Please read this statement carefully before proceeding to access this Site. Your use of this site indicates your agreement to abide by its terms. If you do not agree with these terms, please do not use this Website.
Should we ask you to provide certain information by which you can be identified when using this Website, then you can be assured that it will only be used in accordance with this privacy statement.
VDL, LLC may change this policy from time to time by updating this page. You should check this page from time to time to ensure that you are happy with any changes. This policy became effective on April 5, 2011, and was last updated on December 16, 2020.
Personal data that we may collect about you relates to any information about a natural person that makes you identifiable, such as your name and email address. Specifically to our Site, we may receive your name and email address if you email us, or if you use our chatbot.
Sensitive personal data
We do not knowingly collect any personally identifiable information from children under the age of 13. If a parent or guardian believes that we have personally identifiable information of a child under the age of 13 in our database, please contact us immediately at [email protected] and we will use our best efforts to promptly remove such information from our records.
General Data Protection Regulations (GDPR)
What is a Data Controller?
For general data protection regulation purposes, the “data controller” means the person or organization who decides the purposes for which and the way in which any personal data is processed. The data controller is VDL, LLC. You can reach us at [email protected]
What is a Data Processor?
A “data processor” is a person or organization which processes personal data for the controller.
What is Data Processing?
Data processing is any operation or set of operations performed upon personal data, or sets of it, be it by automated systems or not. Examples of data processing explicitly listed in the text of the GDPR are: collection, recording, organizing, structuring, storing, adapting, altering, retrieving, consulting, using, disclosing by transmission, disseminating or making available, aligning or combining, restricting, erasure or destruction.
Transferring your information outside of Europe
As part of the services offered to you through this website, the information which you give to us may be transferred to countries outside the European Union (“EU”). We and some of our third-party providers are located outside of the EU. Specifically, this Website is hosted in the United States.
By submitting your personal data, you’re agreeing to this transfer, storing or processing. If you use our services while you are outside the EU, your information may be transferred outside the EU to give you those services.
Access to your personal information and the right to be forgotten
You can request to receive an exported file of the personal data we hold about you, including any data you have provided to us. You can also request that we erase any personal data we hold about you. To exercise this right, please email [email protected]
As mentioned above, except for the information that you choose to provide us, we do not currently collect any personal information.
The right to remove information does not include any data we are obliged to keep for administrative, legal, or security purposes.
If you feel that your personal data has been processed in a way that does not meet the GDPR, you have a specific right to lodge a complaint with the relevant supervisory authority in your country. The supervisory authority will then tell you of the progress and outcome of your complaint.
California Consumer Privacy Act of 2018 (CCPA)
Under the CCPA:
- You have a right to request disclosure of the personal information we collect.
- You have a right to request disclosure of personal information sold or disclosed for a business purpose.
- You have a right to the deletion of your personal information.
- You have a right to opt-out of the sale of your personal information.
- You have a right to data access and data portability.
- We are prohibited from discriminating against you for exercising your consumer rights.
- We are obligated to notify you of your rights.
Information We Collect
We may collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular visitor or device (“personal information”). In particular, we have collected the following categories of personal information from visitors within the last twelve (12) months:
A. Identifiers. Examples: A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers. Do we collect? YES - name and email address if you provide them to us by emailing us or by using our chatbot.
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). Examples: A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories. Do we collect? YES - name and email address if you provide them to us by emailing us or by using our chatbot.
C. Protected classification characteristics under California or federal law. Examples: Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information). Do we collect? NO.
D. Commercial information. Examples: Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. Do we collect? NO.
E. Biometric information. Examples: Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data. Do we collect? NO.
F. Internet or other similar network activity. Examples: Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement. Do we collect? YES. Through our partners Google Analytics and AdThrive, we collect information on your interaction with our website or with advertisements on our website. However, this information is anonymous in the sense that it’s not connected to your name or email address.
G. Geolocation data. Examples: Physical location or movements. Do we collect? NO. We have access to aggregate geolocation data through Google Analytics, but it is not connected to specific users (names, emails, or IP addresses).
H. Sensory data. Examples: Audio, electronic, visual, thermal, olfactory, or similar information. Do we collect? NO.
I. Professional or employment-related information. Examples: Current or past job history or performance evaluations. Do we collect? NO.
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). Examples: Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. Do we collect? NO.
K. Inferences drawn from other personal information. Examples: Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. Do we collect? NO.
We obtain the personal information listed above from the following sources:
1. Directly from you. For example, when you email us or use our chatbot and use your real name.
2. Directly and indirectly from activity on our website. For example, from website usage analytics collected automatically.
Use of Personal Information
We may use or disclose the personal information we collect for one or more of the following business purposes:
1. To fulfill or meet the reason for which the information is provided. For example, if you provide us with your email address when asking a math question, we will use that email address to respond to your question.
2. To provide you with information that you request from us.
3. To improve our website and present its contents to you.
We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
Sharing Personal Information
We may disclose your personal information to a third party for a business purpose.
In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:
Category A: Identifiers: Internet Protocol address.
Category F: Internet or other similar network activity: Information on a consumer’s interaction with a website, application, or advertisement.
We disclose your personal information for a business purpose to the following categories of third parties: Service providers such as advertising agencies and Google Analytics.
In the preceding twelve (12) months, we have not sold any personal information.
Your Rights and Choices
The CCPA provides California residents with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.
1. Access to Specific Information and Data Portability Rights. You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:
- The categories of personal information we collected about you.
- The categories of sources for the personal information we collected about you.
- Our business or commercial purpose for collecting or selling that personal information.
- The categories of third parties with whom we share that personal information.
- The specific pieces of personal information we collected about you (also called a data portability request).
