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VIDINSURANCE PRIVACY POLICY
Effective May 25th 2018

1.  Compliance Certification Programs
VidInsurance is committed to helping our customers support their regulatory compliance requirements. Our Information Security Risk Management Program is built on a solid foundation of widely-accepted frameworks for Information Security and Risk Management, including ISO and NIST. Independent audits from attest to the integrity of our compliance with specific regulatory mandates, including EU-U.S. Privacy Shield Framework, SOC2, and GDPR.

VidInsurance adheres to Fair Information Practice Principles of notice, choice, access, security, and enforcement.

2.  Notice
VidInsurance provides customers and website visitors with notice of our information practices before collecting their Personal Information.

VidInsurance knows that You care about how Your information is used and shared, and takes data privacy seriously. This Privacy Policy describes our current policies and practices with regard to data collected by us and by third parties on our behalf.

VidInsurance connects Clients with individuals who register to use our Website (“Interviewees”) in order to participate in the claims process. The VidInsurance Service facilitates the submission of Interviewees’ Claims (“Claims”), including the online recording of text, audio and video responses to questions selected by Clients along with reference checking. The Service utilizes a number of dynamic products, including, VidClaims as further described on the Website (the “VidInsurance Offerings”).

The term "VidInsurance," when used in this Privacy Policy, means VidInsurance, Inc. and its subsidiaries, divisions, branches, affiliates or companies under the control of VidInsurance, Inc.

This Privacy Policy covers natural persons who visit our websites, users who register on the VidInsurance Platforms, VidInsurance customers, VidInsurance employees, and VidInsurance third-party vendors.

3.  Choice
It is always Your choice whether or not to provide Personal Information. However, if You choose not to provide requested Personal Information, You will not be able to use certain features of the Website, Apps and/or Services. We collect the following information about You and Your use of our Website, Apps and/or Services in order to provide You the Services and to create a better, more personalized experience for You:

• Your email address, Your name, Your log in information (including a password selected by You), Your physical address, Your phone number, Your postal or zip code; and

• If You are a Client You may choose to add details of Your or Your company’s history and insurance claims practices to Your profile which You can make available to all Interviewees.

• If You are an interviewee, any content that You provide to us about You.

4.  Access
Upon request, VidInsurance will provide You with information about whether we hold any of Your Personal Information. VidInsurance enables customers and website visitors with the ability to access and correct Personal Information we have collected. If You have any concerns or suspect unauthorized activities associated with Your account, please contact us at security(@) vidinsurance.com. We will respond to Your request within a reasonable timeframe.

VidInsurance acknowledges that You have the right to access, update, revoke permission to process, or request the deletion of Your Personal Information. Any such query can be directed to VidInsurance’s Data Protection Officer at dpo(@) vidinsurance.com. If requested to remove data under either scenario, we will respond within a reasonable timeframe.

5.  Security
The security of Your Personal Information is important to us. We use commercially reasonable efforts to ensure that Your Personal Information is stored and maintained in a secure environment. VidInsurance exercises managerial and technical safeguards designed to protect against the loss or unauthorized use or disclosure of Personal Information belonging to our customers and website visitors. These safeguards include: encryption, malware protection, logical and physical access controls, and detection of social engineering attacks.

It is our customer’s responsibility to ensure authorized access to Personal Information by selecting and protecting Your password appropriately and limiting access to Your VidInsurance resources.

6.  Enforcement
VidInsurance monitors and reviews security safeguards and takes corrective action whenever we discover deviations from our Privacy Policy.

7.  Data Classifications
Personal Data means any information relating to an identified or identifiable natural person.

Sensitive Personal Data is Personal Data comprised of an individual's financial account number, social security number, driver's license number or other government-issued identification number, financial account password or PIN, mother's maiden name, answers to security questions, or other Personal Data that allows access to financial accounts, or that can be used to facilitate identity theft, as well as any other special category of Personal Data such as biometric, genetic or health data, data concerning sex life or sexual orientation, racial or ethnic origin, data concerning a person’s political opinions, religious beliefs, membership in trade unions or criminal history.

