We at ValueLabs, respect your personal data and we are committed to protecting and respecting your privacy. That is why, we have tried to make the information in this Privacy Policy understandable and clear, required by the law. This privacy policy tells you about the information we collect from you when you use our website, apps or our platform. With this policy, we are providing you with information about us, about why and how we use your data, and about the rights you have over your data.
“Customer” is hereby referred to as an entity that directly engages with ValueLabs AiDE to use our services. “Customer’s End Users” are hereby referred to as end-users who use customer platforms and thus use ValueLabs AiDE services indirectly.
We are committed to respecting and protecting the privacy of both Customer and Customer’s End Users and the personal information we may obtain through our services or other Company operations. Accordingly, we have created this Privacy Policy to inform all users about how we collect, use and share Customer information and personal information of Customer’s End Users, and about our customer information privacy practices in general.
ValueLabs AiDE’s privacy policy describes how we (“we” or “us”) collect and use information in connection with your access to and use of our website, apps, platform and related services. By accessing and/or using any of our services, you accept and signify your informed consent to the practices described in this Privacy Policy.
We operate out of our ValueLabs Inc., 200 South Wacker Drive 32nd Floor, Chicago, IL 60606 and ValueLabs (UK) Limited, 79 College Rd, Harrow Middlesex, HA1 1BD, UK. ValueLabs AiDE brings artificial intelligence to our clients/platform users and helps them achieve greater service efficiency. The chatbot systems supported by our platform analyze inbound messages and provide users with accurate responses. This reduces the average handling time by up to 80% and automates repetitive and recurring questions right after integration. The system is based on complex algorithms, trained on historical data, is constantly optimized during operational use so that future requirements can be processed more efficiently. For the purposes of the EU General Data Protection Regulation (the ‘GDPR’), ValueLabs AiDE is the ‘Data Controller’ and is responsible for your personal data in some cases while the ‘Data Processor’ in others. You can contact us by post at the above address or email us at dataprivacy@valuelabs.com.
We collect both the “personal information” and “non-personal information,” collectively defined as “information”. This policy describes the types of information we may collect from you or that you may provide when you visit the website, aideplatform.com.
This policy applies to information we collect:
Please read this policy carefully to understand our policies and practices regarding your information and how we treat the information. If you do not agree with our policies and practices, please do not use our website or Apps. By accessing or using this Website or the Apps, you agree to the privacy policy. This policy may change from time to time.
The type of information that we collect depends on how you use our products. We collect several types of information from and about users of our Website and Apps, including information:
Category of Personal Data What Information We Collect
ValueLabs collects the following types of data:
Customer Data
ValueLabs collects Personal Data from Customers relating to Customer accounts and management of them. As Customers navigate the ValueLabs services, we may also collect information through the use of commonly used information-gathering tools, such as cookies and Web beacons (“Web Site Navigational Information”). Web Site Navigational Information includes standard information from Customer’s Web browsers (such as browser type and browser language), their Internet Protocol (“IP”) address, and the actions they take on the ValueLabs services (such as the Web pages viewed, and the links clicked).
We may use Personal Data from Customers to provide products and/or services to Customers, collect payment for our products and/or services, administer sweepstakes and contests, enhance the operation of the ValueLabs AiDE services, improve our marketing and promotional efforts, analyze the use of the ValueLabs AiDE services, improve the ValueLabs AiDE services, and tailor the experience of Customers in using the ValueLabs AiDE services.
We may also use Personal Data to troubleshoot, resolve disputes, accomplish administrative tasks, contact Customers, enforce our agreements with Customers, including our Master SaaS Subscription Agreements or Terms of Service, and this Privacy Policy, comply with applicable law, and cooperate with law enforcement activities. The ValueLabs AiDE services may include social media features such as the Facebook “like” button or other associated social media buttons and widgets and such social media features which are hosted by a third party or directly on the ValueLabs AiDE services may collect Customers’ IP addresses and other information. Such interactions are governed by the applicable privacy policy of those social media features.
Customer’s End User Data
As part of the provision of the ValueLabs AiDE service to Customers, ValueLabs collects certain Personal Data and other, Non-Personal Data about Customer’s End Users as determined by the applicable Customer (“Customer’s End User Data”). ValueLabs does not control or otherwise approve any messages or requests for Customer’s End User Data made by a Customer to a Customer’s End User.
If Customer is using the GenAI Services, the Services may send applicable portions of the Customer content, including Customer’s End User Data in an anonymized form or as-is based on its requirements, to other applications or websites, including to third-party AI providers which are authorized by the Customer for the scope of its engagement with ValueLabs. By using the GenAI Services, the Customer authorizes and instructs ValueLabs to send its content to the applicable third-party AI provider, which will be handled in accordance with its terms once your content flows out of our environment. ValueLabs is not responsible for Customer content after it has been provided to a third-party AI provider since we will not have control over their environment.
