Your Privacy Rights
This privacy notice was last updated on 04/13/2021.
Please read this privacy policy carefully as it contains important information on who we are, how and why we collect, store, use, and share your personal information collected from our websites and mobile applications. It also explains your rights in relation to your personal information and how to contact us in the event you have a complaint.
1. Definitions.
Key Terms |
Definition |
We, us, our |
Virtual Property Management Solutions, LLC |
Personal information |
Any information relating to an identified or identifiable individual. |
Website |
Any of our websites at which you accessed this privacy policy, including www.virtualpmsolutions.com |
Applications |
Our mobile application is available for you to install or otherwise operate on your cellular phone or other device. |
Platform |
The Website, Mobile Application, and the services we provided through them. |
User |
Users of the Website or Application may be Clients or Freelancers as defined in the VPM Terms of Service Agreement (www.virtualpmsolutions.com/tos) |
2. Personal Information We Collect About You.
We may collect and use the following personal information that identifies, relates to, describes, is reasonable, capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household:
Categories of Personal Information |
Personal Information Collected |
Personal Identifiers |
Name, address, phone, date of birth, taxpayer ID number, email. |
Payment Information |
If you use our Platform to make or receive payments, we collect information that you submit. Many pieces of information about your payment, such as your bank account or credit card number, are actually collected by a third-party payment processor through the Platform as described in greater detail below. |
Communication |
Emails or electronic correspondence that you send to us or another User or that you post to a public or private forum on the Platform. |
Internet or other electronic network activity information. |
IP Address, URL, browsing history, search history, and information about your interaction with the Platform or an online advertisement. |
3. How Your Personal Information is Collected.
We collect most of this personal information directly from you. For example, when you contact us through our website or send us other Communications. However, we may also collect information:
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When you create a profile on the Platform and submit documents or records;
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When you communicate with another User or exchange Correspondence;
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When you install and/or operate an Application on your device;
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When you apply for a freelancing opportunity on the Platform; and
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From cookies and similar online tracking and analytic technology on our website.
4. Information collected by our desktop applications (Mac, Windows, and Linux):
We may also collect screenshots, applications currently being worked on, web URLs visited, time you are active, the operating system you are using, whether or not you have an input device such as a monitor, whether your mouse is actively moving or not, the names of projects or tasks being worked on, the amount of time worked on those tasks, the browser version you are using, and whether your keyboard is being typed on.
Note: Virtual Property Management Solutions LLC does not utilize a keylogging program.
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Use of Cookies. We use technologies, such as cookies, to analyze traffic to our website. You are given the option to consent to the collection and use of your data in this manner prior to it being collected.
a. Google Analytics. For more information about how Google uses data when you use our site, visit www.google.com/policies/privacy/partners. Users may download the Google Analytics Opt-out Browser Add-on at: https://tools.google.com/dlpage/gaoptout.
5. How and Why We Use Your Personal Information.
We use your personal information:
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Where you have given consent, including where you have consented to provide your information to another User in connection with a freelancing opportunity on our Platform.
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To comply with our legal and regulatory obligations;
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For our legitimate interests or those of a third party.
A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.
The table below explains what we use (process) your personal information for and our reasons for doing so
What we use your personal information for |
Our reasons |
To provide products or services to you |
For the performance of our contract with you or to take steps at your request before entering into a contract |
To respond to your communications |
To communicate with you in response to Communication |
To prevent and detect fraud |
For our legitimate interests or those of a third party, i.e. to minimize fraud that could be damaging for us and for you |
As necessary to comply with professional, legal, and regulatory obligations that apply to our business, e.g. under health and safety regulation or rules |
To comply with our legal and regulatory obligations |
Gathering and providing information required by or relating to audits, inquiries or investigations by regulatory bodies |
To comply with our legal and regulatory obligations |
Ensuring business policies are adhered to, e.g. policies covering security and internet use |
For our legitimate interests or those of a third party, i.e. to make sure we are following our own internal procedures so we can deliver the best service to you |
Operational reasons, such as improving efficiency, training, and quality control |
For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service for you at the best price |
Ensuring the confidentiality of commercially sensitive information |
For our legitimate interests or those of a third party, i.e. to protect trade secrets and other commercially valuable information To comply with our legal and regulatory obligations |
Statistical analysis to help us manage our business |
For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service for you at the best price |
Preventing unauthorized access and modifications to systems |
For our legitimate interests or those of a third party, i.e. to prevent and detect criminal activity that could be damaging for us and for you To comply with our legal and regulatory obligations |
Updating customer records |
For the performance of our contract with you or to take steps at your request before entering into a contract To comply with our legal and regulatory obligations For our legitimate interests or those of a third party, e.g. making sure that we can keep in touch with our customers about existing orders and new products |
Ensuring safe working practices, staff administration, and assessments |
To comply with our legal and regulatory obligations For our legitimate interests or those of a third party, e.g. to make sure we are following our own internal procedures and working efficiently so we can deliver the best service to you |
Marketing our services to:
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For our legitimate interests or those of a third party, i.e. to promote our business to existing and former customers |
External audits and quality checks |
For our legitimate interests or those of a third party, i.e. to maintain our accreditations so we can demonstrate we operate at the highest standards To comply with our legal and regulatory obligations |
6. Promotional Communications.
We may use your personal information to send you updates (by email, text message, telephone, or post) about our products and services.
We have a legitimate interest in processing your personal information for promotional purposes (see above “How and why we use your personal information”).
