Privacy Policy

EFECTIVE DATE 02-JAN-2024

Overview

This Privacy Policy describes how V Group Inc. ("V Group Inc.," "we," “our” or "us") and its subsidiaries and affiliates collect, use, and safeguard the information you provide to us. This Privacy Policy is applicable to the information provided by you or collected by us when you visit our websites available presently and those that would be made available in future including www.vgroupinc.com, www.vgroupdigital.com, webstore.vgroup.net, contexttocall.com, tournamentedition.com, amdecs.com, reviewcaddy.com, carts.vgroup.net, smtu.vgroup.net, Tournament Edition application, Context To Call application, Lyt application, MKX Notes, Shop Your Way Relay application, CamFlash application, SFV Notes, LeanTV application, ScanNGen application, iDiagnosis application, FastER website and application, Context to Call Softphone website and application (collectively known as “Website”). This policy also applies when any information is requested from us online through the Website.

By using or accessing the Website you agree that we may use your information as stated in this Privacy Policy. If you do not agree to our use of your information according to this Privacy Policy, and to the Terms of Use that are posted on the Website, please refrain from using the Website.

Revisions

Our Privacy Policy may be revised and updated at any time without prior notice, and your continued use of the Website after such revisions signifies your acceptance and abidance to the revised terms. The revisions made to the Privacy Policy will be immediately effective when posted on the Website. The “Effective Date” mentioned at the top of this Privacy Policy indicates its last revision date. The current version supersedes the previous versions of the policy. You are advised to periodically check the updated terms of use for the updated changes.

Information Collected

You may browse the Website without providing any personal identifiable information to us, however, technology and usage data are automatically collected.

Types of Data Collected:

1. Personal Data 
   While using the Website, we may ask you to provide us with certain personal information. “Personal Data” is defined as any information that you may provide to us that can be used to identify you individually, including but not limited to first name, last name, email address, phone number, shipping and/or billing address, or financial details, such as payment cards you use to purchase products.
2. Technology and Usage Data  
   Usage Data is collected automatically when using the Website. This data is automatically submitted information regarding your computer, mobile device, and connection, including previous and subsequent URL, Internet Protocol address, device type, browser type, browser version, pages visited, date/time of visit, duration of visit, unique device identifiers, mobile device unique ID, mobile operating system, and other diagnostic data.

We use cookies and similar tracking technologies to track activity on the Website and store certain information. Tracking technologies used are beacons, tags, and scripts to collect and analyze data to improve the Website. Cookies can be "Persistent" or "Session" cookies. Persistent Cookies remain on your personal computer or mobile device when you go offline, while Session Cookies are deleted as soon as you close your web browser.

You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. The “Help” feature on most browsers provides information on how to accept cookies, disable cookies or to notify you when receiving a new cookie. If you do not accept cookies, you may not be able to use some features of the Website.

Why we collect your Personal Data

• To provide and maintain the Website, including to monitor the usage of the Website.
• To manage Your Account: to manage your registration as a user of the Website. The personal data you provide can give you access to different functionalities of the Website that are available to you as a registered user.
• For the performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items, or services you have purchased or of any other contract with us through the Website.
• To contact You: To contact you by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application's push notifications regarding updates or informative communications related to the functionalities, products, or contracted services, including the security updates, when necessary or reasonable for their implementation.
• E-Newsletters: To provide special offers and general information about other goods, services, and events which we offer that are like those that you have already purchased or enquired about unless you have opted not to receive such information.
• To manage your requests: To attend and manage your requests to us.
• For business transfers: We may use your information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal data held by us about the Website users is among the assets transferred.
• For other purposes: We may use your information for other purposes, such as data analysis, identifying usage trends, web activity and traffic, determining the effectiveness of our promotional campaigns, and to evaluate and improve the Website, products, services, marketing, and the customer experience.

