Privacy Policy
Introduction
What the VIRT™ Site does
This site (“the VIRT™ Site”), which is operated by Global Health Strategies, LLC (“GHS,” “we” or “us”), provides a database of listings of conferences and other events (“Events”) on diverse topics of global concern, including COVID-19, climate, economic opportunity, and sustainable development (“Event Listings”), copies of materials that were displayed or distributed at or in connection with such Events (“Event Materials”), and/or audiovisual recordings of all or part of such Events (“Event Recordings”). Event Listings, Event Materials, and Event Recordings will be referred to collectively as “Listing Material.” Our provision of this information and other information on the VIRT Site will be referred to as “the Services.”
What this Privacy Notice does
This Privacy Notice describes how we collect and use your personally identifying information through the VIRT Site.
Personally Identifying Information
“Personally Identifying Information” (or, “PII”) is information that identifies you as an individual or relates to you as an identifiable individual. Under the European General Privacy Data Regulation, such information is referred to as “personal data.” Personally Identifying Information, may include, but is not limited to, your first and last name, Social Security number, and home address. Under some privacy laws, Personally Identifying Information may include online and device identifiers such as your IP address, usage data such as your browsing history (where you came from to get to the VIRT Site), protected classifications such as email address, your gender or sexual orientation, and information about your personal preferences that may be collected through cookies and other tracking devices.
Capitalized terms
Unless otherwise noted, capitalized terms in this Privacy Notice have the same meaning that those terms have in our Terms of Use.
Questions
For questions about this Privacy Notice and how your PII may be collected, stored, used, and shared, please contact us by email at __________.
Changes to this Privacy Notice
GHS may make changes to this Privacy Notice at any time. If and when we do, we will inform you by posting the revised Privacy Notice here on the VIRT Site. You are responsible for periodically visiting the VIRT Site and this Privacy Notice to check for any changes. Any changes that are made to this Privacy Notice will apply to both any personal information that we hold prior to the effective date of the amended Privacy Notice and any personal information that we collect on or after such effective date. Your continued use of the VIRT Site after this Privacy Notice has been amended shall be deemed to be your continued acceptance of the terms and conditions of the Privacy Notice, as amended.
Information collected when you use the VIRT Site
When you set up an account on the VIRT Site (a “User Account”) or ask to receive our newsletter, you will need to provide your name, street address, phone number, and your email address.
As the VIRT Site develops, we may also ask for your credit-card information. (Note: If we do collect your credit-card information, it will go to a third-party payment processor. GHS will not receive or store that information.)
If you register for an Event through or on the VIRT Site, you will need to provide certain PII. If, when you click on the link to register for an Event, you are taken directly to the site of the company that is producing and/or hosting that Event, your registration PII will be collected by that company directly. If your registration takes place on the VIRT Site, then we will collect that PII and provide it to the Event host.
Other PII you choose to give us.
Contacting us
If you e-mail us, we will have your e-mail address and whatever other PII you include in the e-mail.
Information collected automatically
When you use the VIRT Site, we automatically collect certain information that includes PII. This information, which may be collected even if you have not created a User Account, may include:
Online identifiers
Geo location/tracking details, mobile device type and unique mobile device identification numbers, mobile device event information (such as crashes, system activity and hardware settings, browser type, browser language, the date and time of your request and referral URL), browser fingerprint, operating system, browser name and version, and/or personal IP addresses.
Usage Data
Authentication data, security questions, click-stream data, public social networking posts, and the web pages or sites that you visited just before or just after coming to the VIRT Site, searches on the VIRT Site for Events or Listing Material, registrations on the VIRT Site for Events, the pages or other content that you view or interact with on the VIRT Site, and, each time you visit the VIRT Site, the date and time of that visit.
To find out how we automatically collect this information using cookies and other technology, which cookies we use, and how you may opt out of tracking on the VIRT Site, please see our Cookie Policy [LINK].
USE (PROCESSING) OF PII
Site access
The PII you provide when you create a User Account is used to enable you to access the VIRT Site and use the Services.
