Updated: 23 January 2019
This privacy notice (“Privacy Notice”) describes how Vestigos (“Vestigos”, “we” or “us”) collects, uses, shares, and retains personal information that you provide to us, or that we collect, when you use the Vestigos website located at www.vestigos.com, use Vestigos products and services and complete related forms, participate in Vestigos events, or communicate with one of our customer service representatives (“Personal Data”).
1. Data Protection Contacts
Vestigos are headquartered in Dubai , UAE. You may contact Vestigos’s internal data protection resource if you have any questions or concerns about Vestigos’s policies or practices regarding Personal Data.
E-Mail: [email protected]
2. Collection of Personal Information
A. Information You Directly and Voluntarily Provide to Us.
Membership: If you provide your Personal Data to Vestigos to become a member of Vestigos, or if you sign up to become a registered user of any website operated by Vestigos, you will be required to provide certain information as part of the registration process. This information will include your first and last name, email address, title, business name and mailing address.
We may also request that you voluntarily provide other information. Membership information is used to communicate with you, to design content and activities that we believe would be of interest to you, and to ensure that Vestigos will not violate any applicable UAE sanctions in providing you access to Vestigos’s goods and services. If you wish to opt-out of receiving these communications, please update your consent to receive communications field in your member profile.
Events and Conferences: Vestigos may host events that include in-person and virtual conferences, training, knowledge sharing and webinars. If you register for an Vestigos event and you are an Vestigos member, we will access the information in your member account to provide you with information and services associated with the event.
Communications with Vestigos: If you communicate or correspond with us by email, through postal mail, via phone or through other forms of communication, we may collect the information you provide as part of those communications. For example, if you correspond with us through email, we may collect and store the email address you use to send the applicable correspondence and use it to respond to your inquiry; to notify you of Vestigos conferences or other services; or to keep a record of your complaint, accommodation request, and similar purposes.
B. Information We Automatically Collect from You.
We may automatically collect information about you when you use the Sites or our services. For example, if you access the Sites through a computer, we will automatically collect information such as your browser type and version, computer and connection information, IP address and standard web log information. If you access the Sites through a mobile device, we may also be able to identify the location of your mobile device. You may choose not to share your location details with us by adjusting your mobile device’s location services settings. For instructions on changing the relevant settings, please contact your service provider or device manufacturer. This information that we automatically collect from you is used to enhance the performance of Vestigos’s website. Vestigos also uses your location information (if shared with Vestigos) to identify the geographic locations from which our content is accessed so that we can better understand what content topics may be most relevant in that region, and to Vestigos members generally, and to develop resources around those content topics.
We may automatically collect information from you when you use the Sites using “cookies” and other similar technologies, such as web beacons. Cookies are small amounts of data that are stored within your computer’s Internet browser and that are accessed and recorded by the websites that you visit so that they can recognize the same browser navigating online at a later time. The cookies are not able to execute code or access other information stored on the computer. Web beacons are transparent pixel images that are used in collecting information about website usage, email response and tracking.
Information that may be collected by cookies when you use the Sites may include, without limitation:
the pages you visit within the Sites;
the date and time of your visit to the Sites;
the amount of time you spend using the Sites;
the Internet Protocol (IP) address used to connect your computer to the Internet; and/or
your computer and connection information such as your browser type and version, operating system and platform.
This information is collected to enhance the site performance and end user experience. You can set your browser to reject cookies or to notify you when you are sent a cookie.
To learn more about your ability to manage cookies and web beacons, please consult the privacy features in your browser. In addition, to find out more about cookies, including how to see what cookies have been set on your device and how to manage and delete them, visit www.allaboutcookies.org.
Vestigos will not associate identifiers from cookies or similar technologies with sensitive identifiers about you, such as race, religion, sexual orientation or health.
C. Information Collected by Third Parties through Third-Party Links and Content.
The Sites may include links to other websites and other content from third-party businesses and can offer direct interaction with external websites, networks or platforms that are outside Vestigos’s control. These third-party businesses may use cookies, web beacons or other similar technology to collect information about you. Vestigos does not have access to or control over these third parties or the cookies, web beacons or other technology that these third parties may use. We are not responsible for the security, privacy of the information collected by these third parties or the privacy practices of these third parties or the content on any third-party website. You are encouraged to review the privacy policies of the different websites you visit.
D. Information Collected by Third-Party Analytics Services.
We may work with third-party analytics services to help us understand how the Sites are being used, such as tracking the frequency and duration of use of the Sites. We may use Google Analytics, and web analytics services provided by Google (“Analytics Tools”) to collect information about your use of the Sites. These Analytics Tools may use cookies to collect information about the content you view, what websites you visit immediately prior to and after visiting the Sites, and your system information and geographic information.
