Last updated: February 2021
We are dedicated to protecting your privacy and safeguarding your personal information. This Policy describes:
- how we collect, use, disclose, and protect the personal information of our customers and users (“you”) of our site(s) on the World Wide Web, other online sites, services, tools and applications of all kinds (collectively, the “Online Sites & Services“);
- the types of information we may collect from you or that you may provide when you visit or use the Online Sites & Services; and
- our practices for collecting, using, maintaining, protecting, and disclosing your personal information.
This Policy outlines the privacy practices and procedures concerning the personal information we collect, use or disclose about you on the Online Sites & Services, in email, text and other electronic messages between you and the Online Sites & Services, and through mobile and desktop applications you download from the Online Sites & Services, which provide dedicated non-browser-based interaction between you and the Online Sites & Services.
Table of Contents
1. POLICY ACCEPTANCE
3. INFORMATION WE COLLECT ABOUT YOU AND HOW WE COLLECT IT
4. AUTOMATIC DATA COLLECTION TECHNOLOGIES
5. HOW WE USE YOUR INFORMATION
6. DISCLOSURE OF YOUR INFORMATION
7. TRANSFER OF INFORMATION INTERNATIONALLY
8. HOW WE PROTECT YOUR INFORMATION
9. PRIVACY BREACH RESPONSE
10. USE AND DISCLOSURE OF PERSONAL INFORMATION FOR MINORS
11. ACCESSING AND CORRECTING YOUR PERSONAL INFORMATION
12. CHALLENGING COMPLIANCE AND DISPUTE RESOLUTION
14. CONTACT, ENQUIRIES, COMPLAINTS
1. Policy Acceptance
If you are using the Online Sites & Services on behalf of any person, you confirm that you are legally authorized to accept the terms and conditions of this Policy on such person’s behalf.
The Online Sites & Services are not intended for any person under 13 years of age. Please see below for the section on the Use and Disclosure of Personal Information for Minors.
3. Information We Collect About You and How We Collect It
We collect information about you through direct interactions with you when you provide it to us, for example, by filling in forms or corresponding with us, and through automated technologies or interactions when you use the Online Sites & Services, for example, usage details, IP addresses, and information collected through cookies and other tracking technologies.
The types of information that we collect include:
- Personal information that we can reasonably use to directly or indirectly identify you, such as your name, zip code / postal code, email address, telephone number, age range, Internet protocol (IP) address used to connect your computer to the Internet, user name or other similar identifier, billing and account information, your Account Information (as defined below), and any other identifier we may use to contact you (“personal information”).
We use your personal information to confirm your identity and administer your participation in the Online Sites & Services, including, for instance, to permit you to use services through the Online Sites & Services, respond to correspondence from you, or to deliver administrative notices to you.
We also use your email address or telephone number to send you newsletters, messages about our new features, special offers, promotional announcements, consumer surveys and other correspondence concerning our service. Occasionally, we may send these materials to you via postal mail.
If you no longer want to receive newsletters or other announcements, simply access the “Settings” within the Vantage Guest Account or visit the Settings section on our app and uncheck those items to unsubscribe. You may also opt out of receiving further communications from Vantage by contacting us at email@example.com.
- Non-personal information that does not directly or indirectly reveal your identity or directly relate to an identified individual, such as demographic information, or statistical or aggregated information. Statistical or aggregated data does not directly identify a specific person, but we may derive non-personal statistical or aggregated data from personal information. For example, we may aggregate personal information to calculate the percentage of users accessing a specific feature of the Online Sites & Services or showcase traffic patterns for uses of the services available with the Online Sites & Services.
- Account Information, which as described in the Terms of Service, is used to provide services to you and we may from time to time connect other online financial accounts, and obtain account information from those third parties. You may also provide us with financial information. All of this information is referred to as “Account Information.” We treat your Account Information as personal information.
- Special requests may be made to request you to provide us, at your discretion, with personal information in connection with special requests such as contests or special offers.
