Virtual Global Services Limited

PRIVACY POLICY

VGSL, (“VGSL,” “we,” or “us”) respects your privacy. This Privacy Policy Statement (“Privacy Policy”) describes the ways we collect information from and about you, and what we do with the information, so that you may decide whether or not to provide information to us. By accessing our website, or purchasing our products or services, you agree to this Privacy Policy in addition to any other agreements we might have with you. In the event that such agreements contain terms that conflict with this Privacy Policy, the terms of those agreements will prevail.

This Privacy Policy ludes VGSL’s Privacy Policy Statement and the Privacy Shield Notice.

VGSL’s Privacy Policy Statement

Our Collection of your Information

Personal Information

The information we collect may include your personal information, such as your name, contact information, IP addresses, product and service selections, and other things that identify you. We collect personal information from you at several different points but not limited to the following:

when we correspond with you as a customer or prospective customer;
when you visit our website or use the Platform;
when you register as an end-user of our services and an account is created for you;
when you contact us for help;
when you attend our customer conferences or webinars; and
When the site sends us error reports or application analytics data.

Our Use of your Personal Information

VGSL may use information that we collect about you to:

Deliver the products and services that you have requested;
Manage your customer relationship and provide you with customer support;
Perform research and analysis about your use of, or interest in, our products, services, or content, or products, services or content offered by others;
Communicate with you by e-mail, postal mail, telephone or mobile devices about products or services that may be of interest to you either from us, or other third parties;
Develop and display content and advertising tailored to your interests on our site and other websites;
Verify your eligibility and deliver prizes in connection with promotions, contests and sweepstakes;
Enforce our terms and conditions;
Manage our business, and
Perform functions as otherwise described to you at the time of collection.

Our Disclosure of your Personal Information to Third Parties

We may share your personal information with third parties only in the ways that are described in this Privacy Policy:

We may provide your information to affiliated entities within our corporate group, as well as with vendors who perform functions on our behalf; such parties provide hosting and maintenance services, virtual infrastructure, payment processing, analysis and other services for us;
Third party contractors may have access to our databases. Usually these contractors sign a standard confidentiality agreement;
We may share your data with any parent company, subsidiaries, and joint ventures, other entities under a common control or third-party acquirers. We expect these other entities will honor this Privacy Policy;
We may allow a potential acquirer or merger partner to review our databases, although we would restrict their use and disclosure of this data during the diligence phase;
As required by law enforcement, government officials, or other third parties pursuant to a subpoena, court order, or other legal process or requirement applicable to Jive; or when we believe, in our sole discretion, that the disclosure of personal information is necessary to prevent physical harm or financial loss; to report suspected illegal activity or to investigate violations of our agreements or company policies; to enforce our terms and conditions, to protect the security or integrity of our products and services, and
When you give us consent to do so.

Please note that these third parties may be in other countries where the laws on processing personal information may be less stringent than in your country.

Potential for Other Users to Contact You

To the extent that a given application supports personal messaging functionality between and among end users, you may receive personal messages from other end users. You can disable this functionality by using the unsubscribe and other disabling instructions in the given application.

Our Security Measures to Protect your Personal Information

VGSL uses industry-standard technologies when transferring and receiving data exchanged between VGSL and other companies to help ensure its security. The Organization has security measures in place to help protect information under our control from the risk of accidental or unlawful destruction or accidental loss, alteration or unauthorized disclosure or access.

Our Use of Cookies, Web Beacons, Web Analytics Services, and Links

Cookies: Many of our web pages use “cookies.” Cookies are text files we place in your computer’s browser to store your preferences. Cookies, by themselves, do not tell us your e-mail address or other personally identifiable information unless you choose to provide this information to us by, for example, registering at one of our sites. However, once you choose to furnish the site with personal information, this information may be linked to the data stored in the cookie. We use cookies to understand site usage and to improve the content and offerings on our sites. We also may use cookies to offer you products, programs, or services. You have many choices with regards to the management of cookies on your computer. All major browsers allow you to block or delete cookies from your system. To learn more about your ability to manage cookies, please consult the privacy features in your browser.

Web Beacons: VGSL and third parties may also use small pieces of code called “web beacons” or “clear gifs” to collect anonymous and aggregate advertising metrics, such as counting page views, promotion views, or advertising responses. These “web beacons” may be used to deliver cookies that conform to VGSL’s cookie requirements.

Web Analytics Services: We use Google Analytics, a service for the marketing analysis of the site provided by Google. Google Analytics uses cookies to allow us to see how you use our site, so we can improve your experience. Google’s ability to use and share information collected by Google Analytics about your visits to the site is restricted by the Google Analytics Terms of Use available at http://www.google.com/analytics/terms/us.html and the Google Privacy Policy available at http://www.google.com/policies/privacy/. You can prevent Google Analytics from recognizing you on return visits to the site by disabling cookies in your browser. If you prefer to not have data reported by Google Analytics, you can install the Google Analytics Opt-out Browser Add-on available at https://tools.google.com/dlpage/gaoptout.

