Your privacy is critically important to us. At Virtual CCO, we have a few fundamental principles:
- We are thoughtful about the personal information we ask you to provide and the personal information that we collect about you.
- We store personal information for only as long as we have a need to keep it.
- We aim for full transparency on how we gather, use, and share your personal information.
Who We Are and What This Policy Covers
Virtual CCO is a consulting service and website that also provides information and services about content strategy to startup founders, small-business owners, nonprofits, solopreneurs, independent professionals, and others. We also aim to build a community around the people in these organizations, as well as content-strategy professionals. Our mission is to democratize content strategy, to make its principles and practices accessible to all. Our vision is to ensure that every piece of digital content tracks back to a clear organizational purpose.
- Our website virtualcco.com
- Our other Virtual CCO products, services, and features that are available on or through our and other websites
Below we explain how we collect, use, and share information about you, along with the choices that you have with respect to that information.
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Information We Collect
We only collect information about you if we have a reason to do so–for example, to provide our Services, to communicate with you, or to make our Services better.
We currently collect information in two ways: if and when you provide information to us and automatically through operating our Services. We may in the future also collect information from outside sources and will let you know if/when we do.
Information You Provide to Us
We collect information that you provide to us. The amount and type of information depends on the context and how we use the information. Here are some examples:
- Basic Account Information: We ask for basic information from you in order to set up your account. For example, we require individuals who sign up for a VirtualCCO.com account to provide an email address along with a name and a username. You may provide us with more information – like your address and other information you want to share – but we don’t require that information to create a VirtualCCO.com account.
- Billing and Contact Information: If you buy something from us – a subscription to a VirtualCCO.com plan, for example, you will provide additional personal and payment information, such as your name, credit card information, and contact information.
- Communications with Us (Hi There!): You may also provide us information when you respond to surveys, communicate with our staff about a support question, post a question about in our public forums, or sign up for our newsletters. When you communicate with us via form, email, phone, VirtualCCO.com comment, or otherwise, we store a copy of our communications (including any call recordings as permitted by applicable law).
Information We Collect Automatically
We also collect some information automatically:
- Log Information: Like most online service providers, we collect information that web browsers, mobile devices, and servers typically make available, such as the browser type, IP address, unique device identifiers, language preference, referring site, the date and time of access, operating system, and mobile network information.
- Usage Information: We collect information about your usage of our Services. For example, we collect information about the actions that site administrators and users perform on a site using our VirtualCCO.com services. We also collect information about what happens when you use our Services (e.g., page views and other parts of our Services) along with information about your device (e.g., screen size, name of cellular network, and mobile device manufacturer). We use this information to, for example, provide our Services to you, as well as get insights on how people use our Services, so we can make our Services better.
- Location Information: We may determine the approximate location of your device from your IP address. We collect and use this information to, for example, calculate how many people visit our Services from certain geographic regions. We may also collect information about your precise location via our mobile apps (when, for example, you post a photograph with location information) if you allow us to do so through your mobile device operating system’s permissions.
Information We Collect from Other Sources
We may in the future also get information about you from other sources. We will notify you via email if/when we do this.
How and Why We Use Information
Purposes for Using Information
We use information about you as mentioned above and for the purposes listed below:
- To provide our Services – for example, to set up and maintain your account or charge you for our paid Services;
- To further develop and improve our Services;
- To monitor and analyze trends and better understand how users interact with our Services, which helps us improve our Services and make them easier to use;
- To measure, gauge, and improve the effectiveness of our advertising, and better understand user retention and attrition — for example, we may analyze how many individuals purchased a paid plan after receiving a marketing message or the features used by those who continue to use our Services after a certain length of time;
- To monitor and prevent any problems with our Services, protect the security of our Services, detect and prevent fraudulent transactions and other illegal activities, fight spam, and protect the rights and property of Virtual CCO and others, which may result in us declining a transaction or the use of our Services;
- To communicate with you. For example, we may email you to solicit your feedback, share tips for getting the most out of our products, or keep you up to date on Virtual CCO; and
- To personalize your experience using our Services, provide content recommendations, target our marketing messages to groups of our users (for example, those who have a particular plan with us or have been our user for a certain length of time), and serve relevant advertisements.
Legal Bases for Collecting and Using Information
A note here for those in the European Union about our legal grounds for processing information about you under EU data protection laws, which is that our use of your information is based on the grounds that:
(1) The use is necessary in order to fulfill our commitments to you under the applicable terms of service or other agreements with you or is necessary to administer your account — for example, in order to enable access to our website on your device or charge you for a paid plan; or
(2) The use is necessary for compliance with a legal obligation; or
(3) The use is necessary in order to protect your vital interests or those of another person; or
(4) We have a legitimate interest in using your information — for example, to provide and update our Services; to improve our Services so that we can offer you an even better user experience; to safeguard our Services; to communicate with you; to measure, gauge, and improve the effectiveness of our advertising; and to understand our user retention and attrition; to monitor and prevent any problems with our Services; and to personalize your experience; or
How We Share Information
We do not sell our users’ private personal information.