- Technical information such as including your login information, browser type and version, time zone setting, browser plug-in types and versions, device type, operating system and platform, or information about your internet connection, the equipment you use to access the Online Sites & Services, the name of the Internet domain you used to access the Internet, the IP address of the web site from which you linked directly to our Online Sites & Services, the date and time you accessed a Site, the pages you visited, and usage details. We use this technical information to monitor the effectiveness of the Online Sites & Services and to consider potential improvements to the Online Sites & Services.
We use different methods to collect your information, including through:
- Direct interactions with you when you provide it to us, for example, by filling in fields or forms or corresponding with us by phone, email, or otherwise.
- User contributions when you may, voluntarily, provide information for us to publish or display on public areas of the Online Sites & Services or transmit to other users of the Online Sites & Services or third parties.
- Automated technologies or interactions, as you navigate through our Online Sites & Services. Information collected automatically may include usage details, IP addresses, and information collected through cookies and other tracking technologies.
The information we collect directly from you on or through the Online Sites & Services may include:
- Information that you provide by filling in forms on the Online Sites & Services. This includes information provided at the time of registering to use the Online Sites & Services, subscribing to our services, posting material, or requesting further services. We may also ask you for information when you enter a contest or promotion, and when you report a problem with the Online Sites & Services.
- Records and copies of your correspondence (including email addresses), if you contact us.
- Your responses to surveys that we might ask you to complete for research purposes.
- Details of transactions you carry out through your use of the Online Sites & Services and of the fulfillment of your orders. You may be required to provide financial information before placing an order through the Online Sites & Services.
You may also provide information to be published or displayed (hereinafter, “posted“) on public areas of the Online Sites & Services or transmitted to other users of the Online Sites & Services or third parties (collectively, “User Contributions“). Your User Contributions are posted on and transmitted to others at your own risk. Although we may limit access to certain pages, please be aware that no security measures are perfect. Additionally, we cannot control the actions of other users of the Online Sites & Services with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that unauthorized persons will not view your User Contributions.
4. Automatic Data Collection Technologies
- Details of your visits to the Online Sites & Services, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Online Sites & Services.
- Information about your computer and internet connection, including your IP address, operating system, and browser type.
The information we collect automatically is technical information and may include personal information, and we may maintain it or associate it with personal information we collect in other ways or receive from third parties. Such collection helps us to improve the Online Sites & Services 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 the Online Sites & Services according to your individual interests.
- Speed up your searches.
- Recognize you when you return to the Online Sites & Services.
The technologies we use for this automatic data collection may include:
- Cookies. A cookie is a small file placed on the hard drive of your computer. A persistent cookie remains on your hard drive for an extended period, and we use that to identify you should you return to our website and want to find information that you had started even if you are not logged in, or don’t have a user account. Session cookies are temporary cookie files which are erased when you close your browser, which means when you restart your browser and go back to the site that created the cookie, the website will not recognize you. You will have to log back in (if login is required) or select your preferences/themes again if the Online Sites & Services use these features. A new session cookie will be generated, which will store your browsing information and will be active until you leave the site and close your browser. You can choose whether to accept cookies by adjusting the settings of your browser. If your browser is set to reject cookies, you may still be able to use the Online Sites & Services, but your use may be limited to certain minimal functionality.
- Web Beacons. Pages of the Online Sites & Services may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit Vantage, for example, to count users who have visited those pages and for other related app or website statistics (for example, recording the popularity of certain website or app content and verifying system and server integrity).
We may also use these technologies to collect information about your activities over time and across third-party websites, apps or other online services (behavioural tracking). To learn more or to opt-out of tailored advertising please visit Digital Advertising Alliance of Canada or Network Advertising Initiative for information on how you can opt out of behavioural tracking on or through the Online Sites & Services and how we respond to browser signals and other mechanisms that help users exercise their choices about behavioural tracking.
When you use the Online Sites & Services or their content, certain third parties may collect information about you or your device. These third parties may include: advertisers, ad networks, and ad servers; analytics companies; your mobile device manufacturer; and your mobile service provider.
