Last update : 06 May 2022

Villars Institute – PRIVACY POLICY

Villars Institute understands that protecting your personal information is important. This Privacy Policy sets out our commitment to protecting the privacy of personal information provided to us, or otherwise collected by us when providing our software through our platform and providing our consulting services to you and when making accessible our website available at villarsinstitute.org to you ( Services ) or when otherwise interacting with you.

Amendments

We may, at any time and at our discretion, vary this Privacy Policy by publishing the amended Privacy Policy on our website. We recommend you check our website regularly to ensure you are aware of our current Privacy Policy. In the event we make any significant changes to this Privacy Policy we will use our reasonable endeavours to inform you of such changes in advance in writing.

It is important that the personal information we hold about you is true, complete, accurate and current. Accordingly, please notify us of any changes to your personal information (for example, if you change your email address).

The information we collect

Personal information : is information or an opinion, whether true or not and whether recorded in a material form or not, about an individual who is identified or reasonably identifiable.

The types of personal information we may collect about you include:

As a user of our software and/or as a member:

• your name;
• your employer and job title;
• geographical information;
• biographical information;
• your contact details, including email address, mailing address, and/or telephone number;
• your preferences and/or opinions;
• your credit card or other payment and bank account details (including through our third-party payment processor, if any);
• information you provide to us in respect of our account recovery functions related to your account with us and the use thereof by you;
• information you provide to us, including through feedback, customer surveys or otherwise;
• details of services we have provided to you and/or that you have enquired about, and our response to you;
• support requests submitted to us and our response to you;
• information about your access and use of our Services, including through the use of Internet cookies, your communications with our online Services, the type of browser you are using, the type of operating system you are using and the domain name of your Internet service provider;
• your browser session and geo-location data, device and network information (including your IP address), statistics on page views and sessions, acquisition sources, search queries and/or browsing behaviour;
• additional personal information that you provide to us, directly or indirectly, through your use of our Services, associated applications, associated social media platforms and/or accounts from which you permit us to collect information; and
• any other personal information requested by us and/or provided by you or a third party.

When you visit our website:

• your browser session and geo-location data, device and network information, statistics on page views and sessions, acquisition sources, search queries and/or browsing behaviour;
• your contact details, including email address and/or telephone number;
• your preferences and/or opinions;
• information you provide to us, including through feedback, customer surveys or otherwise;
• details of services we have provided to you and/or that you have enquired about, and our response to you;
• support requests submitted to us and our response to you;
• information about your access and use of our Services, including through the use of Internet cookies, your communications with our online Services, the type of browser you are using, the type of operating system you are using and the domain name of your Internet service provider;
• additional personal information that you provide to us, directly or indirectly, through your use of our Services, associated applications, associated social media platforms and/or accounts from which you permit us to collect information; and
• any other personal information requested by us and/or provided by you or a third party.

Sensitive information: is a sub-set of personal information that is given a higher level of protection. Sensitive information means information relating to your racial or ethnic origin, political opinions, religion, trade union or other professional associations or memberships, philosophical beliefs, sexual orientation or practices, criminal records, health information or biometric information.

Sensitive information: The types of sensitive information we may collect about you include:

• your professional associations and memberships.

Unless otherwise permitted by law, we will not collect sensitive information about you without first obtaining your consent.

How we collect personal information

We collect personal information in a variety of ways, including:

• Directly: We collect personal information which you directly provide to us, including when you register for an account, through the 'contact' form on our website, when you interact with or utilise our Services, via email, when you provide feedback to us on our website and/or feedback form, when you request our assistance via email, or over the telephone, or when otherwise communicating with you.
• Indirectly: We may collect personal information which you indirectly provide to us while interacting with us or third parties, such as when you use our Services, when you review our Services online, via social media or blogs, from events, or over the telephone.
• From third parties: We collect personal information from third parties, such as third-party payment providers, service providers who have referred you to us, details of your use of our website from our analytics and cookie providers and marketing providers. See the “Cookies“ section below for more detail on the use of cookies.

