Last updated: February 16, 2022
Context and Purpose of this Privacy Notice
The company operating the website http://www.viamo.io and the newsletter ViaMoments is Viamo Inc, 111 Research Drive, Unit 302, Saskatoon – Saskatchewan, S7N 3R2, Canada (“Viamo”, “we”, “us”, “our”).
As a global organization, Viamo must comply with privacy and data regulations in multiple jurisdictions. The Canadian parent company must comply with Canada’s Personal Information Protection and Electronic Documents Act (PIPEDA). Viamo subsidiaries need to comply with all local regulations and laws in their operating markets across North America, Africa, Asia, Latin America and the Caribbean. Although Viamo does not frequently process Personal Data of residents in the European Union (EU), the European Economic Area (EEA) or the United Kingdom (UK), EEA/UK Clients have contractual requirements for Viamo to comply with the principles of the General Data Protection Regulation (GDPR) when delivering services outside the EEA/UK.
This Privacy Notice describes how Viamo obtains, processes and shares your Personal Data when we are Data Controllers and what rights you have, in line with Art. 12, 13 and 14, GDPR. It applies to Personal Data you provide to us, or which we collect when you visit our website, request information about our services and products, subscribe to our newsletter or apply for a job. Following PIPEDA and GDPR definitions, we define Personal Data as data that relates to a specific individual that can be identified.
For any questions you might have about this Privacy Notice, how Viamo handles your Personal Data or if you wish to exercise your Data Subject Rights (DSRs), please contact us at firstname.lastname@example.org. To exercise your DSRs, you can alternatively contact our Data Protection Officer (DPO): Silvan Jongerius, TechGDPR DPC GmbH, Heinrich-Roller Str. 15, 10405 Berlin, Germany, Email: email@example.com.
What Personal Data do we collect and for what purposes?
We automatically collect information about visitors of our website, including information about when and how they use our website and technical information like referring URLs, their IP address, device and browser characteristics, language settings and location. We keep this data in log files for up to two weeks for our legitimate interest in preventing fraud, abuse and security incidents as laid out in Art. 6(1)(f), GDPR.
We also collect information through cookies and we process this data for the purpose of optimizing our online presence and for marketing purposes. Cookie preferences can be changed and consent can be withdrawn at any time. See the section on cookies below for more information.
Prospective clients and partners
We collect information via our website and by email and information that is publicly available from prospective clients and partners who want to learn more about Viamo and our products and services. The information we collect includes the first name, last name, email address, telephone number, company or organization, country, language, and the type of request we received. We process this information in the preparatory stage of entering into a contract as laid out in Art. 6(1)(b), GDPR or to provide you with general information about our service in our legitimate interests per Art. 6(1)(f), GDPR.
As prospective clients and partners actively request Viamo to contact them for more information about our products and services, we record this data to effectively communicate with them. Personal Data of prospective clients and partners will be deleted two years after the last contact we had with them unless they become a client of Viamo.
Any Data Subject can sign up for our newsletter through our website or other communication. We only add new subscribers to our mailing list once they subscribed to the newsletter and passed the double-opt-in sent to them via email. For this purpose, we collect the first name, last name, email address, language and industry. When sending the newsletter via a third-party provider, we collect information on when and how visitors use our newsletter and technical information like referring URLs, device and browser characteristics and location.
We rely on consent per Art. 6(1)(a), GDPR, which can be revoked at any time by clicking the unsubscribe link in the footer of our newsletter or by contacting Viamo at firstname.lastname@example.org. We process the Personal Data of our newsletter subscribers for two years and refresh their consent again.
We collect information via our website and by email and information that is publicly available from candidates who apply for the vacancies we regularly advertise. This collection serves the purpose of selecting the right candidate for job offers based on education, work experience and skill set. This may include information such as your name, surname, email address, phone number, birth date, identification number, address, CV, photo, cover letter, work history, experience, academic records and references. Job applications are usually submitted through the Careers section on our website and additional information can be collected throughout the recruitment process. The legal basis for collecting Personal Data from job applicants is the performance of a contract as laid out in Art. 6(1)(b), GDPR.
Personal Data of job applicants is stored and processed for two years under our legitimate interest per Art. 6(1)(f), GDPR to get in touch with you for relevant job openings in the future or defend ourselves against legal claims.
When you visit our website for the first time, we will show you a cookie banner and ask for your consent to place non-essential cookies. The non-essential cookies are placed on our behalf by HubSpot, a third-party marketing software provider, by the content management system WordPress and by reCAPTCHA, a Google service that helps protect our site against spam enquiries on contact forms. As soon as you click the accept button, you consent to us collecting the following cookies:
|Cookie category & legal basis||Cookies & purpose|
The cookies on your device will be stored and processed for up to 13 months from your last visit. You can change your cookie settings anytime in the cookie banner. If you do delete the cookies in your browser and visit our website again, you may again be asked for consent.
Why am I required to provide Personal Data?
This Privacy Notice applies to Personal Data you provide to Viamo, or which we collect when you visit our website, request information about our services and products, subscribe to our newsletter or apply for a job. As a general principle, when you provide Viamo with your Personal Data based on consent, you do this entirely on a voluntary basis. Choosing not to consent or not to provide Personal Data is generally not detrimental. However, there are circumstances in which we cannot take action without specific data, for example, when Personal Data is required to fulfill a contact request, deliver a service or provide you with our newsletter.
How do you protect my Personal Data?