Customer’s End Users should be aware that a customer can request such Customer’s End User Data from them in order to use the Customer’s website(s), web applications, API and/or mobile application(s) and that Customer’s End User Data may then be included in the information given to ValueLabs AiDE through your use of ValueLabs AiDE services. Therefore, Customer’s End Users should review the privacy policy of a customer’s website(s), web applications, API, and/or mobile application to assess the security of any information a Customer’s End User discloses. To the extent that ValueLabs does receive any Customer’s End User Data, ValueLabs shall make reasonable efforts, consistent with the terms of this Privacy Policy, to maintain the confidentiality of such Customer’s End User Data.
ValueLabs has no direct relationship to the Customer’s End Users whose Customer’s End User Data it processes and such Customer’s End User who seeks access, or who seeks to correct, amend, or delete inaccurate Customer’s End User Data should direct his or her query to the applicable Customer for removal. Once such Customer requests removal of such applicable Customer’s End User Data, ValueLabs will respond to such request within the agreed SLA during discussions with the customer.
ValueLabs’ Customers may electronically submit Customer’s End User Data to ValueLabs. ValueLabs will not review, share, distribute, or reference any such Customer’s End User Data except as provided in ValueLabs’ applicable agreement with Customer, or as may be required by applicable law.
ValueLabs acknowledges that Customer’s End Users have the right to access their Personal Data. If Personal Data pertaining to a Customer’s End User has been submitted to us by a customer, and a Customer’s End User wishes to exercise any rights it may have to access, correct, amend, or delete such Personal Data, the Customer’s End User should inquire with the Customer directly.
Non-Personal Data: “Non-Personal Data” is information that does not identify a specific person.
Website users
ValueLabs collects several types of information that is about you but individually does not identify you, information comprising communications with you, about your browsing sessions using the Website (Internet activity information), including, but not limited to, browsing history, search history, and information regarding a user’s interaction with the Website and/or geolocation information (based on IP address).
Non-Personal Data from Customers
ValueLabs may receive Non-Personal Data from Customers, which may include data such as the URL of the website a customer visited before participating in ValueLabs services, the URL of the website visited after participating in ValueLabs AiDE services, the type of browser the Customer is using, or general and/or aggregated location data that does constitute Personal Data. We, and/or our authorized Third-Party Service Providers (defined below), may automatically collect this information when Customers visit or use ValueLabs AiDE services through the use of electronic tools like Cookies and Web beacons or Pixel tags, as described below in this Privacy Policy.
We use Non-Personal Data to provide products and/or services to Customers, enhance the operation of ValueLabs AiDE services, troubleshoot, administer ValueLabs AiDE services, analyze trends, gather demographic information, comply with applicable law, and cooperate with law enforcement activities. We may also share this information with our authorized Third-Party Service Providers to measure the overall effectiveness of our products and services.
Non-Personal Data from Customer’s End Users
ValueLabs AiDE ’s Customers may electronically submit Non-Personal Data from Customer’s End Users to ValueLabs AiDE services. ValueLabs AiDE does not review, share, distribute, or reference any such Non-Personal Data except as provided in ValueLabs AiDE ’s applicable agreement with Customer, or as may be required by applicable law. ValueLabs AiDE uses such Non-Personal Data for the purpose of enhancing or providing the ValueLabs AiDE service.
Cookies: To facilitate and customize your experience with the ValueLabs AiDE service, we may store cookies on your computer or other similar device through which you access the ValueLabs AiDE services. A cookie is a text file containing small amounts of information, which is downloaded to your device when you first visit a website. A cookie helps us keep track of your visits & activities on a website. It asks permission to be stored on your computer. Once you agree, the stored file or the cookie helps analyze web traffic or lets you know when you visit a particular site. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences that are stored on the computer after you agree.
Other Tracking Devices: When you access ValueLabs AiDE website, pixel tags and web beacons generate a Non-Personally Identifiable notice of that action. Pixel tags allow us to measure and improve our understanding of visitor traffic and behavior on ValueLabs AiDE website, as well as give us a way to measure our promotions and performance. We may also utilize pixel tags and web beacons provided by our marketing partners for the same purposes.
We collect this information:
We use the information that we collect about you or that you provide to us, including any personal information:
We limit the collection and use of personal information to that which is necessary for the identified purpose (see the previous section - How we may use your information) and will not be used for any other purposes. Personal information used will be retained as per legal or contractual requirements in a secure system unless you requested us to dispose of your information.
We will delete your personal data as soon as we no longer have a need or a legal basis to process it.
We may disclose aggregated non-personally identifying information about our users, and information that does not identify any individual, without restriction.
We may disclose personal information that we collect, or you provide as described in this privacy policy:
The website pages can contain links to sites, services, and functions of third parties, subsidiaries, and affiliates that may use and conform to different rules and procedures of confidentiality provision from those stated here. ValueLabs is not responsible for the Policy of confidentiality of such resources.
