Privacy Policy

Last Updated: March 2024

Introduction

Valente Sherman Inc. dba VISO TRUST, a Delaware corporation (collectively referred to herein as “VISO TRUST”, “we”, “our” or “us”), recognizes the importance of protecting the personal information we collect from our users (“Users”, “you”, or “your”) who visit our website, www.visotrust.com (the “Website”), utilize our platform or otherwise interact with us. This Privacy Policy applies to data collection by VISO TRUST and shall apply to your use of the Website and other applications including app.visotrust.com, and software, communications, capabilities, and Services (“Services”) offered by us.

By using the Services, you signify your acceptance of this Privacy Policy. If you do not agree to this Privacy Policy, please do not use the Services.

Regardless of which country you live in, by accessing our Website or using our Services, you authorize us to transfer, store, and use your information in the United States, and any other country where we operate. In some of these countries, the privacy and data protection laws and rules regarding when government authorities may access data may vary from those in the country where you live. If you do not agree to the transfer, storage, and use of your information in the United States and any other country where we operate, please do not access our Website or use our Services.

If you have any questions or comments about this Privacy Policy, please contact us at [email protected].

Information We Collect

We collect information, including Personal Data, to provide better Services to all our Users. We use the term “Personal Data” to refer to any information that identifies or can be used to identify you.

When you access our Website or use our Services, we collect Personal Data in the following ways:

1. Information You Give to Us

1. Website
  You may choose to provide us with Personal Data about yourself, including your name, organization name, title, address, phone number, and email address by completing forms on our website, such as when you request information about our Services or register. In some instances, you may elect to provide us with location and address information. You may also provide us with Personal Data about yourself when you report a problem or have a question about our Services.
2. Email Communications
  By providing an email address on the VISO TRUST Services, you agree that we may contact you in the event of a change in this Privacy Policy, to provide you with any Service-related notices, or to provide you with information about our events, invitations, or related educational information.

2. Information We Obtain from Your Use of Our Services

We collect certain information automatically, such as your operating system version, browser type, and internet Service provider. We also collect information about your interaction with the Services, such as creating or logging into your account, or opening or interacting with the Services on your mobile device. When you use our Service, we automatically collect and store this information in Service logs. This includes: details of how you used our Service; Internet protocol address; cookies that uniquely identify your browser, the referring web page, and pages visited. We may also collect and process information about your actual location. The information we collect automatically is statistical data and may or may not include Personal Data, but we may maintain it or associate it with Personal Data we collect in other ways or receive from third parties.

1. 1. Location Data
    If you grant us access to your location, VISO TRUST may collect information about your location when you use our Services. When you use our Services via a wireless device, we may solicit your permission to collect your location data. Some features within our application may only function upon confirmation of your location, and therefore such features will not be available if you choose not to provide your location data to us. If you enable location Services for our Applications, we may collect location data periodically as you use or leave open our Application. We may associate such location data with the Personal Data you provide to us. Depending on the platform you use to access our Applications (e.g., Apple’s iOS, Google’s Android), you may be able to control whether location data is collected from within “Settings” or other controls on your wireless device or the Applications.
  2. Device ID
    When using our Services, we or our Service provider may collect your unique device ID. We may use such information for internal purposes and to provide you a better experience, such as to troubleshoot application problems you may experience. We may associate the device ID with the Personal Data you provide to us. You may learn more about opting out of any anonymous device ID collection via the privacy settings available within your mobile device.

3. Social Networking

When using our Services or when using certain third-party social networking Services (for example, Facebook or Twitter) (each a “Social Network”), you may have the option to connect your VISO TRUST information with that Social Network (and its users). Information we may share with a Social Network may include but is not limited to, technical information about your VISO TRUST activity. Information we may access about you, with your consent, from a Social Network, may include, but is not limited to, your basic Social Network information, your location data, your lists of contacts, friends, and followers, and certain information about your activities on the Social Network. If you permit a connection between a Social Network and VISO TRUST, we and that Social Network may be able to identify you and associate information received pursuant to that connection with information we already have about you. We recommend that you familiarize yourself with the privacy policy and privacy control options of any Social Network with which you choose to share information or to connect to the Services.