The information generated by these cookies about your use of the Sites will be transmitted to and stored by the applicable analytics services. The information collected by these analytics services allows us to analyze your use of the Sites. The Analytics Tools may also transfer this information to third parties where required to do so by law, or where such third parties process the information on their behalf. You may refuse the use of cookies by selecting the appropriate settings on your browser, however, please note that if you do this you may not be able to use the full functionality of the Sites.
At the moment that you cancel your Vestigos membership or withdraw your consent for the processing of personal information, Vestigos will not be able to access the personal information processed by third-party analytics. By using the Sites, you consent to the processing of data about you by Google in the manner and for the purposes set out above. You can opt-out of Google Analytics by installing Google’s opt-out browser add-on, and out of interest-based Google ads using Google’s Ads Settings.
E. Information You Share on Third-Party Websites or through Social Media Services.
The Sites may include links to third-party websites and social media services where you will be able to post comments, stories, reviews or other information outside of Vestigos’s control. Your use of these third-party websites and social media services may result in the collection or sharing of information about you by these third-party websites and social media services.
Vestigos is not responsible for the security or privacy of any information collected by other websites or other services. Information collected by third parties is governed by their privacy practices. We encourage you to review the privacy policies and settings on the third-party websites and social media services with which you interact to make sure you understand the information that may be collected, used, and shared by those third-party websites and social media services.
F. Information You Post on the Sites.
If you decide to participate in our platforms and professional networking features, keep in mind that your personal information (for example, your name and online user name), along with any substantive information you disclose in the communication you decide to post, will be publicly accessible and viewable by others who visit that area. In addition, we may highlight certain users’ postings or contributions to other members of the Vestigos professional networking features.
For example, users who participate actively in our social networking features, like contributing materials and engaging in certain online activities, will be listed as “active members” in a roster that is viewable by all other registered users. It is possible that your posting may result in unsolicited messages from third parties. We strongly recommend that you do not post any information on the public areas of the Sites that allows strangers to identify or locate you or that you otherwise do not want to share with the public.
3. Online Advertising
Vestigos and third-party businesses may use the information collected through the Sites using cookies, web beacons, and other similar technologies to help manage online advertising programs. This information may enable Vestigos and our third-party advertising services and other third-party businesses to track the actions of users online over time and across different websites or platforms to measure statistics relating to marketing efforts, and to deliver electronic advertisements that may be more relevant to individual consumers and that will improve the consumer experience.
For information about how tracking works for online advertising purposes, and what happens when you elect a do-not-track option, visit http://www.aboutads.info/choices. In addition, some third-party businesses may provide a mechanism to opt-out of their technology. For more information about the opt-out process, you may visit the Network Advertising Initiative website, available at: http://www.networkadvertising.org/managing/opt_out.asp.
Do Not Track: Your browser may allow you to adjust your browser settings so that “do not track” requests are sent to the websites that you visit. However, Vestigos does not respond to “Do Not Track” (DNT) signals. To determine whether any of the third-party services it uses honor the “Do Not Track” requests, please read their privacy policies.
4. Use, Sharing and Retention of Personal Information
A. How We Use Your Information.
Vestigos uses personal information for the purposes described at the time of collection, to provide membership benefits and other services to you, including order processing, processing of membership applications, or registering you for event or training programs, to otherwise process your requests or address your inquiries. Vestigos also publishes the names, titles, country and business affiliations of officers, committee members and others who have assisted with initiatives or projects to provide recognition of their achievements to the Vestigos community.
Vestigos also uses your information, as permitted by law, to provide you with information about Vestigos, our products and services or other products and services in which we believe you may be interested. If you are a member or registered user, we may email you about products and services that we believe may be of interest to you. If you wish to opt-out of receiving these emails from us, please follow the instructions contained in an applicable email you receive from us, which will allow you to opt-out of receiving these types of email communications from us.
We may also use your personal information to tailor your experience at our Sites, to compile and display content and information that we think you might be interested in, and to provide you with content according to these preferences. Vestigos may also use this information to help us understand our members’ needs and interests, to better tailor our products and services to meet your needs.
B. How We Share Your Information with Third Parties.
Except as set forth in this Privacy Notice or when specifically agreed to by you, we will not disclose personal information we gather from you to third parties unless Vestigos is required to share this information to complete your request or for legitimate business purposes. Vestigos shares personal information in the following circumstances:
Third-Party Service Providers. We may share your information with vendors or third parties who deliver or provide goods and services or otherwise act on behalf of or at the direction of Vestigos. These third parties may include, for example, our third-party technology providers, product-fulfillment companies, and third-party event hosts, hotels for conference registrants, sponsors, co-sponsors and exhibitors. These third-party service providers will only have access to the information needed to perform these limited functions on our behalf. If you do not wish to have your information included in an attendee list or to receive information from sponsors, co-sponsors and/or exhibitors, you can express your preferences when you register for events or you may contact Vestigos directly at [email protected].
