Privacy Policy

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Last Updated: January 6, 2021

Privacy Policy

Introduction
Welcome. You have arrived at a website provided by Vincit, Inc. (“Vincit,” “Company” or “we,” “our” or “us”). We respect your privacy and want to protect your personal information.
This Privacy Policy governs the Company’s website (including www.vincit.com,), its subdomains, and all portals, applications, products, services, events, and any interactive features, applications, or other services that post a link to this Privacy Policy (the “Site”) as well as to all the “Personal Information” defined below that we may collect from you via phone calls or other communications with our personnel or in any other instance when you contact us. We refer to all of the above as our “Services.”
The website www.vincit.fi is run by the Company’s affiliated company in Finland and is governed by a separate privacy policy at https://www.vincit.fi/en/privacy-statement/.
If you voluntarily provide your information in the course of interacting with our Sites or otherwise using our Services, we will take that as your agreement to our collection, use, and disclosure of your information as set forth in this Privacy Policy. This Privacy Policy is part of our Terms of Service, which govern your use of the Site.
By using our Site or contacting us to inquire about our Services, you consent to our Privacy Policy and agree to our Terms of Service.
We are required by law to tell you what information we collect from you, why we collect it, how we use it, under what circumstances we may share it with third parties, how we protect that information, and how you may opt out of the sale of that information. If you have questions about this Privacy Policy, contact us at privacy@vincit.com . This Privacy Policy does not apply to any products, services, websites, or content that are offered by third parties which are governed by their respective privacy policies. PLEASE READ CAREFULLY PRIOR TO USING OUR SERVICES. BY ACCESSING AND USING THE SITE AND OUR SERVICES, YOU AFFIRM THAT YOU HAVE READ, UNDERSTOOD, AND AGREE TO ABIDE TO THIS PRIVACY POLICY AND THE TERMS OF SERVICE. IF YOU DO NOT AGREE TO ABIDE TO THE TERMS OF SERVICE AND THIS PRIVACY POLICY, YOU MAY NOT ENTER, ACCESS, OR OTHERWISE USE OUR SERVICES. IF YOU USE THE SERVICES ON BEHALF OF SOMEONE ELSE, YOU REPRESENT TO US THAT YOU ARE AUTHORIZED BY SUCH INDIVIDUAL TO ACCEPT THIS PRIVACY POLICY AND YOU DO ACCEPT THIS PRIVACY POLICY ON SUCH INDIVIDUAL’S BEHALF
What Information We Collect
(a) Information You Provide to Us
We do not require any personal information to allow you to merely access and view the Site.
In some circumstances we may ask you to provide us with certain information, including but not limited to,
  • (i) your first and last name;
  • (ii) email address;
  • (iii) home or business address;
  • (iv) telephone number or mobile number;
  • (v) business and position information;
  • (vi) business address information;
  • (vii) other information that could reasonably be used to identify you personally or identify your household (hereinafter, “Personal Information”); and/or
  • (viii) demographic information, such as your country, state, or county of residence or business operation (“Demographic Information”).
Your decision to provide us with information is voluntary, but if you choose not to provide any requested information, you may not be able to take advantage of all of the Site’s features or our Services.
We may collect this information when you:
  • Request information from us via webforms, emails or telephone;
  • Contact us regarding a question, concern, or inquiry, such as when you make inquiries concerning our Sites and/or Services;
  • Sign up or request to be placed on our mailing and/or email marketing lists; or
  • Apply for employment with us.
Your decision to provide us with information is voluntary, but if you choose not to provide any requested information, you may not be able to take advantage of all of the Site’s features or our Services.
(b) General Browsing In addition to information that you choose to submit to us, we and/or our service providers may automatically collect and/or store certain information when you visit or interact with the Site(s) (“Usage Information”). This Usage Information may be stored and/or accessed from your personal computer, laptop, tablet, mobile phone or other device (a “Device”) whenever you visit or interact with our Site(s). Usage Information may include:
  • Your IP address, IDFA, Android/Google Advertising ID, IMEI, or another unique identifier (“Device Identifier”);
  • Your Device functionality (including browser, browser language, operating system, hardware, mobile network information);
  • Referring and exit web pages and URLs;
  • The areas within our Site(s) that you visit and your activities there, including remembering you and your preferences;
  • Your Device location or other geolocation information, including the zip code, state or country from which you accessed the Services;
  • Your Device characteristics; and
  • Certain other Device data, including the time of day you visit our Site(s).