How we use your Personal Information

If you provide us with personal information, we will use it to respond to requests you make, to provide customer support, to register any account you sign up for on the Website, to complete orders placed on the Website, and for other purposes you authorize or request. By providing personal information to us, you may receive email notifications for our products and services, however we do not rent, sell, or otherwise distribute to third parties, your personal information entered or collected on the Website. You may opt out of any email notifications in the manner set forth in our Terms of Use.

While we use all reasonable efforts to safeguard the confidentiality of your information, you agree that we will have no liability for disclosure of any information obtained due to errors in transmission or the unauthorized acts of third parties.

We may share statistical or aggregated non-personal information about our users with advertisers, business partners, sponsors and other third parties. We may employ third party companies and individuals to facilitate the Website, to provide services you opt for on our platform, to perform Website related services and/or to assist us in analysing how our Service is used.

These third parties have access to your Personal Information only to perform specific tasks on our behalf and are obligated not to disclose or use your information for any other purpose. These third parties are bound by the privacy policy provided on their website and you may access them on their respective websites. This data is used to customize the Website content and advertising to deliver a better experience to our users.

We may provide your information to others as required or permitted by law, including in response to law enforcement inquiries, legal process, in connection with a sale or merger of all or part of our business, or in connection with a bankruptcy or similar proceeding. We reserve the right to disclose user information in special cases, when we have reason to believe that disclosing this information is necessary or appropriate to identify, contact, or bring legal action against someone who may be causing injury to or interference with (either intentionally or unintentionally) our rights or property, other Website users, or anyone else that could be harmed by such activities. We may disclose personal information without notice to you in response to a subpoena or when we believe in good faith that the law requires it or to respond to an emergency.

The Website may contain links to other sites that are not operated by us. If you click on a third-party link, you will be directed to that third party's site. We strongly advise you to review the Privacy Policy of every site you visit. We have no control over, and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.

Business Transaction

If our any of the Website is involved in a merger, acquisition or asset sale, your Personal Information may be transferred as a business asset. In such cases, we will provide notice of such a merger on the Website before your Personal Information is transferred and/or becomes subject to a different Privacy Policy.

International Data Transfers:

As a global enterprise, we may transfer your Personal Data both internally across our offices and data centers, and externally with our partners, service providers, and other third parties. These transfers may occur within the same country or across international borders. It's important to note that the countries involved may have data protection regulations that differ from those in your own country.

To ensure compliance with applicable data protection laws regarding such transfers, we implement appropriate measures. In certain circumstances, we may also be obligated to disclose Personal Data in response to lawful requests from authorities, such as law enforcement or security agencies.

When required by law, we utilize one or more of the following data transfer mechanisms:

• Transfers to specific countries or recipients recognized as having an adequate level of protection for Personal Data under applicable law.
• or other lawful methods available to us in accordance with applicable regulations."

Protection of Personal Information

It is our policy to protect your personal information by doing the following:

• Safeguarding any data, computer files and documents containing your personal information from any misuse by third parties;
• Destroying, erasing or making unreadable any data, computer files and documents containing your personal information prior to their disposal;
• Protecting the confidentiality of your personal information;
• Prohibiting the unlawful disclosure of your personal information;
• Restricting access to your personal information to any third parties except in accordance with the terms of this Privacy Policy; and
• Limiting access to your personal information only to our employees who need such access and only to the extent that it is needed.

If there is ever a breach of security regarding your personal information, we intend to comply with applicable state and federal law requirements regarding the notification and disclosure to you and to the appropriate authorities of the circumstances surrounding the breach.

Policies for California

We respect the rights of privacy for California residents and are committed to complying with the California Consumer Privacy Act 2020 (CCPA).

The CCPA provides California residents with specific rights regarding personal information. If you are a California resident and have provided us with your personal information, you may request the information we have collected or have your Personal Identifiable Information deleted. The Act also provides you with the right to opt out of the sale of your Personally Identifiable Information and if between 13 and 16 years of age, it is required to collect opt-in consent, however V GROUP Inc. does not sell personal information.