Volunteers and Board Members. We may share your information with our affiliates, subsidiaries and Vestigos volunteers and board members for purposes of conducting Vestigos’s internal business operations. Vestigos also makes publicly available the names, titles, country and business affiliations of officers, committee members and others who have assisted with initiatives or projects.
Vestigos Events. If you are an event attendee, speaker, or sponsor, certain items of your information may be included in the event roster, which will be publicly disclosed, and may also be shared with third-party event sponsors and exhibitors. Further, by registering and attending an Vestigos event, you agree irrevocably, with no compensation to you, that Vestigos or any third party who is acting on Vestigos’s behalf may create images, videos and/or sound recordings of you (“works”) at the event for marketing purposes. This grant of rights in the works also includes the rights to adapt, reproduce, distribute, perform, make available to the public, broadcast, retransmit or sublicense the works to Vestigos’s affiliates. This grant of rights in the works also includes all current and future media and is not restricted to time or territory.
Response to Subpoenas, Court Orders, Government Requests or to Protect Rights and to Comply with Our Policies. To the extent permitted by law, we will disclose your information to government authorities or third parties if: (a) required to do so by law or regulation, or in response to a subpoena or court order or any other enforceable governmental request or order; (b) we believe in our sole discretion that disclosure is reasonably necessary to protect against fraud, to protect the property or other rights of us or other users, third parties or the public at large; or (c) we believe that you have abused the Sites by using them to attack other systems or to gain unauthorized access to any other system, to engage in spamming or otherwise to violate applicable laws. You should be aware that, following disclosure to any third party, your information may be accessible by others to the extent permitted or required by applicable law.
Business Transfers; Bankruptcy. In the event of a merger, acquisition, bankruptcy or other sale of all or a portion of our assets, any user information owned or controlled by us may be one of the assets transferred to third parties. Unless you are residing in the European Economic Area, we reserve the right, as part of this type of transaction, to transfer or assign your information and other information we have collected from users to third parties. Vestigos will still ensure the confidentiality and security of any user information. Other than to the extent ordered by a bankruptcy or other court, the use and disclosure of all transferred user information will be subject to this Privacy Notice.
Aggregate Information. We may share your information with affiliated or unaffiliated third parties on an anonymous, aggregate basis. While this information will not identify you personally, in some instances these third parties may be able to combine this aggregate information with other data they have about you, or that they receive from third parties, in a manner that allows them to identify you personally.
Where we do share your personal data with third parties, Vestigos takes steps to ensure that they use appropriate safeguards to protect your personal data.
C. Information for Individuals Located in the European Union.
Legal Basis for The Processing of Personal Information from EEA Residents
If you reside within the European Economic Area (EEA), our processing of your personal information will be legitimized as follows:
(i) Whenever we require your consent for the processing of your personal information such processing will be justified pursuant to Article 6(1) lit. (a) of the General Data Protection Regulation (EU) 2016/679 (“GDPR”). This article in the GDPR describes when processing can be done lawfully.
(ii) If the processing of your personal data is necessary for the performance of a contract between you and Vestigos or for taking any pre-contractual steps upon your request, such processing will be based on GDPR Article 6(1) lit. (b).”). If this data is not processed, Vestigos will not be able to execute the contract with you.
(iii) Where the processing is necessary for us to comply with a legal obligation, we will process your information on basis of GDPR Article 6(1) lit. (c), for example complying in the fields of employment law.
(iv) And where the processing is necessary for the purposes of Vestigos’s legitimate interests, such processing will be made in accordance with GDPR Article 6(1) lit. (f), for example to detect fraud.
Transferring Personal Data from the EU to the US:
Vestigos has its headquarters in the UAE. Information we collect from you will be processed in the UAE. The UAE has not sought nor received a finding of “adequacy” from the European Union under Article 45 of the GDPR). A finding of “adequacy” in short means that the European Commission has decided that this country outside the EEA ensures an adequate level of data protection. Vestigos relies on derogations as set forth in Article 49 of the GDPR as the UAE has no “adequacy” decision and no other safeguards under the GDPR are in place (for example binding corporate rules on the transfer outside the EEA). In particular, Vestigos collects and transfers to the UAE personal data only: with your explicit consent; to perform a contract with you; in a manner that does not outweigh your rights and freedoms. If this data is not processed and transferred, Vestigos will not be able to execute the contract with you or you will not have access to any or all of the benefits and features associated with your transaction. Vestigos endeavors to apply suitable safeguards to protect the privacy and security of your personal data and to use it only consistent with your relationship with Vestigos and the practices described in this Privacy Notice. Vestigos also minimizes the risk to your rights and freedoms by not collecting or storing sensitive information about you.