    (c) Use of Cookies and other Tracking Technologies
We may use various methods and technologies to store or collect Usage Information (“Tracking Technologies”). Tracking Technologies may set, change, alter or modify settings or configurations on your Device. A few of the Tracking Technologies used on the Site), include, but are not limited to, the following (as well as future-developed tracking technology or methods that are not listed here):
  • Cookies. A cookie is a file placed on a Device to uniquely identify your browser or to store information on your Device. Our Site may use HTTP cookies, HTML5 cookies, Flash cookies and other types of cookie technology to store information on local storage.
  • Web Beacons. A Web Beacon is a small tag (which may be invisible to you) that may be placed on our Site’s pages and messages.
  • Embedded Scripts. An embedded script is programming code that is designed to collect information about your interactions with the Site, such as the links you click on.
  • ETag, or entity tag. An Etag or entity tag is a feature of the cache in browsers. It is an opaque identifier assigned by a web server to a specific version of a resource found at a URL.
  • Browser Fingerprinting. Collection and analysis of information from your Device, such as, without limitation, your operating system, plug-ins, system fonts and other data, for purposes of identification.
  • Recognition Technologies. Technologies, including application of statistical probability to data sets, which attempt to recognize or make assumptions about users and devices (e.g., that a user of multiple devices is the same user).
We may use Tracking Technologies for a variety of purposes, including:
  • To allow you to use and access the Site, including for the prevention of fraudulent activity and improved security functionality;
  • To assess the performance of the Site, including as part of our analytic practices or otherwise to improve the content, products or services offered through the Site;
  • To offer you enhanced functionality when accessing the Site, including identifying you when you sign into our Site or keeping track of your specified preferences or to track your online activities over time and across third-party sites; and
  • To deliver content relevant to your interests on our Site and third-party sites based on how you interact with our content.
To learn more about how to opt out of Google’s use of the Google analytics cookies, visit, here https://tools.google.com/dlpage/gaoptout].
To learn more about how to opt out of DoubleClick’s use of cookies, visit the DoubleClick opt-out page, here https://support.google.com/ads/answer/2662922?hl=e]. If you would like more information about behavioral advertising practices, go to the Digital Advertising Alliance’s WebChoices tool at http://www.aboutads.info. To learn about your choices in connection with these practices on the particular device on which you are accessing this Privacy Policy, please visit http://www.networkadvertising.org/choices and http://www.aboutads.info/choices.
You may also click on the informational icon contained within each interest-based ad. We do not control these opt-out links or whether any particular company chooses to participate in these opt-out programs. We are not responsible for any choices you make using these mechanisms or the continued availability or accuracy of these mechanisms.
Please note that even if you exercise the opt-out choices above, you may continue to receive advertisements, for example, ads based on the particular website you are viewing (e.g., contextually based ads). Also, if your browser (like some Safari browsers) is configured to reject opt-out cookies when you opt out on the DAA or NAI websites, your opt-out may not be effective.
(d) Information We Collect When You Interact with Third-Party Sites
The Site may include functionality that allows certain kinds of interactions between the Site and your account on a third-party website or application. The use of this functionality may involve the third-party site providing information to us. For example, we may provide links on the Site to facilitate sending a communication from the Site or we may use third parties to facilitate emails or postings to social media (like a “Share” or “Forward” button). These third parties may retain any information used or provided in any such communications or activities and these third parties’ practices are not subject to our Privacy Policy. We may not control or have access to your communications through these third parties. Further, when you use third-party sites or services, you are using their services and not our services and they, not we, are responsible for their practices. You should read the applicable third-party privacy policies before using such third-party tools on our Site.
(e) Information from Third Parties.
In addition, we may collect information about you from other sources, including consumer credit reporting agencies in connection with an application for employment. We may combine the information we collect from third parties with information that we have collected from you or through your use of the Services.

