Last modified: April 17, 2018
View the Space, Inc. (“VTS” or “We”) respects your privacy and is committed to protecting it through our compliance with this policy.
This policy applies to information we collect:
- Through VTS Properties;
- In email, text, and other electronic messages between you and VTS.
- Through mobile and desktop applications you download, which provide dedicated non-browser-based interaction between you and a VTS Property.
It does not apply to information collected by:
- Offline communication with VTS parties or through any other means outside of the VTS Properties; or
- Any third party, including through any application or content (including advertising) that may link to or be accessible from or on a VTS Property.
Information we collect about you and how we collect it
We collect several types of information from and about users of VTS Properties, including information:
- By which you may be personally identified, such as name, postal address, e-mail address, and telephone number (“Personal Data“); and/or
- About your internet connection, the equipment you use to access VTS Properties, and usage details.
We collect this information:
- Directly from you when you provide it to us by filling in forms on VTS Properties, by sending correspondence to us, or by completing transactions through the VTS Properties.
- Automatically as you navigate through the Website. Information collected automatically may include usage details, traffic data, location data, logs, other communication data and the data regarding the resources that you access and use on the VTS Properties, and information about your computer and internet connection, including your IP address, operating system and browser type.
Your opt-in will be required for any automatic data collection that isn’t purely for VTS internal analytics or necessary for your use of the VTS Properties. The information we collect automatically is statistical data and does not include personal information, but we may maintain it or associate it with personal information we collect in other ways or receive from third parties.
How we use your information
We use information that we collect about you or that you provide to us, including any Personal Data:
- To present VTS Properties and their contents to you;
- To provide you with information, products, or services that you request from us;
- To improve the VTS Properties by storing information about your preferences, customizing elements of the VTS Properties to your interest, speeding up your searches, and recognizing you when you return to the VTS Properties;
- To fulfill any other purpose for which you provide it;
- To provide you with notices about your account/subscription, including expiration and renewal notices;
- To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection;
- To notify you about changes to the VTS Properties or any products or services we offer or provide though it;
- To allow you to participate in interactive features on VTS Properties;
- In any other way we may describe when you provide the information;
- For any other purpose with your consent.
VTS will only use your Personal Data in ways that are compatible with the limited purpose for which it was collected, unless we receive your permission otherwise. Before we use your Personal Data for a purpose that is materially different than the purpose we collected it for, or that you later authorized, we will provide you with the opportunity to opt out of such usage. We maintain reasonable procedures to help ensure that Personal Data is reliable for its intended use, accurate, complete, and current.
Disclosure of your information
We may disclose aggregated information about our users that does not identify any individual, without restriction.
- To our subsidiaries and affiliates;
- To contractors, service providers, and other third parties we use to perform functions on our behalf and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them. We take reasonable and appropriate steps to ensure that third-party agents and service providers process Personal Data in accordance with our obligations and to stop and remediate any unauthorized processing. Under certain circumstances, we may remain liable for the acts of our third-party agents or service providers who perform services on our behalf for their handling of Personal Data that we transfer to them;
- 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 VTS’ assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by VTS about users of the VTS Properties is among the assets transferred;
- 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 valid government or regulatory request;
- If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of VTS, our customers, or others.
Data processing and GDPR
VTS’ core offering is the VTS Platform, which allows customers to upload and manage their commercial real estate portfolios. Data input into the VTS Platform is known as “Platform Data.” Under GDPR, VTS is a Data Processor of VTS Platform Data. Users of the VTS Platform are the Controllers of Platform Data and are responsible for all Controller obligations, such as choosing the appropriate legal basis for collecting and using tenants’ personal data.
Data controlling and GDPR
VTS collects, stores and processes business contact data (used for direct marketing, demonstrations, and business development) and user usage data (used for internal analytics, user experience tracking, and marketing purposes.) Under GDPR, VTS is a Data Controller with regards to business contact data and usage data. Business contact data is obtained by VTS on the basis of your consent (where you affirmatively provide it to VTS, for example when requesting a product demonstration) or for VTS’ legitimate interest in responding to your queries, assisting you in your use of the VTS Properties, and otherwise communicating with VTS users, customers, and potential customers. User usage data is obtained for VTS’ legitimate interest of providing customer support, improving the VTS Properties, and communicating with VTS customers or potential customers. Individuals can opt out of the use of business contact data at any time by making a request to email@example.com. User usage data is a part of the VTS platform. Therefore, when an individual would like to opt-out of collection of usage data, the individual will no longer be able to use the VTS platform.
Accessing, correcting your information and exercising GDPR data rights
VTS operations are based in the United States, which is the geographic location for all VTS data processing.
You can review and change your personal information by logging into the particular VTS Property and visiting your account profile page.
You may also send us an email at firstname.lastname@example.org to request access to, correct, or delete any personal information that you have provided to us, or request execution of the following rights:
- Receive a copy of your personal data;
- Correction of your personal data;
- Deletion of all of your personal data;
- Restricting or ending the use or processing your personal data for a particular purpose;
- Obtaining a copy of your personal data in a machine-readable ‘open format’ (e.g., XML, JSON, CSV, text file format);
- Opt out of automated decision making.
VTS cannot delete all of your Personal Data except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect. In the event that you do not opt to have your data deleted, VTS may retain your Personal Data only for so long as we have a legitimate business purpose to use that data, but in no event longer than seven years from your last interaction with VTS.
Third-Party data controllers
We may only transfer Personal Data to unaffiliated third-party data controllers when you have opted-in to that transfer. These third-parties do not act as agents or service providers and are not performing functions on our behalf. We will enter into written contracts with any and all unaffiliated third-party data controllers requiring them to provide the same level of protection for Personal Data as we do. We will also limit their use of your Personal Data so that it is consistent with any consent you have provided and with the notices you have received. If we transfer your Personal Data to one of our affiliated entities within our corporate group, we will ensure that your Personal Data does not receive any less protection.
We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. All information you provide to us is stored on our secure servers behind firewalls. Any payment transactions will be encrypted.
The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to a VTS Property, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.
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 VTS over the internet. 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 VTS Properties.
Questions or complaints
You can direct any questions or complaints about the use or disclosure of your Personal Data to us at email@example.com. We will investigate resolve any complaints, disputes, or rights request regarding the use or disclosure of your Personal Data within thirty (30) days of receiving your inquiry.
If you live in the EU and are unsatisfied with the resolution of your complaint, you may contact the EU data protection authorities at https://www.jamsadr.com/file-an-eu-us-privacy-shield-or-safe-harbor-claim for further information and assistance.