Last Updated: July 8, 2020
What Types of Information and Data Does VoiceTown Collect, and When Does It Collect This Data?
VoiceTown collects various types of Personal Information. We collect this information when you provide it to us (whether directly or through our subsidiaries and/or representatives) or when you use certain services provided by VoiceTown.
“Personal Information” is information that can be used to identify, locate, or contact you as a natural person, as well as other information about you that we tie to Personal Information. Personal Information that we collect includes, but is not limited to, the following types of information:
- “Contact Information” that allows us to identify and communicate with you, such as your name, phone number, address, email, and language preferences.
- “Transactional Information” about how you interact with us, our subsidiaries and Sponsoring Organizations, including services you request, customer service inquiries, and customer account information.
“Non-Personal Information” is any information that does not does not identify a natural person and is not identifiable to a natural person, such as:
- Cookies and other tools used in a non-identifiable way;
- Anonymized information;
- Aggregated information; and
- Information about your business operations, including, but not limited to:
- Operation-specific data, such as location data, when kept in a non-identifiable way; and
- The name, form, and contact details of legal persons.
In addition to the methods described above, Personal Information and Non-Personal Information may be collected by VoiceTown from its subsidiaries and authorized Sponsoring Organizations as part of its standard business operations, to provide services to the subsidiaries and authorized sponsoring organizations, and as otherwise agreed pursuant to agreements between VoiceTown and such subsidiaries and authorized Sponsoring Organizations.
When data is described as “anonymized,” it means that the data is no longer associated with a particular person. When data is described as “aggregated,” it means that such information has been combined with other data in such a way that no person can be identified or linked to any specific action or information.
How VoiceTown Uses Your Information (the “Purposes”)
- To Complete Orders and Provide Requested Services. To fulfill orders for products or services, and for other services or purposes as you may request or direct, such as product delivery, maintenance, and the like.
- Product and Customer Support. To provide support services, to deliver upgrades and product improvement communications.
- Marketing and Surveys. To communicate offers for products, building content, and services from VoiceTown or its subsidiaries, dealers, suppliers, partners, or authorized sponsoring organizations, including offers based on your demographics and psychographics, interests, personal and business characteristics and your location; to administer surveys, polls, sweepstakes, contest, loyalty programs and other promotional events; and to provide other information which may be of interest to you, such as VoiceTown company news, catalogs, announcements, reminders, and technical bulletins. Please contact us if you would not like to be contacted by VoiceTown for marketing purposes without being asked. We will provide you with the opportunity to opt-out of marketing information or market research inquiries.
- General Business Purposes. To provide and accomplish standard business tasks, such as payment processing, financial account management, product development, contract management, website administration, web-forum management, order or contract fulfillment, analytics, fraud prevention, corporate governance, reporting and legal compliance.
- As Disclosed at the Time of Collection. In any other manner that we may describe when you provide the information to us.
These Purposes may be necessary for VoiceTown to perform a contract to which you are a party, comply with a legal obligation to which VoiceTown is subject, protect VoiceTown’s vital interests or the interests of another natural person, or otherwise pursue VoiceTown’s legitimate business purposes and objectives. VoiceTown may obtain your consent to process your Personal Information, as necessary.
Because Non-Personal Information does not personally identify you, VoiceTown may use and disclose Non-Personal Information for any purpose. In some instances, VoiceTown may combine Non-Personal Information with Personal Information (such as combining your name with your location data). If VoiceTown combines any Non-Personal Information with Personal Information, VoiceTown will treat the combined information as Personal Information.
In addition, VoiceTown reserves the right to use anonymized and aggregated Personal Information to improve its products and services, to create and publish reports, to conduct statistical analysis about our customers and products, and for other activities that do not result in the disclosure of your identifiable information.
When Will VoiceTown Disclose Your Information, and Who May Receive It?
VoiceTown is committed to being transparent regarding the manner in which we use and disclose your information. We may disclose and share your information as follows:
- In order to fulfill the purposes of products and services, we may disclose and make accessible to a Sponsoring Organization and its affiliates in accordance with the terms of an agreement between VoiceTown and such Sponsoring Organization.