You can opt-out of several third party ad servers’ and networks’ cookies simultaneously by using an opt-out tool created by the Digital Advertising Alliance of Canada or an opt-out tool created by the Network Advertising Initiative. You can also access these websites to learn more about online behavioural advertising and how to stop websites from placing cookies on your device. Opting out of a network does not mean you will no longer receive online advertising. It does mean that the network from which you opted out will no longer deliver ads tailored to your web preferences and usage patterns.
We do not control these third parties’ tracking technologies or how they use them. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.
5. 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 the Online Sites & Services and their content to you.
- To provide you with information, products, or services that you request from us.
- To fulfill the purposes for which you provided the information or that were described when it was collected, or any other purpose for which you provide it.
- To provide you with notices about your account.
- To carry out our obligations and enforce our rights arising from any contracts with you, including for billing and collection or to comply with legal requirements.
- To notify you about updates and changes to the Online Sites & Services or any products or services we offer or provide though the Online Sites & Services.
- To improve the Online Sites & Services, products or services, marketing, or customer relationships and experiences.
- To allow you to participate in interactive features, social media, or similar features on the Online Sites & Services.
- To measure or understand the effectiveness of the advertising we serve to you and others, and to deliver relevant advertising to you.
- In any other way we may describe when you provide the information.
- For any other purpose with your consent.
We use location information we collect to: create personalized experiences for guests and to understand guest preferences to create a more efficient operational experience.
We may use your information to contact you about our own and third-parties’ goods and services that may be of interest to you, as permitted by law. If you do not want us to use your information in this way, please adjust your user preferences in your account profile or use the unsubscribe mechanism at the bottom of our emails or email us at firstname.lastname@example.org.
We may use the information we have collected from you to enable us to display advertisements to our advertisers’ target audiences. Even though we do not disclose your personal information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.
6. Disclosure of Your Information
- To our subsidiaries and affiliates.
- In accordance with applicable law, 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 Vantage’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Vantage about our customers and users is among the assets transferred. If such transfer occurs, we will use commercially reasonable efforts to ensure that the buyer or successor, as the case may be, maintains privacy policies similar to those of this Policy.
- To advertisers and advertising networks that require the information to select and serve relevant advertisements to you and others. We do not disclose data about identifiable individuals to our advertisers, but we may provide them with aggregate information about our users. We may also use such aggregate information to help advertisers target a specific audience. We may make use of the personal information we have collected from you to enable us to display our advertisers’ advertisement to that target audience.
- To third parties to market their products or services to you if you have consented to these disclosures. For example, Vantage may partner with third parties to provide specific services such as making charitable donations. When you request such services, We will share your personal information to such third parties for them to provide the services. We contractually require these third parties to keep personal information confidential and use it only for the purposes for which we disclose it to them.
- To contractors, service providers, and other third parties we use to support our business (such as analytics and search engine providers that assist us with improvement and optimization of the Online Sites & Services) and who are contractually obligated to keep personal information confidential, use it only for the purposes for which we disclose it to them, and to process the personal information with the same standards set out in this policy.
- To fulfill the purpose for which you provide it.
- For any other purpose disclosed by us when you provide the information.
- With your consent.
We may also disclose your personal information:
- To comply with any court order, law, or legal process, including to respond to any government or regulatory request, in accordance with applicable law. In response to a request by law enforcement or other government officials relating to a criminal investigation or alleged illegal activity, or other activity that may expose us or you to legal liability, Vantage can (and you authorize Vantage to) disclose your personal information and other information about you as Vantage, in its sole discretion, believes necessary or appropriate.
- To enforce or apply our Terms of Service https://vantage.co/terms-of-use/ and other agreements, including for billing purposes.
