Privacy Policy

Privacy Promise

Last revised August 24, 2021

Introduction

VOS Consulting Group, LLC (“Company” or “We”), respects your privacy and is committed to protecting it through compliance with this policy.

This policy describes the types of information we may collect from you or that you may provide when you visit the website VOS Consulting Group (“Website”) and our practices for collecting, using, maintaining, protecting, and disclosing that information. Company is the data controller for information processed through the Website.

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our website. By accessing or using this Website, you agree to this privacy policy. This policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of this Website after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

Children

Our website is not intended for nor targeted towards children as defined by applicable law. We do not knowingly collect personal information from children. If you are younger than the age of consent in your jurisdiction, do not use or provide any information on this Website or on or through any of its features or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or username you may use. If you believe we might have any information from or about a child under the applicable age of consent, please contact us at Privacy@infosecom.com and we will delete it.

Information We Collect About You and How We Collect It

We collect several types of information from and about users of our website, including information:

We collect this information:

Automatically as you navigate through the site. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies.
From third parties, for example, our business partners.
Information that you provide by filling in forms on our Website. This includes information provided at the time of requesting further services.
Records and copies of your correspondence with us (including email addresses).
Your responses to surveys that we might ask you to complete for research purposes.
Your search queries on the Website.
Information We Collect Through Automatic Data Collection Technologies.
Details of your visits to our Website, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Website.
Information about your computer and internet connection, including your IP address, operating system, and browser type.

The information we collect automatically can be associated with other personal information 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, including 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.
Recognize you when you return to our Website.

The technologies we use for this automatic data collection include:

Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.
Flash Cookies. Certain features of our Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Website. Flash cookies are not managed by the same browser settings as are used for browser cookies. For information about managing your privacy and security settings for Flash cookies, see International Data Transfers
Web Beacons. Pages of the Website and 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 the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

Cookie Policy

When you visit any website, it may store or retrieve information on your browser, mostly in the form of cookies. This information might be about you, your preferences or your device and is mostly used to make the site work as you expect it to. The information does not usually directly identify you, but it can give you a more personalized web experience. Because we respect your right to privacy, you can choose not to allow some types of cookies. Click on the different category headings to find out more and change our default settings. However, blocking some types of cookies may impact your experience of the site and the services we are able to offer. https://cookiepedia.co.uk/giving-consent-to-cookies

How We Use Your Information

We use information that we collect about you or that you provide to us, including any personal information:

To present our Website and its contents to you.
To provide you with information, or services that you request from us.
To fulfill any other purpose for which you provide it.
To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
To notify you about changes to our Website or any products or services we offer or provide though it.
In any other way we may describe when you provide the information.
For any other purpose to fulfil our legitimate interests or with your consent.
We may disclose aggregated anonymized information about our users without restriction.

International Data Transfers

When you use the Website and provide information through the Website, your information may be transferred to a destination outside your jurisdiction, including to the United States. The United States has not received a finding of “adequacy” from the European Union under Article 45 of the GDPR. Company relies on the safeguards set forth in Article 46 of the GDPR or derogations for specific situations set forth in Article 49 of the GDPR in order to transfer personal information across international borders. In particular, Company transfers personal information across international borders only: with your consent; to perform a contract with you; or to establish, exercise, or defend legal claims. Individuals in the EU may request a copy of applicable Article 46 agreements by emailing privacy@infosecom.com. 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 opt out of receiving targeted ads from members of the Network Advertising Initiative (“NAI”) on the NAI’s website: https://www.networkadvertising.org/.

Your Rights

To the extent required by law, Company provides you with (i) reasonable access to the personal information collected through the Website, and (ii) the ability to review, correct, export, and delete such personal information. Please contact us using any of the methods identified in the “Contact Information” section if you would like to exercise your individual rights and for information on any fee required to obtain copies of your personal information. We will not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect. Individuals in the European Union: You have the right to lodge a complaint with a supervisory authority if you believe we have processed your personal data in a manner inconsistent with your privacy rights. We kindly request that you contact us first so that we may address your concern.

Your California Privacy Rights

California Civil Code Section § 1798.83 permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to Privacy@infosecom.com. The following disclosures are made pursuant to the California Consumer Privacy Act of 2018 (“CCPA”) and identify the categories of personal information we have collected from California consumers on our website over the past twelve months, the categories of sources from which the information was collected, the business or commercial purpose for which the information was collected, and the categories of third parties with whom we shared that information are described below.

