Privacy Policy
- To see our privacy statement click here.
- To see our General Data Protection Regulation (GDPR) Addendum click here.
- To see our California Privacy Rights Act (CPRA) compliance statement click here.
- To see our Virginia Consumer Data Protection Act (VCDPA) Privacy Notice click here.
- To see privacy information for individuals located in Canada click here.
If experiencing any difficulties accessing our website content, please reach out to hr@vaco.com for further assistance and/or alternative arrangements.
Introduction
Vaco, LLC and its affiliates and subsidiaries (“Company”, “us”, “our”, or “we”) have created this privacy policy in order to demonstrate our firm commitment to your privacy. This privacy policy will inform you of our information gathering and dissemination practices when you visit our websites using this privacy policy. This policy also covers information we collect about you offline, from third parties, or when you visit one of our locations or in person or contact us by phone. Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it.
Changes to this Privacy Policy.
The terms of this policy may change, so please check it from time to time. We reserve the right to amend this privacy policy at our discretion and at any time. This version was last updated on December 28, 2022. We keep our privacy policy under regular review, and we will place any updates on this web page. When we make changes to this privacy policy, we will post the updated notice on our websites and update the notice’s effective date. Your continued use of our website(s) following the posting of changes constitutes your acceptance of such changes.
Who Does This Privacy Policy Apply To?
This policy generally applies to all individuals with whom we interact or from whom we collect and use their information. If you are an EU data subject, a California resident, Virginia resident, or an individual located in Canada, please also refer to the sections below or click on the hyperlinks that will provide additional information and rights you may have with respect to your personal information:
- For EU Data Subjects
- California Privacy Rights Act (CPRA) Privacy Notice
- Virginia Consumer Data Protection Act (VCDPA) Privacy Notice
- For Individuals in Canada
Information Collection
We collect several types of information from and about you, including:
- Information Provided by You, such as name, address, email address, telephone number, Social Security number, employment history, skills, qualifications, remuneration level, whether you have a disability, and other personally identifying information. For example, we collect information from you when you fill out a form on our website, provide us your resume, or provide us your information at a job fair;
- Information Collected Automatically as you navigate through our websites. Information collected automatically may include usage details, domain address, IP addresses, internet browser, operating system, your internet connection, the equipment you use to access our website, and information collected through cookies.
- Information from Third Parties about you. As part of our services, we may also collect information from certain job application websites, such as LinkedIn and Monster.com.
Social Security Number Protection Policy
Social Security numbers are classified as “Restricted” information under our policies. As such, Social Security numbers may only be accessed by and disclosed to our associates and others with a legitimate business purpose in accordance with applicable laws and regulations. Social Security numbers, whether in paper or electronic form, are subject to physical, electronic, and procedural safeguards. These restrictions apply to all Social Security numbers collected or retained by us.
Information Use
We may use information that we collect about you or that you provide to us:
- to present our websites and their content to you and to improve our websites (we continually strive to improve our website offerings based on the information and feedback we receive from you);
- to provide you with information or services that you request from us, including processing and reviewing your job application and assessing your suitability for employment;
- to provide you with notices about your account and to improve customer service (your information helps us to more effectively respond to your customer service requests and support needs);
- to carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection;
- to notify you about changes to our website or any products or services we offer or provide through it;
- to allow you to participate in interactive features on our website and to personalize your experience (your information helps us to better respond to your individual needs);
- to conduct surveys or raffles;
- to enable communications to you regarding our services such as email and phone;
- to work with marketing partners to provide you with products or services that may be of interest to you;
- to fulfill any other purpose for which you provide it and in any other way we may describe when you provide the information; and
- for any other purpose with your consent.
Disclosure of Your Information
We may disclose information that we collect about you or that you provide us directly as described in this privacy policy:
- to our subsidiaries, affiliates, and internal network of companies;
- to contractors, service providers, and other third parties we use to support our business;
- to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Company’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Company about our website users is among the assets transferred;
- to fulfill the purpose for which you provide it. For example, to facilitate an employment contract;
- for any other purpose disclosed by us when you provide the information;
- with your consent.