Why We Collect Information
We may use your information for various purposes, including:
  • Responding to your requests for information;
  • Providing professional services to you:
  • Verifying your identity and for fraud prevention;
  • Invoicing you for our Services;
  • Processing of job applications and communications related to recruitment;
  • Providing you with updates and information about services we provide;
  • Sending you marketing information about Vincit and our affiliated entities;
  • Sending you email communications such as electronic newsletters about our Services and events which may be of interest to you;
  • Remarketing based on website behavior online and on social media;
  • Improving the effectiveness of our Site, our marketing endeavors, and our product and service offerings;
  • Helping us address problems with and improve our Site and our products and services, including testing and creating new products, features, and services;
  • Protecting the security and integrity of the Site, including understanding and resolving any technical and security issues reported on our Sites;
  • Engaging in analysis, research, and reports regarding the use of our Sites and Services;
  • For internal business purposes;
  • Complying with the law and protecting the safety, rights, property or security or Vincit, the Services, and the general public; and
  • For purposes disclosed at the time you provide your information or as otherwise set forth in this Privacy Policy.

When We Disclose Information
We do not sell your information to third parties, and we will not otherwise disclose your information to third parties, without your express permission or as expressly disclosed in this Privacy Policy.
We may share your information, including your Personal Information, with our affiliates and other third parties, such as companies with whom we have marketing or other relationships, for direct marketing purposes. In addition, we may share the information we have collected about you, including Personal Information, as disclosed at the time you provide your information and as described in this Privacy Policy as follows:
(a) Third Parties Providing Services to Vincit. We may use Third-Party Service providers to perform certain services on behalf of us or the Site(s) or Services, such as: (i) creating and updating Site(s) functionality; (ii) assisting us in Site(s) operations; (iii) managing a database of customer and consumer information; (iv) hosting the Site(s) and improving performance of the Sites; (v) designing and/or operating the Site’s features; (vi) tracking the Site’s activities and analytics, including marketing and market research; (vii) data enhancement (to learn more about our customers); (viii) enabling us to send you special offers or perform other administrative services, such as customer service, security, tech, operational support, email and legal services; and (ix) other services designed to assist us in maximizing our business potential. We may provide these vendors with access to user information to carry out the services they are performing for you or for us. Those vendors may have additional or different privacy policies and/or Terms of Service. You should be sure that you read and agree to those policies and Terms.
(b) To Protect the Rights of Vincit and Others. To the fullest extent permitted by applicable law, we may also disclose your information when required to by law or if we believe in good faith that doing so is necessary or appropriate to: (i) protect or defend the rights, safety or property of Vincit, its affiliates, third parties or the general public (including through the enforcement of this Privacy Policy, our Terms of Service, and other applicable agreements and policies); (ii) comply with legal and regulatory obligations (e.g., pursuant to law enforcement inquiries, subpoenas or court orders); or (iii) to respond to claims that any content violates the rights of a third party. This includes exchanging information with other companies and organizations for fraud prevention, spam/malware protection, and other similar purposes. To the fullest extent permitted by applicable law, we have complete discretion in electing to make or not make such disclosures, and to contest or not contest any requests for such disclosures, all without notice to you.
(c) Business Transfer. We also reserve the right to disclose and transfer all information: (i) to a subsequent owner, co-owner or operator of the Site and/or our Services; or (ii) in connection with a merger, consolidation, restructuring, the sale of substantially all of our interests and/or assets or other corporate change, including during any due diligence process.
We may aggregate, de-identify, and/or anonymize any information collected through the Site(s) or Services such that such information is no longer linked to your personally identifiable information. We may use and share this aggregated and anonymized information (non-Personal Information) for any purpose, including without limitation, for research and marketing purposes, and may also share such data with our affiliates and third parties, including advertisers, promotional partners and others. ___
Your Choices About the Information We Collect
We give you many choices regarding our use and disclosure of your Personal Information for marketing purposes. (Please note that EU and California residents may have different options described below).
You may opt-out from:
  • Receiving electronic communications from us: If you no longer want to receive marketing-related emails from us on a going-forward basis, you may opt-out of receiving these marketing-related emails by sending a request for list removal to privacy@vincit.com or following the instructions for unsubscribing in the email. If you have provided your information to Vincit, and opt-out, Vincit will put in place processes to honor your request. This may entail keeping some information for the purpose of remembering that you have opted-out.
We will try to comply with your request(s) as soon as reasonably practicable.
  • Administrative Correspondence. Please also note that if you do opt-out of receiving marketing-related emails from us, we may still send you messages for administrative or other purposes directly relating to your use of the Services, and you cannot opt-out from receiving those messages.