- We may share Personal Information with our subsidiaries, Sponsoring Organizations, dealers and distributors, and business partners, as needed to accomplish, and consistently with, the Purposes set forth above, or as you authorize or request.
- We may also share Personal Information with our service providers to fulfill the Purposes on our behalf. Our service providers are bound by law or contract to treat your information and data with the same level of protection that we do and to only use it in accordance with our instructions.[CMA1]
- We may disclose Personal Information where needed to affect the sale or transfer of business assets, to enforce our rights, protect our property, or protect the rights, property, or safety of others, or as needed to support external auditing, compliance, and corporate governance functions.
- We will also disclose Personal Information when required to do so by law, such as in response to a subpoena, including to law enforcement agencies and courts in the countries where we operate.
As noted above, VoiceTown reserves the right to use and disclose anonymized and aggregated Personal Information to improve its products and services, to create and publish reports, to conduct statistical analysis about our customers and products, and for other activities that do not result in the disclosure of your identifiable information.
How Long Will VoiceTown Keep your Information?
VoiceTown keeps different kinds of personal data for different lengths of time, depending on the Purposes for which they are processed and the unique circumstances of your situation. VoiceTown will hold your Personal Information as long as necessary for the relevant Purpose. For more information on VoiceTown’s data-retention policy and how long your data might be retained, please contact us as provided below. [CMA2]
Website Data Collection, Cookies, and Similar Technology
When you visit our website or use our mobile applications, we collect certain information by automated means, using technologies such as cookies, pixel tags, browser analysis tools, server logs and web beacons.
For example, when you visit our website, we may place cookies on your computer. Cookies are small text files that websites send to your computer or other Internet-connected device to uniquely identify your browser or to store information or settings in your browser. Cookies allow us to recognize you when you return. They also help us provide a customized experience and enable us to detect certain kinds of fraud. We may also use Adobe Flash Cookies, Microsoft Silverlight, and similar technologies which remember your settings, preferences, and usage in a manner similar to browser cookies to personalize and enhance your online experience, but which are not managed through your browser. To manage your Flash and Silverlight cookies, please see Adobe’s and Microsoft’s websites.
Pixel tags and web beacons are tiny graphic images placed on website pages or in our emails that allow us to determine whether you have performed a specific action. When you access these pages or open or click an email, the pixel tags and web beacons generate a notice of that action. These tools allow us to measure response to our communications and improve our web pages and promotions.
We collect many different types of information from cookies and other technologies. For example, we may collect information about the device you use to access our website, your operating system type, browser type, domain, and other system settings, as well as the language your system uses and the country and time zone where your device is located. Our server logs also may record the IP address or derivative of the device you use to connect to the Internet. An IP address is a unique identifier that devices use to identify and communicate with each other on the Internet. We may also collect information about the website you were visiting before you came to VoiceTown and the website you visit after you leave our site.
Your Choices and Data Control
You can limit the information you provide to VoiceTown. You can also limit the communications that VoiceTown sends to you. To opt-out of marketing emails, you can visit our website and communicate your choice to the relevant privacy contact. Alternatively, you may opt-out of receiving future marketing emails by clicking “unsubscribe” at the bottom of marketing emails we send you.[CMA3]
Please note that even if you opt-out of receiving marketing material, we may still need to contact you with important Transactional Information about your account or your products. For example, even if you opt-out of marketing emails, we will still send you a confirmation when you purchase something from us as well as to provide communications related to our products.
You can manage cookie preferences and opt-out of having cookies and other similar collection technologies used by adjusting the settings on your browser or interface, commonly known as “Do Not Track” settings. All browsers and interfaces are different, so visit the “help” section of your browser or interface to learn about cookie preferences and other privacy settings that may be available. You can manage how your mobile device and mobile browser share location information with VoiceTown, as well as how your mobile browser handles cookies and related technologies by adjusting your mobile device privacy and security settings. Please refer to instructions provided by your mobile service provider or the manufacturer of your device to learn how to adjust your settings. In general, VoiceTown complies and requests that all of its service providers comply with your “Do Not Track” settings you select using your internet browser(s).[CMA4]
VoiceTown complies with applicable law regarding your ability to access, correct, and delete your Personal Information. If you have an online account, you may be able to log into your account to access and update certain information you provided to us. For Personal Information that is not linked to an online account, for assisting in opting-out of communications, or if you need assistance updating or deleting your Personal Information, please contact us via email at firstname.lastname@example.org. You can also write us at the address in the How to Contact Us section below. If you send us a letter, please provide your name, address, email address, and detailed information about the change you would like to make.
