Privacy Policy
VBA PRIVACY POLICY
Effective from January 17, 2023
Welcome to VBA's Privacy Policy
1. Please read carefully
VBA LLC cares deeply about the privacy of its visitors and users. To that end, this Privacy Policy (“Privacy Policy”) describes how VBA LLC., together with its affiliated companies worldwide (“VBA”, “we”, “our”, or “us”), collect, use, and share your Personal Information, as well as an explanation of the data rights you may have in that Personal Information. This Privacy Policy applies to all VBA users, including unregistered visitors, registered users, and premium users (collectively, “Users”, “you”, or “your”), and to all VBA services, including our websites (including www.vbaconnect.com and any of its subdomains, the “Website”), web applications (“VBA Apps”), mobile applications (“Mobile Apps”), and related services (collectively, the “Services”). This Privacy Policy is not intended to override the terms of any contract you have with us, nor any rights you may have under other applicable data privacy laws.
Prior to accessing or using our Services, please read this policy and make sure you fully understand our practices in relation to your Personal Information. If you read and fully understand this Privacy Policy, and remain opposed to our practices, you must immediately leave and discontinue all use of any of our Services. If you have any questions or concerns regarding this policy, please contact us here.
2. What ‘Personal Information’ do we collect?
2.1. User information:
To provide you the Services, we must collect Personal Information relating to an identified or identifiable natural person (“Personal Information”). We collect Personal Information you provide us, from your use of the Services, and from other sources. Here are the types of Personal Information we collect about you:
Information you provide us. When you register for our Services, sign up for any VBA events, subscribe to our blog(s) or newsletter(s), use any of our Services; and/or when you contact us directly by any communication channel (e.g., VBA’s support tickets, emails), you may provide us Personal Information, such as name, email address, phone number, payment information (for Users with Paid Subscriptions), information you include in your communications with us and with other users on our platform, and Personal Information contained in scanned identification documents (such as an ID card, driver’s license, passport, or official company registration documents).
Information we collect when you use the Services. When you visit, download, and/or use any of our Services, we may collect aggregated usage Personal Information, such as Visitors’ and Users’ browsing and ‘click-stream’ activity on the Services, session heatmaps and scrolls, non-identifying Personal Information regarding the Visitor’s or User’s device, operating system, internet browser, screen resolution, language and keyboard settings, internet service provider, referring/exit pages, date/time stamps, etc
Information we collect from other sources. We may receive Personal Information about you from third-party sources, such as i) security providers , fraud detection and prevention providers for example to help us screen out users associated with fraud, ii) social media platforms, when you log-in or sign-up using your social media account, we may receive Personal Information from that service (e.g., your username, basic profile Personal Information) and in some cases, we may collect Personal Information from lead enhancement companies which help us to improve our service offering; iii) advertising and marketing partners in order to monitor, manage and measure our ad campaigns.
2.2. Users of users ‘Personal Information’
We may also collect Personal Information pertaining to visitors and users of our User’s websites or services (“Users-of-Users”), solely for and on our Users’ behalf (as further described in Section 6 below).
2.3. VBA jobs applicant information
We also collect information that is provided to us by VBA jobs candidates (“Applicants”), when they apply to any of the open positions published at https://www.vbaconnect.com/jobs, by e-mail and more.
3. Why do we collect such ‘Personal Information’
We use your Personal Information for the following purposes:
To provide and operate the Services;
.To further develop, customize, expand, and improve our Services, based on Users’ common or personal preferences, experiences and difficulties;
To provide our Users with ongoing customer assistance and technical support;
To be able to contact our Users with general or personalized service-related notices and promotional messages (as further detailed in Section 8 below);
To help us to update, expand and analyze our records to identify new customers;
To facilitate, sponsor, and offer certain contests, events, and promotions, determine participants’ eligibility, monitor performance, contact winners, and grant prizes and benefits;
To analyze our performance and marketing activities;
To create aggregated statistical data and other aggregated and/or inferred information, which we or our business partners may use to provide and improve our respective services;
To provide you with professional assistance.
To enhance our data security and fraud prevention capabilities; and
To comply with any applicable laws and regulations.
We may use techniques like “machine learning” (European law refers to this as “automated decision-making”) to help us improve our services. When we use machine learning, we either: (i) still have a human being involved in the process (and so are not fully automated); or (ii) use machine learning in ways that don’t have significant privacy implications (for example, reordering how applications might appear when you visit the VBA App). We may also use machine learning to help us monitor, identify, and suspend accounts sending spam, or engaging in other abusive or fraudulent activity.