We can only respond to verifiable consumer requests. A verifiable consumer request means a request that is made by the consumer, by a consumer on behalf of a consumer’s minor child, or a person registered with the California Secretary of State that is authorized to act on your behalf. Your verifiable consumer request must include (1) sufficient information that allows us to verify your identity or provides sufficient authority to make the request (example, email address); and (2) describes your request with enough detail to evaluate and respond to your request.

We will not respond to any requests if we cannot verify your identity or authority to make the request and confirm that the personal information belongs to you. You are not required to create an account to make a verifiable consumer request. We are not required to comply with more than one verifiable request from the same consumer in a 12-month period.

As required by the Act, we will provide you the following information upon a verifiable consumer request: (1) categories of Personally Identifiable Information that we collect; (2) categories of sources from which the Personally Identifiable Information is collected; (3) the purpose of collecting such Personally Identifiable Information. Please allow 45 days to complete your request. We will inform you if more time is required to complete it, but it should take no longer than 90 days.

To submit a CCPA request, to request (a) information about your Personally Identifiable Information collected or (b) deletion of your Personally Identifiable Information, please fill out the form and/or contact us via email with your request to datamanager@vgroupinc.com.

Policies for Europe

We respect the rights of privacy for European residents and are committed to complying with the General Data Protection Regulation of 2018 (GDPR). At V Group, we are committed to ensuring compliance with GDPR regulations and safeguarding the rights and privacy of our users.

Consent: We recognize the importance of explicit and unambiguous consent before collecting personal data from our users. This includes information gathered through the use of cookies. It's essential to note that certain data, such as users' computer IP addresses, which may not typically be considered "personal information" in the United States, is deemed as "personal data" according to the GDPR. Therefore, we ensure that consent is obtained before collecting any such data.

Data Breach Notification: In accordance with GDPR regulations, V Group is committed to promptly notifying supervisory authorities and affected data subjects within 72 hours in the event of a data breach that compromises users' personal information, unless certain exceptions apply.

Data Subjects' Rights: We believe in upholding the rights of data subjects regarding their personal information. As such, we communicate these rights clearly in our privacy policy, which is easily accessible on the Website. These rights include:

• The right to be informed: Data subjects have the right to be informed about the collection and use of their personal data at the time of collection.
• The right to access their data: Data subjects can request access to a copy of their personal data through a data subject request. We provide information on the means of collection, processing details, and sharing practices.
• The right of rectification: If a data subject's personal data is inaccurate or incomplete, they have the right to request its rectification.
• The right of erasure: Data subjects have the right to request the erasure of their personal data under certain grounds within 30 days of the request being made.

To submit a GDPR request, to request (a) information about your Personally Identifiable Information collected or (b) deletion of your Personally Identifiable Information, please fill out the form and/or contact us via email with your request to datamanager@vgroupinc.com.

Policies for Canada

We respect the rights of privacy for Canadian residents and are committed to complying with Quebec’s, British Columbia’s Personal Information Protection Act (PIPA), and Alberta’s Personal Information Protection Act (PIPA), as well as the rest of Canada via the Personal Information Protection and Electronic Documents Act (PIPEDA). PIPEDA defines "personal data" as information relating to an "identifiable individual," including but not limited to names, email addresses, and IP addresses.

Under PIPEDA, Canadian consumers have the following rights:

• Control over access to their personal data
• Access to the personal data held by our company
• Correction of any errors in their personal information

Type and Use of Personal Data: We capture personal data such as names, email addresses, and IP addresses for the purpose of business, data flow, subscription, purchase, etc. This data is used solely for the intended purposes and is not shared or disclosed without consent except as outlined in this policy. Data Collection: We collect personal data directly from consumers when they browse the Website, subscribe to our services, register for an account and/ or make a purchase. Additionally, we may collect data through automated means such as cookies when consumers interact with the Website.

Data Sharing: We may share personal data with third-party service providers or partners to facilitate payment services, collection of data regarding business flow, customer experience, etc. These third parties are contractually obligated to handle personal data in compliance with PIPEDA and other applicable privacy laws. As and when a Third-Party website is used for any purpose, the Privacy Policy of the respective site becomes applicable.

