PERSONAL DATA PROCESSING AND PRIVACY POLICY

This privacy policy (the “Privacy Policy”) describes the rules according to which VU INC, a company duly organized in the State of Delaware, United States (hereinafter referred to as “VU”) and its Affiliates (as listed in Appendix I) shall handle the Personal Data of End Users and/or Clients (“USERS”) via the website www.vusecurity.com and/or any other URL that may replace it from time to time (“THE SITE”).

1. DEFINITIONS

Affiliate: It means a company that controls, is controlled by, or is under common control with VU. This control means that the parent company owns at least fifty percent (50%) of the controlled company’s share capital.

Consent: It means any freely given, specific, informed and unambiguous indication that the User accepts, by a statement or by a clear affirmative action, the processing of their Personal Information.

Personal Data: It means any Information of any kind about determined or determinable natural or legal persons.

Sensitive Data: It means personal data revealing racial and ethnical origin, political opinions, religious, philosophical or moral beliefs, trade union memberships and information about an individual’s health or sex life.

User: It means any natural or legal person that uses the Services of VU and whose personal information is processed by VU.

2. USER’S CONSENT

By accepting this Privacy Policy, Users authorize VU to process their Personal Data.

Users understand and accept that they may withdraw their consent at any time by means of a request submitted to the Data Protection Officer via the following e-mail address: dpo.vu@vusecurity.com.

This Privacy Policy applies to the processing of the Users’ Personal Data by VU and its Affiliates. Therefore, the Users’ Personal Data processed under this Privacy Policy may be shared with VU’s Affiliates.

3. RESPONSIBILITY FOR PROCESSING PERSONAL DATA 

VU shall be responsible for processing Personal Data of the Users of the Platform through their Affiliates in accordance with the provisions of this Privacy Policy.

VU has appointed a Data Protection Officer (DPO) who is in charge of complying with the laws relating to the protection of Personal Data, and may be contacted via this e-mail address: DPO.VU@vusecurity.com

4.  PURPOSE OF PERSONAL DATA PROCESSING

Users understand that their Personal Data shall be processed in order to:

1. Maintain, manage, analyze, develop and improve THE SITE.
2. Authorize and administer any access to THE SITE, verify identities, authenticate visitors and provide USERS with the Services;
3. Analyze users’ navigation behavior and create profiles about their navigation preferences and interests.
4. Respond to inquiries submitted via THE SITE.
5. Communicate activities carried out by VU.
6. Offer and/or advertise VU’s products.
7. Access THE SITE, and its improvements.
8. Obtain a diagnosis of potential connectivity problems between THE SITE and the USERS to improve their access.
9. Update the Privacy Policy.

If the Personal Data is used for any purpose other than those listed above, VU shall inform Users, prior to doing so, in order to get their consent.

5. PERSONAL DATA BEING PROCESSED.
   
   a) Users’ Personal Data necessary to access THE SITE and operate it properly, including without limitation the following details:
      I.Full Name
      II.E-mail.
      III. Personal Identification Number.
      IV. Contact Information (such as telephone number, address, country of residence,       V. Geolocation.
   
   b) Information about the Users’ activity and preferences in THE SITE.
   c) Name of provider’s domain (ISP) to access the network.
   d) Date and time of access to THE SITE.
   The Internet address that includes the link that directs to THE SITE.

6.  USER PERSONAL DATA STORAGE.

The Personal Data collected by VU shall be kept for a limited period of time based on the following criteria:

1. legal obligation to keep the data; and
2. Users’ request to delete and/or to stop processing data, as applicable.

After any of the periods established under the criteria referred to above, the User’s Personal Data shall be deleted and the User shall be no longer identified.

7. PERSONAL DATA ASSIGNMENT AND TRANSFER.

Users understand that their Personal Data may be shared with:

• Third parties that provide services to VU and/or its Affiliates.

In this case, the said parties shall act as processors of the Personal Data.

• Affiliates of VU, with the same purposes stated in this Privacy Policy.