Viamo’s website servers are located in Canada, which is recognized as providing an adequate level of protection for Personal Data as determined by the European Commission. To protect your Personal Data, we maintain Technical and Organizational Measures (TOMs) in compliance with Art. 32, GDPR around the processing of your Personal Data and we enter into Data Processing Agreements (DPAs) with third-party providers that we engage
Do you transfer Personal Data internationally?
Viamo operates subsidiaries outside the EEA and we also use third-party providers across several countries. Personal Data may therefore be transferred to countries outside the EEA, including to countries not recognized as providing an adequate level of protection for Personal Data as determined by the European Commission.
Our website servers are located in Canada, which is recognized as providing an adequate level of protection for Personal Data as determined by the European Commission. When you access our website or related services outside of the EEA, your Personal Data may be transferred to Canada or the EEA.
When we transfer personal data to countries outside of the EEA and not on the European Commission’s adequacy list, we may use the European Commission’s Standard Contractual Clauses (SCCs) to safeguard their privacy as per Art. 46, GDPR.
Do you share Personal Data with third parties?
Viamo may share your Personal Data with Viamo subsidiaries and consultants and third-party providers that work for us in connection with the aforementioned data processing purposes. We only share and disclose your Personal Data with Viamo subsidiaries and consultants and other third parties if this is necessary and permitted by law or if you have explicitly given your prior consent for the Personal Data to be transferred.
We may share and disclose Personal Data with the following categories of third parties:
- Viamo subsidiaries and consultants
- Website Hosting Service Providers
- Sales & Marketing Tools
- CRM & Recruiting Tools
- Cloud Computing Services
- Data Analytics Services and Visualization Tools
- Communication & Collaboration Tools
- Design & Product Engineering Tools
Per the DPAs we have in place with Viamo subsidiaries and consultants and third-party providers, they must secure the Personal Data we share with them in compliance with GDPR and they are not allowed to use any Personal Data we share with them for any purposes other than what we have instructed them to. A list of our third-party providers can be provided upon request by reaching out to email@example.com.
What rights do I have in relation to my Personal Data?
At any time, you can request from Viamo to receive information about which Personal Data we process about you, as well as to provide you (in any case) or a third party (if the Personal Data is processed based on Art. 6(1)(a) or (b), GDPR) with a copy of this Personal Data. You can also request the correction or deletion of such data. Please note, however, that Viamo can delete your Personal Data only if there is no statutory obligation or prevailing obligation on Viamo to retain it.
Where Viamo processes your Personal Data based on consent, you can revoke it at any time. For newsletter subscribers, the easiest way to unsubscribe from our newsletter is by clicking the unsubscribe link in the footer of our newsletter. Also, if Viamo processes your Personal Data based on consent or the performance of a contract, you may request a copy of the Personal Data that you have provided to us.
Furthermore, you can request that Viamo restricts your Personal Data from any further processing if:
- You are contesting the accuracy of the data we hold about you, for as long as we need to verify this claim.
- If you believe the processing of the data is unlawful, but you oppose the erasure of the data and request restriction of processing instead.
- If we no longer need your data for the original purpose, but you need them for the establishment, exercise or defence of legal claims.
- If you have objected to the use of your data, while we evaluate if our legitimate grounds for processing your data override yours, as required by Art. 21, GDPR.
Finally, where your Personal Data is processed based on our legitimate interests under Art. 6(1)(f), GDPR, you have the right to object against our use of your data.
If you wish to exercise any of these DSRs, please contact us at firstname.lastname@example.org and specify the processing activities to which your request relates. To exercise your DSRs, you can alternatively contact our DPO: Silvan Jongerius, TechGDPR DPC GmbH, Heinrich-Roller Str. 15, 10405 Berlin, Germany, Email: email@example.com.
Your right to lodge a complaint
If you have a concern about how Viamo handles your Personal Data, we encourage you to first contact us at firstname.lastname@example.org. Should you disapprove of our response and if you are a resident of Canada, the EEA or the UK, you have the right to lodge a complaint with the data protection authorities in Canada, Berlin/ Germany or in the UK. See below for their contact details:
Office of the Privacy Commissioner of Canada
30, Victoria Street
Phone: +1 (0) 819 994 5444
Berliner Beauftragte für Datenschutz und Informationsfreiheit
Phone: +49 (0) 30 138 890
Information Commissioner’s Office
Wycliffe House, Water Lane
Phone: +44 (0) 303 123 1113
If you are a resident of the EEA, you can alternatively contact the data protection authority of the EEA country you live or work in. See here for a list of all data protection authorities in the EEA: https://edpb.europa.eu/about-edpb/about-edpb/members_en.
Use of this website by children
Neither this website nor any related services are intended for anyone under the age of 18 years. If you are younger than 18, you may neither register with nor use this website nor any related services.
Links to external websites
This website may contain links to external websites not operated or managed by Viamo and Viamo is not responsible for the privacy practices or the content of those websites. We, therefore, recommend that you familiarize yourself with the privacy practices of these websites by reading their privacy notices.
Changes to this Privacy Notice
We may modify this Privacy Notice to comply with legal requirements as well as developments within our organization. When we do, we will revise the date and version at the top of this page, and each website visit or interaction with our services will be subject to the newest version of the Privacy Notice. We encourage you to regularly review our Privacy Notice to stay informed. Unless we implement profound changes that we proactively notify you about, you acknowledge that it is your responsibility to review our Privacy Notice to be aware of modifications.