland, or if you use VPG Services while visiting countries outside this area. If you are a resident of a country other than the United States, then by using VPG Services you acknowledge and consent to our collecting, transmitting, and storing your Personal Information out of the country in which you reside.

How do we use cookies and other tracking technologies?

We, and/or our service providers or partners on our behalf, may use tracking technologies, which may run on your device when you use VPG Services. The circumstances in which we may deploy tracking technologies include:

• We may use cookies or local shared objects, such as “Flash cookies.” Cookies are small packets of data that a website stores on your computer’s or mobile device’s hard drive (or other storage medium) so that your computer will “remember” information about your visit. We use both first- and third-party session cookies and persistent cookies. Session cookies make it easier for you to navigate VPG Services; a session ID cookie expires when you close your browser. A persistent cookie remains on your hard drive or in other storage for an extended period of time or until you delete it. You can remove persistent cookies by following directions provided in your web browser’s “help” file. To the extent we provide a log-in portal or related feature on VPG Services, persistent cookies can be used to store your passwords so that you don’t have to enter them more than once. Persistent cookies also enable us to track and target the interests of our visitors to personalize the experience on VPG Services. Similar to many other websites, if you have enabled cookies in your browser, we, independently and through enabled third-party tools and programs, may collect certain technical information using cookies, such as originating IP address, browser type, browser language, how a user got to VPG Services (i.e., the URL of the last website you visited), the next website the user visits, what pages are visited, the length of each site visit, and the date and time of the user’s visit. This information helps us track trends and improve user experiences when using VPG Services.
• HTML5 may be used to store information on your computer or device about your usage of VPG Services. This information can be retrieved by us to determine how VPG Services are being used by our visitors, how VPG Services may be improved, and to customize VPG Services for our users.
• We may send instructions to your computer or device using JavaScript or other computer languages to gather the sorts of information described above and other details about your interactions with VPG Services.

These tracking technologies may be deployed by us and/or our service providers or partners on our behalf. These technologies enable us to assign a unique number to your computer or device, and relate information about your use of VPG Services to other information about you, including your Personal Information. These technologies also enable us to recognize you when you access VPG Services using different web browsers or devices.

VPG understands that some users may have enabled a “do not track” feature or other mechanism intended to provide consumers with a choice regarding the collection of their personally identifiable information; however, consistent with VPG’s rights under applicable law, VPG and VPG Services do not respond to any such “do not track” requests or other signals sent from a web browser. More information on “Do Not Track” is available at http://www.allaboutdnt.com/.

How can you update or delete your information or opt out of messages from us?

If you no longer wish to receive emails or text messages from us (as applicable), you can click on the “Unsubscribe” link provided at the end of each email you receive from us and following the opt-out procedure specified there; please recognize, however, that it may take us a few days to process any opt out request and that even if you opt out of receiving promotional communications from us, we may still send you transactional communications, including messages about your use of VPG Services.

You may request deletion of Personal Information collected or maintained by us. To do so, please submit a request by email to info at vpgcentral.com. We may ask for additional information to verify your request.

We may retain information about you for as long as it is necessary for us to fulfill the purposes described in this Privacy Notice. In order to comply with our obligations under applicable law, collect amounts owed to us, resolve disputes, enforce our legal rights, or otherwise make internal use of information in a lawful manner that is reasonably aligned with the expectations of the user or compatible with the context in which the information was provided, and to undertake any investigations necessitated by the foregoing, some of your information may be retained in our systems even after you opt out or request that your information be deleted.

VPG Services are not aimed at children, and we do not knowingly collect Personal Information from children under the age of 13 through VPG Services. If you are under 13, please do not give us any Personal Information. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce our Privacy Notice by instructing their children to never provide Personal Information without the permission of a parent or legal guardian. If you have reason to believe that a child under the age of 13 has provided Personal Information to us, please contact us at info at vpgcentral.com to request deletion, and we will endeavor to delete that information from our databases as quickly as is reasonably possible.

How can you contact us?

VPG regularly reviews its compliance with this Privacy Notice. Please feel free to contact us with any questions or concerns regarding this Privacy Notice or VPG’s handling of Personal Information by contacting us through VPG Services, emailing us at info at vpgcentral.com, or sending mail to us at Vector Psychometric Group, LLC, 847 Emily Lane, Chapel Hill, NC 27516. If we receive formal written complaints at this address, it is our policy to contact the complaining user regarding his or her concerns. We will cooperate with the appropriate regulatory authorities, including local data protection authorities, to resolve any complaints regarding the use or transfer of Personal Information that cannot be resolved between VPG and an individual.

We hope that can resolve any query or concern you may raise about our use of your information. Individuals located in the EEA or the UK may have the right to lodge a complaint with an applicable supervisory authority.

Additional Terms for Users in California, Nevada, the UK and the EEA

California Privacy Rights

Pursuant to Section 1798.83 of the California Civil Code, residents of California may have the right to obtain certain information about the types of Personal Information that companies with whom they have an established business relationship (and that are not otherwise exempt) have shared with third parties for direct marketing purposes during the preceding calendar year, including the names and addresses of those third parties, and examples of the types of services or products marketed by those third parties. If you wish to submit a request pursuant to Section 1798.83, please contact VPG via email at info at vpgcentral.com.

Nevada Privacy Rights

If you are a resident of Nevada, you have the right to opt-out of the sale of certain Personal Information to third parties who intend to license or sell that Personal Information. You can exercise this right by contacting us at info at vpgcentral.com with the subject line “Nevada Do Not Sell Request” and providing us with your name and the email address associated with your account. Please note that we do not currently sell your personal information as sales are defined in Nevada Revised Statutes Chapter 603A.

EEA and UK Privacy Rights

In countries within the EEA, and in the UK, you have the right, in certain circumstances, to (a) require us delete your Personal Information, (b) require us to restrict processing of your Personal Information (for example, if you contest the accuracy of that information), (c) receive a copy of the Personal Information you provided to us in a structured, commonly used, and machine-readable format and/or instruct us to transmit that data to a third party; and (d) object to our continued processing of your Personal Information, for direct marketing (including profiling) or other purposes. You can exercise these rights free of charge by contacting us using the details in the “Contact us” below.

Where applicable law requires that VPG have a “lawful basis” (or similar grounds) for collecting, retaining and/or processing Personal Information, VPG’s lawful bases for processing Personal Information will depend on VPG’s particular purpose(s) for the processing, and will include the following: if you have given your express consent to our collection and processing of your personal data, then that is our lawful basis for processing that data unless otherwise stated; otherwise, we process your personal data on the ground that such processing is necessary to further our legitimate interests (including: (a) providing effective and innovative services to our users; and (2) to detect, prevent or otherwise address fraud or security issues in respect of our provision of VPG Services), unless those interests are overridden by your interest or fundamental rights and freedoms that require protections of personal data.

You may object to personal data processed pursuant to our legitimate interest. In such case, we will no longer process your personal data unless we can demonstrate appropriate, overriding legitimate grounds for the processing or if needed for the establishment, exercise, or defense of legal claims. You may also object at any time to processing of your personal data for direct marketing purposes by clicking “Unsubscribe” within an automated marketing email or by submitting your request to info at vpgcentral.com with the subject line “GDPR Notice” (the latter for instances where, for example, you would not like to receive follow-ups from our sales team). In such case, your personal data will no longer be used for that purpose.