Privacy Notice for Virginia Residents
REVISED 01/01/2023
This PRIVACY POLICY FOR VIRGINIA RESIDENTS (“Virginia Privacy Policy” or “Privacy Policy”) is provided by Versium and its subsidiaries (collectively, “we,” “us,” or “our”) and applies to natural persons who reside in the Commonwealth of Virginia (“consumer(s),” “you,” or “your”). As required by Virginia law, we explain in this Privacy Policy how we collect, process, use, sell and/or share your personal information, as required by the Virginia Consumer Data Protection Act (the “CDPA”). “Personal Information” may exclude certain information that is publicly available, deidentified, aggregated, subject to the Fair Credit Reporting Act, GLBA, HIPAA, or the Driver’s Privacy Protection Act of 1994, or otherwise exempt or excluded from the CDPA.
Virginia residents have a right to know the following with regard to our collection and processing of their personal data:
- The categories of personal data we process.
- The purpose for which we process personal data.
- How Virginia consumers may exercise their rights under the CDPA.
- The categories of personal data we share with third parties.
- The categories of third parties with whom we share personal data.
The above information is broadly described in our general privacy policy, https://versium.com/privacy-policy. Below is a more detailed description of this information as it relates to Virginia consumers:
| Category | Description | Categories of Third Parties to Whom We May Disclose this Information | Sources of Personal Information |
| Identifiers | Includes direct identifiers, such as name, alias, postal address, unique personal identifier, online identifier, IP address, email address, account name, or other similar identifiers. | -Vendors and service providers -B2B Brands -B2C Brands -Data Aggregators -Political Organizations -Charitable Organizations -Advertising, Marketing and Sales Organizations -Real Estate Investors -Advertising networks -Analytics providers -Social networks -Government entities and law enforcement | Directly from our clients, or their agents related to the services for which they engage us. Directly or indirectly from activity on Sites (e.g., from submissions and website usage details). Advertising networks, Social networks, Internet providers, Government entities, Public Record Data, Data brokers/aggregators, Publicly available sources |
| Customer records | Includes personal information such as name, address, telephone number, education, employment and employment history. | -Vendors and service providers -B2B Brands -B2C Brands -Data Aggregators -Political Organizations -Charitable Organizations -Advertising, Marketing and Sales Organizations -Advertising networks -Analytics providers -Social networks -Government entities and law enforcement | Directly from our clients, or their agents related to the services for which they engage us. Directly or indirectly from activity on Sites (e.g., from submissions and website usage details). Advertising networks, Social networks, Internet providers, Government entities, Public Record Data, Data brokers/aggregators, Publicly available sources |
| Protected classifications, and Sensitive Personal Information | Includes characteristics of protected classifications under applicable laws, such as age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status and gender. | -Vendors and service providers -B2B Brands -B2C Brands -Data Aggregators -Political Organizations -Charitable Organizations -Advertising, Marketing and Sales Organizations -Advertising networks -Analytics providers -Social networks -Government entities and law enforcement | Directly from our clients, or their agents related to the services for which they engage us. Directly or indirectly from activity on Sites (e.g., from submissions and website usage details). Advertising networks, Social networks, Internet providers, Government entities, Public Record Data, Data brokers/aggregators, Publicly available sources |
| Commercial information | Includes records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. | -Vendors and service providers -B2B Brands -B2C Brands -Data Aggregators -Political Organizations -Charitable Organizations -Advertising, Marketing and Sales Organizations -Advertising networks -Analytics providers -Social networks -Government entities and law enforcement | Directly from our clients, or their agents related to the services for which they engage us. Directly or indirectly from activity on Sites (e.g., from submissions and website usage details). Advertising networks, Social networks, Internet providers, Government entities, Public Record Data, Data brokers/aggregators, Publicly available sources |
| Usage data | Includes browsing history, search history, information on a consumer’s interaction with our Sites or advertisements. | -Vendors and service providers -B2B Brands -B2C Brands -Data Aggregators -Political Organizations -Charitable Organizations -Advertising, Marketing and Sales Organizations -Advertising networks -Analytics providers -Social networks -Government entities and law enforcement | Directly from our clients, or their agents related to the services for which they engage us. Directly or indirectly from activity on Sites (e.g., from submissions and website usage details). Advertising networks, Social networks, Internet providers, Government entities, Public Record Data, Data brokers/aggregators, Publicly available sources |