Public Areas
Your use of areas of the Services that are intended for interaction with other users may reveal your name, and other personal information from your profile and may allow you to publish certain personal information about you. By choosing to use these areas, you understand and agree that anyone with access to those areas may access, copy and forward any information about you that is contained in or that you post to those areas. You should use care when disclosing any your personal information to strangers.

Visitors to the Site Outside of the United States
If you are visiting the Site from a location outside of the U.S., your connection will be through and to servers located in the U.S. All information you receive from the Site will be created on servers located in the U.S., and all information you provide will be maintained on web servers and systems located within the U.S. The data protection laws in the United States may differ from those of the country in which you are located, and your information may be subject to access requests from governments, courts, or law enforcement in the United States according to laws of the United States. By using the Site or providing us with any information, you consent to the transfer to, and processing, usage, sharing and storage of your information in the United States and in other countries, as set forth in this Privacy Policy.

Children’s Privacy
Vincit recognizes the importance of children’s safety and privacy. The Site(s) are not designed to attract children and are not intended for use by any children under the age of 13. We do not request, or knowingly collect, any personally identifiable information from children under the age of 13. If you are the parent or guardian of a child under 13 who has provided her or his information to us, please contact us at privacy@vincit.com to request the deletion of that information.

GDPR Privacy Rights
If you are a resident of or located within the European Union (“EU”) or European Economic Area (“EEA”), you have certain additional data protection rights under the General Data Protection Regulation (“GDPR”). These rights include:
  • The right to access, update or delete the information we have on you.
  • The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.
  • The right to object. You have the right to object to our processing of your Personal Information.
  • The right of restriction. You have the right to request that we restrict the processing of your personal information.
  • The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine- readable and commonly used format.
  • The right to withdraw consent. You also have the right to withdraw your consent at any time where we relied on your consent to process your personal information.
Legal Basis for Processing Personal Information under GDPR
Vincit’s legal basis for collecting and using the Personal Information described in this Privacy Policy depends on the Personal Information we collect and the specific context in which we collect it. Vincit may process your Personal Information because:
  • We need to perform a contract with you;
  • You have given us permission to do so;
  • The processing is in our legitimate interests and it is not overridden by your rights; or
  • To comply with the law.
Disclosure of Personal Information under GDPR-Legal Requirements
Vincit may disclose your Personal Information in the good faith belief that such action is necessary to:
  • To comply with a legal obligation
  • To protect and defend the rights or property of Vincit.
  • To prevent or investigate possible wrongdoing in connection with the Service
  • To protect the personal safety of users of the Service or the public
  • To protect against legal liability.
Disclosure for Law Enforcement
Under certain circumstances, Vincit may be required to disclose your Personal Information if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).
Retention of Personal Data
  • Vincit will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use Your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.
  • Vincit will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our Service, or we are legally obligated to retain this data for longer time periods.
If you are a resident of the EU or EEA, you may initiate a request to access, reject, correct, restrict, or erase your Personal Information, or where you may initiate a request for transfer of your Personal Information or initiate a request that we refrain from sending you marketing information by sending us a request at privacy@vincit.com and write “GDPR Request” in the subject line.
Please note that the above individual rights are not absolute, and we may be entitled to refuse requests where certain exceptions apply. Please note that where our processing of your Personal Information relies on your consent and where you then withdraw that consent, we may not be able to provide all or some aspects of our services to you and/or it may affect the provision of those services. Should you wish to raise a concern about our use of information (without prejudice to any other rights you may have), you have the right to do so with your local supervisory authority.