Confidential Data is any proprietary data which is not in the public domain, and/or, data which is controlled by its owner and requires explicit permission to access, store, process, or transfer.

End User Data is data provided by End Users in connection with the VidInsurance Services.

Customer Data is data provided by Customers to VidInsurance in connection with the VidInsurance Services. Customer Data may be Personal Data, Sensitive Personal Data, End User Data or Confidential Data. Agreements between VidInsurance and VidInsurance customers specify how Customer Data and End User Data is processed, transferred, and stored.

With respect to data protection legislation, VidInsurance may be a Data Controller or a Data Processor. VidInsurance is a Data Controller with respect to data provided by website visitors and, customer contact and billing information, and VidInsurance employees.

8.  Collection of Data
VidInsurance groups all user data into 3 main categories for the purposes of informing on the use, retention periods and user configurable options available.
  • Part A: Visitors to our website
  • Part B: Customers of VidInsurance
  • Part C: Interviewees in the VidInsurance Platform
Specific details about each are listed below, which is followed by additional explanatory information on collection practices and data transfers.

8.1.  Part A - Website Visitors

Data we collect about website visitors: what, where, when, and why
​
What      Web log data (IP addresses, cookies)
Where    VidInsurance Public Website
When     You visit
Why        To provide, maintain, tailor and improve our website and service

What      Information You submit through web forms, buttons, hyperlinks, etc.
Where   Social media sites (Facebook, LinkedIn, etc)
When    You visit
Why       Claims search, follower updates, etc.

What     Demographic marketing information
Where  Received from third parties
When   Verifying accuracy of data provided
Why      To enable us to provide a personalized service to You.

Data retention periods for website visitor information

What                           Web log data (IP addresses, cookies)
Where                         Server logs
Retention Period     7 days

What                            Information You submit through web forms, buttons, hyperlinks, etc.
Where                         Social media sites
Retention Period     6 years

What                            Demographic marketing information
What                          Aggregated in the VidInsurance analytics infrastructure used for analyzing and improving marketing campaigns.
Where                         Analytics data repository
Retention Period     Indefinitely

User-Configurable Options for Processing Personal Data

Options for managing Your Personal Information

Marketing Communications: Removal from all communications
Unsubscribe(@) vidinsurance.com

Removal of Personal Information:
Request to be forgotten **

Dpo(@) vidinsurance.com

Filing a Complaint: Complaints about our Privacy Policy or non-resolved privacy issues
Security(@) vidinsurance.com

** VidInsurance is required to maintain records of consent and requests for correcting or deleting Personal Information for 6 years.

8.2.  Part B - Customers of VidInsurance
Data we collect about customers: what, where, when, and why

What     First and Last Name, Postal Address, Email Address, Telephone Number and Payment Type
Where   Dashboard
When    You purchase products or services
Why       To verify Your identity for protection of VidInsurance staff, customers, website visitors, or the public as required or permitted by applicable law.

What     Technical information You submit through forms, email, etc.
Where   VidInsurance Support Forum, VidInsurance Developer Blog, GitHub Pull Requests
When    You explicitly give permission by posting Your content
Why       To assist You in being more productive with VidInsurance

What      Service Notifications
Where   Email or Dashboard
When    We update Your purchased products and services
Why       To inform You about service updates and faults, request feedback or participation in online surveys, and to publish legal notices, such as this Privacy Policy

Data retention periods for customer information
What                         All data submitted voluntarily associated with customer account, such as: name, email address, physical address, phone number
Where                       Dashboard
Retention Period   3 months after account termination

What                         Dashboard access log entries, such as: password, date, time, User ID, URL and source IP address - Logging of administrative changes to an account with VidInsurance will be stored for security purposes. This includes: company name, address, phone number, billing and tax related records
Where                       Dashboard
Retention Period   3 years after account termination

What                          IP addresses           
Where                       Server logs              
Retention Period   3 years

What                          Operational metrics - Aggregated in the VidInsurance Analytics infrastructure used for analyzing and improving operational health
Where                       Analytics data repository             
Retention Period   Indefinitely
 
