Privacy Policy

Last Updated: September 2, 2021

As transparency and privacy are among PRIVO’s core values, we regularly review our privacy notices to make sure we keep you up to date with our practices, what information we collect, how we use it and how we might share it. The ‘What’s New’ section summarizes the changes made to the latest version. To review previous versions of this policy please contact us at privacy@privo.com.

 

Content

Who is PRIVO and What Do We Do

What's New

Changes to this Privacy Policy

Information We Collect From You

What We Do With The Information You Provide

Third-Party Service Providers

Passively Collected Data

Security

How to Update or Remove Your Information

Notice to California Residents

A Note to EU Citizens

EU-U.S. Privacy Shield Framework

 

Who is PRIVO and What Do We Do?

PRIVO.com (the Site) is owned and operated by Privacy Vaults Online, Inc. d/b/a PRIVO (“PRIVO”).  PRIVO is a leader in online privacy protection and the privacy solutions offered by PRIVO include an FTC approved COPPA Safe Harbor Program, as well as GDPRkids™ Privacy Assured and Student Digital Privacy Programs. PRIVO also has the PRIVO iD Platform (The Platform), an identity and consent management platform, also known as PRIVO-Lock™.  In addition, PRIVO has a discovery platform at my.PRIVO.com where a user can find online services in PRIVO’s Kids Privacy Assured program and manage a PRIVO iD account. To review the Platform privacy policy click here.

This Privacy Policy is part of the Terms of Service for PRIVO.com. When you use the Site, you agree to the Terms of Service, including this Privacy Policy. Please read them before using the Site. They can be found here. If you disagree with any part of the Terms of Service or Privacy Policy, please do not use the Site. This policy covers the use of www.privo.com. We do not own or operate mobile applications.

PRIVO is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC). PRIVO complies with the principles of the Privacy Shield. It has also been approved by the United States Federal Trade Commission to create and administer a Safe Harbor program to assist online businesses to comply with the Children's Online Privacy Protection Act ("COPPA"). This Act requires many websites, game platforms, social networks, and mobile apps (each an "Online Service") to secure parental consent before the Online Service can collect information from the child through the Online Service.

When an Online Service becomes a member of the Safe Harbor, it makes legally binding commitments to PRIVO that it will follow the high standards set out by PRIVO for compliance with COPPA, as well as similar laws that may be implemented in other countries, and best practices developed by the privacy community. You may see a PRIVO Seal on various Online Services. This Seal shows that the Online Service is a member of the PRIVO Safe Harbor program, but the Online Service is not operated by PRIVO and has its' own Privacy Policy and Terms of Service, which you should review and approve before using the Online Service.

PRIVO's Student Digital Privacy Program supports ed tech companies and websites and apps for students to comply with FERPA, SOPIPA and California's student digital privacy regulations.

PRIVO's GDPRkids™ Privacy Assured Privacy program requirements ensure that Informational Society Services (website and apps) comply with the General Data Protection Regulation in relation to the processing of the personal data of children.


What's New

We updated this policy on September 2, 2021 to reflect more details about the intended audience for privo.com, to clarify the information we do not collect, provide more details of our security practices and added more ways to contact PRIVO for information regarding previous versions of this policy.


Changes to this Privacy Policy

This Privacy Policy may be updated from time to time, in which case, we will post the new policy. Such revisions will be effective immediately, so please check the latest update effective date and review the Privacy Policy regularly. We will not make any material changes to this privacy policy before notifying you by email, if we have it and obtaining your consent.

If you would like to see a past version of this policy please contact us at privacy@privo.com.


Information We Collect From You

When you visit PRIVO.com, you are given the opportunity to sign up and receive PRIVO's industry eNewsletter which contains information about developments in the world of online privacy, data security and digital kids industry trends. Anyone can sign up for our industry newsletters. However, this Site is not intended for children, students or teachers. You have the option to opt-out of these activities at any time. If you request additional information or seek support when using the Site, we collect your name and contact information to assist us in responding to you. Users cannot upload any content to the Site and it does not include any community or social features. There is no account creation or registration on www.privo.com. No user personal information can be displayed publicly. No personal information is collected from children or students.

We collect the following information from you when you opt in to our eNewsletter:

  • First and Last Name
  • Company Name
  • Job Title
  • Email Address

We collect the following information from you when you make an inquiry about our services using the Contact Us form:

  • First and Last Name
  • Email Address
  • Company Name
  • Job Title
  • Country
  • Phone Number
  • Services You are Interested In
  • Optional Box to Fill Out a Message
  • Website

We collect the following information from you when you opt in to our PRIVO PROTECT program:

  • First and Last Name
  • Email Address
  • Country
  • State
  • Phone Number
  • Your Role (mother, father, educator, family member)
  • How many children you have 12 or under and 13 or older
  • How many devices your children have access to

PRIVO retains this data for as long as required to provide the service to you. You can request to have your data deleted by contacting us at: privacy@privo.com.

PRIVO does not collect precise geo location information or biometric data. Only the information listed above is collected.