We use your Personal Information for the purposes set out in Section 3 where:
Our use of your Personal Information is necessary to perform a contract or to take steps to enter into a contract with you (e.g. to provide you with our customer assistance and technical support);
Our use of your Personal Information is necessary to comply with a relevant legal or regulatory obligation that we have; or
Our use of your Personal Information is necessary to support legitimate interests and business purposes (for example, to maintain and improve our Services and the effectiveness of VBA by identifying technical issues), provided it is conducted in a way that is proportionate and that respects your privacy rights.
4. How we share your ‘Personal Information’
We may share your Personal Information with service providers and others (or otherwise allow them access to it) in the following manners and instances:
Third Party Service Providers: VBA has partnered with a number of selected service providers, whose services and solutions complement, facilitate and enhance our own. These include hosting and server co-location services, communications and content delivery networks (CDNs), data and cyber security services, billing and payment processing services, fraud detection and prevention services, web analytics, e-mail distribution and monitoring services, session recording and remote access services, performance measurement, data optimization and marketing services, content providers, and our legal and financial advisors (collectively, “Third Party Service Provider(s)”).
VBA may share the following categories of Personal Information with Third Party Service Providers for a business purpose:
identifiers, including name, alias, postal address, unique personal identifier, online identifier, internet protocol address, email address, account name, or other similar identifiers.
commercial Personal Information, for example Personal Information regarding products or services purchased, obtained, or considered.
4.1.
The Personal Information may be shared solely in accordance with this policy. Law Enforcement, Legal Requests and Duties: VBA may disclose or otherwise allow access to any categories of your Personal Information described in this Privacy Policy pursuant to a legal request, such as a subpoena, legal proceedings, search warrant or court order, or in compliance with applicable laws, if we have a good faith belief that the law requires us to do so, with or without notice to you.
4.2.
Protecting Rights and Safety: VBA may share any categories of your Personal Information described in this Privacy Policy if we believe in good faith that this will help protect the rights, property or personal safety of VBA, any of our Users, any Users-of-Users, or any member of the general public, with or without notice to you.
4.3.
VBA Subsidiaries and Affiliated Companies: We may share your Personal Information internally within our family of companies, for the purposes described in this Privacy Policy. For example, we may share your Personal Information with varomediagroup.com., our marketing-based subsidiary, in the course of facilitating and providing you with our Services.
Sharing Personal Information by VBA subsidiaries and affiliated companies in the European Union, the United Kingdom and Switzerland with VBA’s subsidiaries located outside these regions will only take place under an approved transfer mechanism, such as the relevant Standard Contractual Clauses.
4.4.
In connection with a change in corporate control: In addition, should VBA or any of its affiliates undergo any change in control, including by means of merger, acquisition or purchase of substantially all of its assets, your Personal Information may be shared with the parties involved in such event.
4.5.
Upon Your Further Direction: The VBA Services enable us, through different techniques, to engage and procure various third party services, products and tools for enhancing our web or mobile sites. If you choose to engage with such Third Party Services, they may have access to and process Personal Information collected through our web, app or mobile sites. For example:
Social Media Features: Our Services may enable you to integrate certain Social Media features, widgets, and single sign on features, such as “Facebook Connect,” or “Google Sign-in” (“Social Media Features”) into our web or mobile sites. These Social Media Features may collect certain Personal Information from you such as identifiers, including name, alias, unique personal identifier, online identifier, internet protocol address, email address, or other similar identifiers. Social Media Features are hosted either by a third party or directly on our Services.
VBA does not control and is not responsible for the actions or policies of any Third Party Service, and your use of any Third Party Service is at your own risk. We encourage you to review any privacy policy accompanying a Third Party Service and ask such Third Party Service for any clarifications you may need before deciding to install and/or use their services.
5. Where do we Store/Process your ‘Personal Information’?
VBA processes data about individuals across the world and may transfer your Personal Information outside of your country. Your security, privacy and confidentiality are our top priority and that's why VBA conducts a vetting process that includes an assessment of the privacy laws in those countries to validate they have strong data protection laws.
5.1.
User's personal information is controlled by partners in Israel, which the European Commission considers as a country offering an adequate level of protection for the Personal Information of E.U. Member State residents.
5.2.
If you are in Europe, the U.K., or Switzerland, when we transfer your Personal Information to a location outside of Europe, partners will make sure that (i) there is a level of protection deemed adequate by the European Commission or (ii) that the relevant Standard Contractual Clauses are in place (i.e., the applicable module of the Standard Contractual Clauses for the transfer of personal data to third countries pursuant to Regulation (E.U.) 2016/679 of the European Parliament and of the Council from June 4, 2021, and the ICO’s International Data Transfer Addendum to the E.U. Commission Standard Contractual Clauses version B1.0, in force from 21 March 2022, as it is revised under Section 18 of its Mandatory Clauses), or (iii) we comply with Data Privacy Framework as applicable to data transfers to the United States, or (iv) we use another legally recognized transfer mechanism in the applicable jurisdiction.
