Virescit Tactical Systems (“VTS”, “our”, “us” or “we”) respects your privacy and is committed to protecting it through our compliance with this policy.
This policy applies to information we collect:
- on our Website;
- in email, phone, text, and other communications between you and us; and
- when you interact with our advertising and applications on third-party websites and services, if those applications or advertising include links to this policy;
It does not apply to information collected by:
- us through any other means, including on any other website operated by VTS or any third party; or
- any third party, including through any application or content (including advertising) that may link to or be accessible from the Website.
2. Data Controller, Data Protection Officer, and Representative
VTS is the data controller of the Personal Data you provide on the Website. At this time, VTS is not required to appoint a Data Protection Officer or a representative in the EU, and has elected not to do so.
3. Individuals Under the Age of 18
Our Website is not intended for individuals under the age of 18 and individuals under the age of 18 are not permitted to use our Website. We will remove any information about an individual under the age of 18 if we become aware of it.
Our Website is not intended for individuals under 18 years of age. No one under age 18 may provide any information to the Website. We do not knowingly collect Personal Data from individuals under 18. If you are under 18, do not use or provide any information on our Website or on or through any of its features, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received Personal Data from an individual under 18 without verification of parental consent, we will delete that information. If you believe we might have any information from an individual under 18, please contact us at Info@VTScyber.com.
4. Information We Collect About You and How We Collect It
We collect different types of information about you, including information that may directly identify you, information that is about you but individually does not personally identify you, and information that we combine with our other users. This includes information that we collect directly from you or through automated collection technologies.
We collect several types of information from and about users of our Website:
- by which you may be personally identified, such as name, address, e-mail address, telephone number, credit or debit card number, publicly available unique identifier (such as, a CAGE code or DUNS number), and any other identifier by which you may be contacted online or offline (“Personal Data”);
- that is about you but individually does not identify you, such as traffic data, location data, logs, referring/exit pages, date and time of your visit to our Website, error information, clickstream data, and other communication data and the resources that you access and use on the Website; and/or
- about your internet connection, the equipment you use to access our Website and usage details.
We collect this information:
- directly from you when you provide it to us;
- automatically as you navigate through the Website. Information collected automatically may include usage details, IP addresses, and information collected through cookies and other tracking technologies; and
- from third parties, for example, your employer and our business partners.
INFORMATION YOU PROVIDE TO US
The information we collect on or through our Website is:
- information that you provide by filling in forms on our Website. This includes information provided at the time of registering to use our Website, purchasing a product or using our cybersecurity professional training and certification services, software engineering, or governance, risk and compliance managed services, or requesting further services. We may also ask you for information when you report a problem with our Website;
- records and copies of your correspondence (including email addresses), if you contact us;
- details of transactions you carry out through our Website and of the fulfillment of your orders. You may be required to provide financial information before placing an order through our Website; and
- your search queries on the Website.
The Personal Data we collect from you (or your employer) is required to enter into a contract with VTS, for VTS to perform under the contract, and to provide you with our products or services. If you refuse to provide such Personal Data or withdraw your consent to our processing of Personal Data, then in some cases we may not be able to enter into the contract or fulfill our obligations to you under it.
You also may provide information to be published or displayed (hereinafter, “posted”) on public areas of the Website (“User Contributions”). Your User Contributions are posted on the Website at your own risk. We cannot control the actions of other users of the Website who may view your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.
INFORMATION WE COLLECT THROUGH AUTOMATIC DATA COLLECTION TECHNOLOGIES
As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns:
- Usage and Equipment Information. As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, for example, details of your visits to our Website, such as traffic data, location, logs, referring/exit pages, date and time of your visit to our Website, error information, clickstream data, and other communication data and the resources that you access and use on the Website.
- Device Information. Information about your computer, mobile device, and Internet connection, specifically your IP address, operating system, browser type, and browser version information.
The information we collect automatically may include Personal Data or we may maintain it or associate it with Personal Data we collect in other ways or receive from third parties. It helps us to improve our Website and to deliver a better and more personalized service by enabling us to:
- estimate our audience size and usage patterns;
- store information about your preferences, allowing us to customize our Website according to your individual interests;
- speed up your searches; and
- recognize you when you return to our Website.
The technologies we use for this automatic data collection may include:
INFORMATION FROM THIRD PARTIES
We may obtain information about you from other sources, including from your employer to supplement information provided by you. This supplemental information allows us to verify information provided to us and to enhance our ability to provide you with our services. This may include details of the transactions initiated or services received through our Website.
5. Lawful Basis for Processing Your Personal Data
We have a lawful basis for our processing of your Personal Data, including processing for our legitimate interests (when balanced against your rights and freedoms), to fulfill our obligations to you under a contract with you, and required by law, and with your consent.