Facebook Pixel: We use Facebook pixel to track visitor activity on your website. It works by loading a small library of functions which you can use whenever a site visitor takes an action like Click Buy Now Button or Call Now Button. In order to access pixel, we have to generate e unique code from Facebook and insert it into website page header or footer. Facebook collects data from Http Header, Pixel ID and Facebook Cookie, Button Click Data, Optional Values, Form Field Names. Facebook Privacy policy available at ( https://developers.facebook.com/docs/facebook-pixel/implementation/gdpr ).

Website Links: We may create links to other web sites. We will make a reasonable effort to link only to sites that meet similar standards for maintaining each individual’s right to privacy. However, many other sites that are not associated with or authorized by VGSL may have links leading to our site. VGSL cannot control these links and we are not responsible for any content appearing on these sites. This website does not control the privacy policies of third parties, you are subject to the privacy practices of that third party. We encourage you to ask questions before you disclose any personal information to others.

App Links: A given application may provide you with an advertising link to other, third-party sites and applications. Such third-party sites will have their own data collection practices and policies. Please review the privacy policy for such sites and exercise caution in providing information that personally identifies you. We have no responsibility, access, or control over the data collection practices and policies of such third-party sites and applications. You will use such sites and applications at your own risk and outside of the scope of this Privacy Policy. The provision of such advertisements is done on an “As Is” basis, with no endorsements or representations.

Other: VGSL websites may use third parties to present or serve the advertisements that you may see at its web pages and to conduct research about the advertisements and web usage. This Privacy Policy does not cover any use of information that such third parties may have collected from you or the methods used by the third parties to collect that information.

Limiting Use, Disclosure, Retention

VGSL identifies the purposes for which the information is being collected before or at the time of collection. The collection of your personal data will be limited to that which is needed for the purposes identified by VGSL. Unless you consent, or we are required by law, we will only use the personal data for the purposes for which it was collected. If VGSL will be processing your personal data for another purpose later on, VGSL will seek your further legal permission or consent; except where the other purpose is compatible with the original purpose. We will keep your personal data only as long as required to serve those purposes. We will also retain and use your personal data for as long as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

International Transfers of your Personal data

We are a global company. Information collected from you may be stored and processed in Bangladesh, European Economic Area, the United States, Singapore or any other country in which VGSL or agents or contractors maintain facilities, and by accessing our sites and using our services, you consent to any such transfer of information outside of your country. Such countries may have laws that are different, and potentially not as protective, as the laws of your own country.

Accuracy of Personal data

We do our best to ensure that the personal data we hold and use is accurate. We rely on the customers we do business with to disclose to us all relevant information and to inform us of any changes.

Your Access to and Updating of your Personal data

Reasonable access to your personal data may be provided upon request made to VGSL. If access cannot be provided within that time frame, VGSL will provide the requesting party a date when the information will be provided. If for some reason access is denied, we will provide an explanation as to why access has been denied. We may charge a reasonable fee in advance for copying and sending the information requested.
If you would like us to delete any persona Data held about you, we will do so on request unless we need to hold the information as part of the provision of products and services to you.

Marketing Communications

We offer those who provide personal contact information a means to choose how we use the information provided. You may manage your receipt of marketing and non- transactional communications by clicking on the “unsubscribe” link located on the bottom of our marketing emails.

Notice to End Users

Most of our services are intended for use by organizations. Where the services are made available to you through an organization (e.g. your employer), that organization is the administrator of the services and is responsible for the accounts and/or service over which it has control. Please direct your data privacy questions to your administrator, as your use of the services is subject to that organization’s policies. We are not responsible for the privacy or security practices of an administrator’s organization, which may be different than this policy.

Administrators may be able to:

Help you exercise the rights described in Section 12 (if applicable);
Allow you to reset your account password;
Restrict, suspend or terminate your access to the services;
Access information in and about your account;
Access or retain information stored as part of your account;
Change your information, lauding profile information associated with your account;
Allow you or restrict your ability to edit, restrict, modify or delete information.

Please contact your organization or refer to your administrator’s organizational policies for more information.

Children’s Privacy

Because of the nature of our business, our services are not designed to appeal to minors. We do not knowingly attempt to solicit or receive any information from anyone under the age of 13. If you are a parent or guardian and you are aware that your child has provided us with personal data, please contact us immediately.

Changes to our Privacy Policy

VGSL may amend this Privacy Policy at any time by posting a new version. It is your responsibility to review this Privacy Policy periodically as your continued use of this website and our products and services represent your agreement with the then-current Privacy Policy.

Contacting Us

We have designated a Data Protection Officer who is responsible for monitoring VGSL’s ongoing compliance of this Privacy Policy. If you have any questions about this Privacy Policy, the practices or concerns of this site, please contact our Data Protection Officer at privacy@vgsl.com.bd.