4. Cookies and Similar Technologies

We use various technologies to collect and store information when you use the Services, including the use of cookies or similar technologies to identify your browser or device. We also use these technologies to collect and store information when you interact with Services from our partners, such as advertising Services. Our third-party advertising and analytics partners include Google, Lead Forensics and similar partners. The technologies we use for this automatic data collection may include:

1. Cookies
  A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate settings on your browser. However, if you select this setting you may be unable to access certain parts of our Services. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Services.
2. Web Beacons
  Pages of our Services or our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us, for example, to count users who have visited those pages or opened an e-mail and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
3. Clickstream Data
  Clickstream data is information collected by our computers when you request Web pages from the Services. Clickstream data may include information such as the page served, the time spent viewing the page, the source of the request, the type of browser making the request, the preceding page viewed, and similar information. Clickstream data permits us to analyze how visitors arrive at the Services, what type of content is popular, and what type of visitors in the aggregate are interested in particular kinds of content on the Services.

5. Network Advertisers

Third party companies that manage and deliver advertisements to websites and applications are commonly referred to as “network advertisers.” A permitted network advertiser may use cookies, web beacons, or similar technologies to collect information about your interaction with the Services or to tailor certain advertisements and content delivered within the Services or on other websites within such network advertiser’s ad network. These companies may also use non-cookie technologies to recognize your computer or device and/or to collect and record information about your web activity including your activities on or off of the Services. Please keep in mind that your web browser may not permit you to block the use of these non-cookie technologies, and those browser settings that block cookies may have no effect on such techniques.

6. Other Advertising
We share certain data with Social Networks to allow us to target existing users and customers with highly relevant advertising campaigns. We will not share your name, address, email address, telephone number, or other Personal Data for the purpose of such campaigns. In addition to advertisements for our own Services, we may facilitate third parties to advertise their own goods or Services including through targeting those advertisements to those that might be most interested in them. If you would prefer that we not share your information with third parties for their own marketing purposes, please contact [email protected].

Our Legal Basis for Collecting Personal Data

Whenever we collect Personal Data from you, we may do so on the following legal bases:

Your consent to such collection and use;
Out of necessity for the performance of an agreement between us and you, such as your agreement to use our Services or your request for Products;
Our legitimate business interest, including but not limited to the following circumstances where collecting or using Personal Data is necessary for:
- Intra-organization transfers for Partner data for administrative purposes;
- Product development and enhancement, where the processing enables VISO TRUST to enhance, modify, personalize, or otherwise improve our Services and communications for the benefit of our users, and to better understand how people interact with our Services;
- Communications and marketing, including processing data for direct marketing purposes, and subject to your opt-in for these purposes, and to determine the effectiveness of our promotional campaigns and advertising;
- Fraud detection and prevention;
- Enhancement of our cybersecurity, including improving the security of our network and information systems; and
- General business operations and diligence.

Provided that, in each circumstance, we will weigh the necessity of our processing for the purpose against your privacy and confidentiality interests, including taking into account your reasonable expectations, the impact of processing, and any safeguards that are or could be put in place. In all circumstances, we will limit such processing for our legitimate business interest to what is necessary for its purposes.

Your Failure to Provide Personal Data

Your provision of Personal Data is required in order to use certain parts of our Services and our programs. If you fail to provide such Personal Data, you may not be able to access and use our Services and/or our programs, or parts of our Services and/or our programs.

How We Use Information We Collect

We use your Personal Data in ways that are compatible with the purposes for which it was collected or authorized by you, including for the following purposes:

To present, operate, or improve the Service, including analysis of Service activity;
To inform you about Services and products available from VISO TRUST;
To authorize access to our Services;
To provide, maintain, administer, or expand the Services, performing business analyses, or for other internal purposes to support, improve or enhance our business, and other products and Services we offer;
To personalize the Services to your goals;
To customize or tailor your experience of the Services, which may include sending customized messages;
To administer content, promotion, sweepstakes, surveys, voting polls or other Service features;
To communicate about, and administer your participation in, special programs, surveys, contests, online campaigns, online programs, sweepstakes, and other offers or promotions, and to deliver pertinent emails;
To improve our Service;
To secure our Services, including to authenticate Users;
To use statistical information that we collect in any way permitted by law, including from third parties in connection with their commercial and marketing efforts;
To respond to and support users regarding their use of the Services;
To comply with all applicable legal requirements;
To enforce our Terms and Conditions and other agreements;
To perform data analysis and testing;
To investigate possible fraud or other violations of our Terms of Use or this Privacy Policy and/or attempts to harm our Users;
To resolve disputes;
To otherwise fulfill the purpose for which the information was provided;

We will ask for your consent before using information for a purpose other than those set out in this Privacy Policy.