We take the security of your personal data very seriously and have policies and procedures in place to ensure our compliance with the GDPR. We have implemented appropriate administrative, physical, and technical safeguards for the security and confidentiality of your information and use reasonable efforts to maintain physical and information security management programs to protect your information from loss, misuse, alteration, unauthorized access, and disclosure.
At ValueLabs, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.
Further, we use secure encryption technology to protect certain categories of information. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
Despite these precautions, no data security safeguards guarantee 100% security all of the time. Although we do our very best to protect your personal details, the transmission of information via the internet is not completely secure and we can’t and don’t guarantee the absolute security and protection of your data.
The safety and security of your information also depend on you where you are expected to follow safe online behavior while dealing with our websites, apps, or platform.
In accordance with applicable laws, we provide you with certain choices regarding the information you provide to us. Depending on where you reside, you may have the following rights:
If we cannot verify if you (or your authority to act on behalf of another person), we have the right to deny requests. While verifying your identity we shall generally avoid requesting additional information from you for purposes of verification. If, however, we cannot verify your identity from the information already maintained by us, we may request additional information from you, which shall only be used for the purposes of verifying your identity while you are seeking to exercise your rights, and for security or fraud-prevention purposes. We shall delete any new personal information collected for the purposes of verification as soon as practical after processing your request, except as required to comply with applicable legislation.
If you have a complaint about our use of your information, we would prefer you to contact us directly in the first instance so that we can address your complaint. However, you can also contact the respective authorities office of your region via their website or write to them.
To enable you(subscriber) to be compliant with your data protection obligations, we are prepared to sign an appropriate Data Processing Addendum (DPA). You can request a DPA from ValueLabs by sending an email to our DPO desk at dataprivacy@valuelabs.com. Once we get your request, we will review the same and if everything looks good to us, forward the DPA to you for your signature.
We store and process any personal data collected in connection with Data Subjects (who use our SaaS) in:
We store and process any personal data collected in connection with Data Subjects (who use our website or any other user) in:
For international transfers of personal data from the European Economic Area ("EEA"), the UK or Switzerland, we implement such measures as are necessary to ensure we provide appropriate safeguards for the transferred data, including through the use of Standard Contractual Clauses or another lawful transfer data transfer mechanism.
If you are a resident of the state of California, USA, California law may provide you with additional rights regarding our use of your personal information. Learn more about your California privacy rights, here.
Because of changes in technology and the growth and development of our business, or for other business reasons, we may need to change this privacy policy from time to time. It is our policy to post any changes we make to our privacy policy on this page. If we make material changes to how we treat our users’ personal information, we will post a copy of the new policy with its effective date on the Website and notify you through a notice on the Website home page. The date the privacy policy was last revised is identified at the top of the page. You are responsible for periodically visiting our website and this privacy policy to check for any changes.
You can reach us using the contact details given in the section “Who we are” if you:
Effective: 17th January, 2024
This privacy notice for ValueLabs LLP (doing business as ValueLabs ) ("we," "us," or "our"), describes how and why we might collect, store, use, and/or share ("process") your information when you use our services ("Services"), such as when you:
Questions or concerns? Reading this privacy notice will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at dataprivacy@valuelabs.com.
What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with us and the Services, the choices you make, and the products and features you use.
Do we process any sensitive personal information? We do not process sensitive personal information. / We may process sensitive personal information, when necessary, with your consent or as otherwise permitted by applicable law.
What are your rights? Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information. Learn more about your privacy rights.
How do I exercise my rights? The easiest way to exercise your rights is by filling out our data subject access request form available here: DSAR Form, or by contacting us. We will consider and act upon any request in accordance with applicable data protection laws.
In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent.
We process your personal information for a variety of reasons, depending on how you interact with our Services, including:
To facilitate account creation and authentication and otherwise manage user accounts. We may process your information so you can create and log in to your account, as well as keep your account in working order.
To deliver and facilitate delivery of services to the user. We may process your information to provide you with the requested service.
To respond to user inquiries/offer support to users. We may process your information to respond to your inquiries and solve any potential issues you might have with the requested service.
To send administrative information to you. We may process your information to send you details about our products and services, changes to our terms and policies, and other similar information.
To fulfill and manage your orders. We may process your information to fulfill and manage your orders, payments, returns, and exchanges made through the Services.
To enable user-to-user communications. We may process your information if you choose to use any of our offerings that allow for communication with another user.
To request feedback. We may process your information when necessary to request feedback and to contact you about your use of our Services.
To send you marketing and promotional communications. We may process the personal information you send to us for our marketing purposes, if this is in accordance with your marketing preferences. You can opt out of our marketing emails at any time. For more information, see "WHAT ARE YOUR PRIVACY RIGHTS?" below.