What We Do With The Information You Provide

PRIVO only uses information collected directly from you for the purposes stated. We will also use your information to update you about changes to our policies and to give you information about additional products and services we, or one of our clients, may offer. PRIVO will disclose information about you, in a manner that is not aggregated or anonymous, if we believe it is legally necessary to do so, for example, in response to a court order or civil subpoena, or to law enforcement or other government officials in connection with an investigation of fraud, intellectual property infringement, or other activity that is illegal or may expose PRIVO to legal liability.

In addition, in the event of a merger, acquisition, reorganization, bankruptcy or other similar event, PRIVO customer information may be transferred to our successor or assigned but will remain governed by and protected in strict accordance with this Privacy Policy and no further use of customer information will be made without explicit consent.


Third-Party Service Providers

PRIVO works with a number of third-party service providers solely to support our services. Information shared with these third parties is not used for any other purposes. For more information on these providers please click here.

PRIVO does not sell or rent your personal information. Nor do we serve interest based advertising or track you and build a profile of you.


Passively Collected Data

In order to manage, maintain, and improve the Site, we will sometimes passively collect non-personally identifiable information about visitors using the data transfer logs of the Site or “cookies”.  The information we may collect through passive collection technologies, such as “cookies”, includes IP address and browser type, as well as time spent on the Site or areas visited.  Our logs do not normally contain any personally identifiable information and are used only to improve the design, functionality, and content of the Site and to enable us to personalize your experience with the Site. PRIVO utilizes HubSpot to assist in these efforts by providing general analytical data on use and functionality of the Site for internal purposes. Data is collected, processed, and stored securely and is not shared with other parties. For more information, visit HubSpot's Privacy Policy. PRIVO does not track you, that is, it does not collect personally identifiable information about your online activities over time and across third-party Web sites or online services.

The Site does not employ technology that responds to browser signals that permit users to limit tracking.


Security

PRIVO is SOC 2 Type 2 certified. We use generally accepted security measures and safeguards and require that the third parties it works with agree to do the same. The measures and safeguards include limiting access to the data to those persons who need it to complete their work for PRIVO.

We have put in place industry standard physical, electronic, and managerial procedures to safeguard and help prevent unauthorized access, maintain data security, and correctly use the information we collect online.


How to Update or Remove Your Information

PRIVO keeps your information for as long as necessary in providing the services listed in this policy. Personal information is not used for any other purpose. If you want to opt out of services, review your information, or delete your information, please contact us at privacy@privo.com.

If you opt out of receiving our newsletters, PRIVO will cease sending them immediately. If you request we remove your personal information from our records we will delete it within ten working days of receiving your request unless we have a legal requirement to retain it.

Privacy Vaults Online, Inc., d/b/a PRIVO
17949 Main St., #1025
Dumfries, VA 22026
703–569–0504 (telephone)
703–783–8752 (fax)
privacy@privo.com (email)

Attn: Privacy Officer


Notice to California Residents

PRIVO does not disclose personal information to third parties for marketing purposes.

For further information about our privacy practices, or to review and request to have deleted any personal information you have shared with us, please contact us at: privacy@privo.com.


A Note to EU Citizens

PRIVO complies with the rights given to EU Citizens under the General Data Protection Regulation (GDPR). These rights are as follows:

  • to correct the personal data we have about you;
  • to withdraw your consent to the processing of your personal data;
  • to obtain a copy of the personal data we hold about you;
  • to have your personal data deleted;
  • to transfer your personal data to another controller to provide you with services;
  • to restrict the personal data we have;
  • to request we stop processing your personal data.

You can action any of these rights by contacting us at: privacy@privo.com.

If you are an EU citizen and would like to make a complaint about the way we process your personal data, you can contact the relevant Data Protection Authority (DPA). Please contact us at privacy@privo.com to find out more.


EU-U.S. Privacy Shield Framework

PRIVO complies with the EU-U.S. Privacy Shield Framework set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union to the United States.  PRIVO has certified to the Department of Commerce that it adheres to the Privacy Shield Principles.  If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/.

In the context of an onward transfer, a Privacy Shield organization has responsibility for the processing of personal information it receives under the Privacy Shield and subsequently transfers to a third party acting as an agent on its behalf.  The Privacy Shield organization shall remain liable under the Principles if its agent processes such personal information in a manner inconsistent with the Principles, unless the organization proves that it is not responsible for the event giving rise to the damage.

In compliance with the Privacy Shield Principles, PRIVO commits to resolve complaints about our collection or use of your personal information.  EU individuals with inquiries or complaints regarding our Privacy Shield policy should first contact PRIVO at: 

17949 Main St., #1025
Dumfries, VA 22026
703–569–0504 (telephone)
703–783–8752 (fax)
privacy@privo.com(email)
Attn: Privacy Officer

PRIVO has further committed to refer unresolved Privacy Shield complaints to JAMS, an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please visit https://www.jamsadr.com/file-an-eu-us-privacy-shield-claim for more information or to file a complaint.  The services of JAMS are provided at no cost to you.

Under certain conditions, more fully described on the Privacy Shield website, you may invoke binding arbitration when other dispute resolution procedures have been exhausted.

The EU-US Privacy Shield, as a legal basis for transfers of personal data, has been invalidated by a judgement from the Court of Justice of the European Union. However, for as long as PRIVO is self-certified to the Privacy Shield, PRIVO agrees to process EU Data in compliance with the Privacy Shield Principles.