PRIVACY POLICY

VBC GLOBAL PRIVACY POLICY (THIS “PRIVACY POLICY”)
Last revised and effective as of: August 8, 2024

This Privacy Policy applies to information collected by VBC Global Consulting, LLC DBA VBC Global (“VBC” “we” or “us” or “our”):

through your use of the VBC website at https://vbcgc.com/ and any subdomains and any features and information available thereon, and any online forms or other online requests submitted by you such as to subscribe to VBC newsletters (along with associated and successor websites, applications, features, blogs, forms and information, or any part thereof, collectively, the “Site”);
that you may provide to us when you meet us in person such as at business conferences, when you are involved in our networking activities, or in an online event hosted by us such as a webinar (collectively, “Networking Activities”); and
where an individual natural person engages us as a client or prospective client, or where an employee, representative, or agent of a corporate entity that is a client or prospective client (collectively, “Clients”) makes such information available to us, or where we otherwise receive information in connection with our provision of legal services (“Client Services”).

As used herein, “you” and “your” mean a user of the Site, an individual who engages in Networking Activities with us, or any individual whose information we handle in connection with providing Client Services, including any individual who engages us as or on behalf of a Client. As used in this Privacy Policy (a) “GDPR” means the General Data Protection Regulation (EU) 2016/679; (b) “UK Data Protection Laws” means the UK GDPR and the UK’s Data Protection Act 2018 (“UK DPA 2018”); (c) “UK GDPR” means the UK equivalent of the GDPR, as defined in section 3(10) (and as supplemented by section 205(4)) of the UK DPA 2018; and (d) “European Data Protection Laws” means the GDPR and/or UK Data Protection Laws, in each case to the extent applicable.

As used in this Privacy Policy, the terms “using” and “processing” information include using cookies on a computer, subjecting the information to statistical or other analysis and using or handling information in any way, including, but not limited to collecting, storing, evaluating, modifying, deleting, using, combining, disclosing and transferring information within VBC or among our affiliates within the United States or internationally.

This Privacy Policy serves to notify you of the following:

1. 1. WHAT INFORMATION ABOUT ME IS COLLECTED?

In connection with the Site, Networking Activities, and Client Services, we may collect information about you. Such information may include your name, address, occupation, employer, title and position, areas of interest, e-mail address, and telephone number. In addition, in connection with our provision of Client Services, such information may include government issued identification numbers, signature, date of birth, beneficial ownership information, and any other information needed to provide the Client Services. Furthermore, in connection with Client Services (to the extent applicable), our Outside Contractor (as defined below) that is responsible for billing and payment processing services (the “Payment Services Provider”) may collect your billing and credit card information from you directly. We may also collect demographic information, browser types, unique device identifiers, device types, requested URL, referring URL, browser language, the pages you view, the date and time of your visit, domain names, and statistical data involving the use of the Site. To the extent any such information can be used to identify you or can be tied to you in an identifiable manner, such information amounts to ‘personal data’ for the purposes of and as defined in the European Data Protection Laws (to the extent applicable).

Information you provide to us for the purposes of attending Networking Activities, including dietary requirements, may reveal information about your health or religious beliefs. Further, in connection with Client Services, we may collect from you, or you may make available to us, special categories of personal data. By agreeing to this Privacy Policy, you explicitly consent to the processing of any such special categories of personal data. “Special categories of personal data” consist of personal data for the purposes of and as defined in the European Data Protection Laws, which is to be treated with particular sensitivity, and includes information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic or biometric data, data concerning health or data concerning a person’s sex life or sexual orientation. [Back]

1. 1. WHERE AND WHEN IS INFORMATION COLLECTED (INCLUDING THROUGH THE USE OF COOKIES AND ACTION TAGS)?

We will collect information that you submit to us. We may also receive information about you from third parties providing analytics services as part of your use of the Site, or (in connection with Client Services) from third parties providing credit and debit card authorization and fraud screening. We may also receive information from or on behalf of our Clients.

