CCPA

California Consumer Privacy Act Notice

1. CCPA Notice

This California Consumer Privacy Act Notice is provided by Virtually Human Studio Pty Ltd  (ABN 90 636 113 409) (‘VHS’ )(“we” or “us”). 

This notice only applies to information about residents of California. A California resident is a natural person (as opposed to a corporation or other business entity) who resides in California). If you are not a resident of California, please refer to the privacy policy relevant to your jurisdiction. 

This notice explains:

1. how we collect, use, and disclose personal information about California residents; and 
2. the relevant rights California residents have under the California Consumer Privacy Act (“CCPA”).
   

2. Who are we?

VHS owns and operates the website is at:  https://www.vhslab.com/

We respect your privacy and share your concern about the security of data you may submit to our platform.

3. Personal information

1. What is Personal Information?
   
   Under the CCPA, Personal Information is information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. It could include an individual’s name, postal address, driver’s license number, passport number, social security number, email address, internet browsing history, and geolocation data.

2. What is not Personal Information?
   
   Personal information does not include publicly available information, which is information that is lawfully made available from federal, State or local government records. Personal information does not include consumer information that has been de-identified or aggregate consumer information.

4.The categories of personal information we collect

We collect personal information in a variety of contexts, including to provide our services, and for our employment and human resources activities.

The information we collect will depend on the purpose we seek it for, which may be determined by the relationship, or interaction, we have with an individual. 

We collected the following categories of personal information in the past 12 months, as indicated.

(a) Identifiers, such as real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers. Yes

(b) Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)), including name, contact details, telephone number, physical and email address, financial information such as bank account details, bank account transaction details, account balances, and payment card details. Yes

(c) Characteristics of protected classifications under California or federal law such as gender, age, and marital status. Yes

(d) Commercial information, such as transaction information, purchase history, financial details and payment information. Yes

(e) Biometric information. Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data. No

(f) Internet or other network activity, such as browsing history, search history, online behavior, interest data, and interactions with our and other websites, applications, systems and advertisements. Yes

(g) Geolocation information, such as device location, physical location or movements. Yes

(h) Sensory data, such as audio, electronic, visual and similar information, such as images and audio, video or call recordings created in connection with our business activities. Yes

(i) Professional or employment-related information, including job role, professional related information, work history, education history and resumes. Yes

(j) Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. No

(k) Inferences based on information about an individual to create a profile or summary about, for example, a person's preferences and characteristics. Yes

5. Categories of Sources of personal information

We try to only collect personal information about a California resident which is reasonably necessary for, or directly related to, the particular function or activity we are carrying out. The main way we collect personal information about an individual is when an individual gives it to us, usually by webform, email, and telephone.

1. When you register an account: Information requested may include name, addresses, emails, telephone numbers, Metamask Wallet address, other crypto wallet address, user details where relevant. We may collect other applicable information using a webform.
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2. Account verification: We may collect information to enable us to process verification of your account information and so we can authenticate who you are.
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3. When you contact us: This includes information gathered through webforms, email, or other means of communication between you and us, and where relevant between you and the other party to a transaction.
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4. When you give us consent for a particular purpose: We may, from time to time, request your consent to provide us with information for a particular purpose. With your consent, third-party services that provide a mechanism to share information you have provided to the third party through the use of an application program interface (API), such as Facebook Connect. 
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5. Indirect information: We may collect information from someone authorized by you, and you may authorize a third party to collect information on behalf of you.
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6. Browsing our website: We may collect information from your browser, and device, including IP address, geographical location, search terms, device description, device operating system, browsing times and dates, user ID, location information, page view statistics, website traffic information, referral url, and web log information.
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7. Surveys: We may ask you questions relating to products or services offered through our website in order to provide a tailored response.
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8. Cookies and web beacons: We collect information using cookies and similar technologies, relevant to viewed pages, followed links, and other browsing behavior. You can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable a choice to disable all cookies or only third party Cookies. By default, most internet browsers accept Cookies but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device. You can choose to delete Cookies on your computer or device at any time, however, information may be lost that enables access to Our Site more quickly and efficiently including, but not limited to, login and personalisation settings. It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.   Our web pages may contain electronic images known as web beacons (also called single-pixel gifs) that we use to help deliver cookies on our websites, and to count users who have visited those websites. We may also include web beacons in our promotional email messages or newsletters, to determine whether and when you open and act on them. In addition to placing web beacons on our own websites, we sometimes work with other companies to place our web beacons on their websites or in their advertisements. This helps us to develop statistics on how often clicking on an advertisement on an VHS website results in a purchase or other action on the advertiser's website. VHS may contain web beacons or similar technologies from third-party analytics providers that help us compile aggregated statistics about the effectiveness of our promotional campaigns or other operations. These technologies enable the analytics providers to set or read their own cookies or other identifiers on your device, through which they can collect information about your online activities across applications, websites or other products.
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9. Other sources: We may get information from sites which are used to verify your identity, publicly available information, information from other users, information related to transactions and delivery of goods and services, and demographic information which is lawfully available to us.
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10. General: We collect personal information which is reasonably necessary for the functions or activities of our business and VHS. We will only collect information by lawful and fair means and not in an unreasonably intrusive way.

6.The business purpose for which we use personal information. 

Our use of personal information will always have a lawful basis, either because consent has been given to our use of personal information or because it is reasonably necessary to provide our services and undertake our activities. 