For EU Residents:
The General Data Protection Regulation (“GDPR”), particularly Articles 15 to 21, affords you a number of rights as a data subject. VoiceTown encourages you to read and learn about those rights on your own. However, the following will help you to begin to understand those rights.
- The Right to Access: This allows you to request from VoiceTown information about your Personal Information, including what data VoiceTown has and how and why it is being processed.
- The Right to Rectification: In the event that some or all of the Personal Information that VoiceTown has concerning you is inaccurate, this gives you the right to have those inaccuracies rectified.
- The Right to Erasure: In some cases, you may have the right to request that VoiceTown erase your Personal Information that it has in its possession.
- The Right to Restriction of Processing: This gives you the right, in some circumstances, to have VoiceTown process your Personal Information only with your consent.
- The Right to Object to Processing: Where VoiceTown is processing your Personal Information on the ground of its legitimate interests, or to carry out tasks in the public interest or to exercise official authority, you have a right to object to the processing on grounds relating to your particular situation. In cases where you object to VoiceTown’s processing of your personal data for direct marketing purposes, the processing will cease.
- The Right to Data Portability: This allows you to request from VoiceTown a copy of your Personal Information that it has on file and to transfer that information to someone else without any interference from VoiceTown. In some cases, you may be able to request that VoiceTown transfer your Personal Information directly to a third party on your behalf.
In addition, to the extent that VoiceTown processes any of your Personal Information on the basis of your consent, you have the right to withdraw that consent at any time, without affecting the lawfulness of processing that was based on your consent before its withdrawal.
If you are a natural person residing in the EU and at any time you believe VoiceTown has violated one of your rights listed above, or if you believe VoiceTown is in violation of one or more of the provisions of the GDPR, you have the right to lodge a complaint with a Data Protection Authority. More information about the Data Protection Authorities can be found at https://ec.europa.eu/info/law/law-topic/data-protection/reform/what-are-data-protection-authorities-dpas_en.
Information and Data Security
VoiceTown has implemented an information and data security program that contains administrative, technical and physical controls that are designed to reasonably safeguard Personal Information.
Transfer of Information, Transfers to Other Countries
Privacy Policies of Third Parties
An Authorized Individual-Representative may authorize and/or have access to a records for a minor child or other individual over whom an Authorized Individual has legal authority (“Dependent”). Through the account, the Authorized Individual-Representative may allow for Dependent to engage in communications and transactions as permitted between the Authorized Individual-Representative and the VoiceTown through the account. A Dependent’s account will be linked to an Authorized Individual-Representative’s account until the earlier of the date: (i) the Dependent reaches the age of 18; (ii) the Authorized Individual-Representative is no longer the legal representative of the Dependent; or, (iii) VoiceTown is notified by a court of law or agency with appropriate authority that the Dependent has been emancipated or that a different Authorized Individual-Representative has been named. Each Authorized Individual-Representative agrees that a Dependent’s account also may be linked to the account of another Authorized Individual-Representative, and each Authorized Individual-Representative will have the same rights to access and communicate through the Dependent’s account.
Plug-Ins to Social Media and Other Third Party Services
In addition, VoiceTown’s websites may also contain links, plug-ins, APIs, and other tools that enable you to share content on our website or your own content through third party social media or other services (such a Facebook, Twitter, Google+, and other services). All use of such third party services, including through links found on our website, shall be considered public information and shall be subject to the terms and conditions of such third party services.
Amendments and Changes
Your California Privacy Rights
California Civil Code Section § 1798.83 permits users of our website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please contact us using the information below.
How to Contact Us
VoiceTown Holdings, LLC
3412 Oak Ridge Road
Minnetonka, Minnesota 55305