We may also disclose your personal information:
- to comply with any court order, law, or legal process, including to respond to any government, regulatory, or law enforcement request;
- to enforce or apply our agreements, including providing our products and services; and
- if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Company, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
We may disclose aggregated information about our users and deidentified data or information that does not identify an individual.
Security
We have implemented reasonable measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure.
We store your information on servers located in the United States.
Cookies and Other Technologies
We use first- and third-party cookies and other various technologies to help us provide information to you more effectively. A cookie is a unit of data stored on the user’s hard drive that helps us remember you and your preferences.
You can refuse to use cookies by turning them off in your browser. You do not need cookies turned on to use our websites. However, a drawback to this is that you will be limited in some areas of our sites and may notice some impact on overall functionality.
Third-Party Links
This website may contain links to other third-party websites. Please be aware that we are not responsible for the content or privacy practices of such other sites. We encourage our users to be aware when they leave our site and to read the privacy statements of any other site that collects personally identifiable information.
Children Under the Age of 13
Our website is not intended for children under 13 years of age. No one under age 13 may provide any information to or on the website. We do not knowingly collect personal information from children under 13. If you are under 13, do not use or provide any information to or on this website or through any of its features. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us in one of the ways provided in the Contact Information section, below.
Do Not Track
Vaco does not respond to web browser “do not track” signals or other mechanisms. Other parties may collect personally identifiable information about your activities over time and across different websites when you use our website or services.
Changes to Our Privacy Policy
It is our policy to post any changes we make to our privacy policy on this page.
Contacting Us
If there are any questions regarding this privacy policy, you may contact us via e-mail at privacy@vaco.com or mail at the below address:
Address:
Vaco, LLC
5501 Virginia Way
Suite 120
Brentwood, Tennessee 37027
General Data Protection Regulation (GDPR) Addendum
Effective Date: June 1, 2020 | Last Revised on: December 28, 2022 | Last Reviewed on: December 28, 2022
Aggregate and Special Categories of Personal Information
We collect, use, and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal information but is not considered personal information in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your personal information to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal information so that it can directly or indirectly identify you, we treat the combined data as personal information which will be used in accordance with this privacy policy.
We do not collect Special Categories of personal information about you unless there is a clear reason for doing so i.e., conducting criminal background checks for employment purposes. We will only collect and store special categories of personal information with your consent or other valid justification.
Children Under 16
We do not collect personal information on individuals under 16 without parental consent. If we become aware that a child under 16 has provided us with personal information, we will take steps to require that consent is given or authorized by the holder of parental responsibility over the child. If you become aware that a child under the age of 16 has provided Us with Personal Information without parental consent, please contact us at privacy@vaco.com.
How We Use Your Personal Information
We are the sole owner of the information collected about you. We will not sell, swap, or rent this information.
The legal basis that we rely on for processing your information will depend upon the circumstances in which it is being collected and used, but will in most cases fall into one of the following categories:
- where you have provided your consent to allow us to use your data in a certain way;
- where the processing is necessary to carry out for the performance of a contract with you;
- where the processing is necessary in order for us to comply with a legal obligation; or
- where it is in our legitimate interests to perform our functions, for example, sending you administrative communications where our legitimate interest is to provide services to you.
Company uses Internet Protocol addresses to analyze trends, administer our websites, track user movement, and gather broad demographic information for aggregate use. Internet Protocol addresses are not linked to personally identifiable information.
Marketing Communications
Depending on your relationship with us or where you give us your consent, we will also use your personal information in order to send you marketing communications in connection with marketing activities, products, and services.
You decide how you want us to contact you, whether by mail, email or by phone and you can update your communication preferences at any time by contacting us at the Contact Details below.