Why we collect, hold, use and disclose personal information

We process your personal information for purposes based on legitimate business interests, the fulfilment of our contract with you, compliance with our legal obligations, and/or your consent which are described further below:

Personal information: We may collect, hold, use and disclose personal information for the following purposes:

As a user of our software and/or as a member and/or as a contact for a partner of ours:

• to enable you to access and use our software, including to provide you with a login and to send private messages to other users of our platform;
• to allow other users of our platform to contact you directly;
• to provide our Services to you;
• to run promotions, competitions and/or offer additional benefits to you;
• to contact and communicate with you about our Services, including in response to any support requests you lodge with us or other enquiries you make with us;
• for internal record keeping, administrative, invoicing and billing purposes;
• for analytics, market research and business development, including to operate and improve our Services and associated applications, if any;
• for advertising and marketing, including to send you promotional information about our services and other information that we consider may be of interest to you;
• to comply with our legal obligations and resolve any disputes that we may have; and/or
• if otherwise required or authorised by law.

When you visit our website:

• to provide our website to you;
• to contact and communicate with you about any enquiries you make with us via our website;
• to comply with our legal obligations and resolve any disputes that we may have; and/or
• if otherwise required or authorised by law.

Sensitive information: We only collect, hold, use and disclose sensitive information for the following purposes:

• any purposes you consent to;
• the primary purpose for which it is collected, which is to provide our Services to you and to enable you to obtain the full benefit of those Services;
• secondary purposes that are directly related to the primary purpose for which it was collected, including disclosure to the below listed third parties as reasonably necessary to provide our Services to you; and
• if otherwise required or authorised by law.

Our disclosures of personal information to third parties

We only share and disclose your personal information in the following situations:

• Contractual. We may share personal information with any third-party partners to enable us to provide you with the Services including (without limitation) IT service providers, data storage, web-hosting and server providers, email marketing providers, debt collectors, maintenance or problem-solving providers, marketing providers, professional advisors and payment systems operator. Such third parties will only have access to your personal information to the extent that they need to perform those services. They are required to keep your personal information confidential and may not use it other than as we ask them to and always in accordance with this Privacy Policy.
• Compliance with Legal Obligations. We may disclose your personal information where we are legally required to do so in order to comply with applicable laws, governmental requests, judicial proceedings, court orders, or legal processes, such as in response to a court order or a subpoena (including in response to requests from public authorities in order to meet national security or law enforcement requirements).
• Vital Interests. We may disclose your personal information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, illegal activities or situations involving potential threats to the safety of any person, or where we believe it is necessary for the purpose of providing evidence in connection with litigation proceedings in which we are involved.
• Business Transfers. We may share or transfer your personal 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.
• Partners. Provided you have given us consent to do so we may share your personal information with our business partners to offer you certain products, services or promotions.
• With your consent. We may disclose your personal information for any other purpose with your consent, including with any person who you have named as a person we can contact to discuss your account and any agent or representative of yours, our employees, contractors, related entities and/or our existing or potential agents.

Google Analytics : We may have enabled Google Analytics Advertising Features including Remarketing Features, Advertising Reporting Features, Demographics and Interest Reports, Store Visits, Google Display Network Impression reporting etc.. We and third-party vendors may use first-party cookies (such as the Google Analytics cookie) or other first-party identifiers, and third-party cookies (such as Google advertising cookies) or other third-party identifiers together.

You can opt-out of Google Analytics Advertising Features including using a Google Analytics Opt-out Browser add-on found here. To opt-out of personalised ad delivery on the Google content network, please visit Google's Ads Preferences Manager here or if you wish to opt-out permanently even when all cookies are deleted from your browser you can install their plugin here. To opt out of interest-based ads on mobile devices, please follow these instructions for your mobile device: On android open the Google Settings app on your device and select “ads“ to control the settings. On iOS devices with iOS 6 and above use Apple's advertising identifier. To learn more about limiting ad tracking using this identifier, visit the settings menu on your device.

Overseas disclosure

We may store personal information overseas. Where we, or any third parties that we use, transfer your personal information overseas, we will take all reasonably practicable measures to protect your personal information in accordance with this Privacy Policy and applicable laws. To the extent that any transfer requires approved safeguards to be in place we will only transfer your personal information to countries that have been deemed to provide an adequate level of protection for personal information. Where information is transferred overseas and specific measures are required in respect of that transfer, we will ensure those measures are put in place, for example ensuring the information is protected in accordance with Australian Privacy Principles, using an International Data Transfer Agreement or Standard Model Contractual Clauses. Please contact us if you want further information on the specific mechanism(s) used by us when transferring your personal information overseas.