Cookies and Action Tags

We may collect information passively using “cookies” and “action tags.”

“Cookies” are small text files that can be placed on your computer or mobile device in order to identify your web browser and the activities of your computer on the Site and other websites. Cookies can be used to personalize your experience on the Site (such as dynamically generating content on webpages specifically designed for you), to assist you in using the Site (such as saving time by not having to reenter your name each time you use the Site), to allow us to statistically monitor how you are using the Site to help us improve our offerings, or to determine the popularity of certain content.

In addition to cookies that we may place on your computer or mobile device, cookies might also be placed on your computer or mobile device by third parties that we use to provide analytics-related services or to collect information in order to provide analytics-related services. In the course of providing analytics-related services, such third-party analytics providers could place or recognize unique cookies on your browser.

You do not have to accept cookies to use the Site. Although most browsers are initially set to accept cookies, you may reset your browser to notify you when you receive a cookie or to reject cookies generally. Most browsers offer instructions on how to do so in the “Help” section of the toolbar. However, if you reject cookies, certain features or resources of the Site may not work properly or at all and you may experience some loss of convenience.

For the avoidance of doubt, the Site may use third-party service platforms (including to help analyze how users use the Site). These third-party service platforms may place cookies on your computer or mobile device. If you would like to disable “third-party” cookies, you may be able to turn them off by going to the third party’s website.

Here are links to the main third-party platforms we use:

https://www.google.com/policies/privacy/
https://wordpress.org/about/privacy/cookies/

“Action tags,” also known as web beacons or gif tags, are a web technology used to help track website usage information, such as how many times a specific page has been viewed. Action tags are invisible to you, and any portion of the Site or e-mail sent on our behalf, may contain action tags.

By using cookies and action tags together, we can gain valuable information to improve the Site and measure the effectiveness of our marketing campaigns. We may also combine information collected from cookies with information that you may provide, such as information provided in a form that you complete.

Finally, you should be aware that third parties may use their own cookies or action tags when you click on a link to their websites or services on or from the Site. This Privacy Policy does not govern the use of cookies or action tags or the use of your information by such third-party websites or services.

Log Files

We also collect information through our Internet log files, which record data such as user IP addresses, browser types, domain names, and other anonymous statistical data involving the use of the Site. This information may be used to analyze trends, to administer the Site, to monitor the use of the Site, and to gather general demographic information. We may link this information to other information about you for these and other purposes such as personalizing your experience on the Site and evaluating the Site in general. [Back]

1. 1. DOES VBC COLLECT INFORMATION FROM CHILDREN UNDER 13 YEARS OF AGE?

We are committed to protecting the privacy of children. The Site is not designed for or directed to children under the age of 13. We do not collect information from any person we actually know is under the age of 13. [Back]

1. 1. WHAT DOES VBC DO WITH THE INFORMATION IT COLLECTS?

We will only use your information to the extent that the law allows us to do so. Pursuant to the European Data Protection Laws, legal bases for our processing your information may include (without limitation):

(a) where you have given consent to the processing, which consent may be withdrawn at any time without affecting the lawfulness of processing based on consent prior to withdrawal;

(b) where it is necessary to perform the contract we have entered into or are about to enter into with you (whether in relation to the provision of the Site, Client Services, or otherwise);

(d) where it is necessary for the purposes of our legitimate interests (or those of a third party) in providing the Site, engaging in Networking Activities, or providing the Client Services and your interests or fundamental rights and freedoms do not override those legitimate interests.

We use the information collected to provide the Site to you, to engage in Networking Activities, to provide the Client Services to you, to contact you for billing purposes, to help us understand who uses the Site, for internal operations such as operating and improving the Site, and so that we and third parties acting on our behalf can contact you regarding information that may be of interest to you.

Unless you opt out (to the extent permitted by applicable law), we and third parties acting on our behalf may subsequently send you electronic newsletters and contact you regarding information and news that may be of interest to you. If you no longer desire to receive these communications, we will provide you with the option to change your preferences in each communication we send to you. You may also inform us by email to: unsubscribe@vbcgc.com

If you identify yourself to us by sending us an e-mail with questions or comments, we may use your information to respond to your questions or comments, and we may file your questions or comments (with your information) for future reference.