Policies for Children

Children under the age of 16 shall not be allowed to register for an account or place any orders for products through the Website. We respect the rights of privacy for parents and children and are committed to complying with the Children’s Online Privacy Protection Act of 1998 (COPPA) as well as CCPA. We do not knowingly collect personal data from children under the age of 13 in reference to COPPA, under the age of 14 in reference to Quebec’s privacy law and under 16 in reference to CCPA. We also note that CCPA prohibits sale of personal data of consumers between 13-16 years of age unless the guardian has authorized the sale. We comply with this requirement.  
If we determine that any child under the age of 16 has placed an order or subscribed for any services on the Website, we shall immediately cancel such order/subscription. If it is identified that any child under the age of 16 has registered for an account on the Website, we shall suspend or terminate such account unless and until we receive evidence satisfactory to us that the customer is at least 16 years old and that our policies for children under 16 years old have otherwise been complied with.  
We will take measures to remove any unintentionally disclosed personal information from the Website as soon as practicable.

Privacy Policies of Third Parties used to Process Orders

As disclosed in our Terms of Use, we use the services of a third party to process orders placed on the Website. Additional third-party payment processors may also be retained in connection with the processing of your orders. With respect to any of these third parties, it is our expectation that they have their own privacy policies in place and will comply with such policies. We will refuse to do business with any such companies that do not have privacy policies or that knowingly fail to comply with their own privacy policies. However, we cannot guarantee the security of your personal information once you transfer it to these third parties. You should contact these third parties directly if you wish to inquire further about the privacy policies they have in place.

Privacy Policy Does Not Apply to Third Party Websites

This Privacy Policy applies to the Website only and does not apply to any other website you visit, including those you access through links on the Website to 3rd party websites or in pursuance to the availed services on the Website. This is inclusive of, but not limited to social websites such as www.facebook.com, www.twitter.com, www.instagram.com, www.youtube.com, www.pinterest.com, www.tiktok.com and www.linkedin.com. We are not responsible for the protection of your personal information when you visit any other websites besides the Website. For this reason, please be careful and responsible whenever you are using any other websites you access through links on the Website and be sure to review the privacy policies of other websites. We cannot warrant the security of any personal information that you submit to any outside person or entity or to any other website besides the Website. Any personal information submitted by you to any outside person or entity or to any other website is done at your own risk.

Termination and Deletion of Personal Identifiable Information

You have the option to discontinue using V Group's Services at any time. To request the deletion of your account and associated data, please use our online form. Once you confirm your request and provide written permission for further information over communication, we will erase your data from our system, adhering to both our internal policies and those of our partners, if applicable.  
Please note that certain data, such as demographic information, usage patterns, billing and shipping addresses, financial payment summaries, and usage context, may be retained for business purposes, including promotions and strategic planning. This retention also helps prevent abuse of services or multiple benefit availing simultaneously.

Furthermore, we reserve the right to suspend or terminate your access to our Services or delete your account under the following circumstances:

• Violation of our Terms of Service or Usage Policies.
• Compliance with legal requirements.
• When your use of our Services poses a potential risk or harm to V Group, our users, or any other individuals.

Correction of Inaccurate Data

To ensure the accuracy of user information, individuals have the option to update their profile details and billing information as needed. Additionally, our management periodically reviews and removes long-term inactive or inaccurate data. This process is conducted in collaboration with our technical teams and may involve the implementation of technical procedures by ourselves or our partner.

Contact Information

The Website is owned and operated by V GROUP Inc., a New Jersey, USA corporation. Questions about this Privacy Policy should be directed to: [Finance / Contracts Manager], c/o V GROUP Inc., 379 Princeton Hightstown Rd., Building 3 Suite 2A East Windsor NJ 08520 or by email to datamanager@vgroupinc.com.  
To submit a request in relation to: 
(a) information about your Personally Identifiable Information collected or (b) deletion of your Personally Identifiable Information: please contact us via email with your request to datamanager@vgroupinc.com.