What                         
Platform access - Entries will be maintained, containing date, time, operation performed (connect, publish, etc).
Where                       Server Security Audit Logs            
Retention Period   3 years

User-Configurable Options for Processing or Sharing Personal Data
Reasons to share Your Personal Information

Customer Notifications:
We may receive correspondence from You in connections with our Website and our services, including questions You may have about this Privacy Policy, customer support interactions or other matters.
Support(@) vidinsurance.com
VidInsurance Platform Notifications:
You may receive correspondence from us in connections with our Website and our services, including scheduled maintenance, changes to our Privacy Policy or Terms of Service, or security-related notifications.
Dashboard

Options for managing Your Personal Information

Marketing Communications: Removal from all communications
unsubscribe(@) vidinsurance.com
Correcting customer account information:
Dashboard or Support(@) vidinsurance.com
Terminating Your VidInsurance Account:
Support(@) vidinsurance.com

8.3.  Part C - Interviewees in the VidInsurance Platform

Data we collect about customers: what, where, when, and why
What    First and Last Name, Postal Address, Email Address, Telephone Number and any other information You provide as part of the application process
Where  Application Process
When   You purchase products or services
Why      To verify Your identity for protection of VidInsurance staff, customers, website visitors, or the public as required or permitted by applicable law.

What    Technical information You submit through forms, email, etc.
Where  VidInsurance Support Forum, VidInsurance Developer Blog, GitHub Pull Requests
When    You explicitly give permission by posting Your content
Why      To assist You in being more productive with VidInsurance

What     Service Notifications
Where  Email or Dashboard
When    We update Your purchased products and services
Why       To inform You about service updates and faults, request feedback or participation in online surveys, and to publish legal notices, such as this Privacy Policy

Data retention periods for customer information
What                        All data submitted voluntarily associated with an interviewee process, such as: name, email address, physical address, phone number
Where                      Dashboard
Retention Period  3 months after the position You have applied to has been closed

What                         IP addresses
Where                      Server logs
Retention Period  3 years

What                         Operational metrics - Aggregated in the VidInsurance Analytics infrastructure used for analyzing and improving operational health
Where                       Analytics data repository
Retention Period   Indefinitely

What                         Platform access - Entries will be maintained, containing date, time, operation performed (connect, publish, etc).
Where                       Server Security Audit Logs
Retention Period   3 years

User-Configurable Options for Processing or Sharing Personal Data
Options for managing Your Personal Information

Removal of Personal Information:
Request to be forgotten **
Dpo(@) vidinsurance.com
Filing a Complaint: Complaints about our Privacy Policy or non-resolved privacy issues
Security(@) vidinsurance.com

** VidInsurance is required to maintain records of consent and requests for correcting or deleting Personal Information for 6 years.

9.  Collection of Personal Data Through Social Media
Our Website includes hyperlinks to other websites including Social Media sites, such as Facebook, and interactive, third-party widgets we host on our Website. These features may collect information You submit voluntarily, or may set a cookie to enable functionality. VidInsurance is responsible for assuring its third-party vendors comply with our Privacy Policy and honor commitments to restrict information collection and usage exclusively for our stated purposes.

10.  Online Collection of Additional Data
As You navigate through and interact with our Website and Services, we may use automatic data collection technologies to collect certain information about Your equipment, browsing actions and patterns, location, and workplace usage patterns, including:

• Details of Your visits to our Website or App and other communication data and the resources that You access and use on the Site or App.

• Information about Your computer and Internet connection, including Your IP address, operating system, and browser type.

• We also may use these technologies to collect information about Your online activities over time and across third-party websites or other online services (behavioral tracking).

• When You access and use the App, we may automatically collect certain details of Your access to and use of the App, including traffic data, location data, and other communication data and the resources that You access and use on or through the App.

• We may collect information about Your mobile device and Internet connection, including the device’s unique device identifier, IP address, operating system, browser type, mobile network information and the device’s telephone number.

• Our App collects real-time information about the location of Your device.

We and our third-party service providers may collect information about You in a variety of ways. We and/or our third-party partners may employ various tracking technologies, such as cookies, web beacons and analytics software, that help us better manage content on our Service by informing us what content is effective.