Information We Share

We do not sell Personal Data; however, we may share Personal Data with companies, organizations, and individuals outside of the Organization when one of the following circumstances applies:

With your consent. We will share Personal Data with companies, organizations, or individuals outside of VISO TRUST when we have your consent to do so.
For external processing. We provide Personal Data to our affiliates or other trusted businesses or partners to process it for us, based on our instructions and in compliance with our Privacy Policy and any other appropriate confidentiality and security measures. These third parties include payment processors, such as financial institutions and their vendors and contractors that process transactions, marketing partners, and similar partners. It is our policy to only share Personal Data with contractors, Service providers, and other third parties who are bound by contractual obligations to keep Personal Data confidential and use it only for the purposes for which we disclose it to them. Under certain circumstances, you may avoid having us share your information with our business partners and vendors by not granting us permission to share your information. Not granting us permission to share your information with our business partners or vendors may limit your access to their Services through the Services.
For Legal Reasons. We will share Personal Data with companies, organizations, or individuals outside of VISO TRUST if we have a good-faith belief that access, use, preservation, or disclosure of the information is reasonably necessary to:
- meet any applicable law, regulation, legal process, or enforceable governmental request.
- enforce applicable Terms of Use, including investigation of potential violations.
- detect, prevent, or otherwise address fraud, security, or technical issues.
- protect against harm to the rights, property, or safety of VISO TRUST, our Users, or the public as required or permitted by law.
We attempt to notify Users about legal demands for their Personal Data when appropriate in our judgment, unless prohibited by law or court order or when the request is an emergency. We may dispute such demands when we believe, in our discretion, that the requests are overbroad, vague, or lack proper authority, but we do not promise to challenge every demand.
Business Transfers. If we establish a new related entity, are acquired by or merged with another organization, or if substantially all of our assets are transferred to another organization, Personal Data about our users is often a transferred business asset. In the event that VISO TRUST itself or substantially all of our assets are acquired, Personal Data about our users may be one of the transferred assets.
Non-Personal and Aggregate Service Use Information. VISO TRUST may compile and share your information in aggregated form (i.e., in a manner that would not personally identify you) or in de-identified form so that it cannot reasonably be used to identify an individual (“De-Identified Information”). We may disclose such De-Identified Information publicly and to third parties, for example, in public reports about exercise and activity, or to VISO TRUST Partners under agreement with us. VISO TRUST may also disclose De-Identified Information for general research purposes and in research collaborations with third parties, such as universities, hospitals or other laboratories to determine the prevalence of particular conditions among Users or to determine whether a User might be suitable for research or clinical trials. VISO TRUST may also use De-Identified Information for commercial collaborations with private companies for purposes such as product design or enhancement of Services.

Our Retention of Your Personal Data

We will retain your Personal Data only for as long as is required to fulfill the purposes for which it was collected, including to provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with any legal, regulatory, accounting or reporting requirements, unless otherwise permitted by law.

Your Rights and Choices

Depending upon where you reside, certain choices and rights may be available to you under applicable data protection laws. If you have questions about what rights may apply to you, please contact us.

For California Residents:

Do Not Track: Our websites are not designed to respond to “do not track” requests from browsers.

“Shine the Light” and “Eraser” Laws: Residents of the State of California may request a list of all third parties to which we have disclosed certain information during the preceding year for those third parties’ direct marketing purposes.

California Consumer Privacy Act (CCPA)/California Privacy Rights Act (CPRA): The CCPA, as amended by the CPRA, provides California residents and/or their authorized agents with specific rights regarding the collection and storage of their Personal Data.

Your Right to Know: California residents have the right to request that we disclose the following information to you about our collection and use of your Personal Data over the past twelve (12) months. We may ask you to provide certain information to identify yourself so that we may compare it with our records in order to verify your request. Upon verification, we will disclose to you:

The categories of Personal Data we have collected about you.
The categories of sources for the Personal Data we have collected about you.
The specific pieces of Personal Data we have collected about you.
Our business or commercial purpose for collecting or selling your Personal Data.
The categories of third parties to whom we have sold or shared your Personal Data, if any, and the categories of Personal Data that we have shared with each third-party recipient.

Your Right to Opt-Out of Sale or Sharing of Personal Data: Under the CCPA, as amended by the CPRA, California residents have the right to opt-out of the sale of their Personal Data and/or the sharing of Personal Data with third parties for the purposes of cross-contextual behavioral advertising or profiling by submitting a request. Please note that we do not sell Personal Data, including the Personal Data of any individuals under the age of 16, nor do we share any Personal Data for the purposes of cross-contextual behavioral advertising.

Your Right to Limit Use of Sensitive Personal Data: California residents have the right to request that we limit our use of any sensitive Personal Data to those uses, which are necessary to perform the Services or for other business purposes under the CCPA, as amended by the CPRA.