To deliver targeted advertising to you. We may process your information to develop and display personalized content and advertising tailored to your interests, location, and more. For more information see our Cookie Policy: Cookie Policy.
To protect our Services. We may process your information as part of our efforts to keep our Services safe and secure, including fraud monitoring and prevention.
To identify usage trends. We may process information about how you use our Services to better understand how they are being used so we can improve them.
To determine the effectiveness of our marketing and promotional campaigns. We may process your information to better understand how to provide marketing and promotional campaigns that are most relevant to you.
To save or protect an individual's vital interest. We may process your information when necessary to save or protect an individual’s vital interest, such as to prevent harm.
WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?
In Short: We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e., legal basis) to do so under applicable law, like with your consent, to comply with laws, to provide you with services to enter into or fulfill our contractual obligations, to protect your rights, or to fulfill our legitimate business interests.
If you are located in the EU or UK, this section applies to you.
The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. As such, we may rely on the following legal bases to process your personal information:
In legal terms, we are generally the “data controller” under European data protection laws of the personal information described in this privacy notice, since we determine the means and/or purposes of the data processing we perform. This privacy notice does not apply to the personal information we process as a “data processor” on behalf of our customers. In those situations, the customer that we provide services to and with whom we have entered into a data processing agreement is the “data controller” responsible for your personal information, and we merely process your information on their behalf in accordance with your instructions. If you want to know more about our customers' privacy practices, you should read their privacy policies and direct any questions you have to them.
If you are located in Canada, this section applies to you.
We may process your information if you have given us specific permission (i.e., express consent) to use your personal information for a specific purpose, or in situations where your permission can be inferred (i.e., implied consent). You can withdraw your consent at any time. Click here to learn more.
In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent, including, for example:
In Short: We may share information in specific situations described in this section and/or with the following categories of third parties.
Vendors, Consultants, and Other Third-Party Service Providers. We may share your data with third-party vendors, service providers, contractors, or agents (“third parties”) who perform services for us or on our behalf and require access to such information to do that work. We have contracts in place with our third parties, which are designed to help safeguard your personal information. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will also not share your personal information with any organization apart from us. They also commit to protect the data they hold on our behalf and to retain it for the period we instruct. The categories of third parties we may share personal information with are as follows:
We also may need to share your personal information in the following situations:
DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
In Short: We may use cookies and other tracking technologies to collect and store your information.
We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information. Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Policy: Cookie Policy URL.
HOW DO WE HANDLE YOUR SOCIAL LOGINS?
In Short: If you choose to register or log in to our Services using a social media account, we may have access to certain information about you.
Our Services offer you the ability to register and log in using your third-party social media account details (like your Facebook or Twitter logins). Where you choose to do this, we will receive certain profile information about you from your social media provider. The profile information we receive may vary depending on the social media provider concerned, but will often include your name, email address, friends list, and profile picture, as well as other information you choose to make public on such a social media platform.
We will use the information we receive only for the purposes that are described in this privacy notice or that are otherwise made clear to you on the relevant Services. Please note that we do not control, and are not responsible for, other uses of your personal information by your third-party social media provider. We recommend that you review their privacy notice to understand how they collect, use and share your personal information, and how you can set your privacy preferences on their sites and apps.
IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?
In Short: We may transfer, store, and process your information in countries other than your own.
Our servers are located in India. If you are accessing our Services from outside India, please be aware that your information may be transferred to, stored, and processed by us in our facilities and by those third parties with whom we may share your personal information (see " WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION? " above), in India, and other countries.
If you are a resident in the European Economic Area (EEA), United Kingdom (UK), or Switzerland, then these countries may not necessarily have data protection laws or other similar laws as comprehensive as those in your country. However, we will take all necessary measures to protect your personal information in accordance with this privacy notice and applicable law.
European Commission's Standard Contractual Clauses:
We have implemented measures to protect your personal information, including by using the European Commission's Standard Contractual Clauses for transfers of personal information between our group companies and between us and our third-party providers. These clauses require all recipients to protect all personal information that they process originating from the EEA or UK in accordance with European data protection laws and regulations. Our Data Processing Agreements that include Standard Contractual Clauses would be executed as applicable. We have implemented similar appropriate safeguards with our third-party service providers and partners and further details can be provided upon request.
Binding Corporate Rules:
These include a set of Binding Corporate Rules ("BCRs") established and implemented by us. Our BCRs have been recognized by EEA and UK data protection authorities as providing an adequate level of protection to the personal information we process internationally.
[EU-US] and [Swiss-US] Privacy Shield Framework[s]
We and the following entities and subsidiaries: ValueLabs comply with the [EU-US] and [Swiss-US] Privacy Shield Framework[s] as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information transferred from [the European Union (EU)], [the UK], and [Switzerland] to the United States. Although Privacy Shield is no longer considered a valid transfer mechanism for the purposes of [EU] and [Swiss] data protection law, in light of the judgment of the Court of Justice of the European Union in Case C-311/18 and opinion of the Federal Data Protection and Information Commissioner of Switzerland dated 8 September 2020, we will continue to comply with the principles of the [EU-US] and [Swiss-US] Privacy Shield Framework[s]. Learn more about the Privacy Shield program.
