Last Updated: July, 2021
Our commitment to privacy
BRAVOMAX SERVICES LTD is the Data Controller of the website VRSumo.com (the “Website”), a company domiciled at Office E 11 Old Ladies Court, High Street, Battle TN33 0AH, England, hereinafter referred as “Company”, “us”, “we”, “our” as context may require. If you have any concerns related to the processing of your personal data, please at email@example.com.
We take your privacy seriously, and we want to provide a safe and secure user experience for you. This Policy is designed to help you understand how and why we process your personal information, and what you can do about it.
What personal data do we collect?
Through the Website, we collect certain types of personal data when you register on the site, such as name, email address and credit card details in order to complete your registry. By providing this information and by clicking on the “I accept” (or equivalent) button incorporated in the registration form, you declare that the information and data you have provided are accurate and truthful, and you explicitly consent the processing of special categories of personal data that belong to you.
If you want to subscribe to any upgrade services, you may be requested to provide us your financial information, such as your credit card number, again.
What are cookies?
A “cookie” is a small piece of data that a website stores in a designated file on your computer, smartphone, tablet or smart tv. Cookies are commonly used to store usernames and/or passwords to facilitate access to the site. Cookies can also be used to store user preferences, login dates and times, and content viewing history. Cookies are sometimes used to store basic information about the user's or your computer's browsing habits, up to the point, as the case may be, of being able to recognize you. When you visit a website, that site can access that information which it stored in a cookie. Cookies make your online experience easier and more personalized.
Our site’s servers automatically identify your computer by its Internet Protocol (IP) address (a unique string of numbers that is assigned to your computer by your Internet Service Provider) each time you access the site, and maintain logs of the specific content on the site that you access. Our servers also record various information pertaining to your computer configuration, including the Web browser software you use, the resolution settings of your monitor, and the website from which you were referred to us, if any. We use this information anonymously to help us determine what is the most beneficial for our users and how we can create a better overall user experience.
You can allow, block or delete cookies installed on your computer by setting your Internet browser options. If you block them, certain services that require their use may not be available to you. Below are links to information on how you can activate your preferences in the major browsers:
- Google Chrome
- Mozilla Firefox
- Internet Explorer
- Safari for IOS (iPhone, iPad)
Please be advised that when Cookies are disabled or rejected, you may not be able use the Member Services or experience the full functionality of the Site.
What do we do with your personal data?
The main reason we collect data is to operate effectively and provide a quality experience for you. Please read below to obtain a more detailed explanation of the purposes for which we may process your personal data:
- a) To manage the contractual or pre-contractual relationship: We use information about you to provide the services to you, including to process transactions, manage your registration as a user, allow your access to the private or members area, authenticate you when you log in, provide customer support, operate and maintain the Site, provide you with the services you have requested and attend to your requests for information, as well as to facilitate the exercise of your rights. We also analyze your profile, Website activity and preferences to recommend connections and to recommend your profile to others.
- b) Based on the existence of a legitimate interest of the Website: We use information about you to customize your experience, keep you informed about the services of the Website, send you news and other activities that we carry out related to the services of the Website that may be of your interest, and to carry out periodic reviews of our services and satisfaction surveys in order to evaluate and improve the quality of the service we provide.
- c) We may also process your personal data in order to carry out internal reviews and, if necessary, contact you in the event that a possible fraud, misbehavior, or identity theft is detected or there are well-founded suspicions. However, if you do not want your data to be processed for these purposes, you may object at any time by contacting us at firstname.lastname@example.org.
- d) On the basis of your explicit, free and unequivocal consent that you grant at the time of collecting your data: to process the special categories of personal data that belong to you, in order to provide you the services. By clicking on the “I accept” button incorporated in the registration form, you expressly consent the processing of your personal data for these purposes.
Who is your data shared with?
We may share the information we collect from users with the following third parties, for the following purposes:
Affiliates and service providers:
- a) Credit card processing companies to process payments for goods and services and to verify that user credit card account is valid and active
- b) E-mail service providers to send out e-mails on our behalf
- c) Sales partners to sell our services
- d) Data partners to process data on our behalf (e.g., removing duplicate information, analyzing data, etc.)
- e) Marketing partners who may market our products for us and provide analysis of such marketing efforts.
These affiliates and service providers will have access to user information as needed to perform their functions on our behalf, but we do not permit them to use your information for other purposes. In addition, apart from the circumstances described above, we will not share credit card information with any third parties without prior informed consent from you.
Third-party marketing companies: to send users selected marketing, other than Sensitive Information (defined as a credit card number, financial account number, Social Security number, driver’s license number, or credit score). These businesses and third parties may include:
- a) providers of direct marketing services and applications, including lookup and reference, data enhancement, suppression, and validation vendors
- b) e-mail marketers
- c) telemarketers (where permitted by applicable law)
- d) text-message-based marketers (where permitted by applicable law)
- e) direct marketers
- a) social media companies: when the users access certain features or buttons that allows them to login with their social media credentials to our online services, they will share information with other social media companies, such as the fact that they have interacted with us. These third parties may combine this information with other information they may have about the users. These companies are exclusively responsible of the data processing that they carry out in relation with your information when navigating their sites. Additionally, we encourage users to proactively review the corresponding Privacy Policies from these social media companies
- b) business partners: we may establish commercial relationships with other companies aiming to create a broader community able to enrich your experience with BRAVOMAX SERVICES LTD products and services. These third parties may offer the users a broader catalogue of relevant services, products and or eligibility to promotional offers. These companies are exclusively responsible of the data processing that they carry out in relation with your information when navigating their sites. Additionally, we encourage users to proactively review the corresponding Privacy Policies from these companies
To any acquiring entity in connection with any sale, merger, consolidation, change in control, transfer of substantial assets, reorganization, or liquidation of BRAVOMAX SERVICES LTD;
To respond to a subpoena, court order, or legal process served on us or otherwise to comply with the law;
To protect the rights, property, or safety of users or others (e.g., by exchanging information with other companies and organizations for fraud protection purposes, by providing information to law enforcement where we believe the Site is being or has been used to commit unlawful acts).