Your Right to Delete: California residents have the right to request that we delete any of the Personal Data collected from you and retained by us, subject to certain exceptions. We may ask you to provide certain information to identify yourself so that we may compare it with our records in order to verify your request. Once your request is verified and we have determined that we are required to delete the requested Personal Data in accordance with the CCPA, as amended by the CPRA, we will delete, and direct our third-party service providers to delete, your Personal Data from their records. Your request to delete the Personal Data that we have collected may be denied if we conclude it is necessary for us to retain such Personal Data under one or more of the exceptions listed in the CCPA, as amended by the CPRA.

Your Right to Correct: Under the CCPA, as amended by the CPRA, California residents have the right to request that we correct any inaccurate Personal Data we maintain about you, taking into account the nature of the Personal Data and the purposes for which we are processing such Personal Data. We will use commercially reasonable efforts to correct such inaccurate Personal Data about you.

Non-Discrimination: You will not receive any discriminatory treatment by us for the exercise of your privacy rights conferred by the CCPA, as amended by the CPRA.

For Individuals Located in the European Economic Area (EEA), the United Kingdom (UK) or Switzerland:

You have a number of rights under applicable data protection laws in relation to your personal data. Under certain circumstances, you have the right to:

Have access to your Personal Data by submitting a request to us;
Have your Personal Data deleted;
Have your Personal Data corrected if it is wrong;
Have the processing of your Personal Data restricted;
Object to further processing of your Personal Data, including to object to marketing from us;
Make a data portability request;
Withdraw any consent you have provided to us;
Restrict any automatic processing of your Personal Data; and
Complain to the appropriate Supervisory Authority.

Verifying Your Request: Only you, or a person that you authorize to act on your behalf, may make a request related to your Personal Data. In the case of access and deletion, your request must be verifiable before we can fulfill such request. Verifying your request will require you to provide sufficient information for us to reasonably verify that you are the person about whom we collected Personal Data or a person authorized to act on your behalf. We will only use the Personal Data that you have provided in a verifiable request in order to verify your request. We cannot respond to your request or provide you with Personal Data if we cannot verify your identity or authority. Please note that we may charge a reasonable fee or refuse to act on a request if such request is excessive, repetitive, or manifestly unfounded.

Third Party Links

We may provide links to other sites or resources provided by third parties. These links are provided for your convenience only. We have no control over the contents of those sites or resources and accept no responsibility for them or for any loss or damage that may arise from your use of them. If you decide to access any of the third-party links via our Websites and/or Services, you do so entirely at your own risk and subject to the terms and conditions of those sites.

International Transfer

We are committed to complying with applicable laws, regulations and mandatory government standards regarding the protection of Personal Data. Countries where we process data, may have laws that are different, and potentially not as protective, as the laws of your own country. If we transfer your Personal Data out of your jurisdiction, we will implement suitable safeguards and rely on legally provided mechanisms to lawfully transfer data across borders to ensure that your Personal Data is protected.

How We Protect Personal Data

VISO TRUST maintains administrative, technical, and physical safeguards designed to protect Personal Data and information against accidental, unlawful, or unauthorized destruction, loss, alteration, access, disclosure, or use. We implement appropriate technical and organizational measures to ensure a level of security appropriate to the risk, taking into account technological reality, cost, the scope, context, and purposes of processing weighted against the severity and likelihood that the processing could threaten individual rights and freedoms.

Children

Our Website and Services are not intended for use by children. We do not intentionally gather Personal Data about visitors who are under the age of 13. If a child has provided us with Personal Data, a parent or guardian of that child may contact us to have the information deleted from our records. If you believe that we might have any information from a child under the age of 13 in the applicable jurisdiction, please contact us at [email protected]. If we learn that we have inadvertently collected the Personal Data of a child under 13, or equivalent minimum age depending on jurisdiction, we will take steps to delete the information as soon as possible.

Changes to this Privacy Policy

This Privacy Policy is effective as of the date stated at the top of this page. We may change this Privacy Policy from time to time. By accessing and using the Website and Services after we notify you of such changes to this Privacy Policy, you are deemed to have accepted such changes. Please refer back to this Privacy Policy on a regular basis.

How to Contact Us

If you need to contact us regarding security or privacy, including reporting any known or suspected security incidents or vulnerabilities please do so at [email protected].
If you have any specific questions about this Privacy Policy or if you would like to exercise any of the privacy rights available to you, please contact us via email or phone or by writing to us at the address below:

Send email to: [email protected]

Send mail to our address:
VISO TRUST (DBA)
Valente Sherman, Inc.
PO BOX 193152
San Francisco, CA 94119-3152
www.visotrust.com

If you are located in the United Kingdom or EU/EEA and believe we have not adequately resolved any issues, you may contact the Supervisory Authority concerned.