September 06, 2022
This privacy notice for
Virtual Performance Tool
," "we," "us," or
), describes how and why we might collect, store, use,
and/or share ( "process" ) your information when you use our services ( "Services"
), such as when you:
- Visit our
at https://www.virtualperformancetool.com , or any website of ours that links to this privacy notice
- Engage with
us in other related ways, including any sales, marketing, or events
Questions or concerns? Reading this privacy notice will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at
SUMMARY OF KEY POINTS
This summary provides key points from our privacy notice, but you can find out more details about any of these topics by clicking the link following each key point or by using our table of contents below to find the section you are looking for. You can also click here to go directly to our table of contents.
What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with
Virtual Performance Tool
and the Services, the choices you make, and the
products and features you use. Click
here to learn more.
Do we process any sensitive personal information?
We do not process sensitive personal information.
Do we receive any information from third parties?
We do not receive any information from third parties.
How do we process your information? We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent. We process your information only when we have a valid legal reason to do so. Click here to learn more.
In what situations and with which
parties do we share personal information? We may share
information in specific situations and with specific third
parties. Click here to learn more.
How do we keep your information safe? We have
technical processes and procedures in place to protect your personal information. However, no
electronic transmission over the internet or information storage technology can be guaranteed to be
100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third
parties will not be able to defeat our security and improperly collect, access, steal, or modify
your information. Click here to learn more.
What are your rights? Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information. Click here to learn more.
How do you exercise your rights? The easiest way to exercise your rights is by filling out our data subject request form available
, or by contacting us. We will consider and act upon any request in
accordance with applicable data protection laws.
Want to learn more about what
Virtual Performance Tool
does with any information we collect? Click
here to review the notice in full.
TABLE OF CONTENTS
1. WHAT INFORMATION DO WE COLLECT?
Personal information you disclose to us
In Short: We collect personal information that you provide to us.
We collect personal information that you voluntarily provide to us when you
register on the Services,
express an interest in obtaining information
about us or our products and Services, when you participate in activities on the Services, or
otherwise when you contact us.
Personal Information Provided by You. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:
We do not process sensitive information.
Payment Data. We may collect data necessary to process your payment if you make purchases, such as your payment instrument number (such as a credit card number), and the security code associated with your payment instrument. All payment data is stored by
You may find their privacy notice link(s) here:
All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.
Information automatically collected
In Short: Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you visit our Services.
We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.
The information we collect includes:
- Log and
Usage Data. Log and usage data is service-related, diagnostic, usage, and performance
information our servers automatically collect when you access or use our Services and which we
record in log files. Depending on how you interact with us, this log data may include your IP
address, device information, browser type, and settings and information about your activity in
the Services (such as the date/time stamps associated
with your usage, pages and files viewed, searches, and other actions you take such as which
features you use), device event information (such as system activity, error reports (sometimes
Data. We collect device data such as information about your computer, phone, tablet, or
other device you use to access the Services. Depending on the device used, this device data may
include information such as your IP address (or proxy server), device and application
identification numbers, location, browser type, hardware model, Internet service provider and/or
mobile carrier, operating system, and system configuration information.
Data. We collect location data such as information about your device's location, which
can be either precise or imprecise. How much information we collect depends on the type and
settings of the device you use to access the Services. For example, we may use GPS and other
technologies to collect geolocation data that tells us your current location (based on your IP
address). You can opt out of allowing us to collect this information either by refusing access
to the information or by disabling your Location setting on your device. However, if you choose
to opt out, you may not be able to use certain aspects of the Services.
2. HOW DO WE PROCESS YOUR INFORMATION?
In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent.
We process your personal information for a variety of reasons, depending on how you interact with our Services, including:
facilitate account creation and authentication and otherwise manage user
accounts. We may process your information so you can create and log in to your
account, as well as keep your account in working order.
- To request feedback. We
may process your information when necessary to request feedback and to contact
you about your use of our Services.
- To protect our Services. We
may process your information as part of our efforts to keep our
Services safe and secure, including fraud monitoring and
- To identify usage
trends. We may process information about how you use
our Services to better understand how they are being used so we
can improve them.
- To save or protect an
individual's vital interest. We may process
your information when necessary to save or protect an
individual’s vital interest, such as to prevent
3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?
In Short: We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e.
legal basis) to do so under applicable law, like with your
consent, to comply with laws, to provide you with services
to enter into or
contractual obligations, to protect your rights, or to
fulfill our legitimate
If you are located in the EU or UK, this section applies to you.
The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. As such, we may rely on the following legal bases to process your personal information:
- Consent. We
may process your information if you have given us
, consent) to use your personal information for a specific purpose. You can withdraw your consent at any time. Click here to learn more.
- Legitimate Interests. We may process your information when we believe it is reasonably necessary to achieve our legitimate business interests and those interests do not outweigh your interests and fundamental rights and freedoms. For example, we may process your personal information for some of the purposes described in order to:
Analyze how our services are used so we can improve them to engage and retain users
- Diagnose problems and/or
prevent fraudulent activities
- Understand how our users
use our products and services so we can improve
Obligations. We may process your
information where we believe it is necessary for
compliance with our legal obligations, such as to
cooperate with a law enforcement body or
regulatory agency, exercise or defend our legal
rights, or disclose your information as evidence
in litigation in which we are involved.