Changes to Our Privacy Policy

It is our policy to post any changes we make to our privacy policy on this page with a notice that the privacy policy has been updated on the Website home page. If we make material changes to this policy, we will notify you in accordance with applicable law. The date the privacy policy was last revised is identified at the top of the page. You are responsible for periodically visiting our Website and this privacy policy to check for any changes.

Privacy Notice

Effective Date: January 16, 2023
Notice Version: 2.0

Data Controller Contact Information:

VOS Consulting Group

287 S. Robertson Blvd, Ste 200, Beverly Hills, CA 90211
(310) 341-2554

privacy@vosconsultinggroup.com

Our privacy notice governs our privacy practices when you are using our websites https://www.vosconsultinggroup.com

Definitions

‘NONPERSONAL DATA’ (NPD) means any information that is in no way personally identifiable.

‘PERSONAL DATA’ (PD) means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person can be identified directly or indirectly by reference to an identifier such as a name, an identification number, location data, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person. PD is in many ways the same as Personally Identifiable Information (PII). However, PD is broader in scope and covers more data.

‘SENSITIVE PERSONAL DATA’ (SPD) means a consumer’s social security, driver’s license, state identification card, or passport number; a consumer’s account log-in, financial account, debit card, or credit card number in combination with any required security, access code, password, or credentials allowing access to an account; a consumer’s exact geolocation; a consumer’s ethnic or racial origin, religious or philosophical beliefs, or union membership; the contents of a consumer’s mail, text messages, and email unless the business is the intended receiver of the communication; a consumer’s genetic data; the processing of biometric data to uniquely identify a consumer; personal information collected and analyzed about a consumer’s health; sex life or sexual orientation.

Topics Covered in Our Privacy Notice

YOUR RIGHTS

INFORMATION WE COLLECT AND HOW WE COLLECT IT

HOW YOUR PD IS USED AND DISCLOSED
DATA RETENTION POLICY
PROTECTING THE PRIVACY RIGHTS OF THIRD PARTIES

DO NOT TRACK SETTINGS

LINKS TO OTHER WEBSITES

PROTECTING CHILDREN’S PRIVACY

OUR EMAIL POLICY
OUR SECURITY POLICY

TRANSFERRING PD FROM OTHER COUNTRIES

YOUR CALIFORNIA PRIVACY RIGHTS

CHANGES TO OUR PRIVACY NOTICE

YOUR RIGHTS

Contact us using the information at the top of this privacy notice to exercise any of your legal rights contained within this privacy notice. We will respond to your request within 30 days after receiving it. Occasionally it may take longer for multiple requests or complex circumstances.

When using our website and submitting PD to us, you have certain rights under privacy laws in the United States including the California Consumer Privacy Act (CaCPA), the California Privacy Rights Act (CPRA), and privacy laws of other countries including the European Union General Data Protection Regulation (the EU GDPR), the UK General Data Protection Regulation (the UK GDPR), the UK Data Protection Act of 2018, Canada’s Personal Information Protection and Electronic Documents Act (PIPEDA), and other global privacy laws. Even if not listed here, we will make reasonable efforts to honor data subject access requests even though we may be under no legal obligation to do so. However, we reserve the right to decline any data subject access request that we are not legally obligated to comply with. Your rights include but are not limited to the following:

The right to equal service, and price, and not be discriminated against even if you exercise your privacy rights.
The right to one or more means where you can submit requests under this privacy notice including (at minimum) a toll-free telephone number and an email address if the business operates a storefront and a website. If the business operates only an Internet website, then it must have a dedicated email address where you can submit requests for information required to be disclosed by law.
The right to know whether your PD is sold or disclosed and to whom.
The right to request that we do not sell any of your PD.
The right to be informed about the PD that we collect from you and how we process them.
The right to get confirmation that your PD are being processed and you can access your PD.
The right to have your PD corrected if they are inaccurate or incomplete.
The right to request the removal or deletion of your PD if there is no compelling reason for us to continue processing them. However, the right to deletion is not absolute and can be overridden to continue data processing in some cases where we still have a legal ground or overriding legitimate interest to process your data.
The right to ‘block’ or restrict the processing of your PD. When your PD are restricted, we are permitted to store your PD, but not to process them further.
The right to request the PD that you provided to us and use them for your own purposes. Upon express request, we will provide your data to you or another service or product provider within 30 days of your request subject to commercial and industrial secrets.
The right to object to us processing your PD for the following reasons:
1. processing was based on legitimate interests or the performance of a task in the public interest/exercise of official authority (including profiling);
1. direct marketing and targeted advertising (including profiling);
1. processing for purposes of scientific/historical research and statistics.
The right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects regarding you or similarly significantly affects you.
The right that we limit the collection of your PD to that which is "adequate, relevant and reasonably necessary with the purposes for which the data is processed.
The right that we do not process your PD for purposes that are neither reasonably necessary nor compatible with the disclosed purposes for which such personal data is processed, as disclosed to you unless the controller obtains your consent.
The right to designate an authorized agent to make a request on your behalf. When designating an authorized agent, you must provide a valid power of attorney, the requester’s valid government-issued identification, and the authorized agent’s valid government-issued identification.
The right to file a complaint with supervisory authorities if your information has not been processed in compliance with your rights under privacy laws.