5.3.
VBA's data storage providers are contractually committed to protect and secure your data.
Among other things, VBA will ensure that there is the adequate level of protection or that relevant Standard Contractual Clauses are in place for the international transfer of our EU users’ data.
When our partners transfers E.U. Personal Information to a third country that the European Commission did not find will adequately protect your information, Partners ensures that it has taken additional measures to comply with the European data protection laws.
Data Privacy Framework: Partners and its covered entities DeviantArt, Inc., InkFrog, Inc, Modalyst, Inc and SpeedTab, Inc, complies with Data Privacy Framework (“DPF”) that embeds the EU-U.S. Data Privacy Framework (“EU-U.S. DPF”), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (“Swiss-U.S. DPF”) as set forth by the U.S. Department of Commerce, European Commission, UK Government, and Swiss Federal Administration regarding the collection, use, and retention of personal information transferred from the European Union, the United Kingdom (and Gibraltar), and Switzerland to the United States. Partner has certified to the U.S. International Trade Administration (ITA), within the U.S. Department of Commerce that it adheres to the Data Privacy Framework Principles. If there is any conflict between the terms in this Policy and the Data Privacy Framework Principles, the Data Privacy Framework Principles shall govern. VBA’s commitment to subject the personal information described in this Policy to the Data Privacy Framework is subject to the enforcement and investigative powers of the United States Federal Trade Commission.
To learn more about the Data Privacy Framework Program visit https://www.dataprivacyframework.gov, and to view partner's certification, please click here.
VBA may share personal information with third parties under certain circumstances described in this Policy, subject to obligations under the Data Privacy Framework Principles extend to third parties acting as agents who help us run our business and provide services, and VBA remains liable should a third party acting as our agent process personal information subject to this Policy in a manner inconsistent with this Policy, except where VBA is not responsible for the event giving rise to the damage.
In compliance with the Data Privacy Framework Principles, Our partners commits to resolve complaints about our collection or use of your personal information. E.U., UK and Swiss individuals with inquiries or complaints regarding our Data Privacy Framework policy should first contact us our partners: here.
7. Use of cookies and other third-party technologies
We and our Third Party Service Providers use cookies and other similar technologies (“Cookies”) in order for us to provide our Service and ensure that it performs properly, to analyze our performance and marketing activities, and to personalize your experience.
Please note that we do not change our practices in response to a “Do Not Track” signal in the HTTP header from a browser or mobile application, however, most browsers allow you to control cookies, including whether or not to accept them and how to remove them. You may set most browsers to notify you if you receive a cookie, or you may choose to block cookies with your browser.
8. Communications from VBA
8.1. Promotional messages
We may use your Personal Information to send you promotional content and messages by e-mail, text messages, notifications within our platform, marketing calls and similar forms of communication from VBA or our partners (acting on VBAs behalf) through such means.
If you do not wish to receive such promotional messages or calls, you may notify VBA at any time or follow the “unsubscribe” or STOP instructions contained in the promotional communications you receive.
8.2. Service and billing messages
VBA may also contact you with important information regarding our Services, or your use thereof. For example, we may send you a notice (through any of the means available to us) if a certain Service is temporarily suspended for maintenance; reply to your support ticket or e-mail; send you reminders or warnings regarding upcoming or late payments for your current or upcoming subscriptions; forward abuse complaints regarding our app or website; or notify you of material changes in our Services.
It is important that you are always able to receive such messages. For this reason, you are unable to opt-out of receiving such Service and Billing Messages unless you are no longer a VBA User (which can be done by deactivating your account).
We may also contact you with service and billing-related messages and content. You will not be able to opt-out of receiving such messages.
9. Your rights in relation to your ‘Personal Information’
VBA believes that it is imperative that all VBA users have control over their Personal Information. Therefore, depending on the way you use the VBA Services, you may have the right to request access to, receive a copy of, update, amend or delete, port certain Personal Information to another service, restrict, or object to certain uses of your Personal Information (for example, for direct marketing purposes). Further, when we rely on your consent for processing of your Personal Information (for instance, for direct marketing) you can withdraw your consent at any time, and such withdrawal will take effect from thereon.
VBA will not charge you more if you exercise any of these rights and will continue to provide you with the same level of service.