If you are in the European Union, the processing of your Personal Data is lawful only if it is permitted under the applicable data protection laws. We have a lawful basis for each of our processing activities (except when an exception applies as described below):
- Legitimate Interests. We will process your Personal Data as necessary for our legitimate interests. Our legitimate interests are balanced against your rights and freedoms and we do not process your Personal Data if your rights and freedoms outweigh our legitimate interests. Our legitimate interests are to: facilitate training and certification status to you; facilitate communication between VTS and you; detect and correct bugs and to improve our Website; safeguard our IT infrastructure and intellectual property; detect and prevent fraud and other financial crime; promote and market our business; check your credit and perform risk assessments; develop our product and services;
- To Fulfill Our Obligations to You or Your Employer under our Contract. We process your Personal Data in order to fulfill our obligations to you or your employer pursuant to our contract between you and us or your employer and us to deliver our services to you. For example, if your employer has engaged us to provide training to you, we may bill your employer for your training.
- As Required by Law. We may also process your Personal Data when we are required or permitted to by law; to comply with government inspections, audits, and other valid requests from government or other public authorities; to respond to legal process such as subpoenas; or as necessary for us to protect our interests or otherwise pursue our legal rights and remedies (for instance, when necessary to prevent or detect fraud, attacks against our network, or other criminal and tortious activities), defend litigation, and manage complaints or claims.
6. Special Categories of Information
We generally do not request you provide and do not process any special categories of Personal Data.
VTS does not ask you to provide, and we do not knowingly collect, any special categories of Personal Data from you.
7. Automated Decisions Making
We generally do not use your Personal Data with any automated decision making processes.
VTS does not use your Personal Data with any automated decision making process, including profiling, which may produce a legal effect concerning you or similarly significantly affect you.
8. How We Use Your Information
We use your Personal Data for various purposes described below, including to:
provide our Website to you;
provide our products and services to you;
provide you with information you request from us;
enforce our rights arising from contracts;
notify you about changes; and
provide you with notices about your account.
We use information that we collect about you or that you provide to us, including any Personal Data:
- to present our Website and its contents to you;
- to provide our training, certification and managed services and products to you;
- to establish your eligibility to receive the services from your employer;
- to facilitate transactions between you and us or your employer and us for products and services you purchase through the Website;
- to provide you with information, products or services that you request from us;
- to fulfill any other purpose for which you provide it;
- to provide you with notices about your account, including expiration and renewal notices;
- to carry out our obligations and enforce our rights arising from any contracts entered into between you and us or your employer and us, including for billing and collection;
- to notify you about changes to our Website or any services we offer or provide though them;
- to maintain, secure, or improve our Website and services;
- to respond to your questions or inquiries;
- to provide you with newsletters or other promotional content related to our services;
- in any other way we may describe when you provide the information; and
- for any other purpose with your consent.
We may also use your information to contact you about our products and services that may be of interest to you, including through newsletters. If you wish to opt-out of receiving such communications, you may do so at any time by clicking unsubscribe at the bottom of these communications. For more information, see Choices About How We Use and Disclose Your Information.
our subsidiaries and our affiliates;
our third-party service providers that we use to support our business;
to a company we merge, acquire, or that buys us, or in the event of change in structure of our company of any form;
to comply with our legal obligations;
to enforce our rights; and
with your consent.
- to our subsidiaries and affiliates;
- to contractors, service providers, and other third parties we use to support our business. These entities provide IT and infrastructure hosting and support services, marketing, advertising, payment processing services, and e-learning content providers;
- to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of VTS’ assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by VTS about our Website’s users is among the assets transferred;
- to fulfill the purpose for which you provide it. For example, if you direct us to provide the certification results to an employer, we will transmit your training and certification results to the recipients you identify;
- for any other purpose disclosed by us when you provide the information; and
- with your consent.
We may also disclose your Personal Data:
- to comply with any court order, law, or legal process, including to respond to any government or regulatory request;
- if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of VTS, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
We offer you choices on how you can opt out of our use of tracking technology, disclosure of your Personal Data for our advertising to you, and other targeted advertising.
We do not control the collection and use of your information collected by third parties described above in Disclosure of Your Information. When possible, these organizations are under contractual obligations to use this data only for providing the services to us and to maintain this information strictly confidential. These third parties may, however, aggregate the information they collect with information from their other customers for their own purposes.
In addition, we strive to provide you with choices regarding the Personal Data you provide to us. We have created mechanisms to provide you with control over your Personal Data:
- Disclosure of Your Information for Third-Party Advertising. By using our Website, you consent to our sharing of your Personal Data with our affiliates and third parties who promote our products and services. If you wish to unsubscribe from such affiliate and third parties’ promotions, you can do so by clicking the unsubscribe link at the bottom of any email or other marketing communications you receive from them.
- Promotional Offers from VTS. If you do not wish to have your email address used by VTS to promote our own products and services, you can opt-out at any time by clicking the unsubscribe link at the bottom of any email or other marketing communications you receive from us. This opt-out does not apply to information provided to VTS as a result of a purchase or your use of our services.