**PRIVACY NOTICE FOR CALIFORNIA RESIDENTS **
Vincit collects certain types of personal information about you during your relationship with Vincit as a user or visitor to the Sites. Under California law, if you are a resident of California, under certain circumstances, you have the right to request certain information that we collect about you, including:
  • The categories of Personal Information we have collected from you;
  • The categories of sources from which we collected the Personal Information;
  • The business purpose we have for collecting or sharing that Personal Information;
  • The categories of third parties with whom we share such Personal Information; and
  • The specific pieces of Personal Information we have collected about you.
In addition, you may request that we provide you with:
  • The categories of Personal Information that we sold about you, and the categories of third parties to whom the personal information was sold, by category or categories of Personal Information for each category of third parties to whom the information was sold;
  • The categories of Personal Information that we have disclosed about you for a business purpose;
  • The category or categories of consumers’ Personal Information that we have sold, or if we have not sold consumers’ Personal Information; and
  • The category or categories of consumers’ Personal Information that we have disclosed for a business purpose, or if we have not disclosed that information for a business purpose.
Please note that if we collected information about you for a single one-time transaction and do not keep that information in the ordinary course of business, that information will not be retained for purposes of a request under this section. In addition, if we have de-identified or anonymized data about you, we are not required to re-identify or otherwise link your identity to that data if it is not otherwise maintained that way in our records.
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
  • Deny you goods or services.
  • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
  • Provide you a different level or quality of goods or services.
  • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.
Right to Know Information
If you are a California resident and would like to request information about the Personal Information we have collected about you in the prior 12 months, please contact us at this email address privacy@vincit.com with “California CCPA Rights” in the subject line and provide your email address and state the nature of your request.
If applicable, we will provide the requested information free of charge once in a 12-month period, but please note that where we receive unfounded, excessive, or repetitive requests, we may elect to decline the request. Note also that we will not be able to provide information we do not ordinarily retain in the course of our regular business practices.
In order to verify your identity, we will request that you provide a signed declaration under penalty of perjury that you are a California resident and the consumer whose Personal Information is the subject of the request.
Right to Delete Information
The CCPA also gives you the right to request that we delete personal information we have collected about you and for us to direct service providers to do the same, with certain exceptions as set forth in the CCPA. Note that you may also delete certain Personal Information you have provided to us through your online account.
When processing a request to delete, we may erase some information and we may de-identify some information (when we de-identify information, we implement technical safeguards and business processes that prohibit re-identification, business processes to prevent inadvertent release of de-identified information and will make no attempt to re-identify the information).
If you are a California resident and would like to request that we delete your information, please contact us at this email address privacy@vincit.com include “California CCPA Rights” in the subject line and provide your email address and state the nature of your request.
In order to verify your identity, we will request that you provide a signed declaration under penalty of perjury that you are a California resident and the consumer whose Personal Information is the subject of the request.
Right to Opt-Out of the Sale of Personal Information
The CCPA also provides a right to California residents to request to opt-out of the sale of Personal Information.
Vincit does not sell your personal information for monetary compensation.
As indicated above, we may allow third-party advertising companies to collect data from visitors to our Services, including to better serve you more relevant advertisements. These online advertising practices (and certain analytics or similar activities), may potentially be considered “sales” under the CCPA under certain circumstances. You can limit this type of tracking through industry opt-outs and by limiting ad tracking on your mobile device.
You may also be able to limit the access these third-party advertising companies have to information about you when you use our Site by installing a browser or browser extension that can enable you to block the functionality of some tracking technologies.
If you use different computers or browsers, you may need to indicate your opt-out choices across those computers and browsers.