If you are a VBA user, you can access and correct a lot of your Personal Information directly through your account. You can also exercise your rights by sending your request to info@vbaconnect.com. When we receive your right request, we may take steps to verify your identity before complying with the request to protect your privacy and security.
Before fulfilling your request, we may ask you for additional information in order to confirm your identity and for security purposes. We reserve the right to charge a fee where permitted by law (e.g. if your request is unfounded or excessive).
You have the right to file a complaint with your local supervisory authority for data protection (but we still recommend that you contact us first).
If you are a VBA User, and you wish to receive a copy, access and/or request us to make corrections to the Personal Information that you have stored with us, or wish to request a list of what Personal Information (if any) pertaining to you we disclosed to third parties for direct marketing purposes, please email info@vbaconnect.com. We will make reasonable efforts to honor your request promptly (unless we require further information from you in order to fulfill your request), subject to legal and other permissible considerations.
Please note that permanently deleting your VBA account erases all of your Personal Information from VBA's databases. After completing this process, you can no longer use any of your VBA Services, your account and all its data will be removed permanently, and VBA will not be able to restore your account or retrieve your data in the future. If you contact our support channels in the future, the system will not recognize your account and support agents will not be able to locate the deleted account.
10. Additional Information for California residents
If you are a California resident using the Services, the California Consumer Privacy Act ("CCPA") grants you the right to request access to and deletion of the Personal Information VBA collects about you, as well as to request that we disclose how we collect, use, and share your Personal Information.
California residents also have a right to opt-out of the sale of their Personal Information by a business and a right not to be discriminated against for exercising any of their rights under the CCPA.
No sale of Personal Information. VBA does NOT sell (as such term is defined in the CCPA) your Personal Information to third parties, and VBA has not sold Personal Information in the twelve months prior to the effective date of this Privacy Policy.
No Discrimination. VBA does not discriminate against any User for exercising their rights under the CCPA.
California consumers can exercise their CCPA rights directly or through an authorized agent by signing in to their registered VBA account at Vbalogin.com and following the instructions outlined below. Please note: in order to protect Users’ accounts and Personal Information and safeguard Users’ privacy rights, we verify Users’ deletion and access requests, and to that extent, we may ask you for additional information or documentation (depending on the case), such as account related information, and, in some cases, billing information used to purchase paid Services, and a copy of documents that can assist with verifying your identity.
Such identification documentation (if requested) will be used only for verification purposes and we will delete it after your request is processed.
The following instructions apply to Personal Information we may collect from California residents on or through our Services.
Right to Know: If you want to exercise your right to know or receive a copy or access the Personal Information that you have stored with us, please submit a request to access your Personal Information by submitting a request by email to info@vbaconnect.com.
Right to Deletion: If you want to exercise your right to request deletion of any of your Personal Information that you have stored with us, please submit a request to delete all your Personal Information (including information accessible via your User account and any other Personal Information we hold about you) by submitting a request by email to info@vbaconnect.com.
Once we receive and verify your consumer request, we will delete your personal information from our records unless an exception applies. We will make reasonable efforts to honor your request promptly and consistent with requirements under applicable law.
Please note that permanently deleting your VBA account erases all of your Personal Information from VBA's databases. After completing this process, you can no longer use any of your VBA Services, your account, and all its data will be removed permanently, and VBA will not be able to restore your account or retrieve your data in the future. Additionally, if you contact our support channels in the future, the system will not recognize your account, and support agents will not be able to locate the deleted account.
If you cannot access your VBA account or if you wish to exercise your CCPA rights through an authorized agent operating on your behalf, you, or your authorized agent (as applicable) may send a request to info@vbaconnect.com. To process your request, in order to protect Users’ accounts and Personal Information, we may ask you or your authorized agent for the verifying information detailed above, which may vary according to the circumstances of your request. Authorized agents will also need to provide VBA with a copy of the consumer’s signed authorization designating them as their agent.
The rights described in this section may also apply to other U.S. States' residents, according to applicable laws and regulations.
11. Questions and complaints
If you have any questions or concerns about our collection, use or disclosure of Personal Information, or if you believe that we have not complied with this Privacy Policy or applicable data protection laws, please contact our partner – details are set out at the end of this Privacy Policy.
Our Data Protection Officer team will investigate the complaint and determine whether a breach has occurred and what action, if any, to take. We take every privacy complaint seriously and will make all reasonable efforts to resolve your complaint promptly and in accordance with applicable law.
You can file a complaint with your local supervisory authority for data protection at any time, however we recommend that you contact us first so we can try to resolve it.
12. Data retention
We may retain your Personal Information (as well as Users’ Personal Information) for as long as your User Account is active, as indicated in this Privacy Policy, or as otherwise needed to provide you with our Services.