- If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Vantage, our customers, or others. This includes:
- exchanging information with other companies and organizations for the purposes of fraud protection, intellectual property rights protection, and credit risk reduction;
- enforcing applicable sections of any agreement between you and Vantage, including investigation of potential violations thereof;
- detecting, preventing or otherwise addressing fraud, security or technical issues; or
- protecting against imminent harm to the rights, property or safety of Vantage, its users or the public as required or permitted by law.
7. Transfer of Information Internationally
Information on the Online Sites & Services may be located in or accessed from outside of Canada or sent to others outside of Canada. Please note that any personal information that is outside of Canada may be subject to access by law enforcement and government authorities having jurisdiction in those countries in which the information is located. We will use reasonable efforts to ensure all personal information is protected, but cannot ensure that the laws of other countries will offer the same level of protection as Canadian laws. By submitting personal information to us, you hereby consent to the transmission, processing and/or storage of personal information outside of Canada.
8. How We Protect Your Information
We use physical, electronic, and administrative measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. All safety and security measures are appropriate to the sensitivity level of the information collected. Any payment transactions will be encrypted using SSL technology.
The safety and security of your information also depends on you. Where you have chosen (or we have given you) a password for access to certain parts of the Online Sites & Services, you are responsible for keeping this password confidential and to not to share your password with anyone. It is important for you to protect against unauthorized access to your password and to your computer or other device that you use to access the Online Sites & Services.
Unfortunately, the transmission of information via the Internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to the Online Sites & Services. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Online Sites & Services. Vantage shall not be liable for the transfer of any personal information resulting from loss or distribution of data, the corruption of storage media, power failures, natural phenomena, riots, acts of vandalism, sabotage, terrorism or any other event beyond our control.
The Online Sites & Services may contain links to other Online Sites & Services that are not necessarily under our control. Vantage is not responsible for the privacy practices of such other Online Sites & Services and encourages you to be aware when you leave the Online Sites & Services and to read the privacy policies of each and every web site and mobile app that collects personally identifiable information.
Except as otherwise permitted or required by applicable law or regulation, we will only retain your personal information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Under some circumstances we may anonymize your personal information so that it can no longer be associated with you. We reserve the right to use such anonymous and de-identified data for any legitimate business purpose without further notice to you or your consent.
9. Privacy Breach Response
The security of your personal information is important to us; please advise our privacy officer immediately of any incident involving the loss or unauthorized access to or disclosure of personal information that is in our custody or control.
Employees of Vantage are required to immediately report any breach of privacy, or suspected breach of privacy, to Vantage’s privacy officer. A breach of privacy includes unauthorized external or internal access to our physical records or electronic records, misdirected communications, including mail, fax, and electronic communications, and the loss or theft of physical records or electronic records stored on data storage devices.
Vantage’s privacy officer will coordinate a review of the matter and investigate all reported privacy breaches or suspected privacy breaches, all in accordance with our breach protocols. Where a privacy breach has occurred, we may notify the affected individuals and may report the breach to the relevant privacy commissioner or to the appropriate authorities, including the police.
10. Use and Disclosure of Personal Information for Minors
We believe strongly in the online privacy protection of minors and adhere to the US Federal Children’s Online Privacy Protection Act. The Online Sites & Services are not intended for children under 13 years of age. No one under age 13 may provide any information to or on the Online Sites & Services. We do not knowingly collect personal information from children under 13. If you are under 13, do not use or provide any information on the Online Sites & Services or on or through any of the features or register on the Online Sites & Services, make any purchases through the Site, use any of the interactive or public comment features of the Online Sites & Services, or provide any information about yourself to us, 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 information from a child under 13 without verification of a Parent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us at email@example.com.
All users under the age of 19 must have a parent or guardian register and create an account with us for their minor user to use. Through this registration process, we will obtain verifiable consent from a parent or guardian as required by law before collecting personal information from users aged 13-18 years old.
If we learn we have collected or received personal information from a person under 19 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a person under 19, please contact our privacy officer.
In the future, we may use other levels of verification when a minor participates in activities where the personal information will be used internally by us or disclosed to other individuals or to the public. It is our policy not to condition participation in an activity on disclosure of more personal Information than is reasonably necessary to participate in the activity.