10.1.  Advertising
We may partner with third-party data or ad network(s) and other service providers to show You relevant ads, including ads displayed on the Service and on other companies’ websites or apps, on any of Your devices. We and our service providers may use cookies and web beacons to deploy and read cookie identifiers and Mobile Ad IDs, associated with Your activities on the Service, third-party websites, mobile apps, or other information we collect, to provide You targeted advertising based upon Your interests. They may also use these technologies, along with activity information they collect, to recognize You across the devices You use, such as a mobile device and a laptop or other computer. These ad networks and their customers may also use any of this information to measure ad performance, understand their (or our) audience, or otherwise improve and enhance their marketing.

Similarly, we or a third-party data partner may associate cookies with hashed (non-human readable) versions of Your registration data (e.g., Your email address), along with other interest-based or demographic data. You can learn more about or opt out of this type of advertising through the links in the following paragraph.

10.2.  Mobile Opt-Out
You can opt out of having Your Mobile Ad IDs used for interest-based mobile advertising by accessing the settings on Your Apple or Android mobile device, as follows:

• Apple Devices: If You have an Apple device, You can opt out of most cross-app advertising by updating to iOS 6.0 or higher and setting Limit Ad Tracking to ‘ON.’ You can do this by clicking on Settings > General > About > Advertising, and toggling Limit Ad Tracking to ‘ON.’

• Android Devices: If You have an Android device, You can opt out of most cross-app advertising by clicking on Google Settings > Ads, and selecting the option to opt-out of interest-based ads.

Please note that these platforms control how these settings work, so the above instructions may change. Likewise, if Your device uses other platforms not described above, please check the settings for those devices.

10.3.  Web-Based Opt-Out
If You wish to opt-out of many of the ad platforms that serve or support interest-based advertising (or learn more about this type of advertising), go to http://www.networkadvertising.org/managing/opt_out.asp, http://www.aboutads.info/choices and http://preferences-mgr.truste.com/ to opt out in desktop and mobile web browsers. You may download the AppChoices app at www.aboutads.info/appchoices to opt out in mobile apps. For individuals in the EU, please also visit http://www.youronlinechoices.eu/. Please note that opting out does not opt You out of being served advertising. You will continue to receive generic ads.

10.4.  Cookies
When You visit our website or otherwise interact with the Service we (or third-party data or ad networks we work with) may send one or more “cookies” to Your computer or other devices. Cookies are alphanumeric identifiers stored on Your computer through Your web browser and are used by most websites to help personalize Your web experience. Some cookies may facilitate additional site features for enhanced performance and functionality such as remembering preferences, allowing social interactions, analyzing usage for site optimization, providing custom content, allowing third parties to provide social sharing tools, and serving images or videos from third-party websites. Some features on this site will not function if You do not allow cookies. We may link the information we store in cookies to any Personal Information You submit while on our site.

We may use both session ID cookies and persistent cookies. A session ID cookie expires when You close Your browser. A persistent cookie remains on Your hard drive for an extended period of time. Persistent cookies enable us to track and target the interest of our users to enhance the experience on our site. If You do not want information collected through the use of cookies, there is a simple procedure in most browsers that allows You to automatically decline cookies, or be given the choice of declining or accepting the transfer to Your computer of a particular cookie (or cookies) from a particular site. You may also wish to refer to http://www.allaboutcookies.org/manage-cookies/index.html. If You reject cookies, You may still use our site, but some features on the site will not function properly.

Functional cookies, persistent and session type, store information to enable core site functionality.

Analytics cookies allow us to count page visits and traffic sources, so we can measure and improve the performance of our site and our marketing campaigns.

Advertising cookies may be set through our website by our advertising partners. Data may be collected by these companies that enable them to serve up advertisements on other sites that are relevant to Your interests.

10.5.  Web Beacons
We (or third-party data or ad networks we work with) may use Web Beacons alone or in conjunction with cookies to compile information about our Service, or other information we or they have collected. Web Beacons are tiny graphic objects that are embedded in a web page or email and are usually invisible to the user but allow checking that a user has viewed the page or email. Web Beacons may be used within the Service to track email open rates, web page visits or form submissions. In some cases, we tie the information gathered by Web Beacons to our Users’ Personal Information. For example, we use clear gifs in our HTML-based emails to let us know which emails have been opened by recipients. This allows us to gauge the effectiveness of certain communications and the effectiveness of our marketing campaigns.