Consent

You will be required to give consent to certain processing activities before we can process your personal information. Where applicable, we will seek consent from you when you first submit personal information to or through the Services.

If you have previously given your consent, you may freely withdraw such consent at any time. You can do this by emailing info@villarsinstitute.org or, where applicable, clicking the 'Unsubscribe' button that appears in mailing list communications.

If you withdraw your consent, and if we do not have another legal basis for processing your personal information, then we will stop processing your personal information. If we do have another legal basis for processing your personal information, then we may continue to do so subject to your legal rights.

Please note that if we need to process your personal information in order for you to use the Services and you object or do not provide consent to us processing your personal information, you accept that the Services will no longer be available to you.

Your rights and controlling your personal information

You have certain rights in relation to the personal information that we hold about you depending on where you are located or from. For Australian, EU and UK citizens and residents you have a number of specific rights, details of these rights and how to exercise them are set out below. If you are based in another country and request to exercise one of the rights below or any other right you may have, we will do our best to fulfil such a request and will always fulfil the request if legally required. Please note that we will require evidence of your identity before we are able to respond to any requests. This is a security measure to ensure that your personal information is not disclosed to a person who does not have the right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response. To exercise or discuss any of your rights, please contact us via info@villarsinstitute.org.

• Right of Access. If you are in the EU and UK, you have the right at any time to ask us for a copy of the personal information that we hold about you and to check that we are lawfully processing it. Where we have good reason, and where data protection law permits, we can refuse your request for a copy of your personal information, or certain elements of the request. If we refuse your request or any element of it, we will provide you with our reason(s) for doing so. If you are in Australia, you may request access to the personal information that we hold about you. An administrative fee may be payable for the provision of such information. Please note, in some situations, we may be legally permitted to withhold access to your personal information. If we cannot provide access to your information, we will advise you as soon as reasonably possible and provide you with the reasons for our refusal and any mechanism available to complain about the refusal. If we can provide access to your information in another form that still meets your needs, then we will take reasonable steps to give you such access.

• Right of Correction or Completion. If you are in the EU or UK, if the personal information we hold about you is not accurate or is out of date and requires amendment or correction, you have a right to have the data rectified or completed. If you are in Australia, if you believe that any information we hold about you is inaccurate, out of date, incomplete, irrelevant or misleading, please contact us using the details below. We will take reasonable steps to promptly correct any information found to be inaccurate, out of date, incomplete, irrelevant or misleading. Please note, in some situations, we may be legally permitted to not correct your personal information. If we cannot correct your information, we will advise you as soon as reasonably possible and provide you with the reasons for our refusal and any mechanism available to complain about the refusal.

• Right of Erasure. If you are in the EU or UK, in certain circumstances, you have the right to request that the personal information we hold about you is erased (for example, if the personal information is no longer necessary for the purposes for which it was collected or processed or our processing of the personal information is based only on your consent and there are no other legal grounds on which we may process the personal information).

• Right to Anonymity. If you are in Australia, where practicable we will give you the option of not identifying yourself or using a pseudonym in your dealings with us.

• Right to Object to or Restrict Processing. If you are in the EU or UK, in certain circumstances, you have the right to object to our processing of your personal information (for example, if we are processing your personal information on the basis of our legitimate interests but there are no longer any compelling legitimate grounds to justify our processing overriding your rights and interests).

You may also have the right to restrict our use of your personal information, for example during a period in which we are verifying the accuracy of your personal information in circumstances where you have challenged the accuracy of that personal information.

• Right of Data Portability. If you are in the EU or UK, in certain instances, you have a right to receive the personal information that we hold about you (or a portion thereof) in a structured, commonly used and machine-readable format.

In such circumstances, you can ask us to transmit your personal information to you or directly to a third-party organisation on your behalf.

While we are happy for such requests to be made, we are not able to guarantee technical compatibility with a third-party organisation's systems. We are also unable to comply with requests that relate to personal information of others without their consent.

• Right to Lodge a Complaint. You have the right to make a complaint at any time. We would, however, appreciate the chance to deal with your concerns before you approach any supervisory body, so please contact us in the first instance with full details of your complaint. We will promptly investigate your complaint and respond to you, in writing, setting out the outcome of our investigation and the steps we will take in response to your complaint. If you are in Australia and if you are not satisfied with our response, you also have the right to contact the Office of the Australian Information Commissioner. In the UK your complaint may be made to the Information Commissioner's Office (the ICO), the UK supervisory authority for data protection issues (https://ico.org.uk/concerns).