We adhere to and comply with the Privacy Shield Principles when processing personal information from [the EU], [UK], or [Switzerland]. If we have received your personal information in the United States and subsequently transfer that information to a third party acting as our agent, and such third party agent processes your personal information in a manner inconsistent with the Privacy Shield Principles, we will remain liable unless we can prove we are not responsible for the event giving rise to the damage.
With respect to personal information received or transferred pursuant to the Privacy Shield Framework[s], we are subject to the investigatory and enforcement powers of the US Federal Trade Commission ("FTC"). In certain situations, we may be required to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
If you have any questions or concerns relating to our Privacy Shield certification, please write to us at dataprivacy@valuelabs.com.. We commit to resolving any complaints or disputes about our collection and use of your personal information under the Privacy Shield. [However, if you have an unresolved complaint in connection with our certification, we commit to cooperating with the panel established by [the EU data protection authorities (DPAs)], [the UK Information Commissioner], and [the Swiss Federal Data Protection and Information Commissioner], as applicable, and to comply with the advice given by them in respect of the complaint. See the following list of EU DPAs.
HOW DO WE KEEP YOUR INFORMATION SAFE?
In Short: We aim to protect your personal information through a system of organizational and technical security measures.
We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.
DO WE COLLECT INFORMATION FROM MINORS?
In Short: We do not knowingly collect data from or market to children under 18 years of age.
We do not knowingly solicit data from or market to children under 18 years of age. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Services. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at dataprivacy@valuelabs.com.
WHAT ARE YOUR PRIVACY RIGHTS?
In Short: In some regions, such as the European Economic Area (EEA), United Kingdom (UK), Switzerland, and Canada, you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time.
In some regions (like the EEA, UK, Switzerland, and Canada), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; (iv) if applicable, to data portability; and (v) not to be subject to automated decision-making. In certain circumstances, you may also have the right to object to the processing of your personal information. You can make such a request by contacting us by using the contact details provided in the section “ HOW CAN YOU CONTACT US ABOUT THIS NOTICE? ” below.
We will consider and act upon any request in accordance with applicable data protection laws.
If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your Member State data protection authority or UK data protection authority.
If you are located in Switzerland, you may contact the Federal Data Protection and Information Commissioner.
Withdrawing your consent: If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us by using the contact details provided in the section " HOW CAN YOU CONTACT US ABOUT THIS NOTICE? " below or updating your preferences.
However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.
We DO NOT sell personal data to third parties or process personal data for targeted advertising. You can opt out from the selling of your personal data, targeted advertising, or profiling by disabling cookies in Cookie Preference Settings. To submit a request to exercise these rights described above, please email dataprivacy@valuelabs.com. or fill in the DSAR Form – EEA/UK.
Opting out of marketing and promotional communications: You can unsubscribe from our marketing and promotional communications at any time by clicking on the unsubscribe link in the emails that we send, replying “STOP” or “UNSUBSCRIBE” to the SMS messages that we send, or by contacting us using the details provided in the section " HOW CAN YOU CONTACT US ABOUT THIS NOTICE? " below. You will then be removed from the marketing lists — however, we may still communicate with you, for example to send you service-related messages that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes.
Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services. You may also opt out of interest-based advertising by advertisers on our Services. For further information, please see our Cookie Policy: Cookie Policy URL.
If you have questions or comments about your privacy rights, you may email us at dataprivacy@valuelabs.com.
CONTROLS FOR DO-NOT-TRACK FEATURES
Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.
DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
In Short: If you are a resident of California, Colorado, Connecticut, or Virginia, you are granted specific rights regarding access to your personal information.
What categories of personal information do we collect?
We have collected the following categories of personal information in the past twelve (12) months:
| Category | Examples | Collected |
|---|---|---|
| A. Identifiers | Contact details, such as real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address, and account name | YES |
| B. Personal information categories listed in the California Customer Records statute | Name, contact information, education, employment, employment history, and financial information | YES |
| C. Protected classification characteristics under state or federal law | Gender and date of birth | NO |
| D. Commercial information | Transaction information, purchase history, financial details, and payment information | NO |
| E. Biometric information | Fingerprints and voiceprints | NO |
| F. Internet or other similar network activity | Browsing history, search history, online behavior, interest data, and interactions with our and other websites, applications, systems, and advertisements | YES |
| G. Geolocation data | Device location | YES |
| H. Audio, electronic, visual, thermal, olfactory, or similar information | Images and audio, video or call recordings created in connection with our business activities | NO |
| I. Professional or employment-related information | Business contact details in order to provide you our Services at a business level or job title, work history, and professional qualifications if you apply for a job with us | YES |
| J. Education information | Student records and directory information | NO |
| K. Inferences drawn from collected personal information | Inferences drawn from any of the collected personal information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics | YES |
| L. Sensitive personal information | Account login information, drivers’ licenses, health data, precise geolocation, racial or ethnic origin, religious or philosophical beliefs, and sex life or sexual orientation | NO |
How do we use and share your personal information?