- If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
- sales, identifying the personal information categories that each category of recipient purchased; and
- disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
2. Deletion Request Rights
You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our service providers to:
- Complete the transaction for which we collected the personal information, provide a service that you requested, or take actions reasonably anticipated within the context of our relationship with you.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
- Debug products to identify and repair errors that impair existing intended functionality.
- Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
- Comply with a legal obligation.
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
Exercising Access, Data Portability, and Deletion Rights
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by emailing [email protected]
Only you or a person registered with the California Secretary of State that you authorize to act on your behalf may make a verifiable consumer request related to your personal information.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information.
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
Response Timing and Format
We endeavor to respond to a verifiable consumer request within 45 days of its receipt. We will deliver our written response by email. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
- Deny you services.
- Provide you a different level or quality of services.
- Suggest that you may receive a different level or quality of services.
What information do we collect about you and how?
VDL, LLC, as a Data Controller, is bound by the requirements of the General Data Protection Regulations (GDPR). We are also bound by the requirements of the California Consumer Privacy Act (“CCPA.”)
We may collect the following information:
1. Personal Information You Voluntarily Submit to the Website
We may collect personal information from you such as your name or email address. For example, you may voluntarily submit information to the Website by emailing us or using our chatbot.
2. Automatically-Collected Information
We automatically collect certain information about you and the device with which you access the Website. For example, when you use the Website, we will log your IP address, operating system type, browser type, referring website, pages you viewed, and the dates/times when you accessed the Website. We may also collect information about actions you take when using the Website, such as links clicked.
We may log information using cookies, which are small data files stored on your browser by the Website. We may use both session cookies, which expire when you close your browser, and persistent cookies, which stay on your browser until deleted, to provide you with a more personalized experience on the Website.
For more information, please visit allaboutcookies.org. You can set your browser not to accept cookies and the above website tells you how to remove cookies from your browser.
You agree that we are entitled to obtain, use and process the information you provide to us to enable us to discharge the Services, including contacting you via email and analysis for website improvement purposes.
We use Google Analytics to store information about how visitors use our Website so that we may make improvements and give visitors a better user experience.
You may use this page to opt-out of interest-based advertising.
6. CafeMedia Advertising
7. IP addresses
An IP or Internet Protocol Address is a unique numerical address assigned to a computer as it logs on to the internet. VDL, LLC. does not have access to any personally identifiable information and we would never seek this information. Your IP address is logged when visiting our site, but our analytic software only uses this information to track how many visitors we have from particular regions.
Who we may share your information with
We may share your information with third-party companies that function on our behalf. Examples include, but are not limited to, companies that assist us with serving advertisements on the Site (such as Adthrive.com), analyzing data (such as Google Analytics), and providing technical assistance. We may share information about you that they need to perform their functions.
How will we use your information and why?
At VDL, LLC. we take your privacy seriously and will only use your personal information to provide the Services you have requested from us. We will only use this information subject to your instructions, data protection law and our duty of confidentiality.
Our lawful reason for processing your personal information is “A legitimate interest” eg to respond to your request to receive emails from us. We collect information on our website to process your inquiry and send you emails and newsletters. We do not sell personal information and will not share your information for marketing purposes with other companies so that they may offer you their own products and services.
We may use the information collected in the following ways:
- To operate and maintain the Website;
- To send you promotional information, such as newsletters. Each email promotion will provide information on how to opt-out of future mailings;
- To send you administrative communications, such as administrative emails, confirmation emails, technical notices, updates on policies, or security alerts;
- To respond to your inquiries;
- To track and measure analytics and advertising on the Website;
- To protect, investigate, and deter against unauthorized or illegal activity.
Except when required by law, we will not sell, distribute, or reveal your email addresses or other personal information without your consent; however, we may disclose or transfer personal information collected through the Website to third parties who acquire all or a portion of our business, which may be the result of a merger, consolidation, or purchase of all or a portion of our assets.
From time to time, we may use anonymous data, which does not identify you, or data combined with data from other parties. This type of anonymous data may be provided to other parties for marketing, advertising, or other uses. Examples of this anonymous data may include analytics or information collected from cookies.
You may subscribe to our newsletter, which may be used for advertising purposes. All newsletters sent may contain tracking pixels. The pixel is embedded in emails and allows an analysis of the success of online marketing campaigns. Because of these tracking pixels, we may see if and when you open an email and which links within the email you click. Also, this allows the Website to adapt the content of future newsletters to the interests of the user.
Security precautions in place about data collected
When you give us personal information, we take steps to make sure that it’s treated securely. Our Website is encrypted and protected with the following software: DV SSLs from Let’s Encrypt. When you are on a secure page, a lock icon will typically appear on web browsers.
Non-sensitive details such as your email address are sent normally over the Internet, and this can never be guaranteed to be 100% secure. As a result, while we strive to protect your personal information, we cannot guarantee the security of any information you transmit to us, and you do so at your own risk. Once we receive your information, we make our best effort to ensure its security on our systems.
If you have consented to receive marketing by subscribing to our blog, we will send you information about new blog posts, or other emails and newsletters which may be of interest to you. You may opt-out at any point as set out below. You have a right at any time to stop us from contacting you for marketing purposes. To opt-out please email: [email protected], or use the “Unsubscribe” link on any email you receive from us.
How long will we hold your data?
GDPR requires us to retain personal data no longer than is necessary for the purpose we obtained it for.
We will hold your personal data that you voluntarily gave to us, eg name and email for marketing purposes, for as long as you wish to continue receiving emails from us. With each email you receive from us, you will have the opportunity to opt-out by unsubscribing.
As for information collected by Google Analytics, we have set our user data retention period to the shortest offered, which is 14 months.
Links to other websites
Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.
Embedded content from other websites
How to contact us