If we are relying on consent to process your personal information, you have the right to withdraw your consent at any time. Please note however that this will not affect the lawfulness of the processing that occurred before the withdrawal of such consent.

Information retention

If you are in the EU or UK, we will only keep your personal information for as long as it is necessary for the purposes set out in this Privacy Policy, unless a longer retention period is required or permitted by law (such as tax law, accounting requirements or other legal or regulatory requirements).

If you are in the EU or UK, when we have no ongoing business purpose to justify the processing of your personal information, we will either delete or anonymise it, 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.

Storage and security

We are committed to ensuring that the personal information we collect is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures, to safeguard and secure personal information and protect it from misuse, interference, loss and unauthorised access, modification and disclosure.

While we are committed to security, we cannot guarantee the security of any information that is transmitted to or by us over the Internet. The transmission and exchange of information is carried out at your own risk. We have procedures in place to deal with any suspected data security breach. We will notify you and any applicable supervisory body of a suspected data breach where we are legally required to do so.

Cookies

We may use cookies on our website from time to time. Cookies are text files placed in your computer's browser to store your preferences. Cookies, by themselves, do not tell us your email address or other personally identifiable information. However, they do recognise you when you return to our online website and allow third parties, such as Google and Facebook, to cause our advertisements to appear on your social media and online media feeds as part of our retargeting campaigns. If and when you choose to provide our online website with personal information, this information may be linked to the data stored in the cookie.

We use the following cookies:

• Essential cookies. These cookies are required for the operation of the Services. They include, for example, cookies that enable you to log in to secure areas of the Services, use a shopping cart or make use of e-billing services.

• Analytical/performance cookies. These cookies allow us to recognise, and count the number of, visitors and to see how visitors move around the Services when they are using it. This helps us to improve the way the Services works, for example by ensuring that users are finding what they are looking for easily.

• Functionality cookies. These cookies enable us to recognise you when you return to the Services. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).

• Targeting cookies. These cookies record your visit to the Services, the pages you have visited and the links you have followed. We will use this information to make the Services and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for related purposes.

You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our website.

Please note that third parties (including, for example providers of external services like web traffic analysis services) may also use cookies, over which we have no control.

You block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of the Services.

If you would like more information about these third-party cookies, it is available from www.youronlinechoices.com/uk.

Note that when third parties are collecting information about you, those third parties are acting as controllers in their own right (i.e., they are not acting on our behalf).

Individuals under 13

The Services are not directed to individuals who are under the age of 13 and we do not solicit or knowingly collect personal information from children under the age of 13. If you believe that we have unknowingly collected any personal information from someone under the age of 13, please contact us immediately.

Links to other websites clients can link their social media accounts

Our website may contain links to other party's websites. We do not have any control over those websites and we are not responsible for the protection and privacy of any personal information which you provide whilst visiting those websites. Those websites are not governed by this Privacy Policy.

Personal information from social network accounts

If you connect your account with us to a social network account, such as Facebook, Google, or LinkedIn, we will collect your personal information from the social network. We will do this in accordance with the privacy settings you have chosen on that social network.

The personal information that we may receive includes your name, ID, user name, handle, profile picture, gender, age, language, list of friends or follows and any other personal information you choose to share.

We may use the personal information we receive from the social network to create or supplement a profile for you on our platform and to enable others to communicate with you.

If you agree, we may also use your personal information to give you updates on the social network which might interest you. We will not post to your social network without your permission.

Where we have accessed your personal information through your Facebook account, you have the right to request the deletion of personal information that we have been provided by Facebook. To submit a request for the deletion of personal information we acquired from Facebook, please send us an email at the address at the end of this Privacy Policy and specify in your request which personal information you would like deleted. If we deny your request for the deletion of personal information, we will explain why.

Contact Us

We welcome your feedback and questions on this Privacy Policy. If you wish to contact us about this Privacy Policy or have any other questions, please email us via info@villarsinstitute.org.

For any questions or notices, please contact us at:

Villars Institute

Email: info@villarsinstitute.org

Last update : 06 May 2022