In this regard, we inform you that any transfer will be made taking into account all the necessary legal safeguards. We also guarantee that we sign specific contracts with all our service providers as required by the applicable regulations.
We guarantee that the necessary safeguards are in place to ensure that the data can be transferred securely, either because the provider offers adequate guarantees through, among others, its participation in the Privacy Shield EU-US and Swiss-US, the signing of Standard Contractual Clauses of the European Commission, or any of the exceptions contained in the regulations.
How long do we keep your data?
Last but not least, as indicated in our Terms and Conditions, we do not knowingly collect or solicit personal data from children underaged/minors. If you are an underaged child/minor, please do not attempt to register on the Website or otherwise use the services or send us any personal data. In this sense, please note that if we learn that we have collected any kind of personal data from an underaged child/minor, we will delete that information as soon as possible. If you believe that an underaged child may have provided us personal data, please contact us at email@example.com.
How to change account information and preferences
You may make changes to your personal information and notification options contacting us. Please contact us at firstname.lastname@example.org and explain us what changes you want to make, and we will be delighted to assist you. We kindly remind you that in order for us to adequately provide the services, you must keep your information up to date and, subsequently, you agree to regularly check the information provided to ensure it is updated and accurate at all times. You can ask us to stop sending you marketing communications at any time. You may do so by following the instructions in those communications. Alternatively, please contact us at email@example.com stating that you want to opt-out of marketing communications from us. However, please note that this will not prevent us from sending other communications related to the services, since these are essential to comply with the contractual relationship between you and us.
Your rights and how to exercise them
European citizens or residents
In case you are a European citizen or resident and are subject to the GDPR and, consequently, you may exercise the following rights:
- 1. Right to access your personal data to know what data is being processed and the purposes for which it is being processed.
- 2. Right to rectify inaccurate personal data.
- 3. Right to erasure of your personal data where possible.
- 4. Right to request the restriction of the processing of your personal data when: a) the accuracy of your data is being verified, b) the processing is unlawful, c) your data is not processed but is needed for exercising or defending claims or d) you have opposed to the processing of your data to carry out a mission of public interest or to satisfy a legitimate interest, while it is checked whether the legitimate grounds for processing prevail over your interests.
- 5. Right to object to automated decision-making.
- 6. Right to object to the processing of your personal data when the legal basis for our processing is the legitimate interest. We will stop processing the data, except where legitimate purposes prevail or to exercise or defend against possible claims.
- 7. Right to data portability, to receive the personal data submitted to us and obtained during your contractual relationship with us in electronic form, and transmit the data to another entity.
- 8. Right to withdraw the consent granted to us.
To exercise your rights, please contact us at firstname.lastname@example.org stating the right you wish to exercise. We kindly inform you that the exercise of these rights is free of charge. Under the GDPR, you may also file a claim with the corresponding Supervisory Authority if you believe we have violated the data protection legislation when processing your personal data.
If you are a California resident and are subject to the CCPA, please note that you may exercise the following rights:
- 1. The right to know and request from us what personal information has been collected during the past 12 months and for what purposes it will be used. Specifically, information regarding the categories of data processed, the sources from which the data was obtained, the purposes of the processing and/or whether such information will be sold to third parties, and the categories of third parties to whom such personal information will be disclosed to. For this purpose, you may consult the previous sections "What personal data do we collect", "What do we do with your personal data?" and "Who is your data shared with”.
- 2. The right to delete your personal information where possible.
- 3. "Do Not Sell My Information" meaning the right to object to the sale of your personal information to third parties as mentioned herein.
We also inform you that by exercising any of the above rights, you will not be discriminated against or subject to different treatment.
To exercise your rights, please contact us at email@example.com stating the right you wish to exercise and how you will prove you are a California resident. We kindly inform you that the exercise of these rights is free of charge.
When you receive any communication from us, by clicking the "opt-out" button in the notice, you can unsubscribe from all the previously accepted commercial notices.
Confidentiality And Security
The Website employs industry standard security measures to ensure the security of all data. Your personal information is protected by physical, electronic, and procedural safeguards in compliance with applicable regulations, as well as further administrative, managerial, and technical safeguards, including firewalls and data encryption.
Minors under 18 years old cannot use the services available via the Website. The Website does not knowingly collect, process, market or sell information to or about minors. Parents and/or guardians shall undertake and implement the necessary measures and mechanisms to prevent minors from accessing the Website and/or providing personal data, and the Website accepts no liability in this regard.
Questions And Suggestions
If you have questions or concerns regarding this policy or your personal data, please feel free to contact us at firstname.lastname@example.org.