Event registration
The PII you provide when you register for an Event is used to register you for whichever Event you have signed up for and to confirm your registration for that Event.
Newsletter
If you ask to receive our newsletter, we will use your email address to send it to you.
Responses to requests
If you contact us, we will use your email address to send you whatever information you have requested.
Marketing
We also may use your PII to identify and to send you emails about Events that we think you might be interested in based on the Events for which you have already registered or searched.
Recordkeeping
We may process your PII for the purposes of creating and maintaining databases related to the VIRT Site and back-up copies of those databases.
Security
We may process your PII for the purpose of keeping the VIRT Site secure and preventing fraud and other criminal activity.
LEGAL BASES FOR PROCESSING YOUR PII
We rely on a number of bases when processing your PII:
Consent, namely, your voluntarily providing us with your PII when you create a User Account, register for an Event, sign up to receive emails, or contact us. Further down in this Privacy Notice, you will see how you can withdraw that consent.
The contract we enter into with you when you agree to our Terms of Use [LINK].
Our legitimate interests in operating the VIRT Site, providing and improving the Services, keeping the VIRT Site safe and secure, making sure that we have access to all the information we need to operate the VIRT Site and provide the Services, communicating with you both in response to your queries and in offering you information that may be of interest to you.
Legal obligations to which we may be subject, such a law, regulation, search warrant, subpoena or court order or to exercise or defend legal claims.
DISCLOSURE OF PII TO THIRD PARTIES
Disclosure to third parties
Affiliates
We may share your PII and other information with a parent company, subsidiary, joint venture, or other company under common control with us.
Event hosts
If we collect your PII when you register for an Event, we may share that PII with the entity that is producing and/or hosting that Event.
Service providers
We may provide your PII to service providers who perform or contribute to the Services, help us operate the VIRT Site and provide the Services (“Service Providers”). Service Providers include vendors and suppliers that provide us with technology, services or content for sending email, analyzing the operation of the VIRT Site and the Services, analyzing data generated by user activity, research, marketing, and customer service. These Service Providers’ access to your PII is limited to the information reasonably necessary to perform their limited functions. If a Service Provider obtains access to your PII in the course of providing services, its use of your PII will be governed by its own privacy notice. Our current Service Providers and the current links to their privacy notices are:
Disclosure for legal reasons
Safety
We may disclose your PII to protect the safety, rights, or property of the public, any person, or GHS; to investigate, prevent, or otherwise address suspected fraud, harassment or other violations of any law, rule or regulation or our Terms of Use; to detect, prevent or otherwise address security or technical issues; or as we believe is required by law, regulation, or legal process.
Change of control
If we engage in a merger, acquisition, disposition, change of control, bankruptcy, dissolution, reorganization, or similar transaction or proceeding, or otherwise transfers the operations of the VIRT Site that relates to your PII, we will transfer your PII to the successor entity.
Disclosure under the CCPA
The VIRT Site is not currently subject to the California Consumer Privacy Act (“CCPA”). If and when the VIRT Site does become subject to the CCPA, we will revise the VIRT Site and this Privacy Notice to meet the CCPA’s requirements.
“Do Not Track” Signals
With some browsers, it is possible for a user to activate a “Do Not Track” signal, to indicate that the user does not want to be tracked across the websites that the user visits.
The VIRT Site does not respond Do Not Track signals. So, if you have activated a Do Not Track signal in your own browser, the VIRT Site will not block tracking of your activity on the VIRT Site by Google, its affiliates, and anyone else.
Storage of information
We store PII and Non-PII that we collect through the Services on our own servers and/or on servers operated by third parties. Currently, these third-party servers are located in the United States. If, in the future, we begin to use servers that are located in other countries or in other jurisdictions, we will update this Privacy Notice.
You consent to have your PII, and Non-PII that may be collected when you use the VIRT Site collected, stored and processed on servers in the United States. Of course, you may back up your PII on your own computer independent of GHS or the Services.