We may also use the information collected to contact you regarding the Client Services or, to the extent applicable, about your billing account status. You will not be able to opt out from these communications as they contain important information relevant to our provision of the Client Services and/or to the extent applicable, are necessary for the performance of our contract with you.

We may also use the information gathered to perform statistical analysis of user behavior or to evaluate and improve the Site. We may link some of this information to other information about you for internal purposes or to improve your experience with the Site. [Back]

1. 1. WHEN DOES VBC DISCLOSE INFORMATION TO THIRD PARTIES?

We generally disclose information we gather from or about you through the Site, in connection with Networking Activities, or in connection with our provision of the Client Services to the following types of third parties and as otherwise set forth in this Privacy Policy or as specifically authorized by you.

Laws, Legal Rights, and Ethical Obligations

We may disclose your information if we believe in good faith that we are required to do so in order to comply with an applicable statute, regulation, rule or law, ethical obligation, a subpoena, a search warrant, a court or regulatory order, lawful requests by public authorities, including to meet national security or law enforcement requirements, or other valid legal process. We may disclose information in special circumstances when we have reason to believe that disclosing this information is necessary to identify, contact or bring legal action against someone who may be violating a contract with us, to detect fraud, to meet contractual or ethical obligations, to protect our rights or our property, for assistance with a delinquent account, or to protect the safety and/or security of our users or Clients, the Site or the general public.

Third Parties Generally

We may provide information to third parties, including where such information is combined with similar information of other users of the Site. For example, we might inform third parties regarding the number of unique users who use the Site or the demographic breakdown of users of the Site. In addition to the above, when users use our Site, third parties (including without limitation third-party analytics service providers) may directly collect information about our users’ online activities over time and across different websites. The third parties to which we may provide or who may independently directly collect information may include providers of analytics services (including vendors and website tracking services), merchants, affiliates and other actual or potential commercial partners, sponsors, licensees and other similar parties. Please note in particular that the Site may use Google Analytics, including its data reporting features. Information collected by Google Analytics includes but is not limited to web metrics. For information on how Google Analytics collects and processes data, please see the site “How Google uses data when you use our partners’ sites or apps”, currently located at www.google.com/policies/privacy/partners/. For information on opting out of Google Analytics, we encourage you to visit Google’s website, including its list of currently available opt-out options presently located at https://tools.google.com/dlpage/gaoptout.

Professional Advisors.

We may provide your information to professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us.

Outside Contractors

We may employ independent contractors, vendors and suppliers (collectively, “Outside Contractors”) to provide specific services and products related to the Site, such as hosting and maintaining the Site, providing credit card processing and fraud screening (in connection with Client Services, to the extent applicable), including the Payment Services Provider, developing applications for the Site, and related to our Networking Activities. In the course of providing products or services to us, these Outside Contractors may have access to your information. We use reasonable efforts to ensure that these Outside Contractors are capable of protecting the security of your information.

Sale of Business

We reserve the right to transfer information, where permitted by our professional confidentiality obligations (to the extent applicable), to a third party in connection with a sale, merger or other transfer of all or substantially all of the assets of VBC or any of its Corporate Affiliates (as defined below), or that portion of VBC or any of its Corporate Affiliates, or in the event that we discontinue our business or file a petition or have filed against us a petition in bankruptcy, reorganization, or similar proceeding.

Affiliates

We may disclose information about you to our Corporate Affiliates. For purposes of this Privacy Policy: “Corporate Affiliate” means any person or entity which directly or indirectly controls, is controlled by or is under common control with VBC, whether by ownership or otherwise; and “control” means possessing, directly or indirectly, the power to direct or cause the direction of the management, policies or operations of an entity, whether through ownership of fifty percent (50%) or more of the voting securities, by contract or otherwise.