Data Profiling and Analysis
We may also carry out analysis of the personal information we collect directly or indirectly from you (including from your interactions with our websites and request of certain services), third party sources, and publicly available information to create a profile of your interests, characteristics, and preferences. This is for the purposes of sending you promotional messages, marketing, advertising, and other information that we believe may interest you. Please let us know if you would prefer us not to process your data in this way by contacting us at privacy@vaco.com.
How We Share and Transfer Your Personal Information
Within the Vaco Network
We may share information within the Vaco corporate family of companies that (of which all share common ownership or control) to help us maintain websites, communicate with you, provide our products and services, and conduct further data processing.
Service Providers and Business Partners
We may share your information with certain outside vendors and service providers in order to ensure the adequate performance of our services or the provision of our products to you. Service providers may help us with:
- information processing;
- fulfilling customer orders;
- delivering products to you;
- managing and enhancing customer data;
- reviewing and assessing employment backgrounds and qualifications;
- providing customer service, advertising, or payment services;
- assessing your interest in our products and services, and
- conducting research or satisfaction surveys.
Legal Requirements
Notwithstanding the foregoing, we will consider, and may release, personally identifiable information to third parties: (1) to comply with valid legal requirements such as a law, regulation, search warrant, subpoena, or court order; or (2) in special cases, such as a physical threat to you or others.
With Your Consent
We may share your personal information other than as described in this policy if we notify you and you consent to the sharing.
International Transfers
Given that the Internet is a global environment, using it to collect and process personal information necessarily involves the transmission of data on an international basis. This means for instance that data you pass to us may be processed outside the European Economic Area (EEA). In such cases where such transfer occurs, we endeavor to maintain an adequate level of protection in accordance with General Data Protection Regulation (“GDPR”), including, where appropriate, requiring contractual commitments between companies transferring personal information, as these clauses bind the parties and require them to protect the privacy and security of the data.
Third-Party Links
This website may contain links to other sites, not owned, associated, or managed by us. Please be aware that while we try our best to only link to reputable websites, we are not responsible for the privacy practices of such other sites. Users are encouraged that, when they leave our site, they should read the privacy statements of each website that collects personally identifiable information.
Data Security and Access
We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used, or accessed in an unauthorized way, altered, or disclosed. In addition, 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.
We have put in place procedures to deal with any suspected personal information breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
Data Retention
We will retain your personal information for the period necessary to fulfill purposes outlined in this policy, unless a longer retention period is required or permitted by law, or you provide consent for a longer retention period. For example, we may ask you if you would like us to retain your information for future employment opportunities.
Correction/Updating Personal Information
You can help us keep our records up to date by telling us when your contact details and other personal information change. You can also change your mind at any time about how we contact you or ask us to stop contacting you altogether.
Please contact us to make changes at privacy@vaco.com or via the address below:
- Vaco UK Limited, Hamilton House, Mabledon Place, London, WC1H 988
Your Rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. If you wish to exercise any of the rights set out below, please email us at privacy@vaco.com. You have the right to:
- Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
- Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us to continue to process it. You also have the right to ask us to delete or remove your personal information where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal information for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which overrides your rights and freedoms.
- Request restriction of processing of your personal information. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Request the transfer of your personal information to you or to a third party. We will provide to you, or a third party you have chosen, your personal information in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to draw up a contract with you.
- Withdraw consent at any time where we are relying on consent to process your personal information. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal information (or to exercise any of your other rights). This is a security measure to ensure that personal information is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Contact Details
If you have any questions, comments, or suggestions, please let us know by contacting us:
- By email: privacy@vaco.com
You also have the right to lodge a complaint at any time with your member state data protection authority for data protection issues. We would, however, appreciate the opportunity to handle your concerns before you contact your authority, so please contact us in the first instance.
California Privacy Rights Act (CPRA) Privacy Notice
Effective Date: January 1, 2023 | Last Revised on: January 1, 2023 | Last Reviewed on: January 1, 2023
This section applies only to those who reside in the State of California.
The purpose of this CPRA Privacy Policy and Notice at Collection is to provide California residents, at or before the time we collect your personal information, with a comprehensive description of our online and offline practices regarding the collection, use, disclosure, and sale of personal information and of the rights of consumers regarding your personal information.