Retention and deletion of PII
We will keep your PII
We dispose of your PII by deleting it from the VIRT Site database.
Transfer of information
We may transfer information that we collect about you, including PII, to affiliated entities, or to other third parties across borders and from your country or jurisdiction to other countries or jurisdictions around the world to process your PII there for the purposes set out in this Privacy Notice and permit our suppliers and subcontractors to do so.
Transfers to countries or jurisdictions whose data protection laws do not have an adequacy determination will be protected by appropriate safeguards, namely, the use of standard contractual clauses (“SCCs”) adopted or approved by the competent data protection authorities.
Currently our only suppliers and subcontractors are the service providers identified earlier in the “Service Providers” section of this Privacy Notice, and their terms of use incorporate data processing agreements that contain the SCCs.
You acknowledge that any PII that you submit to or through the VIRT Site may be available, via the Internet, around the world. We cannot prevent the use or misuse of your PII by others.
Security
We use SSL certificates to protect your personal information as you transmit it from your computer to the VIRT Site and to protect your information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. We also use a software program to stop certain kinds of attacks. But no Internet transmission is ever 100% secure or error-free. In particular, e-mail sent to or from the VIRT Site may not be secure. Be careful about sending us any confidential information, and keep secure any passwords, ID numbers, or other special access features that you use on the VIRT Site.
The VIRT Site may contain links or references to other sites in addition to the ones we have already mentioned. Please be aware that we do not control such other sites and that, in any case, this Privacy Notice does not apply to those sites. We encourage you to read the Privacy Notice of every site you visit.
Protection of information
You are responsible for maintaining the privacy of your User Account information and for controlling access to your communications from the VIRT Site at all times.
Your PII will be stored in secure third-party data centers. Nevertheless, we cannot (i) ensure or warrant the security of any PII that you transmit when you use the VIRT Site or (ii) guarantee that information stored on or transmitted through the VIRT Site may not be accessed, disclosed, altered, or destroyed. If any PII under our control is compromised as a result of a breach of security, we will take reasonable steps to investigate the situation, and where appropriate, we will notify those individuals whose information may have been compromised and take other steps, in accordance with any applicable laws and regulations.
Children
We do not knowingly collect PII from anyone under 13. If we become aware that a child under 13 has provided us with PII, we will take steps to remove such information and terminate the child's account.
If you are a parent and you become aware that your child has provided us with PII without your consent, please contact us at __________ and we will take steps to remove such information and close the child’s account.
Your rights with respect to your PII
You can change any of your PII that you have provided to us by emailing us at __________ .
If you are a citizen or resident of the European Economic Area, in accordance with applicable data protection law, you have the right to:
Access your PII that we have collected;
Have your PII corrected or deleted;
Object to our processing of your PII;
Withdraw consent that you previously gave us to process your PII;
Ask that your PII be transferred to another service provider, where feasible; or
If you believe that we have not complied with applicable data protection law, lodge a complaint with your local supervisory authority.
If you wish to exercise any of these rights, or have any other questions about our privacy practices, please contact us by email at __________.
Information about us
The VIRT Site is owned and operated by Global Health Strategies LLC, a [New York limited liability company] with a principal place of business at [address].
You can contact us:
By mail, to the postal address given above;
By telephone, on [the contact number published on the VIRT Site]; or
By email, to _____.
Representatives
Our representative within the EU with respect to our obligations under data protection law is [identify representative] and you can contact our representative by [contact details].
Our representative within the UK with respect to our obligations under data protection law is [identify representative] and you can contact our representative by [contact details].
Data protection officer
Our data protection officer's contact details are: [contact details].
Date posted/updated
This Privacy Notice was first posted on ________, 2021.
Links to third-party sites
The VIRT Site may contain links to other websites. We do not endorse or control any of those other sites. You should read the Privacy Notice of any site you visit before providing any PII.
Changes to this Privacy Notice
If this Privacy Notice changes, the revised version will be posted here. Please check back periodically, and especially before you provide any PII.
This Privacy Notice was last updated on 03/09/2021.