As Necessary to Perform Client Services

Without limitation of the foregoing, in connection with the Client Services we also may disclose information to certain third parties, which may include without limitation: (1) parties involved in the matter such as lawyers, counterparties, experts, mediators, or witnesses; (2) courts, government agencies, or regulatory bodies; (3) insurers; or (4) service providers such as information technology, document production, or mail delivery services (collectively, “Client Services Related Parties”). [Back]

1. 1. DOES THIS PRIVACY POLICY APPLY WHEN I LINK TO OTHER WEBSITES OR SERVICES?

Our Site may provide you with access to other websites and services. This may include providing you with the ability to automatically post updates on Facebook and Twitter. Please be aware that we are not responsible for the privacy practices of any websites or services other than the Site. A link to a third-party website does not constitute or imply endorsement by us. Additionally, we cannot guarantee the quality or accuracy of information presented on those websites. We encourage you to read the privacy policies or statements of each and every such website and service. This Privacy Policy applies solely to information collected by us through the Site, Networking Activities, or Client Services. [Back]

1. 1. IS THE INFORMATION COLLECTED UNDER THIS PRIVACY POLICY SECURE?

We want your information to remain secure. We strive to provide transmission of your information from your computer or mobile device to our servers through techniques that are consistent with commercially reasonable standards and to employ administrative, physical, and electronic measures designed to protect your information from unauthorized access.

Notwithstanding the above, you should be aware that there is always some risk involved in transmitting information over the Internet. There is also some risk that others could find a way to thwart our security systems. As a result, while we strive to protect your information, we cannot ensure or warrant the security or privacy of any information you transmit to us, and you do so at your own risk. [Back]

1. 1. COULD MY INFORMATION BE TRANSFERRED TO OTHER COUNTRIES?

Information may be transferred from time to time to our offices or personnel, or to third parties, located throughout the world, and the Site may be viewed and hosted anywhere in the world, including countries that may not have laws of general applicability regulating the use and transfer of such information. By using the Site and submitting such information on it, engaging in Networking Activities with us, or engaging with us in connection with Client Services, you voluntarily consent to the trans-border transfer and hosting of such information. Without limitation of the foregoing, you hereby expressly grant consent to VishkoLaw to: (a) process and disclose such information (including special categories of personal data) in accordance with this Privacy Policy; (b) transfer such information (including special categories of personal data) throughout the world, including to the United States or other countries that do not ensure adequate protection for personal data (as defined in the European Data Protection Laws) (as determined by the European Commission or the UK Information Commissioner’s Office, as applicable, each, an “Inadequate Jurisdiction”) and/or countries that may not have laws of general applicability regulating the use and transfer of such information; and (c) disclose such information (including special categories of personal data) to comply with lawful requests by public authorities, including to meet national security or law enforcement requirements. To the extent required by applicable law: whenever we transfer your personal data to third parties (as described in this Privacy Policy) located in an Inadequate Jurisdiction, we ensure a similar degree of protection is afforded to it; we may use specific contracts approved by the European Commission (accessible at https://eur-lex.europa.eu/eli/dec_impl/2021/914/oj) or the UK Information Commissioner’s Office (accessible at https://ico.org.uk/for-organisations/uk-gdpr-guidance-and-resources/international-transfers/international-data-transfer-agreement-and-guidance/), as applicable, which give personal data the same protection it has in the European Economic Area or the United Kingdom, as applicable, under the European Data Protection Laws; and if we rely on another basis to transfer your personal data to an Inadequate Jurisdiction, we will keep you updated or contact you if required. Please contact us if you want further information on the specific mechanisms used by us when transferring your personal data to an Inadequate Jurisdiction. If you are from a jurisdiction with laws or regulations governing personal data collection, use, and disclosure that differ from those of the United States, please be advised that all aspects of information collected and processed under this Privacy Policy are governed by the internal laws of the United States and the Commonwealth of Massachusetts, USA, regardless of your location. [Back]

1. 1. FOR HOW LONG WILL MY INFORMATION BE KEPT?