We collect Personal Data from Consumers and comply with the California Privacy Rights Act (“CPRA”). This California Privacy Notice applies to California residents (“Consumers,” “you,” or “your”).
For the purposes of this California Privacy Notice, “Personal Data” means information that is linked or reasonably linkable to a particular individual or household. However, the following categories of information are not Personal Data:
- Publicly available information;
- Deidentified or aggregated data; or
- Information otherwise excluded from the scope of the CPRA.
This Privacy Notice provides the following information to California Consumers:
- Categories of Personal Data we collect;
- Purposes for which we use Personal Data;
- Categories of Personal Data we disclose to third parties;
- Categories of third parties to which we disclose Personal Data; and
- How Consumers can exercise their rights under the CPRA:
- The rights to access, correct, or delete Personal Data;
- The right to obtain a portable copy of Personal Data;
- The right to limit the use of sensitive personal data in certain circumstances; and
- The rights to opt out of the sharing of Personal Data for behavioral advertising, sales of personal data, or certain profiling.
Categories of Non-Sensitive Personal Data
The table below outlines the non-sensitive categories of Personal Data Vaco, LLC collects about Consumers and whether and how they are disclosed to third parties.
We collect Non-Sensitive Personal Data from the following sources:
- Directly from our users
- From our affiliates
- From our business partners
| Category of Personal Data: Identifiers |
|---|
| Examples |
| Identifiers may contain the following: Real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name. |
| Purpose(s) |
| To present our websites and their content to you and to improve our websites (we continually strive to improve our website offerings based on the information and feedback we receive from you); |
| To provide you with information or services that you request from us, including processing and reviewing your job application and assessing your suitability for employment; |
| To provide you with notices about your account and to improve customer service (your information helps us to more effectively respond to your customer service requests and support needs); |
| To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection; |
| To notify you about changes to our website or any products or services we offer or provide though it; |
| To allow you to participate in interactive features on our website and to personalize your experience (your information helps us to better respond to your individual needs); |
| To enable communications to you regarding our services such as email and phone; |
| To work with marketing partners to provide you with products or services that may be of interest to you; |
| To fulfill any other purpose for which you provide it and in any other way we may describe when you provide the information; and for any other purpose with your consent. |
| Targeted Advertising |
| We do not engage in targeted advertising or share Personal Information for targeted advertising purposes. |
| Sale |
| We do not sell Personal Information to anyone. |
| Sharing |
| This data may be shared with Affiliates and Business Partners. |
Categories of Sensitive Personal Data
The table below outlines the categories of Sensitive Personal Data Vaco, LLC collects about Consumers and whether they are shared with third parties. Vaco, LLC obtains affirmative consent from Consumers to process the Sensitive Personal Data, in compliance with applicable law.
We collect Sensitive Personal Data from the following sources:
- Directly from our users
- From our affiliates
- From our business partners
| Category of Sensitive Personal Data: Sensitive Category Data |
|---|
| Examples |
| Sensitive Category Data may contain the following: race, religion, national origin, disability, sexual orientation, medical condition, ancestry, pregnancy (includes childbirth, breastfeeding and/or related medical conditions), social security, driver’s license, state identification card, or passport number. |
| Purpose(s) |
| To present our websites and their content to you and to improve our websites (we continually strive to improve our website offerings based on the information and feedback we receive from you); |
| To provide you with information or services that you request from us, including processing and reviewing your job application and assessing your suitability for employment; |
| To provide you with notices about your account and to improve customer service (your information helps us to more effectively respond to your customer service requests and support needs); |
| To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection; |
| To notify you about changes to our website or any products or services we offer or provide though it; |
| To allow you to participate in interactive features on our website and to personalize your experience (your information helps us to better respond to your individual needs); |
| To enable communications to you regarding our services such as email and phone; |
| To work with marketing partners to provide you with products or services that may be of interest to you; |
| To fulfill any other purpose for which you provide it and in any other way we may describe when you provide the information; and for any other purpose with your consent; |
| To perform the employment (or other) contract requisites, and to comply with legal obligations, where applicable. |
| Targeted Advertising |
| We do not engage in targeted advertising or share Personal Information for targeted advertising purposes. |
| Sale |
| We do not sell Personal Information to anyone. |
| Sharing |
| This data may be shared with Affiliates and Business Partners. |
| Retention Period |
| Vaco, LLC retains Sensitive Category Data either (1) when it is no longer needed or (2) when required in compliance with regulatory mandates, whichever is earlier. |
Use of Personal Data
We use Personal Data for the purposes described above. Personal Data may also be used or disclosed as otherwise permitted or required by applicable law.
