top of page

Privacy Policy

A LEGAL DISCLAIMER

Visual Governance Inc. and its affiliated companies (“Visual Governance” or “we”) respect the privacy of personally-identifiable information (“Personal Information”) collected from users of our services.  This Privacy Policy (“Policy”) explains how Visual Governance collects, uses, shares and discloses Personal Information, including via our websites and online portals (the “Visual Governance Sites”).

​

This Policy does not apply to, and Visual Governance is not responsible for: (i) the practices of any other companies or individuals, or (ii) any third-party websites, platforms, devices, applications or services that you access via links from Visual Governance’s website or web applications (“Third Party Services”).  We encourage you to review the privacy policies of any Third Party Services that you access.

​

1. COLLECTION AND USE OF INFORMATION

We collect and use Personal Information in various ways across Visual Governance’s suite of supply chain management, secure collaboration, and risk and identity management services.

​

A. Registration Information.
We collect information when users visit or register on Visual Governance Sites, including name, telephone numbers, email addresses, business address, and other attributes for particular applications (e.g. user role for application, start date of application trial, etc.) (“Registration Information”). We may collect Contact/User Information (Registration Information) directly from a user, or from the user’s company.

Visual Governance uses Registration Information for administrative, billing, marketing and recordkeeping purposes, and to communicate with users about service updates, service adoption by their community and service maintenance. In order to promote community membership and increased adoption of our services, Visual Governance may disclose the name of the user’s company (without identifying the user) to other users and to potential community members. Visual Governance may also include the Registration Information in a User Directory for distribution to other users (please see section 3 below for details on how to opt out of the User Directory). Except as provided in this Privacy Policy or with the consent of the applicable user, Visual Governance will not disclose Registration Information to third parties.

​

B. User Information.
Users communicate, collaborate and exchange information with Visual Governance and other users (“User Information”). User Information includes, among other things, information submitted to Visual Governance Sites, or to other companies via Visual Governance Sites.

​

Visual Governance uses User Information primarily to provide the services on Visual Governance Sites, by making the User Information available on Visual Governance Sites as specified by users. Certain Visual Governance workforce may also have access to User Information for administrative or security purposes. Except as provided in this Privacy Policy or with the consent of the applicable user, Visual Governance will not disclose User Information to third parties or to Visual Governance users other than ones to which the User Information was communicated.

​

C. Tracking Information.
When a user accesses Visual Governance Sites, Visual Governance Sites record and retain general data about the user’s use of Visual Governance Sites including the user’s domain name, the web page(s) from which the user entered Visual Governance Sites, the web page(s) which the user visited on Visual Governance Sites, and the amount of time the user spent on each web page of Visual Governance Sites (“Tracking Information”). Visual Governance may use third-party analytics tools to generate Tracking Information; third parties providing such tools are permitted to transfer Tracking Information only to Visual Governance.

Visual Governance uses Tracking Information to determine the attributes of users, and statistics and general information about usage of Visual Governance Sites, for both internal and external use. Except as provided in this Privacy Policy, Visual Governance will not disclose Tracking Information to third parties in a manner that reasonably permits such information to be identified with an individual user or specific user transaction (see section 2.B below regarding disclosure of Aggregated Data).

​

D. Identity Information
For our services providing identity proofing (i.e. verification) and credentialing, we collect various information associated with the individuals whose identities are being checked (“Identity Information”). Identify Information differs depending upon the type and level of proofing, and may include Registration Information, Tracking Information, user ID numbers associated with proofing, government-issued ID documents (e.g. passport, driver’s license), other legal documents (e.g. birth certificate, marriage license), documents regarding employment, credit history, details of physical and electronic credentials and tokens, nationality, citizenship, physical location and time zone, proofing appointment information, and proofing outcome information. Identity Information is collected in person, over video interfaces and via other forms of electronic communication.

​

Visual Governance uses Identity Information solely to provide proofing, credentialing and access services, to confirm credentials that have been issued, and to maintain the integrity of the proofing and credentialing process reliant services. We do not share Identity Information with the third parties, except as specified in section 2.C of this Policy or with the consent of the user to which the Identify Information relates.

​

E. Cookies.
Visual Governance uses “cookies”—small files stored in user web browsers—to improve the functions of Visual Governance Sites, including optimizing presentation of information, streamlining the log-in process, and recording user preferences. Cookies may store Personal Information including browser information, IP address and username. Please see https://www.wikihow.com/Disable-Cookies regarding how to disable cookies. However, if a user disables cookies, he/she may not be able to log into or use certain features of Visual Governance Sites.