Your Nevada Privacy Rights
If you are a Nevada resident, you have the right to request certain information from us regarding the collection and sale of your personal information (as defined in Nevada Revised Statutes 603A.320) during your visit to our websites or when you otherwise interact with us online. If you have sought or acquired, by purchase or lease, any goods or services for personal, family, or household purposes from the Vincit Site, you may ask us to disclose whether we have sold (for monetary consideration) certain information about you (including your first and last name, physical address, email address, telephone number, social security number, an identifier that allows you to be contacted either physically or online, or other contact information that allows us to identify you personally).
As a Nevada resident, you may also request to opt out of us sharing such information about you. To make this inquiry, please submit a request in writing to privacy@vincit.com with “Nevada Privacy Rights” in the subject line. You must include your full name, email address, and attest that you are a Nevada resident by providing a Nevada postal address in your request. Please state whether you are requesting information and/or opting out.
We will process your request within 60 days, or we will let you know if we need additional time. We may require additional information to verify your identity before we can respond.

California / Delaware Do Not Track Disclosures
Do Not Track (“DNT”) is a web browser setting that requests that a web application disable its tracking of an individual user. When you choose to turn on the DNT setting in your browser, your browser sends a special signal to websites, analytics companies, ad networks, plug in providers, and other web services you encounter while browsing to stop tracking your activity. Various third parties are developing or have developed signals or other mechanisms for the expression of consumer choice regarding the collection of information about an individual consumer’s online activities over time and across third-party websites or online services (e.g., browser do not track signals), but there is no universally-agreed upon standard for what a company should do when it detects a DNT signal. Currently, we do not monitor or take any action with respect to these signals or other mechanisms. You can learn more about Do Not Track here: https://allaboutdnt.com]

International Data Transfers
Because Vincit works with global companies and technologies, we may transfer your Personal Information outside of the country in which it was originally provided. This may include transfers to third parties, such as service providers or affiliated entities who are location outside the United States or the European Union, where data protection laws may not offer the same level of protection as those in the U.S., E.U. or EEA. When we transfer personal data outside of these areas, we take steps to make sure that appropriate safeguards are in place to protect your Personal Information. Our transfers of your personal data outside of the E.U. are safeguarded by data processing agreements (“DPAs”) incorporating Standard Contractual Clauses. You may request a copy of the relevant portions of such agreements by contacting us at privacy@vincit.com. Please include the nature of your request in the subject line.

Updating Personal Information
We prefer to keep your Personal Information accurate and up to date. If you would like to change your contact information, please contact us at privacy@vincit.com.
If so, we will make good faith efforts to make requested changes in our then active databases as soon as reasonably practicable (but we may retain prior information as business records). Please note that it is not always possible to completely remove or delete all of your information from our databases and that residual data may remain on backup media or for other reasons, such as a legitimate business reason.
In addition, please note that if you implement a deletion request but later sign up for information or Services, your most recent request will control our information relationship with you.

Links
For your convenience, the Site and this Privacy Policy may contain links to other websites. Vincit is not responsible for the privacy practices, advertising, products, services, or the content of such other websites. None of the links on the Site should be deemed to imply that Vincit endorses or has any affiliation with the links.

Security
We incorporate commercially reasonable safeguards to help protect and secure your Personal Information. However, no data transmission over the Internet, mobile networks, wireless transmission, or electronic storage of information can be guaranteed 100% secure. As a result, we cannot guarantee or warrant the security of any information you transmit to or from our Site, and you provide us with your information at your own risk.

Questions / Changes in Privacy Policy
If you have questions or concerns with respect to our Privacy Policy, you may contact us at privacy@vincit.com. We may elect to change or amend our Privacy Policy; in such event, we will post the policy changes in our Privacy Policy on the Site, and they will become effective on the date posted. If you are concerned about how your personal information is used, please visit our Site often for this and other important announcements and updates.
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