You have the right to opt-out of receiving promotional communications from us at any time by:
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Using the “unsubscribe” link in emails or “STOP” number in texts; or
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Updating your preferences at www.virtualpmsolutions.com/unsubscribe or, with respect to Applications, through the settings of your Application.
We may ask you to confirm or update your preferences if you instruct us to provide further products and/or services in the future, or if there are changes in the law, regulation, or the structure of our business.
7. Who We Share Your Personal Information With.
We routinely share personal information with:
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Other Users of the Platform;
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Service providers we use to help deliver our products and/or services to you, such as web hosting companies;
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Other third parties we use to help us run our business, such as marketing agencies or website hosts;
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We may share personal information with external auditors.
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We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.
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We may also need to share some personal information with other parties, such as potential buyers of some or all of our business or during a restructuring. We may anonymize information, but this may not always be possible.
8. Do Not Track
Our website does not monitor, recognize, or honor any opt-out or do not track mechanisms, including general web browser “Do Not Track” settings and/or signals.
9. Personal Information We Sold or Disclosed for a Business Purpose.
In the preceding 12 months, we have not sold Personal Information to any third-party.
In the preceding 12 months, we have disclosed for a business purpose to one or more third parties the following categories of Personal Information:
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Personal Identifiers;
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Communications with another User of the Platform;
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Payment Information collected by our third-party payment processor; and,
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Internet or other electronic network activity information
10. Where Your Personal Information is Held.
Information is held at our offices and those of our service providers, representatives, and agents as described above (see above: “Who We Share Your Personal Information with”) or on computer servers used or maintained by those entities.
11. How Long Your Personal Information Will Be Kept.
Unless we delete your information subject to a legitimate request, we reserve the right to keep your personal information indefinitely, including while you have an account with us or while we are providing products and/or services to you. We will also keep your personal information for as long as is necessary:
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To respond to any questions, complaints, or claims made by you or on your behalf;
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To show that we treated you fairly; or
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To keep records required by law.
12. EU Data Subject’s Rights Under the GDPR.
If you are a data subject in the European Union, you may have the following rights under the GDPR:
Right to Access |
The right to be provided with a copy of your personal information (the right of access) |
Right to Rectification |
The right to require us to correct any mistakes in your personal information |
Right to be Forgotten |
The right to require us to delete your personal information—in certain situations |
Right to Restriction of Processing |
The right to require us to restrict processing of your personal information—in certain circumstances, e.g. if you contest the accuracy of the data |
Right to Data Portability |
The right to receive the personal information you provided to us, in a structured, commonly used, and machine-readable format and/or transmit that data to a third party—in certain situations |
Right to Object |
The right to object:
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Right Not to be Subject to Automated Individual Decision-Making |
The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you |
For further information on each of those rights, including the circumstances in which they apply, see the guidance from the UK Information Commissioner's Office (ICO) on individual rights under the General Data Protection Regulation.
13. Your Rights Under the CCPA.
If you are a resident of California, you may have the right under the California Consumer Privacy Act of 2018 (CCPA) and certain other privacy and data protection laws, as applicable, to exercise free of charge:
Disclosure of Personal Information We Collect About You |
You may have the right to know:
Please note that we are not required to:
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Personal Information Sold or Used for a Business Purpose |
In connection with any personal information we may sell or disclose to a third party for a business purpose, you may have the right to know:
You may have the right under the California Consumer Privacy Act of 2018 (CCPA) and certain other privacy and data protection laws, as applicable, to opt-out of the sale or disclosure of your personal information. If you exercise your right to opt-out of the sale or disclosure of your personal information, we will refrain from selling your personal information, unless you subsequently provide express authorization for the sale of your personal information. To opt-out of the sale of your personal information, visit our Do Not Sell My Personal Information page here: www.virtualpmsolutions.com/do-not-sell-my-personal-information |
Right to Deletion |
Subject to certain exceptions set out below, on receipt of a verifiable request from you, we will:
Please note that we may not delete your personal information if it is necessary to:
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Protection Against Discrimination |
You have the right to not be discriminated against by us because you exercised any of your rights under the CCPA. This means we cannot, among other things:
Please note that we may charge a different price or rate or provide a different level or quality of goods and/or services to you if that difference is reasonably related to the value provided to our business by your personal information. |
14. How to Exercise Your Rights.
Application users may delete their account and control their data options on the settings of the Application. California and European users may exercise their rights at:
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On our website at www.vpmsolutions.com; or
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Call us, toll-free, at (800) 759-0279;
Please note that you may only make CCPA-related data access or data portability disclosure request twice within a 12-month period.
If you choose to contact us directly (i.e., outside of logging in to your account on our website), you will need to provide us with:
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Enough information to identify you (e.g., your full name, address);
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Proof of your identity and address (e.g., a copy of your driving license or passport and a recent utility or credit card bill); and
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A description of what right you want to exercise and the information to which your request relates.
We are not obligated to make a data access or data portability disclosure if we cannot verify that the person making the request is the person about whom we collected information, or is someone authorized to act on such person’s behalf.
Any personal information we collect from you to verify your identity in connection with your request will be used solely for the purposes of verification.
15. Changes to This Privacy Notice.
We may change this privacy notice from time to time–when we do, we may inform you via a notice on the website or other means of contact such as email.
16. How to Contact Us.
You may contact us at info@virtualpmsolutions.com or by filling out the form here.