Disclosing Personal Data
We share Personal Data with the following categories of third parties:
- Affiliates: We may share your information with our affiliates, subsidiaries, and representatives as part of providing our services.
- Our Business Partners: We may share relevant personal data with our business partners to provide you with exclusive offers for products and services that may interest you.
See the tables above for more details about how different categories of Personal Data are shared.
We do not sell Personal Data to anyone.
Notice of Financial Incentive
The purpose of this notice of financial incentive is to explain to you the material terms of a financial incentive or price or service difference that we are offering so that you may make an informed decision on whether to participate.
We conduct raffles during job fairs or other in-person events to collect information from individuals with the incentive that these individuals may win a prize. Participation in these raffles is completely voluntary, and you may participate if you are at an event and inform us of your intended participation. However, you may only participate if you provide us with your contact details upon our request. If you decide later on you do not want to participate, you may withdraw at any time by communicating with us at the applicable job fair or event. We value all visitors and potential customers, and your involvement helps us estimate the level of interest individuals like yourself have in our products and services.
Exercising Your Personal Data Rights
California Consumers have the following rights under the CPRA:
- The rights to access, correct, or delete Personal Data;
- The right to obtain a portable copy of Personal Data;
- The right to limit the use of Sensitive Personal Data in certain circumstances; and
- The rights to opt out of the sharing of Personal Data for behavioral advertising, sales of personal data, or certain profiling.
If you are a California Consumer, you can submit a request to exercise your personal data rights and/or an opt-out request under the CPRA either by calling us at our toll-free number, 844-880-8226, or by e-mail at privacy@vaco.com.
To protect your privacy, we may need to authenticate your identity before we respond to your rights request. We will use commercially reasonable efforts to verify your identity for this purpose. Any information you provide to authenticate your identity will only be used to process your rights request. Please be aware that we do not accept or process rights requests through other means (e.g., via fax or social media).
After submitting your request online, you will receive a follow-up email, which may include a link you must click on in order to verify your identity. If you do not click on that link, we may be unable to complete your request due to lack of verification. It is important that you provide a valid email address in order for us to be able to process your request. We will respond to your rights request within 45 days, though in certain cases we may inform you that we will need up to another 45 days to act on your request.
If we suspect fraudulent or malicious activity on or from your account, we will delay taking action on your request until we can appropriately verify your identity and the request as authentic. Also note that each of the rights are subject to certain exceptions. We reserve the right to decline to process, or charge a reasonable fee for, requests from a Consumer that are manifestly unfounded, excessive, or repetitive.
Please note that, in responding to your request, we are not permitted to disclose or provide you with, to the extent we collect such information, your Social Security number, driver’s license number or other government-issued identification number, financial account number, any health insurance or medical identification number, an account password, security questions and answers, or unique biometric data generated from measurements or technical analysis of human characteristics. However, we will inform you with sufficient particularity that we have collected the type of information without disclosing the actual data.
Requests to Know or Delete for Child Under the Age of 13: We do not knowingly collect information of minors under the age of 13.