VU shall communicate Personal Data to the relevant authorities if there is a legal obligation or requirement to do so.

Users accept and agree that, if necessary, VU shall transfer Personal Data outside the Users’ country of residence, by means of an International Transfer of Personal Data. For this type of International Transfer of Personal Data, in addition to the Users’ consent, VU shall use standard contractual rules in accordance with international regulations.

VU undertakes to adopt the organizational, technical and contractual measures necessary to guarantee the protection and security of the Personal Data, pursuant to the rules relating to the protection of personal data of the country where the Service is provided to the Users, and international regulations affecting the Service.

8.  USERS'  RIGHT AS THE OWNERS OF THE PERSONAL DATA.

Users are entitled to:

1. Withdraw any consent given under this Privacy Policy.
2. Access their Personal Data.
3. Rectify their Personal Data.
4. Remove or delete Personal Data to prevent VU from storing and/or processing it.
5. Limit VU’s processing of their Personal Data.
6. Object to the way VU handles their Personal Data.
7. Personal Data Portability.

The rights set out in this document may be exercised by the User who owns the Personal Data or their legal representative, upon prior written notice to DPO.VU@vusecurity.com

9. EXCEPTIONS.

VU may disclose certain Personal Data of Users, when this disclosure is necessary to:

Avoid any legal liability;

Comply with a legal requirement, such as a search warrant, a summons or a court order;

Meet a requirement of a government agency or regulatory entity; and/or

Protect the rights, property or security of VU, Users or third parties.

10.  INFORMATION THAT USERS CHOOSE TO SHARE.

THE SITE may provide links to other services provided by third parties.

VU shall not be responsible for the privacy policies and/or practices of these third-party services. Users shall be responsible for reading and understanding the privacy policies of the said third-party services. This Privacy Policy shall only regulate the information collected and processed by UV’s Platform.

VU may communicate with Users via automatic notifications over THE SITE, by e-mail, SMS, MMS or other text message, and may collect information relating to such communications.

The information collected by VU shall be used to improve the Services.

11.  CONFIDENTIALITY AND INFORMATION SECURITY.

VU has adopted reasonable security measures to protect Users’ Personal Data against unauthorized access, disclosure, change or destruction. Any information collected by VU shall be treated as confidential. Any access for processing Users’ Personal Data shall be restricted to the employees, contractors, operators and agents of VU that necessarily need that access to perform their duties and develop or improve THE SITE.     

In addition, VU shall require suppliers to meet the same confidentiality standards applied by VU to provide the Services to Users and it shall not allow third parties to access the said information.

However, and although VU has designed a security plan to respond to and control incidents with regard to unauthorized access to the private information it collects or stores, VU cannot guarantee that unauthorized third parties shall not breach the relevant security measures and unlawfully use the Users’ information.

12. MINORS.

The registration in the Platform and/or the use of the Service shall be intended for qualified USERS legally capable to enter into contracts in the country where they have registered. Minors shall not be allowed to use the services provided by VU or supply Personal Data or any other information of any kind.

13. CHANGES TO THIS PRIVACI POLICY.

VU may update this Privacy Policy at any time and without prior notice. VU shall keep USERS informed of any changes made to the Privacy Policy before they come into force.

 

Appendix I

VU’s Affiliate companies are:

1. VU Security S.A., a company duly organized and existing under the laws of Argentina.
2. VU Security Uruguay SRL, a company duly organized and existing under the laws of Uruguay.
3. VU Chile SpA, a company duly organized and existing under the laws of Chile.
4. VU Security Limited, a company duly organized and existing under the laws of England and Wales.
5. VU Security & Fraud Prevention SL Unipersonal, a company duly organized and existing under the laws of Spain.
6. VU Inc., a company duly organized and existing under the laws of the state of Delaware, United States of America.
7. VU Cibersecurity Mexico SA de CV, a company duly organized and existing under the laws of Mexico.
8. VU Ciberseguranca LTDA, a company duly organized and existing under the laws of Brazil.