If you wish to confirm that Vestigos is processing your personal data, or to have access to the personal data Vestigos may have about you, please contact us at [email protected]
European Union Data Subject Rights
The European Union’s General Data Protection Regulation and other countries’ privacy laws provide certain rights for data subjects (these are persons that can be identified).
This Privacy Notice is intended to provide you with information about what personal data Vestigos collects about you and how it is used.
If you wish to confirm that Vestigos is processing your personal data, or to have access to the personal data Vestigos may have about you, or have other questions, please contact us via [email protected]
Reasonable access to your personal data will be provided at no cost to Vestigos members, conference attendees and others upon request made to Vestigos at [email protected]. If access cannot be provided within a reasonable time frame, Vestigos will provide you with a date when the information will be provided. If for some reason access is denied, Vestigos will provide an explanation as to why access has been denied.
D. Security of Your Information.
Vestigos uses reasonable physical, technical and administrative measures to safeguard personal information you provide through the Sites or in connection with Vestigos’s products and services. Please be aware that no data transmission over the Internet can be guaranteed to be 100% secure. As a result, Vestigos cannot guarantee or warrant the security of any information you transmit on or through the Sites and you do so at your own risk.
E. Data Storage and Retention.
Your personal data is stored by Vestigos on its servers, and on the servers of the database management services Vestigos engages, located in Asia's GoDaddy servers. Vestigos retains data for the duration of the customer’s or member’s business relationship with Vestigos and otherwise as required under applicable law. Personal data will be kept for no longer than is necessary for the purposes for which your personal data are processed. We will retain your personal data as long as you are an Vestigos member or require our services so that we can provide these services to you.
If you are located in the European Economic Area, at the moment you cancel your Vestigos membership or withdraw your consent for the processing of your personal information, all your personal data received and stored are erased if no longer needed by us. Unless we are required to retain this personal data by law or to comply with our regulatory obligations. In such a case, we will only keep this personal data for as long as necessary. For more information on where and how long your personal data is stored, and for more information on your rights of erasure and portability, please contact our data privacy resource at [email protected].
5. Special Information for California Residents.
If you want to opt-out of Vestigos sharing your information with third parties for their own marketing purposes, you can opt out by contacting [email protected]
Upon receipt, verification and confirmation of your request, Vestigos will process your opt-out and you will receive an email confirming that you have opted-out and that Vestigos stopped using/collecting your personal data as well as deleted it, if the data is no longer required by law.
Section 1798.83 of the California Civil Code requires select businesses to disclose policies relating to the sharing of certain categories of your information with third parties. If you reside in California and have provided your information to Vestigos, you may request information about our disclosures of certain categories of information to third parties for direct marketing purposes. Such requests must be submitted to us via [email protected].
6. How to Contact Vestigos and Modify Your Information or Preferences.
Questions regarding this Privacy Notice should be directed to Vestigos’s data privacy resource: [email protected]. If you would like to modify the types of marketing email messages you receive from Vestigos, you may do so by following the instructions within the body of any email message that you receive from us.
To help us keep your personal information up to date, or to request access to the personal information Vestigos maintains about you, you may go online to your personal profile and update your information in that area.
7. Children
Vestigos is a professional membership association and the Sites are not directed to children under the age of 13. Vestigos does not knowingly collect personally identifiable data from persons under the age of 13 of COPPA (The Children’s Online Privacy Protection Act). If you are a parent of a child under 13, and you believe that your child has provided us with information about him or herself, please contact us at [email protected].
8. Modifications to this Privacy Notice.
From time to time, Vestigos may need to update or modify this Privacy Notice, to reflect changes in our business practices, data collection practices or organization. We reserve the right to amend this Privacy Notice at any time, for any reason, without notice to you, other than the posting of the amended Privacy Notice on the Sites, or, if you have provided your email address to us, sending you an email notifying you of the amended Privacy Notice. It is strongly recommended to check the Site often, referring to the date of the last modification listed at the top. We will in any case not reduce your rights under this Privacy Notice without your explicit and informed consent. If you do not agree to the changes, you should discontinue your use of the Sites, and cease providing personal information to us, prior to the time the modified Privacy Notice takes effect. If you continue using the Sites or provide personal information after the modified Privacy Notice takes effect, you will be bound by the modified Privacy Notice.
9. Questions, Concerns or Complaints
If you have any questions or concerns about this Privacy Notice, please contact Vestigos’s data protection resource at: [email protected].