Using an Authorized Agent to Submit a Request
Only you, or a natural person or a business entity registered with the Secretary of State to conduct business in California that you have authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. If you use an authorized agent, you may provide a power of attorney executed pursuant to California Probate Code sections 4000 to 4465. If a power of attorney that meets those provisions is not submitted, you will be required to provide the authorized agent signed permission to submit a request, verify your identity directly with us, and directly confirm with us that you provided the authorized agent permission to submit the request.
An authorized agent request can be submitted to privacy@vaco.com with the required documentation along with your name, telephone number, and e-mail address for verification.
Limiting the Use of Sensitive Personal Data
The CPRA provides a right to limit some uses of Sensitive Personal Data. In particular, you may direct companies not to use Sensitive Personal Data except as necessary to provide goods or services you have requested.
You may submit a request to limit the use of your sensitive Personal Data by submitting a rights request as described above.
Contact for More Information
If you have any questions or comments about this notice, the ways in which we collect and use your information, your choices, and rights regarding such use, or wish to exercise your rights under California Privacy law, please do not hesitate to contact us at:
Toll-Free Phone: 844-880-8226
Email: privacy@vaco.com
Postal Address:
Vaco Global Headquarters
5501 Virginia Way #120
Brentwood, TN 37027
Attn: Director/Head of Security, Compliance & Risk
Virginia Consumer Data Protection Act (VCDPA) Privacy Notice
Effective Date: January 1, 2023 | Last Revised on: January 1, 2023 | Last Reviewed on: January 1, 2023
We collect Personal Data from Consumers as a Controller under the Virginia Consumer Data Protection Act, as amended, or superseded from time to time (“VCDPA”). This VCDPA Privacy Notice applies to Virginia residents (“Consumers,” “you,” or “your”).
For the purposes of this VCDPA Privacy Notice, “Personal Data” means information that is linked or reasonably linkable to a particular individual. However, the following categories of information are not Personal Data:
- Publicly available information;
- Deidentified data; or
- Information otherwise excluded from the scope of the VCDPA.
This Privacy Notice provides the following information to Virginia Consumers:
- Categories of Personal Data we collect;
- Categories of Personal Data we share with third parties;
- Purposes for which we use Personal Data;
- Categories of third parties with whom we share Personal Data; and
- How Consumers can exercise their rights under the VCDPA:
- The rights to access, correct, or delete Personal Data;
- The right to obtain a portable copy of Personal Data; and
- The right to opt out of targeted advertising, sales of personal data, or certain profiling.
Categories of Non-Sensitive Personal Data
The table below outlines the categories of Personal Data Vaco, LLC collects about Consumers and whether they are shared with third parties.
We collect Non-Sensitive Personal Data from the following sources:
- Directly from our users
- From our affiliates
- From our business partners
| Category of Personal Data: Identifiers |
|---|
| Examples |
| Identifiers may contain the following: real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name. |
| Purpose(s) |
| To present our websites and their content to you and to improve our websites (we continually strive to improve our website offerings based on the information and feedback we receive from you); |
| To provide you with information or services that you request from us, including processing and reviewing your job application and assessing your suitability for employment; |
| To provide you with notices about your account and to improve customer service (your information helps us to more effectively respond to your customer service requests and support needs); |
| To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection; |
| To notify you about changes to our website or any products or services we offer or provide though it; |
| To allow you to participate in interactive features on our website and to personalize your experience (your information helps us to better respond to your individual needs); |
| To enable communications to you regarding our services such as email and phone; |
| To work with marketing partners to provide you with products or services that may be of interest to you; |
| To fulfill any other purpose for which you provide it and in any other way we may describe when you provide the information; and for any other purpose with your consent. |
| Targeted Advertising |
| We do not engage in targeted advertising or share this data for targeted advertising purposes. |
| Sale |
| This data is not sold to third parties. |
| Sharing |
| This data may be shared with Affiliates and Business Partners. |
| Category of Personal Data: Professional Information |