We share information about you in the limited circumstances spelled out below and with appropriate safeguards on your privacy:
- Third Party Vendors: We may share information about you with third party vendors who need to know information about you in order to provide their services to us, or to provide their services to you or your site. This group includes vendors that help us provide our Services to you (like payment providers that process your credit and debit card information, payment providers you use for your ecommerce operations, fraud prevention services that allow us to analyze fraudulent payment transactions, postal and email delivery services that help us stay in touch with you, customer chat and email support services that help us communicate with you), those that assist us with our marketing efforts (e.g. by providing tools for identifying a specific marketing target group or improving our marketing campaigns), and those that help us understand and enhance our Services (like analytics providers) and who may need information about you in order to, for example, provide technical or other support services to you. We require vendors to agree to privacy commitments in order to share information with them.
- Legal and Regulatory Requirements: We may disclose information about you in response to a subpoena, court order, or other governmental request.
- To Protect Rights, Property, and Others: We may disclose information about you when we believe in good faith that disclosure is reasonably necessary to protect the property or rights of Virtual CCO, third parties, or the public at large. For example, if we have a good faith belief that there is an imminent danger of death or serious physical injury, we may disclose information related to the emergency without delay to appropriate authorities.
- With Your Consent: We may share and disclose information with your consent or at your direction.
- Aggregated or De-Identified Information: We may share information that has been aggregated or reasonably de-identified, so that the information could not reasonably be used to identify you. For instance, we may publish aggregate statistics about the use of our Services.
- Published Support Requests:If you send us a request (for example, via a support email or one of our feedback mechanisms), we reserve the right to publish that request in order to help us clarify or respond to your request or to help us support other users. If we do this, we will not identify you.
Information Shared Publicly
Information that you choose to make public is disclosed publicly.
Public information may also be indexed by search engines or used by third parties.
Please keep all of this in mind when deciding what you would like to share on the VirtualCCO.com website.
How Long We Keep Information
We generally discard information about you when we no longer need the information for the purposes for which we collect and use it — which are described in the section above on How and Why We Use Information — and we are not legally required to continue to keep it.
While no online service is 100% secure, we work very hard to protect information about you against unauthorized access, use, alteration, or destruction, and take reasonable measures to do so, such as monitoring our Services for potential vulnerabilities and attacks.
You have several choices available when it comes to information about you:
- Limit the Information that You Provide: If you have an account with us, you can choose not to provide the optional account information, profile information, and transaction and billing information. Please keep in mind that if you do not provide this information, certain features of our Services — for example, paid subscriptions – may not be accessible.
- Opt-Out of Marketing Communications: You may opt out of receiving promotional communications from us. Just follow the instructions in those communications or let us know. If you opt out of promotional communications, we may still send you other communications, like those about your account and legal notices.
- Close Your Account: While we’d be very sad to see you go, if you no longer want to use our Services, you can close your account. Please keep in mind that we may continue to retain your information after closing your account, as described in How Long We Keep Information above — for example, when that information is reasonably needed to comply with (or demonstrate our compliance with) legal obligations such as law enforcement requests, or reasonably needed for our legitimate business interests.
If you are located in certain countries, including those that fall under the scope of the European General Data Protection Regulation (AKA the “GDPR”), data protection laws give you rights with respect to your personal data, subject to any exemptions provided by the law, including the rights to:
- Request access to your personal data;
- Request correction or deletion of your personal data;
- Object to our use and processing of your personal data;
- Request that we limit our use and processing of your personal data; and
- Request portability of your personal data.
You can usually access, correct, or delete your personal data using your account settings and tools that we offer, but if you aren’t able to do that, or you would like to contact us about one of the other rights, please reach us on our contact form.
EU individuals also have the right to make a complaint to a government supervisory authority.
Controller and Responsible Company
Virtual CCO’s Services are worldwide. Virtual CCO, our US-based company, is the controller the processing activities across all of our Services worldwide.
How to Reach Us
Other Things You Should Know
- In the case of US based entities, entering into European Commission approved standard contractual arrangements with them, or ensuring they have signed up to the EU-US Privacy Shield; or
- In the case of entities based in other countries outside the EEA, entering into European Commission approved standard contractual arrangements with them.
You can ask us for more information about the steps we take to protect your personal information when transferring it from the EU.
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