Learn about how we use your personal information in the section, “HOW CAN YOU CONTACT US ABOUT THIS NOTICE?”
We collect and share your personal information through:
Will your information be shared with anyone else?
We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider. Learn more about who we disclose personal information to in the section, "WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?"
We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be "selling" of your personal information.
The categories of third parties to whom we disclosed personal information for a business or commercial purpose can be found under "WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?"
We DO NOT sell or shared any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months. / We have sold or shared the following categories of personal information to third parties in the preceding twelve (12) months:
CALIFORNIA RESIDENTS
California Civil Code Section 1798.83, also known as the "Shine The Light" law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.
If you are under 18 years of age, reside in California, and have a registered account with Services, you have the right to request removal of unwanted data that you publicly post on the Services. To request removal of such data, please contact us using the contact information provided below and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Services, but please be aware that the data may not be completely or comprehensively removed from all our systems (e.g., backups, etc.).
CCPA Privacy Notice
The California Code of Regulations defines a "resident" as:
All other individuals are defined as "non-residents."
If this definition of "resident" applies to you, we must adhere to certain rights and obligations regarding your personal information.
Your rights with respect to your personal data
Right to request deletion of the data Request to delete
You can ask for the deletion of your personal information. If you ask us to delete your personal information, we will respect your request and delete your personal information, subject to certain exceptions provided by law, such as (but not limited to) the exercise by another consumer of his or her right to free speech, our compliance requirements resulting from a legal obligation, or any processing that may be required to protect against illegal activities.
Right to be informed Request to know
Depending on the circumstances, you have a right to know:
In accordance with applicable law, we are not obligated to provide or delete consumer information that is de-identified in response to a consumer request or to re-identify individual data to verify a consumer request.
Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights
We will not discriminate against you if you exercise your privacy rights.
Right to Limit Use and Disclosure of Sensitive Personal Information
We DO NOT process consumer’s sensitive personal information. If the business collects any of the following:
you have the right to direct that business to limit its use of your sensitive personal information to that use which is necessary to perform the Services.
Once a business receives your request, they are no longer allowed to use or disclose your sensitive personal information for any other purpose unless you provide consent for the use or disclosure of sensitive personal information for additional purposes.
Please note that sensitive personal Information that is collected or processed without the purpose of inferring characteristics about a consumer is not covered by this right, as well as the publicly available information.
To exercise your right to limit use and disclosure of sensitive personal Information, please email to dataprivacy@valuelabs.com. or fill in the DSAR Form – California.
Verification process
Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. These verification efforts require us to ask you to provide information so that we can match it with information you have previously provided us. For instance, depending on the type of request you submit, we may ask you to provide certain information so that we can match the information you provide with the information we already have on file, or we may contact you through a communication method (e.g., phone or email) that you have previously provided to us. We may also use other verification methods as the circumstances dictate.
We will only use personal information provided in your request to verify your identity or authority to make the request. To the extent possible, we will avoid requesting additional information from you for the purposes of verification. However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes. We will delete such additionally provided information as soon as we finish verifying you.
Other privacy rights
You can opt out from the selling or sharing of your personal information by disabling cookies in Cookie Preference Settings or follow the cookie policy.
To exercise these rights, you can contact us by email at dataprivacy@valuelabs.com.. If you have a complaint about how we handle your data, we would like to hear from you.
COLORADO RESIDENTS
This section applies only to Colorado residents. Under the Colorado Privacy Act (CPA), you have the rights listed below. However, these rights are not absolute, and in certain cases we may decline your request as permitted by law.
We DO NOT sell personal data to third parties or process personal data for targeted advertising. You can opt out from the selling of your personal data, targeted advertising, or profiling by disabling cookies in Cookie Preference Settings. To submit a request to exercise these rights described above, please email dataprivacy@valuelabs.com. or fill in the DSAR Form - Colorado.
If we decline to take action regarding your request and you wish to appeal our decision, please email us at dataprivacy@valuelabs.com. Within forty-five (45) days of receipt of an appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions.
CONNECTICUT RESIDENTS
This section applies only to Connecticut residents. Under the Connecticut Data Privacy Act (CTDPA), you have the rights listed below. However, these rights are not absolute, and in certain cases we may decline your request as permitted by law.
We DO NOT sell personal data to third parties or process personal data for targeted advertising. You can opt out from the selling of your personal data, targeted advertising, or profiling by disabling cookies in Cookie Preference Settings or follow the cookie policy. To submit a request to exercise these rights described above, please email dataprivacy@valuelabs.com. or fill in the DSAR Form - Connecticut.