| Professional information | Includes professional or employment-related information, current or past job history or performance evaluations. | -Vendors and service providers -B2B Brands -B2C Brands -Data Aggregators -Political Organizations -Charitable Organizations -Advertising, Marketing and Sales Organizations -Advertising networks -Analytics providers -Social networks -Government entities and law enforcement | Directly from our clients, or their agents related to the services for which they engage us. Directly or indirectly from activity on Sites (e.g., from submissions and website usage details). Advertising networks, Social networks, Internet providers, Government entities, Public Record Data, Data brokers/aggregators, Publicly available sources |
| Inferences | Includes inferences drawn from other personal information we collect to create a profile reflecting a person’s preferences, characteristics, psychological trends, predispositions and behavior. | -Vendors and service providers -B2B Brands -B2C Brands -Data Aggregators -Political Organizations -Charitable Organizations -Advertising, Marketing and Sales Organizations -Analytics providers -Social networks -Government entities and law enforcement | Directly from our clients, or their agents related to the services for which they engage us. Directly or indirectly from activity on Sites (e.g., from submissions and website usage details). Advertising networks, Social networks, Internet providers, Government entities, Public Record Data, Data brokers/aggregators, Publicly available sources |
Virginia Residents’ Rights and Choices
The CDPA provides Virginia residents with specific rights regarding their personal and sensitive personal information. This section describes your CDPA rights and explains how you may exercise those rights.
Right to Know
You have the right to know whether we process your personal information and, if so, to request that we disclose to you the information we process regarding you. If you are a Virginia resident, once we confirm you are the consumer whose data is requested, we will disclose to you (up to twice per year) the personal information regarding you that we process. You may make a request that we disclose to you the personal information about you we process by emailing privacy@versium.com or calling us at 1-800-395-0164.
Right to Request that We Delete Your Personal Information
You have the right to request that we delete your personal information that we collected once we receive your request and confirm your identity or authority to make the request. You may make a request to delete your personal information by visiting www.versium.com/opt-out or calling us at 1-800-395-0164.
Right to Opt-out of our Processing of Your Personal Information for Purposes of Advertising, Sale or Profiling
You have the right to request that we not process your personal information for the purposes of targeted advertising, the sale of your personal information, or “profiling in furtherance of decisions that produce legal or similarly significant effects concerning the consumer.” You may make a request to opt-out of our processing your personal information by visiting www.versium.com/opt-out or calling us at 1-800-395-0164.
Right to Correct Your Personal Information
Virginia residents who believe the personal information we process regarding them is not accurate may submit requests that we correct their personal information. You may make a request to correct your personal information by email privacy@versium.com or calling us at 1-800-395-0164.
Sensitive Personal Information
We may not process your sensitive personal data as defined in the CDPA without first obtaining your prior consent. We do not process, sell or otherwise share the sensitive personal data of Virginia consumers and we do not request your authorization to process, sell or otherwise share your sensitive personal data.
General Process for Submitting CDPA Requests
Virginia residents may submit their requests to exercise their CDPA rights by following the methods described above for each specific right or generally by using one of the following methods:
- Calling us at 1-800-395-0164
- Visiting https://versium.com/opt-out
- Emailing privacy@versium.com
Only you or your authorized agent may make a verifiable consumer request related to your personal information.
The verifiable consumer request must:
- Provide sufficient information that allows us to reasonably verify you are the person about whom your request relates to or you are the appointed and authorized representative of the consumer on whose behalf you are submitting the request.
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot grant your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm that the personal information that is the subject of your request relates to you. In some cases, we may request additional information in order to verify your request or where necessary to process your request. If we are unable to adequately verify a request, we will notify the requestor.
Right to Appeal Our Response to Your Request
If you have made a request to exercise any of your rights under the CDPA and you are dissatisfied with our response you may request that our initial response be re-evaluated by submitting an “Appeal” of our decision by emailing privacy@versium.com or calling us at 1-800-395-0164.
Notice Regarding Personal Data of Minors
We do not knowingly collect, process, use, disclose, share or sell the personal information of individuals under the age of 18.
Changes to Our Privacy Policy
We reserve the right to amend this Privacy Policy at our discretion and at any time. When we make changes to this Privacy Policy, we will notify you by email or through a notice on our website.