​

F. Other Information.
A user may choose to send Visual Governance a question via e-mail, register for a special service or otherwise communicate with Visual Governance. Visual Governance uses such information to communicate with users and to enhance Visual Governance Sites to better meet the needs of users. Except as provided in this Privacy Policy, Visual Governance will not disclose such information in a manner that reasonably permits such information to be identified with an individual user or specific user transaction.

​

G. RIGHTS OF CALIFORIA RESIDENTS PURSUANT TO THE CALIFORNIA CONSUMER PRIVACY ACT (the “CCPA”)

California law requires businesses to disclose information regarding the rights of California residents pursuant to the CCPA. Any terms defined in the CCPA (Cal. Civ. Code Section 1798.140) have the same meaning when used in this section.

You may request that we disclose to you the following information covering the preceding 12 months:

(1) The categories of personal information we have collected about you;

(2) The categories of sources from which the personal information was collected;

(3) The business or commercial purpose for collecting or selling personal information;

(4) The categories of third parties with which we share personal information;

(5) The categories of personal information about you that we have sold and the categories of third parties to which the personal information was sold;

(6) The categories of personal information about you that we have disclosed for a business purpose and the categories of third parties to which the personal information was disclosed;

(7) The specific pieces of personal information we have collected about you.

​

You may request the disclosure of the information listed above by calling 954-393-0077 or submitting a request at privacy@visualgovernance.com. Such a request may be referred to as a right to know request. Pursuant to California law, we will verify your identity before complying with any such request.

​

You have the right to request that we delete any personal information about you that we have collected from you, and that we direct any service provider to delete such personal information from its records. Such a request may be referred to as a request to delete. However, pursuant to the CCPA and GDPR, your information may not be deleted under certain circumstances, including where maintenance of your personal information is necessary to: complete the transaction for which the personal information was collected, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, to provide a good or service that you requested or that is reasonably anticipated within the context of your ongoing business relationship with us, or to otherwise perform a contract between us and you; to detect security incidents, protect against or prosecute fraudulent or illegal activity; to enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us; to comply with a legal obligation; or to otherwise use your information internally in a lawful manner that is compatible with the context in which you provided the information.  For more information about these and other situations in which we may not delete your information, please see Cal. Civ. Code Section 1798.105(d) or EU GDPR.

​

You may request the deletion of your information by calling 954-393-0077 or submitting a request at privacy@visualgovernance.com.  Before deleting your personal information, we will verify your identity, as required by the CCPA.

​

You may use an authorized agent to submit a right to know request or a request to delete. To use an authorized agent, you must provide the agent with written authorization. In addition, you may be required to verify your own identity with us. We may deny a request from an agent that does not submit proof that they have been authorized by you act on your behalf. Such requirements, however, will not apply where you have provided the agent with power of attorney pursuant to Cal. Prob. Code Sections 4000 to 4465.

​

You have the right, at any time, to direct  us not to sell your personal information.  This right may be referred to as the right to opt-out.  You may opt out of the sale of your personal information by 954-393-0077 or submitting a request at privacy@visualgovernance.com. If we have a good faith, reasonable, and documented belief that a request to opt-out is fraudulent, we may deny the request. You may use an authorized agent to submit a request to opt-out on your behalf. To do so, you must provide the agent with written authorization do so. We may deny a request from an agent that does not submit proof that they have been authorized by you to act on your behalf.

​

In addition, we do not and will not sell the personal information of minors we have actual knowledge are under the age of 16 without affirmative authorization (known as “opt-in”).

​

In the preceding 12 months, we have collected the following categories of personal name, email, address, company, title, phone information about California residents from the following sources and for the following purposes. Only if you have contacted us directly requesting information or trying to sell your services. 

​

2. SHARING OF INFORMATION WITH THIRD PARTIES

Visual Governance shares Personal Information with certain third parties as described below, and takes responsibility for such sharing as provided in this Policy and applicable law.

  1. Technology Service Providers

    1. Microsoft

    2. AWS

    3. Coro.net

    4. Virtual GRC

    5. HubSpot

    6. Zoho

    7. GENRX

    8. WIX

The Technology service and support providers listed above are designed to be used for supporting Visual Governance information Systems (including Personal Information) within our organization.

  1. Appstraxion Solutions Corp.
    The IT service support provider services are designed to be used for supporting Visual Governance information Systems (including Personal Information) within our organization.

 

B. Aggregated Data.
Visual Governance may process and disclose information in aggregated form (based on Personal Information held by Visual Governance) that does not reasonably identify, the Subscriber, an individual user, or specific user transaction on Visual Governance Sites (“Aggregated Data”), including: (i) providing information regarding trends, purchasing patterns and retail intelligence and research; (ii) performing its obligations under agreements with third party licensors or other users; (iii) internal record keeping and reporting by Visual Governance; (iv) measuring the performance of third-party licensors and service providers; and (v) reporting performance and other statistical information concerning Visual Governance Sites.