10.6.  Flash and HTML5 Storage
We use Local Shared Objects, such as Flash cookies, AND/OR Local Storage, such as HTML5, to store content information and preferences. Third parties with whom we partner to provide certain features on our website or to display advertising based upon Your web browsing activity also use Flash cookies or HTML5 to collect and store information. Various browsers may offer their own management tools for removing HTML5.

10.7.  Do Not Track Signals
At this time, we do not respond to browser ‘do not track’ signals.

10.8.  How We Use Your Information
We use information that we collect about You or that You provide to us, including any Personal Information:

• If You are an Interviewee, to communicate information about You and Your Applications to Clients; this information may identify You personally and You should consult with the Owner about their collection and use of Your Personal Information through the Service;

• To provide the Services and its contents to You, other Interviewees and Clients.

• To provide You with information, products, or services that You request from us.

• To fulfill any other purpose for which You provide it.

• To provide You with notices about Your account/subscription, including expiration, and renewal notices.

• To carry out our obligations and enforce our rights arising from any contracts entered into between You and us, including for billing and collection.

• To notify You about changes to our Website, Service or App or any products or services we offer or provide though it.

• To allow You to participate in interactive features on our Site or App.

• In any other way we may describe when You provide the information.

• For any other purpose with Your consent.

We may also use the information we have collected from You to enable us to display advertisements to our advertisers’ target audiences. Even though we do not disclose Your Personal Information for these purposes without Your consent, if You click on or otherwise interact with an advertisement, the advertiser may assume that You meet its target criteria and may combine Your information with other profile data it has obtained from other sources.

10.9.  Disclosure of Your Information
We may disclose aggregated information about our users without restriction.

We may disclose Personal Information that we collect, or You provide as described in this Privacy Policy:

• If You are an Interviewee to Clients where You have begun the Claims process with or through those Clients;

• To our subsidiaries and affiliates.

• To contractors, service providers, and other third parties we use to support our business solely for the purpose of them providing services to us.

• To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of VidInsurance’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by VidInsurance about our Site or App users is among the assets transferred.

• To fulfill the purpose for which You provide it.

• For any other purpose disclosed by us when You provide the information.

• With Your express consent to other uses not indicated in this Privacy Policy.

We may also disclose Your Personal Information:

• To comply with any court order, law or legal process, including to respond to any government or regulatory request.

• To enforce or apply our terms of service www.vidinsurance.com/tou and other agreements, including for billing and collection purposes.

• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of VidInsurance, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

10.11.  Shareable Profile Link Service
The service called the “Shareable Profile Link Service” is a tool which enables anyone who has the link access to the content at the link (which may include by way of example complete details of an interviewee, including their Personally Identifiable Information) without inputting a password. Clients may elect to share Interviewee’s Personal Information through the Shareable Profile Link Service. VidInsurance hereby disclaims any and all responsibility for any use by a Client of the Shareable Profile Link Service, and any disclosure of any Personal Information as a result of the use of the Shareable Profile Link Service shall be the sole responsibility of the user using that service. You agree to hold VidInsurance harmless from any inadvertent disclosure of Your Personal Information as a result of any Client using such Shareable Profile Link Service. Clients must request the password protection to be turned off in which case they are liable for any such infractions.

11.  Collection of Personal Data About Other People
It is our customer’s and interviewees responsibility to obtain the EXPRESS CONSENT of individual Data Subjects (for example, Your Family Members, Co-Workers, or Customers) to transfer their Personal Data to VidInsurance as a Data Processor and/or Data Importer. VidInsurance processes all such information in accordance with the terms of our Data Processing Agreements, applicable law and/or this Privacy Policy.

12.  Transfers of Data
VidInsurance’s headquarters in Canada is our primary location for business operations. In addition, VidInsurance maintains a presence in the in the United Kingdom, European Union, Australia and the Philippines. Servers hosting the VidInsurance platform are located in the United States, EU, Canada, and Australia.