If a minor has submitted personal information, the parents or guardians of such minor may:
- review the personal information at any time;
- require us to delete all personal information about the minor; or
- refuse the further collection or use of the minor’s personal information by contacting our privacy officer.
Vantage reserves the right to make all or portions of the Site unavailable to users under 13 years of age. Parents and guardians have the right to consent to our collection and use of their minor’s personal information while prohibiting disclosure of personal information to third parties that are not providing support for the internal operations of the Site, and this can be done by contacting us at firstname.lastname@example.org.
11. Accessing and Correcting Your Personal Information
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes. By law you have the right to request access to and to correct the personal information that we hold about you.
If your personal information changes (such as address or payment information), or if you no longer desire to use the Online Sites & Services, you can update your information on the account/registration pages of the Online Sites & Services. If you want to review, verify, correct, or withdraw consent to the use of your personal information you may also send us an email at email@example.com to request access to, correct, or delete any personal information that you have provided to us.
We may request specific information from you to help us confirm your identity and your right to access, and to provide you with the personal information that we hold about you or make your requested changes. Applicable law may allow or require us to refuse to provide you with access to some or all of the personal information that we hold about you, or we may have destroyed, erased, or made your personal information anonymous in accordance with our record retention obligations and practices. If we cannot provide you with access to your personal information, we will inform you of the reasons why, subject to any legal or regulatory restrictions.
We will provide access to your personal information, subject to exceptions set out in applicable privacy legislation. Examples of such exceptions include:
- Information protected by solicitor-client privilege.
- Information that is part of a formal dispute resolution process.
- Information that is about another individual that would reveal their personal information or confidential commercial information.
- Information that is prohibitively expensive to provide.
If you are concerned about our response or would like to correct the information provided, you may contact our privacy officer at firstname.lastname@example.org
If you delete your User Contributions from the Online Sites & Services, copies of your User Contributions may remain viewable in cached and archived pages or might have been copied or stored by other users of the Online Sites & Services.
Where you have provided your consent to the collection, use, and transfer of your personal information, you may have the legal right to withdraw your consent under certain circumstances. To withdraw your consent, if applicable, contact us at email@example.com
Please note that if you withdraw your consent we may not be able to provide you with a particular product or service. We will explain the impact to you at the time to help you with your decision.
12. Challenging Compliance and Dispute Resolution
We are committed to having an accessible and responsible complaint handling process in place to ensure you can express concerns about Vantage’s compliance with privacy legislation and other regulatory requirements. Any complaints, disputes, or other feedback concerning our privacy practices, procedures and this Policy should be submitted directly to our privacy officer. We have established appropriate organizational protocols to respond to such inquiries and will, where appropriate, provide a written response to you or amend our privacy practices and procedures or this Policy.
If there is a dispute regarding your personal information or this Policy, you agree to use reasonable efforts to resolve such dispute with us informally and to consult and negotiate with us in good faith to reach a fair and equitable solution.
If the dispute is not resolved through an informal process within 30 days, either you or we may consult the relevant provincial or federal privacy commissioner.
The headings of sections contained in this Policy are for reference purposes only and shall not affect in any way the meaning or interpretation of this Policy. For purposes of this Policy (a) the words “include,” “includes,” and “including” shall be deemed to be followed by the words “without limitation”; (b) the word “or” is not exclusive; and (c) the words “herein,” “hereof,” “hereby,” “hereto,” and “hereunder” refer to this Policy as a whole.
14. Contact, Enquiries, Complaints
As necessary, Vantage may send you announcements and updates regarding the Online Sites & Services. We communicate via email with you to provide requested services and to resolve issues relating to your account.
Please contact our privacy officer to obtain further information about our policies and procedures or if you have any unresolved enquiries or concerns. Our privacy officer can be contacted as follows:
Attention: Privacy Officer
Address: 1110 Boston Avenue, Suite 100 – Longmont, CO 80501