Interests. We may process your
information where we believe it is necessary to
protect your vital interests or the vital
interests of a third party, such as situations
involving potential threats to the safety of any
If you are located in Canada, this section applies to you.
We may process your information if you have given us specific permission (i.e.
consent) to use your personal information for a
specific purpose, or in situations where your
permission can be inferred (i.e. , implied
consent). You can withdraw your consent at any time.
Click here to learn
In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent, including, for example:
- If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way
- For investigations and
fraud detection and prevention
- For business transactions
provided certain conditions are met
- If it is contained in a
witness statement and the collection is necessary
to assess, process, or settle an insurance
- For identifying injured,
ill, or deceased persons and communicating with
next of kin
- If we have reasonable
grounds to believe an individual has been, is, or
may be victim of financial abuse
- If it is reasonable to
expect collection and use with consent would
compromise the availability or the accuracy of the
information and the collection is reasonable for
purposes related to investigating a breach of an
agreement or a contravention of the laws of Canada
or a province
- If disclosure is required
to comply with a subpoena, warrant, court order,
or rules of the court relating to the production
- If it was produced
by an individual in the course of their
employment, business, or profession and the
collection is consistent with the purposes for
which the information was produced
- If the collection is
solely for journalistic, artistic, or literary
- If the information
is publicly available and is specified by the
In Short: We may share information in specific situations described in this section and/or with the following
may need to share
your personal information in the following
- Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
5. HOW LONG DO WE KEEP YOUR INFORMATION?
In Short: We keep your information for as long as necessary to
the purposes outlined in this
privacy notice unless otherwise
We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements).
purpose in this notice will require us
keeping your personal information for
period of time in which users have an
account with us
When we have no ongoing legitimate business need to process your personal information, we will either delete or
such information, or, if this is
not possible (for example, because your
personal information has been stored in
backup archives), then we will securely
store your personal information and
isolate it from any further processing
until deletion is possible.
6. HOW DO WE KEEP YOUR INFORMATION SAFE?
In Short: We aim to protect your personal information through a system of
and technical security
We have implemented appropriate and reasonable technical and
security measures designed to
protect the security of any personal
information we process. However, despite
our safeguards and efforts to secure
your information, no electronic
transmission over the Internet or
information storage technology can be
guaranteed to be 100% secure, so we
cannot promise or guarantee that
hackers, cybercriminals, or other
third parties will not be able to
defeat our security and improperly
collect, access, steal, or modify your
information. Although we will do our
best to protect your personal
information, transmission of personal
information to and from our Services is
at your own risk. You should only access
the Services within a secure
7. DO WE COLLECT INFORMATION FROM MINORS?
In Short: We do not knowingly collect data from or market to children under 18 years of age.
We do not knowingly solicit data from or market to children under 18 years of age. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Services. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at
8. WHAT ARE YOUR PRIVACY RIGHTS?
some regions, such as the
European Economic Area (EEA), United
Kingdom (UK), and Canada , you
have rights that allow you greater
access to and control over your
may review, change, or terminate your
account at any time.
In some regions (like
UK, and Canada ), you
have certain rights under applicable
data protection laws. These may include
the right (i) to request access and
obtain a copy of your personal
information, (ii) to request
rectification or erasure; (iii) to
restrict the processing of your personal
information; and (iv) if applicable, to
data portability. In certain
circumstances, you may also have the
right to object to the processing of
your personal information. You can make
such a request by contacting us by using
the contact details provided in the
YOU CONTACT US ABOUT THIS
We will consider and act upon any request in accordance with applicable data protection laws.
If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: https://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.
If you are located in Switzerland, the contact details for the data protection authorities are available here: https://www.edoeb.admin.ch/edoeb/en/home.html.
Withdrawing your consent: If we are relying on your consent to process your personal information,
may be express and/or implied consent
depending on the applicable law,
you have the right to withdraw
your consent at any time. You can
withdraw your consent at any time by
contacting us by using the contact
details provided in the section "
YOU CONTACT US ABOUT THIS
However, please note that this will not affect the lawfulness of the processing before its withdrawal nor,
applicable law allows,
will it affect the processing of
your personal information conducted in
reliance on lawful processing grounds
other than consent.
If you would at any time like to review or change the information in your account or terminate your account, you can:
Contact us using the contact information provided.
Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms and/or comply with applicable legal requirements.
If you have questions or comments about your privacy rights, you may email us at
9. CONTROLS FOR DO-NOT-TRACK FEATURES
Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (
) feature or setting you can
activate to signal your privacy
preference not to have data about your
online browsing activities monitored and
collected. At this stage no uniform
technology standard for
and implementing DNT signals has
. As such, we do not currently
respond to DNT browser signals or any
other mechanism that automatically
communicates your choice not to be
tracked online. If a standard for online
tracking is adopted that we must follow
in the future, we will inform you about
that practice in a revised version of
10. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
In Short: Yes, if you are a resident of California, you are granted specific rights regarding access to your personal information.