In order to provide You with the information, products, or services You have requested, Personal Data may be transferred or shared with other companies within our family of companies, including those third-party vendors who act on our behalf, process Personal Data in accordance with the purposes for which the data was originally collected, or for purposes to which Data Subjects have subsequently consented. Our Privacy Policy, supported by model contract agreements and safeguards for data governance, are designed to provide equivalent data protection for all customers wherever they may reside.

For example, regarding normal business operations, VidInsurance may engage a third-party to support our billing, support services, information technology, or mailings on our behalf.

We may also disclose Your Personal Information as required by law, such as to comply with a subpoena or other legal process, when we believe in good faith that disclosure is necessary to protect our rights, protect Your safety, or the safety of others, investigate fraud, or respond to a government request.

13.  Outside Parties and Sites
Through us, You may be introduced to a variety of Interviewees, Clients, third-party vendors and/or websites. The privacy policies of these third parties are not under our control and may differ from ours. The use of any information that You may provide to any third-party, or the use of “cookie” technology by any third-party, will be governed by the privacy policy of the operator of the website that You are visiting. If You have any doubts about the privacy of the information You are providing on another website, we recommend that You contact that website directly for more information and review its privacy policy. To properly process online orders, You may be directed to a third-party credit card processing or other payment processing website. The privacy policies of these third parties are not under our control and may differ from ours. If You have any doubts about the privacy of the information You are providing on another website, we recommend that You contact that website directly for more information and review its privacy policy.

14.  Additional Privacy Protections for Minors
We join the industry in recognizing that children, including young teens, may not be able to make informed choices about Personal Information requested online. VidInsurance does not solicit or collect Personal Information targeted at those under the age of eighteen. VidInsurance’s Terms of Use (TOU) does not permit the use of the Website, Apps and/or Services by users under the age of eighteen.

15.  Data Retention
VidInsurance will keep Your Personal Information for as long as it remains necessary for the identified purposes in Section 8 or as required by law, which may extend beyond the termination of our relationship with You. You acknowledge and agree that if You request that Your name be removed from our databases, it may not be possible to completely delete all Your Personal Information due to legal constraints.

15.1.  RESIDENTS OF THE EUROPEAN ECONOMIC AREA (EEA)
VidInsurance generally processes Personal Information in order to fulfill contracts we have with our customers and end users and to pursue our legitimate business interests listed above. Otherwise, VidInsurance will obtain consent from an individual in respect of processing of Personal Information if required by law to do so.

Further, individuals located in the EEA have certain rights under European law (including under the General Data Protection Regulation) with respect to Personal Information, including the right to request access to, obtain, correct, amend, delete, or limit the use of your personal data. Individual end users, customers or prospective customers located in to the EEA who wish to exercise these rights, should contact VidInsurance using the contact information below in Section 17. If we are processing your information on behalf of a third party then you should contact that party directly because VidInsurance serves as a data processor on behalf of third party in that instance, and can only forward your request to the buyer to allow them to respond. Individuals also have the right to make complaints to regulatory authorities in respect of our privacy practices.

16.  Changes to this Privacy Policy
VidInsurance may make changes to this Privacy Policy from time to time for any reason. Use of information we collect now is subject to the Privacy Policy in effect at the time such information is used. If we make any material changes or changes in the way we use information, we will notify customers via e-mail or by posting an announcement on the Website prior to the change becoming effective. Website users are bound by any changes to the Privacy Policy after such changes have been posted.

In the event that VidInsurance is involved in a merger, acquisition or asset sale, we will continue to ensure the confidentiality of any Personal Information and give affected users notice before Personal Information is transferred or becomes subject to a different privacy policy. Account holders will be notified via email and/or a prominent notice on our Website of any change in ownership or uses of Your information, as well as any choices You may have regarding Your information.

17.  VidCruiter Head-Quarters
VidInsurance Inc.
100 Cameron St., Suite 4000
Moncton, NB E1C 5Y6
Info(@) vidinsurance.com

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