|---|
| Examples |
| Professional Information may contain the following: employment history, salary. |
| Purpose(s) |
| To provide you with information or services that you request from us, including processing and reviewing your job application and assessing your suitability for employment; |
| To fulfill any other purpose for which you provide it and in any other way we may describe when you provide the information; and for any other purpose with your consent. |
| Targeted Advertising |
| We do not engage in targeted advertising or share this data for targeted advertising purposes. |
| Sale |
| This data is not sold to third parties. |
| Sharing |
| This data may be shared with Affiliates and Business Partners. |
| Category of Personal Data: Educational Information |
|---|
| Examples |
| Educational Information may contain the following: attendance, grades, proof of completion. |
| Purpose(s) |
| To provide you with information or services that you request from us, including processing and reviewing your job application and assessing your suitability for employment; |
| To fulfill any other purpose for which you provide it and in any other way we may describe when you provide the information; and for any other purpose with your consent. |
| Targeted Advertising |
| We do not engage in targeted advertising or share this data for targeted advertising purposes. |
| Sale |
| This data is not sold to third parties. |
| Sharing |
| This data may be shared with Affiliates and Business Partners. |
Categories of Sensitive Personal Data
The table below outlines the categories of Sensitive Personal Data Vaco, LLC collects about Consumers and whether they are shared with third parties. Vaco, LLC obtains affirmative consent from Consumers to process the Sensitive Personal Data, in compliance with applicable law.
We collect Sensitive Personal Data from the following sources:
- Directly from our users
- From our affiliates
- From our business partners
| Category of Sensitive Personal Data: Protected Category Data |
|---|
| Examples |
| Protected Category Data may contain the following: race, religion, national origin, disability, sexual orientation, medical condition, ancestry, pregnancy (includes childbirth, breastfeeding and/or related medical conditions). |
| Purpose(s) |
| To provide you with information or services that you request from us, including processing and reviewing your job application and assessing your suitability for employment; |
| To fulfill any other purpose for which you provide it and in any other way we may describe when you provide the information; and for any other purpose with your consent; |
| To perform the employment (or other) contract requisites, and to comply with legal obligations, where applicable. |
| Targeted Advertising |
| We do not engage in targeted advertising or share this data for targeted advertising purposes. |
| Sale |
| This data is not sold to third parties. |
Use of Personal Data
We use Personal Data for the purposes described above. Personal Data may also be used or disclosed as otherwise permitted or required by applicable law.
Sharing Personal Data
We share Personal Data with the following categories of third parties:
- Processors: We use processors to securely handle Personal Data on our behalf and only on our instructions; these companies may not use your Personal Data for their own purposes.
- Affiliates: We may share your information with our affiliates, subsidiaries, and representatives as part of providing our services.
- Our Business Partners: We may share relevant personal data with our business partners to provide you with exclusive offers for products and services that may interest you.
See the tables above for more details about how different categories of Personal Data are shared.
We do not sell Personal Data to anyone.
Exercising Your Personal Data Rights
Virginia Consumers have the following rights under the VCDPA:
- The rights to access, correct, or delete Personal Data;
- The right to obtain a portable copy of Personal Data; and
- The right to opt out of targeted advertising, sales of personal data, or profiling.
If you are a Virginia Consumer, you can submit a request to exercise your personal data rights and/or an opt-out request under the VCDPA either by calling us at our toll-free number, 844-880-8226, or by e-mail at privacy@vaco.com. You may submit a rights request free of charge up to two times per year. To protect your privacy, you must authenticate your identity before we respond to your rights request. We will use commercially reasonable efforts to verify your identity for this purpose. Any information you provide to authenticate your identity will only be used to process your rights request.
After submitting your request online, you will receive a follow-up email, which may include a link you must click on in order to verify your identity. If you do not click on that link, we may be unable to complete your request due to lack of verification. It is important that you provide a valid email address in order for us to be able to process your request.