We will only retain your information for as long as necessary to fulfill the purposes for which we collected it or as otherwise permitted by applicable law.

To determine the appropriate retention period for information, we consider the amount, nature, and sensitivity of that information, the potential risk of harm from unauthorized use or disclosure, the purposes for which we process your information and whether we can achieve those purposes through other means, and the applicable legal requirements. [Back]

1. 1. WHAT CHOICES DO I HAVE REGARDING MY INFORMATION?

We generally use your information as described in this Privacy Policy or as authorized by you or as otherwise disclosed at the time we request such information from you. You generally must “opt in” and give us permission to use your information for any other purpose. You may also change your preference and “opt out” of receiving certain marketing communications from us by following the directions provided in association with the communication or such other directions we may provide or by contacting privacy@vbcglobal.net.

Under certain circumstances and in compliance with the European Data Protection Laws, you may have the right to:

Request access to your information (commonly known as ‘subject access request’). This enables you to receive a copy of the information we hold about you and to check that we are lawfully processing it;

Request correction of the information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected;

Request erasure of your information. This enables you to ask us to delete or remove your information where there is no good reason for us to continue processing it. You also have the right to ask us to delete or remove all of your information in certain circumstances;

Object to processing of your information where we are relying on a legitimate interest (or that of a third party) and there is something about your particular situation which makes you want to object to processing on this ground;

Request the restriction of processing of your information. This enables you to ask us to suspend the processing of your information, for example, if you want us to establish its accuracy or the reason for processing it;

Request the transfer of your information to another party; and

Lodge a complaint with the relevant supervisory authority (as defined in the European Data Protection Laws). If you have any complaints about the way we process your information, please do contact us. Alternatively, you may lodge a complaint with the supervisory authority which is established in your country.

If you want to review, verify, correct or request erasure of your information, object to the processing of your information, or request that we transfer a copy of your information to another party, please contact privacy@vbcglobal.net.

Such updates, corrections, changes and deletions will have no effect on other information that we maintain, or information that we have provided to third parties in accordance with this Privacy Policy prior to such update, correction, change or deletion. To protect your privacy and security, we may take reasonable steps (such as requesting a unique password) to verify your identity before granting you profile access or making corrections. You are responsible for maintaining the secrecy of your unique password and account information at all times.

You should be aware that it may not be technologically possible to remove each and every record of the information you have provided to us from our system. The need to back up our systems to protect information from inadvertent loss means that a copy of your information may exist in a non-erasable form that will be difficult or impossible for us to locate. After receiving your request, we will use commercially reasonable efforts to update, correct, change, or delete, as appropriate, your information stored in databases we actively use and other readily searchable media as appropriate, as soon as and to the extent reasonably practicable.

Do Not Track

The term “Do Not Track” refers to an HTTP header offered by certain web browsers to request that websites refrain from tracking the user. We take no action in response to automated Do Not Track requests. However, if you wish to stop such tracking, please contact us with your request, using our contact details provided below. [Back]

1. 1. HOW WILL I KNOW IF THERE ARE ANY CHANGES TO THIS PRIVACY POLICY?

We may revise this Privacy Policy from time to time. We will not make changes that result in significant additional uses or disclosures of your information without allowing you to “opt in” to such changes. We may also make non-significant changes to this Privacy Policy that generally will not significantly affect our use of your information, for which your opt-in is not required. We encourage you to check this page periodically for any changes. If any non-significant changes to this Privacy Policy are unacceptable to you please contact us immediately. [Back]

1. 1. WHO DO I CONTACT IF I HAVE ANY PRIVACY QUESTIONS?

If you have any questions or comments about this Privacy Policy or feel that we are not abiding by the terms of this Privacy Policy, please contact us in any of the following ways:

By e-mail:

privacy@vbcglobal.net

By postal mail or courier:

Attn: VBC Privacy Officer
2516 Waukegan Road, Ste 148
Glenview, IL 60025-1774

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