C. Subcontractors.
Visual Governance may disclose Personal Information to third parties who support Visual Governance services, with appropriate agreements to ensure the information is used only for such service support and in accordance with this Policy.

D. Disclosure Under Law.
Visual Governance may disclose Personal Information if Visual Governance is required to make such a disclosure under applicable laws, or to report a violation or suspected violation of applicable laws to appropriate governmental authorities.

E. Sale of Company.
In the unlikely event of a sale of Visual Governance or its assets, Visual Governance is likely to disclose Personal Information to the new owners, subject to a requirement that such information be used only in accordance with this Privacy Policy and other contractual commitments to users.

​

3. OPTING OUT

Participation in Visual Governance services is voluntary. To opt out of processing of personal data pursuant to this Privacy Policy, a user should notify Visual Governance through privacy@visualgovernance.com as follows:

  • To opt out data capture by Visual Governance, don’t email or call us and do not use our site.

Notwithstanding any such opt-out request, Visual Governance reserves the right to continue to process user data for purposes related to Aggregated Data as set out in section 2.B. If an opt out would impair the user’s ability to use Visual Governance services or the integrity of Visual Governance services, Visual Governance may contact the user or the user’s employer to discuss and possibly limit the scope of the opt out.

​

4. RETENTION OF INFORMATION

Visual Governance applies the following policies on retention of Personal Information:

  • Registration Information, User Information, Tracking Information and Other Information associated with a user account may be retained for up to 3 years from account deletion. Some such information (including payment information, recently accessed sites and certain access credentials) is deleted immediately upon account deletion. If Personal Information of one user is associated with or stored on the account of a second user, the retention periods will be those for the account of the second user.

  • Identity Information used for proofing is retained for 7.5 years after the credential to which the proofing relates is revoked or expires.

  • Cookies are stored on user computers, and may be deleted at any time by the user (see section 1.E above).

  • Digital certificates and any data that contains Personal Information that is not included in any other format listed in this Policy are retained for no longer than two years.

When data is deleted from Visual Governance operating systems, it may remain in our encrypted back-up storage for a period of 11 years.

​

5. ACCESS TO, CORRECTION AND DELETION OF PERSONAL DATA

Users may request access to, correction or deletion of your Personal Information held by Visual Governance. Visual Governance may choose not to delete Personal Information where the data is necessary to the integrity of Visual Governance services or to the operation of services provided by Visual Governance to other users. EU customers of Visual Governance have certain rights to restriction of data processing and data portability to other service providers. Users may exercise any of these rights by sending email request to privacy@visualgovernance.com.

​

6. SECURITY

Visual Governance uses extensive technological and organizational measures to protect Personal Information and other data from unauthorized disclosure, alteration, or destruction. However, data security presents many risks, and Visual Governance cannot guarantee that information will be 100% secure. Visual Governance relies on customers to select secure passwords, to protect those passwords, and to use appropriate security software and practices on their devices. Please contact Visual Governance with any information regarding unauthorized use of Visual Governance Sites or other Visual Governance services.

​

7. TRANSFER TO UNITED STATES; EU COMPLIANCE

Visual Governance is based in the United States, and information collected by Visual Governance is usually transferred to, processed, and/or stored in the United States. These transfers are authorized as follows:

  • Business Customers. Our customer contracts include standard contractual clauses for controller-to-processor transfers approved by the European Commission, with the customer as controller and Visual Governance as processor. See https://commission.europa.eu/publications/standard-contractual-clauses-international-transfers_en for further information.

  • Individuals. For certain services that involve direct collection of Personal Information from individuals (e.g. identity proofing), we obtain explicit consent to transfer of Personal Information of customers to Visual Governance in the United States.

Visual Governance complies with the EU General Data Protection Regulation with respect to our activities in the EU and European Economic Area.

​

8. UPDATES TO THIS POLICY

From time to time, Visual Governance may update this Policy to reflect changes in the law, changes in Visual Governance’s services, or for other reasons. If Visual Governance makes material changes to the Policy, Visual Governance will notify its users of the updated Policy by posting it on www.Visual Governance.com. 

 

9.CONTACT INFORMATION AND YOUR RIGHTS

If you have inquiries or complaints about this Policy or your Personal Information, you should first contact the office of the Visual Governance chief privacy officer. If Visual Governance receives a written complaint, we will contact the person who made the complaint to follow up. Further contact information for our US offices is available at https://www.Visual Governance.com/contact/.

Visual Governance works with the appropriate regulatory authorities to resolve any complaints regarding Personal Information that we cannot resolve with our customers and users directly. If you are a EU/EEA customer of Visual Governance, you may also have the right to complain to the data protection authorities in your country, and, under certain conditions, to invoke binding arbitration

bottom of page