If we decline to take action regarding your request and you wish to appeal our decision, please email us at dataprivacy@valuelabs.com. Within sixty (60) days of receipt of an appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions.
VIRGINIA RESIDENTS
Under the Virginia Consumer Data Protection Act (VCDPA):
"Consumer" means a natural person who is a resident of the Commonwealth acting only in an individual or household context. It does not include a natural person acting in a commercial or employment context.
"Personal data" means any information that is linked or reasonably linkable to an identified or identifiable natural person. "Personal data" does not include de-identified data or publicly available information.
"Sale of personal data" means the exchange of personal data for monetary consideration.
If this definition of "consumer" applies to you, we must adhere to certain rights and obligations regarding your personal data.
Your rights with respect to your personal data
We DO NOT sell personal data to third parties or process personal data for targeted advertising. Please see the following section to find out how you can opt out from further selling or sharing of your personal data for targeted advertising or profiling purposes.
Exercise your rights provided under the Virginia VCDPA
You can opt out from the selling of your personal data, targeted advertising, or profiling by disabling cookies in Cookie Preference Settings or follow the cookie policy.
You may contact us by email at dataprivacy@valuelabs.com. or fill in the DSAR Form - Virginia.
If you are using an authorized agent to exercise your rights, we may deny a request if the authorized agent does not submit proof that they have been validly authorized to act on your behalf.
Verification process
We may request that you provide additional information reasonably necessary to verify you and your consumer's request. If you submit the request through an authorized agent, we may need to collect additional information to verify your identity before processing your request.
Upon receiving your request, we will respond without undue delay, but in all cases, within forty-five (45) days of receipt. The response period may be extended once by forty-five (45) additional days when reasonably necessary. We will inform you of any such extension within the initial 45-day response period, together with the reason for the extension.
Right to appeal
If we decline to take action regarding your request, we will inform you of our decision and reasoning behind it. If you wish to appeal our decision, please email us at dataprivacy@valuelabs.com. Within sixty (60) days of receipt of an appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If your appeal is denied, you may contact the Attorney General to submit a complaint.
DO OTHER REGIONS HAVE SPECIFIC PRIVACY RIGHTS?
In Short: You may have additional rights based on the country you reside in.
Australia and New Zealand
We collect and process your personal information under the obligations and conditions set by Australia’s Privacy Act 1988 and New Zealand’s Privacy Act 2020 (Privacy Act).
This privacy notice satisfies the notice requirements defined in both Privacy Acts, in particular: what personal information we collect from you, from which sources, for which purposes, and other recipients of your personal information.
If you do not wish to provide the personal information necessary to fulfill their applicable purpose, it may affect our ability to provide our services, in particular:
At any time, you have the right to request access to or correction of your personal information. You can make such a request by contacting us by using the contact details provided in the section “ HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU? ”. You may contact us by email at dataprivacy@valuelabs.com. or fill in the DSAR Form – Australia/New Zealand
If you believe we are unlawfully processing your personal information, you have the right to submit a complaint about a breach of the Australian Privacy Principles to the Office of the Australian Information Commissioner and for a breach of New Zealand's Privacy Principles to the Office of New Zealand Privacy Commissioner.
Republic of South Africa
At any time, you have the right to request access to or correction of your personal information. You can make such a request by contacting us by using the contact details provided in the section “HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?”
If you are unsatisfied with the manner in which we address any complaint with regard to our processing of personal information, you can contact the office of the regulator, the details of which are:
The Information Regulator (South Africa)
General enquiries: enquiries@inforegulator.org.za
We DO NOT sell personal data to third parties or process personal data for targeted advertising. You can opt out from the selling of your personal data, targeted advertising, or profiling by disabling cookies in Cookie Preference Settings or follow the cookie policy. To submit a request to exercise these rights described above, please email dataprivacy@valuelabs.com. or fill in the DSAR Form – South Africa.
Indonesia, Malaysian, Singapore, and Thai Residents
Data subject rights under the PDPA include:
We DO NOT sell personal data to third parties or process personal data for targeted advertising. You can opt out from the selling of your personal data, targeted advertising, or profiling by disabling cookies in Cookie Preference Settings or follow the cookie policy. To submit a request to exercise these rights described above, please email dataprivacy@valuelabs.com or fill in the DSAR Form - Indonesia, Malaysian, Singapore, and Thai Residents.
India Residents
The 2023 India Digital Personal Data Protection Act (DPDPA) requires businesses to collect explicit user consent for the use of cookies and for other types of data processing.
Starting in June 2024, businesses cannot use cookies freely to collect website visitors' personal data for processing. The DPDPA is a comprehensive data protection law that significantly changes the privacy regulatory landscape in India and imposes significant new requirements on businesses, as well as penalties for non-compliance.
