Effective Date: June 30, 2023
Virginia Consumer Data Protection Notice
Your Rights Under VCDPA
In accordance with the Virginia Consumer Data Protection Act you have the right to:
- To confirm whether or not a controller is processing your personal data and to access such personal data;
- To correct inaccuracies in your personal data, taking into account the nature of the personal data and the purposes of the processing of your personal data;
- To delete personal data provided by or obtained about you;
- To obtain a copy of your personal data that you previously provided to us in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the data to another controller without hindrance, where the processing is carried out by automated means; and
- To opt out of the processing of your personal data for purposes of (i) targeted advertising, (ii) the sale of personal data, or (iii) profiling in furtherance of decisions that produce legal or similarly significant effects concerning you.
Information We Collect
We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). In particular, we have collected the following categories of personal information from consumers within the last twelve (12) months:
| Category | Examples | Collected |
|---|---|---|
| Identifiers. | A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers. | YES |
| Commercial information. | Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. | YES |
| Internet or other similar network activity. | Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement. | YES |
| Geolocation data. | Physical location or movements. | NO |
| Professional or employment-related information. | Current or past job history or performance evaluations. | YES |
| Sensitive Data | “Sensitive data” means personal data that includes (A) data revealing racial or ethnic origin, religious beliefs, mental or physical health condition or diagnosis, sex life, sexual orientation or citizenship or immigration status, (B) the processing of genetic or biometric data for the purpose of uniquely identifying an individual, (C) personal data collected from a known child, or (D) precise geolocation data. | NO |
Use of Personal Information
We may use or disclose the personal information we collect for one or more of the following business purposes:
- To provide you with information, products or services that you request from us.
- To provide you with email alerts, and/or SMS messages that may interest you—providing that you opted in to receive those messages while using our website(s).
- To improve our website and present its contents to you.
- As necessary or appropriate to protect the rights, property or safety of us, our clients, or others.
- To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
- As described to you when collecting your personal information or as otherwise set forth in the VCDPA.
- To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred.
We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
Disclosing/Sharing Personal Information
We share/sell the following categories of consumers’ personal information:
- Category: Identifiers.
- Category: Commercial information.
- Category: Internet or other similar network activity.
- Category: Professional or employment-related information.
We disclose your personal information for a business purpose to the following categories of third parties:
- With our vendors that assist us with delivery of email messaging.
- With one or more vendors who provide independent verification of consent, including verification of consent under TCPA;
- Third parties to whom you or your agents authorize us to disclose your personal information in connection with products or services we provide to you;
- Third party vendors that assist us in storing and/or processing of your data;
- Third party vendors that assist us in identifying site issues, observing user behavior, and tracking page performance.
We share/sell consumers’ personal information to the following categories of third parties:
- Our affiliates and/or other third parties to whom you or your agents authorize us to disclose your personal information in connection with products or services we provide to you.
When we share and/or sell your information, we enter into agreements that describe the purpose for which the information is sold, restrict its use to the agreements specified purpose and require that all information remain confidential, and be protected from unauthorized disclosure.
While we are not aware of any activity on our website that would fall under the VCDPA’s definition of “Targeted Advertising”—in an abundance of caution, we are still electing to offer our users the ability to limit any activity on our site that could potentially fall under the VCDPA’s definition of “Targeted Advertising”. CLICK HERE to limit any potential “Targeted Advertising”.
Exercising Access, Data Portability, Opt-out of Selling, Correction and/or Deletion Rights
Contact Information
If you have any questions or comments about this notice, our Privacy Statement, the ways in which we collect and use your personal information, your choices and rights regarding such use, or wish to exercise your rights under Virginia law, please do not hesitate to contact us. Only you or a person that you authorize 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.
You can submit a verified request by:
- Calling us at: 561-406-8199
- Emailing us at: [email protected] (please write VDCPA Request in the subject line)
- Submiting request at:DNSMPI
- My U.S Postal Mail at: 7000 West Palmetto Park Road, Suite #210, Boca Raton, Florida 33433
Response Timing and Format
After receiving a verified request, we will deliver the information to you within 45 days. You may make a verifiable consumer request for access or data portability twice within a 12-month period without incurring any fees.
The verifiable consumer request must:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
Appeal Process
If your request is denied you have the right to appeal. We will respond to all appeals within 60 days of receipt and provide you with a written explanation of the reasons for our decisions.
To appeal:
- Emailing us at: [email protected] (please write VCDPA APPEAL Request in the subject line)
- Submitting request at: DNSMPI and choose APPEAL when submitting the form.