California Civil Code Section 1798.83, also known as the
"Shine The Light"
law, permits our users who are
California residents to request and
obtain from us, once a year and free of
charge, information about categories of
personal information (if any) we
disclosed to third parties for direct
marketing purposes and the names and
addresses of all third parties with
which we shared personal information in
the immediately preceding calendar year.
If you are a California resident and
would like to make such a request,
please submit your request in writing to
us using the contact information
If you are under 18 years of age, reside in California, and have a registered account with Services, you have the right to request removal of unwanted data that you publicly post on the Services. To request removal of such data, please contact us using the contact information provided below and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Services, but please be aware that the data may not be completely or comprehensively removed from all our systems (e.g.
CCPA Privacy Notice
The California Code of Regulations defines a
(1) every individual who is in the State of California for other than a temporary or transitory purpose and
(2) every individual who is domiciled in the State of California who is outside the State of California for a temporary or transitory purpose
All other individuals are defined as
If this definition of
applies to you, we must adhere to
certain rights and obligations regarding
What categories of personal information do we collect?
We have collected the following categories of personal information in the past twelve (12) months:
Contact details, such as real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address, and account name
B. Personal information categories listed in the California Customer Records statute
Name, contact information, education, employment, employment history, and financial information
C. Protected classification characteristics under California or federal law
Gender and date of birth
D. Commercial information
Transaction information, purchase history, financial details, and payment information
E. Biometric information
Fingerprints and voiceprints
F. Internet or other similar network activity
Browsing history, search history, online
G. Geolocation data
H. Audio, electronic, visual, thermal, olfactory, or similar information
Images and audio, video or call recordings created in connection with our business activities
I. Professional or employment-related information
Business contact details in order to provide you our Services at a business level or job title, work history, and professional qualifications if you apply for a job with us
J. Education Information
Student records and directory information
K. Inferences drawn from other personal information
Inferences drawn from any of the collected personal information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics
We may also collect other personal information outside of these categories through instances where you interact with us in person, online, or by phone or mail in the context of:
help through our customer support
in customer surveys or contests;
in the delivery of our Services and to
respond to your inquiries.
How do we use and share your personal information?
You may contact us
referring to the contact details at the
bottom of this document.
If you are using an
agent to exercise your right to
opt out we may deny a request if the
agent does not submit proof that
they have been validly
to act on your
Will your information be shared with anyone else?
We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider. Each service provider is a for-profit entity that processes the information on our behalf.
We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be
of your personal
Your rights with respect to your personal data
Right to request deletion of the data — Request to delete
You can ask for the deletion of your personal information. If you ask us to delete your personal information, we will respect your request and delete your personal information, subject to certain exceptions provided by law, such as (but not limited to) the exercise by another consumer of his or her right to free speech, our compliance requirements resulting from a legal obligation, or any processing that may be required to protect against illegal activities.
Right to be informed — Request to know
Depending on the circumstances, you have a right to know:
we collect and use your personal
categories of personal information
that we collect;
purposes for which the collected
personal information is used;
we sell your personal information to
categories of personal information
that we sold or disclosed for a
categories of third parties to whom
the personal information was sold or
disclosed for a business purpose;
business or commercial purpose for
collecting or selling personal
In accordance with applicable law, we are not obligated to provide or delete consumer information that is de-identified in response to a consumer request or to re-identify individual data to verify a consumer request.
Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights
We will not discriminate against you if you exercise your privacy rights.
Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. These verification efforts require us to ask you to provide information so that we can match it with information you have previously provided us. For instance, depending on the type of request you submit, we may ask you to provide certain information so that we can match the information you provide with the information we already have on file, or we may contact you through a communication method (e.g.
phone or email) that you have
previously provided to us. We may also
use other verification methods as the
We will only use personal information provided in your request to verify your identity or authority to make the request. To the extent possible, we will avoid requesting additional information from you for the purposes of verification. However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes. We will delete such additionally provided information as soon as we finish verifying you.
Other privacy rights
- You may
object to the processing of your
- You may
request correction of your personal
data if it is incorrect or no longer
relevant, or ask to restrict the
processing of the information.
- You can
authorized authorized authorized
- You may
request to opt out from future selling
of your personal information to third
parties. Upon receiving an opt-out
request, we will act upon the request
as soon as feasibly possible, but no
later than fifteen (15) days from the
date of the request submission.
To exercise these rights, you can contact us
by email at
by visiting https://www.virtualperformancetool.com
referring to the contact details at the
bottom of this document. If you have a
complaint about how we handle your data, we
would like to hear from you.
11. DO WE MAKE UPDATES TO THIS NOTICE?
In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.
We may update this privacy notice from time to time. The updated version will be indicated by an updated
date and the updated version will
be effective as soon as it is
accessible. If we make material changes
to this privacy notice, we may notify
you either by prominently posting a
notice of such changes or by directly
sending you a notification. We encourage
you to review this privacy notice
frequently to be informed of how we are
12. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
If you have questions or comments about this notice, you may
email us at
13. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?