Whenever VGSL processes Personal Data, VGSL complies with the Principles (as each principle) applicable to VGSL’s role:

Whenever we collect Personal Data directly from individuals, we shall inform an individual of the purpose for which we collect and use their Personal Data and the types of third parties to which VGSL discloses or may disclose that Personal Data. Please refer to our main Privacy Policy Statement for more information regarding our data handling practices. VGSL shall provide the individual with the choice and means for limiting the use and disclosure of their Personal Data. Notice will be provided in clear and conspicuous language when individuals are first asked to provide Personal Data to VGSL, or as soon as practicable thereafter, and in any event, before VGSL uses or discloses the Personal Data for a purpose other than for which it was originally collected. VGSL may be required to disclose Personal Data in response to a lawful request by public authorities, including to meet national security or law enforcement requirements.
Whenever VGSL collects Personal Data directly from individuals for marketing purposes, those individuals have the opportunity to choose (opt-out) whether their Personal Data is (1) to be disclosed to a third party or (2) to be used for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual by contacting our Data Protection Officer via email at privacy@vgsl.com.bd. For Sensitive Personal Information, VGSL will give individuals the opportunity to affirmatively or explicitly (opt-in) consent to the disclosure of the information to a non-Agent third party or for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual. VGSL shall treat Sensitive Personal Information received from an individual the same as the individual would treat and identify it as Sensitive Personal Information. Agents, technology vendors and contractors of VGSL or affiliated companies may have access to an individual’s Personal Data on a need to know basis for the purpose of performing services on behalf of VGSL or providing or enabling elements of the services. All such agents, technology vendors and contractors who have access to such information are contractually required to keep the information confidential and not use it for any other purpose than to carry out the services they are performing for VMS or as otherwise required by law.

Accountability for Onward Transfer: Whenever we collect Personal Data directly from individuals, prior to disclosing Personal Data to a third party, we shall notify the individual of such disclosure and allow the individual the choice (opt-out) of such disclosure. VGSL shall ensure that any third party to which Personal Data may be disclosed agrees in writing to provide the same level of privacy protection as set forth in this policy. VGSL accountability for personal data that it receives in USA under the Privacy Shield and subsequently transfers to a third party is described in the Privacy Shield Principles. In particular, VGSL remains responsible and liable under the Privacy Shield Principles if third-party agents that it engages to process the personal data on its behalf do so in a manner consistent with the Principles, unless VGSL proves that it is not responsible for the event giving rise to the damage.

Data Security: We shall take reasonable steps to protect the Personal Data from loss, misuse, and unauthorized access, disclosure, alteration and destruction. VGSL has put in place appropriate physical, electronic and managerial procedures to safeguard and secure the Personal Data from loss, misuse, unauthorized access or disclosure, alteration or destruction. However, VGSL cannot guarantee the security of Personal Data on or transmitted via the Internet.
Data Integrity and Purpose Limitation: We shall only process Personal Data in a way that is compatible with and relevant for the purpose for which it was collected or authorized by the individual. To the extent necessary for those purposes, VGSL shall take reasonable steps to ensure that Personal Data is accurate, complete, current and reliable for its intended use.

We acknowledge the individual’s right to access their Personal Data. We shall allow an individual access to their Personal Data and allow the individual the opportunity to correct, amend or delete inaccurate information, except where the burden or expense of providing access would be disproportionate to the risks to the privacy of the individual in the case in question or where the rights of persons other than the individual would be violated. Individuals may contact our Data Protection Officer via email at privacy@vgsl.com.bd to request to access, correct, amend, or delete the personal information VGSL holds about you. In cases where VGSL is a Data Sub-Processor or Processor, individuals must contact the Data Processor or the Data Controller, as applicable.

Your acceptance of these terms

By using this Site and sharing your contact details with VGSL, you signify your acceptance of this policy.
The Site is available only to individuals who are at least 16 years’ old. By using this Site you agree that you’re at least 16 years old.
If you do not agree to this policy, please do not use our Site. Your continued use of the Site following the posting of changes to this policy will be deemed your acceptance of those changes.

Enforcement and Dispute Resolution

With respect to personal data received or transferred pursuant to the Privacy Shield Frameworks, VGSL is subject to the regulatory enforcement powers of the Bangladesh ICT Act. In compliance with the Privacy Shield Principles, VGSL commits to resolve complaints about your privacy and our collection or use of your personal information transferred to the United States pursuant to Privacy Shield. Privacy Shield inquiries or complaints should first contact us at:

Virtual Global Services Limited (VGSL)

House-54/A, Road-132, Gulshan-1, Dhaka-1212, Bangladesh.

E-mail: privacy@vgsl.com.bd.

If your privacy protection complaint was not resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms.

Amendments

This Privacy Statement may be amended from time to time consistent with the requirements of the Policy Frameworks. We will post any revised policy on this website.

Information Subject to Other Policies

We are committed to following the Principles for all Personal Data within the scope of the Privacy Shield Frameworks.