INFORMATION WE COLLECT AND HOW WE COLLECT IT

Generally, you control the amount and type of information that you provide to us when using our website.

Our Legal Basis for Collecting and Processing PD

Our legal basis for collecting and processing your PD when you buy our products or services or fill in any of the contact forms on our website is based on the necessity for the performance of a contract or to take steps to enter into a contract.

Automatic Information

We automatically receive information from your web browser or mobile device. This information may include the IP address of your computer or the proxy server you use to access the Internet, your Internet service provider’s name, your web browser type, the type of mobile device, your computer operating system, and data about your browsing activity when using our website. We use all this information to help improve our website.

When Entering and Using Our Website

When you enter and use our website and agree to accept cookies, some of these cookies may contain your PD.

Our Use of Cookies

Our website uses cookies. A cookie is a small piece of data or a text file that is downloaded to your computer or mobile device when you access certain websites. Cookies may contain text that can be read by the web server that delivered the cookie to you. The text contained in the cookie consists of a sequence of letters and numbers that uniquely identifies your computer or mobile device; it may contain other information as well.

By agreeing to accept our use of cookies you are giving us and the third parties with which we partner permission to place, store, and access some or all the cookies described below on your computer and or mobile device.

Strictly Necessary Cookies - These cookies are necessary for the proper functioning of the website, such as displaying content, logging in, confirming your session, responding to your request for services, and other functions.
Performance Cookies - These cookies collect information about the use of the website, such as pages visited, traffic sources, users’ interests, content management, and other website measurements.
Functional Cookies - These cookies enable the website to remember users’ choices, such as their language, usernames, and other choices while using the website.
Media Cookies - These cookies can be used to improve a website’s performance and provide special features and content. They can be placed by us or third parties who provide services to us.
Advertising or Targeting Cookies - These cookies are usually placed and used by advertising companies to develop a profile of your browsing interests and serve advertisements on other websites that are related to your interests.
Session Cookies - These cookies allow websites to link the actions of a user during a browser session. They may be used for remembering what a user puts in their shopping cart as they browse a website. Session cookies also permit users to be recognized as they navigate a website so that any item or page changes, they make are remembered from page to page. Session cookies expire after a browser session.
Persistent Cookies - These cookies are stored on a user’s device between browser sessions, which allows the user’s preferences or actions across a website or across different websites to be remembered. Persistent cookies may be used for remembering users’ choices and preferences when using a website or target advertising to them.
We may also use cookies for:
- identifying the areas of our website that you have visited;
- personalizing the content that you see on our website;
- our website analytics;
- remarketing our products or services to you;
- remembering your preferences, settings, and log-in details;
- targeted advertising and serving ads relevant to your interests;
- allowing you to disclose content with social networks.

Most web browsers can be set to disable the use of cookies. However, if you disable cookies, you may not be able to access features on our website correctly or at all.

Web Beacons

We may use a technology called web beacons to collect general information about your use of our website and your use of special promotions or newsletters. The information we collect by web beacons allows us to statistically watch the number of people who open our emails.

When Buying Products or Services

When you register as a user or when buying our products or services, we may collect some or all the following information: your name, email address, and telephone number.

Google API

By using our website, you are subject to the Google Privacy Policy and Terms of Service.
When collecting and processing user data, including PD from Google APIs, we will follow Google API Services User Data Policy. We also require that our employees, contractors, and agents comply with the Google API Services User Data Policy.