You can learn more about interest-based advertisements and your opt-out rights and options from members of the Network Advertising Initiative (“NAI”) on its website (www.networkadvertising.org) and from members of the Digital Advertising Alliance on its website (www.aboutads.info). We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can also opt out of receiving targeted ads from members of the NAI on its website.
11. Your Rights Regarding Your Information and Accessing and Correcting Your Information
You may have certain rights under applicable data protection laws, including the right to access and update your Personal Data, restrict how it is used, transfer certain Personal Data to another controller, withdraw your consent at any time, and the right to have us erase certain Personal Data about you. You also have the right to complain to a supervisory authority about our processing of your Personal Data.
Applicable data protection laws may provide you with certain rights with regards to our processing of your Personal Data.
- Access and Update. You can review and change your Personal Data by notifying us through the Contact Information below of any changes or errors in any Personal Data we have about you to ensure that it is complete, accurate, and as current as possible. We may not be able to accommodate your request if we believe it would violate any law or legal requirement or cause the information to be incorrect.
- Restrictions. You have the right to restrict our processing of your Personal Data under certain circumstances. In particular, you can request we restrict our use of it if you contest its accuracy, if the processing of your Personal Data is determined to be unlawful, or if we no longer need your Personal Data for processing but we have retained it as permitted by law.
- Portability. To the extent the Personal Data you provide VTS is processed based on your consent or that we process it through automated means, you have the right to request that we provide you a copy of, or access to, all or part of such Personal Data in structured, commonly used and machine-readable format. You also have the right to request that we transmit this Personal Data to another controller, when technically feasible.
- Withdrawal of Consent. To the extent that our processing of your Personal Data is based on your consent, you may withdraw your consent at any time by closing your account. Withdrawing your consent will not, however, affect the lawfulness of the processing based on your consent before its withdrawal, and will not affect the lawfulness of our continued processing that is based on any other lawful basis for processing your Personal Data.
- Complaints. You have the right to lodge a complaint with the applicable supervisory authority in the country you live in, the country you work in, or the country where you believe your rights under applicable data protection laws have been violated. However, before doing so, we request that you contact us directly in order to give us an opportunity to work directly with you to resolve any concerns about your privacy.
- How You May Exercise Your Rights. You may exercise any of the above rights by contacting us through any of the methods listed under Contact Information below. If you contact us to exercise any of the foregoing rights, we may ask you for additional information to verify your identity. We reserve the right to limit or deny your request if you have failed to provide sufficient information to verify your identity or to satisfy our legal and business requirements. Please note that if you make unfounded, repetitive, or excessive requests (as determined in our reasonable discretion) to access your Personal Data, you may be charged a fee subject to a maximum set by applicable law.
12. Do Not Track Signals
We may use automated data collection technologies to track you across websites. We currently do not honor do-not-track signals that may be sent by some browsers.
We also may use automated data collection technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking). Some web browsers permit you to broadcast a signal to websites and online services indicating a preference that they “do not track” your online activities. At this time, we do not honor such signals and we do not modify what information we collect or how we use that information based upon whether such a signal is broadcast or received by us.
13. Data Security
Information transmitted over the Internet is not completely secure, but we do our best to protect your Personal Data. You can help protect your Personal Data and other information by keeping your password to our Website confidential.
We have implemented measures designed to secure your Personal Data from accidental loss and from unauthorized access, use, alteration, and disclosure.
The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your Personal Data, we cannot guarantee the security of your Personal Data transmitted to our Website. Any transmission of Personal Data is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.
14. Consent to Processing of Personal Data in the United States
We may process your Personal Data outside of your home country, including to the United States.
If you are a resident of the European Economic Area (“EEA”), in order to provide our Website and services to you, we may send and store your Personal Data outside of the EEA, including to the United States. Accordingly, your Personal Data may be transferred outside the country where you reside or are located, including to countries that may not or do not provide an equivalent level of protection for your Personal Data. By using our Website, you represent that you have read and understood the above and hereby consent to the storage and processing of Personal Data that you provide directly to us on our Website or through our services.
15. Data Retention Periods
We retain your Personal Data for as long as you keep your account open. In some instances, we may keep it after you close your account, for example we may keep it:
on our backup and disaster recovery systems;
for as long as necessary to protect our legal interests; and
and to comply with other legal requirements.
VTS will retain your Personal Data for the entire time that you keep your account open. After you close your account, we may retain your Personal Data:
- for as long as necessary to comply with any legal requirement;
- on our backup and disaster recovery systems in accordance with our backup and disaster recovery policies and procedures;
- for as long as necessary to protect our legal interests or otherwise pursue our legal rights and remedies; and
- for data that has been aggregated or otherwise rendered anonymous in such a manner that you are no longer identifiable, indefinitely.
You may contact us through the contact information below.