We will respond to your rights request within 45 days, though in certain cases we may inform you that we will need up to another 45 days to act on your request. If we suspect fraudulent or malicious activity on or from your account, we will delay taking action on your request until we can appropriately verify your identity and the request as authentic. If you believe our response to your rights request is insufficient, you can appeal against our decision by contacting Director/Head of Security, Compliance & Risk at privacy@vaco.com and we will inform you of our final decision within 45 days. We reserve the right to charge a reasonable fee for, or decline to process, requests from a Consumer that are manifestly unfounded, excessive, or repetitive.
Please note that, in responding to your request, we are not permitted to disclose or provide you with, to the extent we collect such information, your Social Security number, driver’s license number or other government-issued identification number, financial account number, any health insurance or medical identification number, an account password, security questions and answers, or unique biometric data generated from measurements or technical analysis of human characteristics. However, we will inform you with sufficient particularity that we have collected the type of information without disclosing the actual data.
Requests to Know or Delete for Child Under the Age of 13: We do not knowingly collect information of minors under the age of 13.
Profiling
The VCDPA defines “profiling” as any automated processing of Personal Data to evaluate, analyze, or predict personal aspects related to an individual’s economic situation, health, personal preferences, interests, reliability, behavior, location, or movements. The law provides a right to opt out of profiling that is part of making decisions that produce legal or similarly significant effects (such as whether to provide financial services, housing, employment, healthcare services, or access to essential goods or services). In some situations, we may engage in this kind of profiling. You may be able to opt out of certain types of profiling by submitting a rights request as described above. Please be aware that we do not accept or process opt-out requests through other means (e.g., via fax or social media).
Contact Us
If you have any questions or comments about this notice, the ways in which we collect and use your information, your choices, and rights regarding such use, or wish to exercise your rights under Virginia Privacy law, please do not hesitate to contact us at:
Toll-Free Phone: 844-880-8226
Email: privacy@vaco.com
Postal Address:
Vaco Global Headquarters
5501 Virginia Way #120
Brentwood, TN 37027
Attn: Director/Head of Security, Compliance & Risk
For Individuals in Canada
Effective Date: June 1, 2020 | Last Revised on: January 1, 2023 | Last Reviewed on: January 1, 2023
How We Collect, Use, Disclose, and Store Your Personal Information
The legal basis that we rely on for collecting, using, or disclosing your information will depend upon the particular circumstances and province in which you are located, but will in most cases be with your knowledge and consent. Circumstances where we do not need your explicit consent include:
- Where we collect, use, or disclose your information for a particular purpose and give you sufficient notice and a reasonable opportunity to object or decline such collection, use, or disclosure within a reasonable time;
- Where legal, medical, or security reasons make it impossible or impractical to seek your consent, such as when collecting information for the detection and prevention of fraud or for law enforcement;
- Where the collection, use, or disclosure of your information would be obvious, you have voluntarily provided your information, or we have a binding contract with you;
- Where the collection, use, or disclosure if otherwise permitted or required by law.
Aside from the entities to whom we disclose your information, as listed above, our employees, contractors, and agents who have a legitimate reason to access or use your information will also have access to your information that we have collected.
Rights
You may have the following rights depending on the particular province in which you are located. Some of the rights you may have include:
- Request access to your personal information. This may enable you to receive a copy of the personal information we hold about you, to check that we are lawfully processing it, and to whom we are disclosing your information. Under certain circumstances, we may not be able to give you access to information, such as if such disclosure could reasonably be expected to threaten the life or security of someone else or it would reveal personal information of someone else.
- Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- Request deletion of your personal information.
- Withdraw consent at any time where we are relying on consent to process your personal information. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
Making a request
To exercise any of the above rights, you must issue your request to us in writing. You can make a request using the applicable methods in the “Contact Information” section below.
Contact Information
If you have any questions or comments about this notice, our privacy policies and practices, your choices, and rights regarding your personal information, or wish to exercise your rights under Canadian law, please do not hesitate to contact us:
Phone: 844-880-8226
Email: privacy@vaco.com
Postal Address:
Vaco Global Headquarters
5501 Virginia Way #120
Brentwood, TN 37027
Attn: Director/Head of Security, Compliance & Risk