Chat Software or Contact Forms

Our website contains chat software or contact forms that enable visitors to communicate with us online or offline by email. Sometimes, visitors can communicate with us without buying our products and services. When you use our chat software or contact forms, we may collect some or all the following information: your email address, first name, last name, location, and any other information you willingly choose to give us. You should limit the information you give to us to one that is necessary to answer your questions.

Google Analytics

Our website uses Google Analytics to collect information about the use of our website. Google Analytics collects information from users such as age, gender, interests, demographics, how often they visit our website, what pages they visit, and what other websites they have used before coming to our website. We use the information we get from Google Analytics to analyze traffic, and improve our marketing, advertising, and website. We do not combine the information collected using Google Analytics with PD. You can prevent Google Analytics from using your information by opting out at this link: https://tools.google.com/dlpage/gaoptout

What Happens If You Don’t Give Us Your PD

If you do not provide us with enough PD, we may not be able to provide you with all our products and services. However, you can access and use some parts of our website without giving us your PD.

HOW YOUR PD IS USED AND SHARED
We use the information we receive from you to:

provide our products and services you have requested or purchased from us;
personalize and customize our content;
make improvements to our website;
contact you with updates to our website, products, and services;
resolve problems and disputes;
contact you with products and services that we believe may be of interest to you;
process the least personal data required to provide app and website functionality;
respect and apply customer consent decisions;
respect and apply customer decisions to opt-out of any data sharing such as a ‘data sale’ or similar concept under applicable laws or regulations;

Communications and Emails

When we communicate with you about our website, we will use the email address you provided when you registered as a user or customer. We may also send you emails with promotional information about our website or offers from us or our affiliates unless you have opted out of receiving such information. You can change your contact preferences at any time through your account or by contacting us using the information at the top of this privacy notice.

Disclosing Your Information When You Log in Using Social Media Websites

If you sign into our services through a third-party social networking service or website, your “friends” list from that service or website might be automatically imported to our services. We do not have any control over the privacy notices and business practices of other third-party services or websites.

If you log into our website using social media websites, you are agreeing to let us use and store your profile information from those websites to make better use of any social media features on our website. This disclosing of information helps us provide you with a better experience when using our website and provides us with information such as visitor traffic. If you use any of the social disclosing icons on our website to disclose our information, you may also be disclosing your personal information through social media websites.

Text Messaging, SMS, Push Notifications, and Telephone Calls

If you provide a mobile telephone number, or landline telephone number to us, you are giving your express consent and authorize us or a third party to contact you by using any of these communication methods. You are not required to give us your consent to contact you through these communication methods. However, withholding your consent may interfere with or prevent us from providing some or all our services to you. You can stop receiving text messages, push notifications, and telephone calls by contacting us or using one of our opt-out methods.

Disclosing Your PD to Third Parties

We do not sell or rent your PD to third parties for marketing purposes.

Disclosing Your PD to Service Providers and or Contractors

At times we give your PD to service providers and or contractors whom we hire to provide services to us. These service providers and or contractors may include but are not limited to payment processors, call centers, data management services, help desk providers, accountants, law firms, state and federal courts, auditors, shopping cart and email service providers, and shipping companies.

Legally Required Releases of Information

We may disclose your PD if such disclosure is (a) required by subpoena, law, or other legal processes; (b) necessary to assist law enforcement officials or government enforcement agencies; (c) necessary to protect us from legal action or claims from third parties, including you and or other users; or (d) necessary to protect the legal rights, personal and or real property, or the personal safety of our company, users, employees, and business partners.

Disclosures to Successors

If our business is sold or merges in whole or in part with another business that would become responsible for providing the website to you, we retain the right to transfer your PD to the new business. The new business would retain the right to use your PD according to the terms of this privacy notice as well as to any changes to this privacy notice as instituted by the new business. We also retain the right to transfer your PD if our company files for bankruptcy and some or all of our assets are sold to another individual or company.

Community Discussion Boards, Blogs, or Other Mechanisms

Our website may offer the ability for users to communicate through online community discussion boards, blogs, or other mechanisms. If you choose to post on these discussion mechanisms, you should use care when exposing any PD, as such information is not protected by our privacy notice nor are we liable if you disclose your PD through such postings. Also, PD which you post on our website for publication may be available worldwide on the Internet. We cannot prevent the use or misuse of such information by others.