1. We use personal information for the reasons the information was provided, which includes: to provide a personalized service, including using our services, using our website; correspondence with you or as directed by you, or on your behalf; to open and maintain an account with us;  carrying out advertising, marketing and educative training or promotional activities; to facilitate marketing from third parties; to detect and investigate fraud and other unlawful activities; to contact you; to improve our services; to provide technical and customer services; to provide feedback to you; to provide subscription services which you have consented to receiving including emails and newsletters; carrying out competitions; improving our services; helping you identify products or services which may be appropriate for you; referring you to product and service providers; in connection with a corporate transaction such as a divestiture, merger, consolidation, or asset sale, or in the unlikely event of bankruptcy; where we provide personalized services, we may analyze the information you supply, as well as your activity on our (and other) services, so that we can offer a more relevant, tailored experience and where appropriate we provide your personal information to third parties for purposes related to providing our services, including for regulatory requirements, processing transactions and identification.
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2. We also use your information to provide you with offers, location based services, and to directly contact you using email, sms, telephone and postal mail for purposes including customer services related matters which includes technical issues, disputes, general assistance, collecting and refunding payments, and surveys. We may also use personal information to enforce agreements.
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3. We may use the personal information we collect for direct marketing. This includes receiving emails and sms messages from us. If you do not wish to receive direct marketing, please contact us in writing with your request. Please note that we may not be able to continue to provide our services to you if you opt out of direct marketing.
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4. We may use information which we hold about you to show you relevant advertising on third-party sites (e.g. Facebook, Google). This could involve showing you an advertising message where we know you have VHS or other VHS services. 
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5. We store personal information for as long as we require it for our business purposes and legal compliance. We store personal information to stop criminal activity, to collect any overdue fees, to resolve disputes, to deal with technical problems, enforce our agreements, and for other purposes under applicable laws. We have security measures in place to protect your personal information. 
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6. Your personal information may be shared with third parties and other companies in the VHS group in order to provide services to you, to enable us to undertake marketing and advertising related activities, for research purposes, to detect or investigate unlawful activities, to meet our legal and compliance policy requirements, and for transaction processing.
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7. We may transfer your personal information to overseas recipients, including other businesses in our group, which may result in your personal data being transferred between, and stored on, servers in the USA, Europe, Australia and other countries. 
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8. We may also access, hold and use aggregated information about the people that use our services. Aggregated information won’t identify you or any other individual but simply provides us with non-personally identifiable data that we’ll use to improve our services, understand our users’ needs and develop tailored content. We may disclose this aggregate information to third parties for purposes including research and publishing statistics related to our business.  Although you would have provided us with the information we aggregate for these purposes, it won’t identify you or enable you to be personally identified.
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9. If we do not need your personal information for any or the purposes set out in this policy, or as required by law, we will take reasonable steps to de-identify or destroy the information.
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10. By using our services, you consent to us collecting, holding and using your personal information in this way.

7.Third parties with whom data is shared

For information generally on how we share your personal information and to which entities, please refer to our Privacy Policy.

In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:

Category A: Identifiers.

Category B: California Customer Records personal information categories.

Category C: Protected classification characteristics under California or federal law.

Category D: Commercial information

Category F: Internet or other similar network activity.

Category G: Geolocation data.

Category I: Professional or employment-related information

Category K: Inferences drawn from other personal information.

We disclose personal information for a business purpose to the following categories of third parties:

1. Companies in the VHS group for operational reasons.
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2. Third party organizations from whom we collect personal information to support human resource and workforce management activities. Examples may include operating systems and platforms, and social networks.
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3. Third party organizations that provide data to support activities such as fraud prevention, underwriting, and marketing. Examples may include internet service providers, social networks, software analytics platforms, operating systems and platforms, data brokers, advertising networks, and data analytics providers.
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4. Third party organizations from whom we collect Personal Information as part of providing products and services, completing transactions, supporting our everyday operations, or business management and development. 

8. Sale of personal information, and how to opt out.

We do not sell your personal information.

9. Consumer Rights

(a) Personal Information Disclosure

California residents have the right to request that we disclose:

(i) the categories of personal information we collected about you and the categories of sources from which we collected such information; 

(ii) the specific pieces of personal information we collected about you; 

(iii) the business or commercial purpose for collecting or selling personal information about you; and 

(iv) the categories of personal information about you that we sold or disclosed for a business purpose and the categories of third parties to whom we sold or to whom we disclosed for a business purpose such information in the preceding 12 months.

2. Right to deletion of personal information

California residents have the right to request that we delete personal information we collected from you subject to certain exceptions.

3. Right not to be discriminated against

California residents have the right to not be discriminated against in pricing and services because of exercising rights under the CCPA.

VHS does not offer financial incentives or price or service differences to consumers in exchange for the retention of a consumer’s personal information.

10. How to make a request

California residents may make a request for the disclosures, opt-out, or deletion of personal information, as set out in this notice, and the CCPA, by email: hello@vhslab.com. 

In order to confirm the identity of the individual making a request, the individual may be required to submit proof of identity for a request to be processed. Verification information may include First Name, Last Name, Street Address, City, Zip, and Date of Birth and either a Social Security Number or a Driver’s License Number and State.  

The information provided will only be used for the purposes of verifying your identity and processing your request. If sufficient information is not provided to verify an identity, the request may not be complied with. 

You may appoint an authorized agent to make a request on your behalf subject to proof of identity and written authorization. 

The request will be responded to pursuant to the CCPA. Not all information is required to be made available, for example information made available from government records, certain data subject to the Fair Credit Reporting Act (FCRA), Gramm-Leach-Bliley Act (GLBA) and certain other laws, and where its application is preempted by, or in conflict with, federal law or the United States or California Constitution.

Date of last update: May, 2022.