The cookie consent requirement is among the most important novelties the law brings to businesses operating within India.
Consent is one of the legal bases for data processing, according to the Indian DPDPA. When it comes to the use of cookies, consent is the only legal basis you can use.
Website operators, known as data fiduciaries under the law, can use cookies for the processing of personal data only if the user agrees with that.
The law relies on the opt-in principle, which means that the website must not use the cookies before getting explicit consent from the visitor.
The India Digital Personal Data Protection Act (DPDPA) 2023 is a comprehensive data protection law that regulates the processing of personal data in India. It is the first comprehensive data protection law in India, and it is based on the principles of fairness, transparency, and accountability.
The DPDPA applies to all organizations that process personal data in India, regardless of size or location. It also applies to organizations that process the personal data of Indian residents, even if the organization is located outside of India.
The DPDPA requires organizations to obtain consent from individuals before collecting or processing their personal data. Individuals have the right to access, correct, and delete their personal data. They also have the right to object to the processing of their personal data and to port their personal data to another organization.
Here are some of the key features of the DPDPA:
Consent-based processing: Organizations must obtain consent from individuals before collecting or processing their personal data.
Data subject rights: Individuals have the right to access, correct, and delete their personal data. They also have the right to object to the processing of their personal data and to port their personal data to another organization.
Data processing requirements: Organizations must process personal data in a fair, transparent, and accountable manner. They must also take appropriate measures to protect the security of personal data.
Data Protection Authority: The DPDPA establishes a Data Protection Board of India to oversee the implementation and enforcement of the law. The Data Protection Authority has the power to investigate complaints, issue orders, and impose fines for violations of the law.
The Indian data protection law also introduces the concept of a significant data fiduciary. This is defined as "any data fiduciary or class of data fiduciaries as may be notified by the Central Government under Section 10." The government has not yet announced which companies will be considered significant data fiduciaries, but it is likely that these will be big companies that process vast amounts of personal data. It's equivalent to the data processor or data controller for GDPR.
The DPDPA is a significant development for data protection in India. It is expected to have a positive impact on the privacy rights of individuals and to help build trust in the digital economy.
How to collect India's DPDPA consent properly
To obtain consent in accordance with the India DPDPA, you must ensure that the consent is:
What happens after collecting DPDPA consent?
Once Data Controller [ValueLabs] have collected explicit users' consent according to the DPDPA principles, you can use cookies and process data with their help.
Data fiduciaries must keep records of the consent obtained in case they need to prove compliance with the laws.
They also must allow the user, i.e., the data principal, to withdraw the consent at any time. When the user withdraws their consent, you must not process their data anymore.
What are the differences between the cookie consent requirements of the DPDPA and other data privacy laws?
Global businesses may wonder how the DPDPA compares to other data protection laws worldwide regarding cookie consent.
Compared to the General Data Protection Regulation (GDPR) of the EU, the greatest difference is in the granularity of the consent. The DPDPA does not require granular consent, but the GDPR does.
When you collect cookie consent from EU users, you must request specific consent for each specific purpose. The data subjects can provide or decline consent for each specific purpose. The same goes for the withdrawal of consent.
In India, general consent for the use of cookies is enough. There is no need to ask for separate consent for each purpose. While this may simplify the process of obtaining cookie approval, some users who don't like specific cookies may decline all your cookies altogether.
When you compare Indian law with the laws in the United States, such as the CCPA or the VCDPA, the greatest difference comes in the use of the opt-in principle in India. The US laws rely on the opt-out principle, meaning that businesses can use cookies until users opt out. In India, businesses must not use cookies before the explicit opt-in by the user.
We DO NOT sell personal data to third parties or process personal data for targeted advertising. You can opt out from the selling of your personal data, targeted advertising, or profiling by disabling cookies in Cookie Preference Settings or follow the cookie policy. To submit a request to exercise these rights described above, please email dataprivacy@valuelabs.com or fill in the DSAR Form - India.
DO WE MAKE UPDATES TO THIS NOTICE?
In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.
We may update this privacy notice from time to time. The updated version will be indicated by an updated "Revised" date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.
HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
If you have questions or comments about this notice, you may contact our Data Protection Officer (DPO), by email at dataprivacy@valuelabs.com , or by post to:
ValueLabs Inc.
200 South Wacker Drive 32nd Floor,
Chicago, IL 60606
If you are a resident in the European Economic Area or United Kingdom, we are the "data controller" of your personal information. You can contact us directly regarding our processing of your information, by email at dataprivacy@valuelabs.com.
If you have any further questions or comments, you may also contact us by post at the following corporate address:
ValueLabs Inc.
200 South Wacker Drive 32nd Floor,
Chicago, IL 60606
HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?
Based on the applicable laws of your country, you may have the right to request access to the personal information we collect from you, change that information, or delete it. To request to review, update, or delete your personal information, please fill in the respective DSAR Form.