DATA RETENTION POLICY
We retain your PD if it is necessary to provide our services and or products to you and to fulfill the purposes outlined in our privacy notice, subject to any legal obligations which may require a longer retention period. PD associated with your account will be kept until it is no longer necessary to provide our services and or products or until you ask us to delete it.

The criteria used to determine our retention periods include:

The length of time we have a continuing relationship with you and provide the services and or products to you that you requested.
Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them).
Whether retention is advisable considering our legal position (such as, for statutes of limitations, litigation, or regulatory investigations).

PD about you that is no longer necessary to provide our products or services may be de-identified and aggregated with other NPD to provide insights, such as statistics on the use of our services and or products. This information will be deidentified from your name and other personally identifiable information.

PROTECTING THE PRIVACY RIGHTS OF THIRD PARTIES

If you make any postings on our website that contain information about third parties, you agree that you have permission to include that information. While we are not legally liable for the actions of our users, we will remove any postings about which we are notified if such postings violate the privacy rights of others.

DO NOT TRACK SETTINGS

Some web browsers have settings that enable you to request that our website not track your movement within our website. Our website does not obey such settings when transmitted to and detected by our website. You can turn off tracking features and other security settings in your browser by referring to your browser’s user manual.

LINKS TO OTHER WEBSITES

Our website may contain links to other websites. These websites are not under our control and are not subject to our privacy notice. We have no responsibility for these websites, and we provide links to these websites solely for your convenience. You accept that your use of and access to these websites are solely at your risk.

PROTECTING CHILDREN’S PRIVACY

Our website is not designed for use by anyone under the age of 16. We do not knowingly collect PD from children under the age of 16. If you are a parent or guardian and believe that your child is using our website and they are under the age of 16, please contact us. Before we remove any information, we may ask for proof of identification to prevent malicious removal of account information. If we discover that a child under the age of 16 is accessing our website, we will delete their information within a reasonable period of time. You acknowledge that we do not verify the age of our users nor have any liability to do so.

OUR EMAIL POLICY
You can always opt-out of receiving email correspondence from us or our affiliates. We will not sell, rent, or trade your email address to any unaffiliated third-party without your permission except in the sale or transfer of our company, or if our company files for bankruptcy as described in the section Disclosures to Successors.

OUR SECURITY POLICY
We have built our website and services using industry-standard security measures and authentication tools to protect the security of your PD. We and the third parties who provide services to us also maintain technical and physical safeguards to protect your PD. SPD is protected at a higher level than most PD. Unfortunately, we cannot guarantee the prevention of loss or misuse of your PD or secure data transmission over the Internet because of its nature. We strongly urge you to protect any password you may have for our website and not disclose it with anyone.

TRANSFERRING PD FROM OTHER COUNTRIES

PD that we collect from you may be stored, processed, and transferred among any countries in which we operate. The European Union has not found the United States and some other countries to have an acceptable level of protection of PD under Article 45 of the GDPR. Our company relies on derogations for specific situations as defined in Article 49 of the GDPR. If you are a European Union user, or a user from another country, with your consent your PD may be transferred to the United States or other countries when you request information from us. When you buy goods or services, we will use your PD to perform a contract with you. Wherever we transfer, process, or store your PD, we will try to apply reasonable safeguards to protect it. We will use the information we collect from you by following the practices described in our privacy notice. Also, we enter into data processing agreements and standard contractual clauses when appropriate. By using our website, services, or products, you agree to the transfers of your PD described within this section.

YOUR CALIFORNIA PRIVACY RIGHTS

California Civil Code Section § 1798.83 permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to privacy@vosconsultinggroup.com. The following disclosures are made pursuant to the California Consumer Privacy Act of 2018 (“CCPA”) and identify the categories of personal information we have collected from California consumers on our website over the past twelve months, the categories of sources from which the information was collected, the business or commercial purpose for which the information was collected, and the categories of third parties with whom we shared that information are described above.

CHANGES TO OUR PRIVACY NOTICE

We reserve the right to change this privacy notice at any time. If our company decides to change this privacy notice, we will post those changes on our website, so our users and customers are always aware of what information we collect, use, and disclose. If at any time we decide to disclose or use your PD in a method different from that specified at the time it was collected, we will provide advance notice by email sent to the email address on file in your account. Otherwise, we will use and disclose our users’ and customers’ PD in agreement with the privacy notice in effect when the information was collected., your continued use of our website, services, and products after any change to this privacy notice will constitute your acceptance of such change. If you have questions about our privacy notice, please contact us through the information at the top of this privacy notice.