We may continue to retain your Personal Information after you deactivate your User Account and/or cease to use any particular Services, as reasonably necessary to comply with our legal obligations, to resolve disputes regarding our Users, prevent fraud and abuse, enforce our agreements and/or protect our legitimate interests.
To determine the appropriate retention period for Personal Information, we consider the amount, nature, and sensitivity of such data, the potential risk of harm from unauthorized use or disclosure of such data, the purposes for which we process it, and the applicable legal requirements.
13. Security
VBA has implemented security measures designed to protect the Personal Information you share with us, including physical, electronic and procedural measures. Among other things, we provide HTTPS secure access to most areas on our site; the transmission of sensitive payment information (such as a credit card number) through our designated purchase forms is protected by an industry standard SSL/TLS encrypted connection; and we regularly maintain a PCI DSS (Payment Card Industry Data Security Standards) certification. We also regularly monitor our systems for possible vulnerabilities and attacks, and regularly seek new ways and Third Party Services for further enhancing the security of our Services and protection of our Visitors’ and Users’ privacy.
Regardless of the measures and efforts taken by VBA, we cannot and do not guarantee the absolute protection and security of your Personal Information, Users’ Personal Information or any other information you upload, publish or otherwise share with VBA or anyone else. We encourage you to set strong passwords for your User Account, and avoid providing us or anyone with any sensitive Personal Information of which you believe its disclosure could cause you substantial or irreparable harm.
Furthermore, because certain areas on our Services are less secure than others (Blogs, Forums), we request and encourage you not to share any Personal Information on any of these areas or via any of these methods.
If you have any questions regarding the security of our Services, you are welcome to contact us here.
14. Third-party websites
Our Services may contain links to other websites or services. We are not responsible for such websites’ or services’ privacy practices. We encourage you to be aware when you leave our Services and to read the privacy statements of each and every website and service you visit before providing your Personal Information. This Privacy Policy does not apply to such linked third party websites and services.
15. VBA jobs applications
VBA welcomes all qualified Applicants to apply to any of the open positions published at https://www.vbaconnect.com/jobs, by sending us their contact details, CV, and other relevant information via the application form on our Website.
16. Public forums and user content
Our Services offer publicly accessible blogs, communities and support forums. Please be aware that any Personal Information you provide in any such areas may be read, collected, and used by others who access them. To request removal of your Personal Information from our blogs, communities or forums, feel free to contact us here. In some cases, we may not be able to remove your Personal Information from such areas. For example, if you use a third party application to post a comment (e.g., the Facebook social plugin application) while logged in to your related profile with such third party, you must login into such application or contact its provider if you want to remove the Personal Information you posted on that platform.
In any event, we advise against posting any Personal Information (via any means) you don’t wish to publicize.
If you upload any user content to your User Account or post it on your User Website and provide it in any other way as part of the use of any Service, you do so at your own risk.
We have put adequate security measures in place to protect your Personal Information. You understand and acknowledge that, even after its removal by you or us, copies of User Content may remain viewable in cached and archived pages or if any third parties (including any of your Users-of-Users) have copied or stored such User Content. To clarify, we advise against uploading or posting any information you do not wish to be public.
17. Updates and interpretation
We may update this Privacy Policy as required by applicable law, and to reflect changes to our Personal Information collection, usage and storage practices. If we make any changes that we deem as “material” (in our sole good faith discretion), we will notify you (using one of the notification methods set forth in Section 15.3 of the Terms of Use) prior to the change becoming effective. In relation to any updated Privacy Policy, we will, as required by applicable law, notify you, seek your consent and/or take any other measures. We encourage you to periodically review this page for the latest Information on our privacy practices. Unless stated otherwise, our most current Privacy Policy applies to all information that we have about you and your Users-of-Users, with respect to our Website, VBA Apps, Mobile Apps and other Services.
Any heading, caption or section title contained herein, and any explanation or summary under the right “#ItsThatEasy” column, is provided only for convenience, and in no way defines or explains any section or provision hereof, or legally binds any of us in any way.
This Privacy Policy was written in English, and may be translated into other languages for your convenience. You may access and view other language versions by changing your language settings. If a translated (non-English) version of this Privacy Policy conflicts in any way with its English version, the provisions of the English version shall prevail.
18. Contact:
If you have any questions about this Privacy Policy or wish to exercise any of your rights as described in Sections 9 or 10 please refer to those sections or contact the Data Protection Officer team here. Our partners will attempt to resolve any complaints regarding the use of your Personal Information in accordance with this Privacy Policy.