- What personally identifiable information of yours is collected;
- Who is collecting the information;
- How the information is used;
- With whom the information may be shared;
- What choices are available regarding collection, use and distribution of the information;
- What kind of security procedures are in place to protect the loss, misuse or alteration of information under our control; and,
- How you can delete or correct any inaccuracies in the information.
I. Collection of Information
A. Personally Identifiable Information
Personally identifiable information (“PII” or “Personal Information”) is information that can be used to identify or contact you. GlobalVRS generally collects Personal Information in two ways: (1) when you choose to use, apply for, register for, or purchase a service or product offered by GlobalVRS, or (2) when you choose to send an e-mail, participate in surveys, or engage in other transactions or interactions with GlobalVRS. We also may collect non-personally identifiable information (“non-PII” or “Non-Personal Information”) when you interact with or respond to e-mails, newsletters or promotional or other informational communications, or register for or use the Web site, products or services of GlobalVRS.
In order to have access to certain GlobalVRS products and services, you are required to complete an application or other registration form(s) and provide other information reasonably necessary for us to provide the products and/or services to you. Some examples of the type of information we collect in the registration form(s) are:
- Your Name
- Your Address(es) (including the physical location from which you will access GlobalVRS VRS or IP Relay services)
- Your Phone Number(s)
- Your E-mail Address(es)
- Your IP Address(es)
- Your Operating System/Machine Type
In addition, Personal Information and Non-Personal Information collected, maintained, or generated by your use of GlobalVRS’s service or products may be transmitted periodically to GlobalVRS as part of software or other updates to equipment and/or services provided to or used by you.
B. Non-Personally Identifiable Information
C. Links to Other Web Sites
D. E-mails or Other Communications
II. Use of Your Personal Information
As noted, Personal Information is information that can be used to identify or contact you. In the course of providing services to you, we collect and maintain certain Personal Information about you. In addition, we may collect and maintain other Non-Personal Information generated by or related to the provision or use of our products or services, including the type of equipment you use, your operating system, and data regarding your usage of our services (including minutes of use, telephone numbers or IP addresses called, date and time of call, etc.).
GlobalVRS will access, use, share or disclose your Personal Information only under the following limited circumstances.
First, we may access, use, share or disclose your Personal Information if reasonably necessary to:
- Initiate, render, bill and collect for the provision of GlobalVRS products or services;
- Comply with valid legal requirements such as a law, regulation, search warrant, subpoena or court order;
- Enforce applicable provisions of GlobalVRS’s “VP-100 Premium GlobalVRS VRS® Service & Products Agreement / VP-200 Premium GlobalVRS VRS® Service & Products Agreement,” including investigation of potential violations;
- Detect, prevent, or otherwise address fraud, security or other technical issues; or
- Protect the rights, property or safety of GlobalVRS, our employees or users, or the public as required or permitted by law.
- Second, GlobalVRS may use your Personal Information to improve our products or services or the content of our Web site or in connection with promotional or other informational communications.
Fourth, in the event that GlobalVRS undergoes a business transition or change in corporate structure, such as a merger, acquisition, or sale of a portion of its assets, users’ Personal Information may become part of the assets transferred. We may choose in such instances to disclose Personal Information and Non-Personal Information about you, the consumer, to a third party for compensation.
Fifth, in order to provide our services, we may occasionally provide information to other companies or independent contractors that work on our behalf.
Finally, information that does not reveal how to identify or contact a user is not Personally Identifiable Information. For example, “aggregated data,” such as the number of visitors who access GlobalVRS’s Web site on a particular day or the percentage of users who download services from GlobalVRS, does not constitute Personal Information under this Policy.
Notwithstanding any other provision of this Agreement, to the extent you use the GlobalVRS Web site to place a telecommunications relay service call, your privacy rights and GlobalVRS’s obligations with regard to any information generated by that call shall be governed by applicable law, including relevant sections of the Communications Act of 1934, as amended, and any applicable implementation rules and orders.
GlobalVRS will continue to revise its policies and implement additional security features as new technologies becomes available. Although we will make every reasonable effort to protect your Personal Information from loss, misuse, or alteration by third parties, no system or service can give a 100% guaranty of security, especially a product or service that relies upon the public Internet. Therefore, you acknowledge the risk that third parties may gain unauthorized access to your information when using our products or services.
IV. Updating or Deleting Your Personal Information
You can always contact us in order to (1) delete your Personal Information from our systems, (2) update the Personal Information that you have provided to us, or (3) change your preferences with respect to marketing contacts or other activities, by calling us at (877) 326-3877. We will endeavor to accommodate such requests, unless such information is needed to comply with valid legal requirements or to protect the rights, property or safety of GlobalVRS, our employees or users, or the public. Any requested changes will not have any effect on other information that GlobalVRS maintains. If you have a complaint or problem you may contact us by calling at (877) 326-3877 and the customer service department will forward your complaint to the appropriate GlobalVRS department for a response or resolution. We try to answer every e-mail in a timely manner but please be aware that some requests may take longer than others.
You should be aware that it may not be technologically possible to remove from our servers each and every record of the information you have provided to GlobalVRS. The need to back-up our systems to protect information from inadvertent loss means that a copy of your Personal Information may exist in a non-erasable form that may be difficult or impossible for us to locate. Nevertheless, upon receiving your request, we will endeavor to delete all Personal Information stored in the databases we actively use for research and daily business activities, as well as other readily searchable communications.