What services does the Privacy Policy cover?

This policy applies to all Virtual Doorman products and services provided by Future Communications Corporation of New York, d/b/a Virtual Service including all Virtual Doorman apps, as well as the Virtual Doorman website (www.virtualdoorman.com) and software (collectively the “Virtual Doorman Service”).

Customers and Users

Our “Customer” is typically an entity acting on behalf of a building or property and those Customers purchase and utilize products or services that are part of the Virtual Doorman Service. As a resident or visitor to our Customers’ properties, you are a user of the Virtual Doorman Service. We collect information from various types of users on behalf of our Customers. Types of users can include building staff, maintenance personnel, managers, etc., as well as residents/tenants, owners, subtenants, guests, etc., service providers (contractors, vendors, etc.) and others. A “Registered User” refers to anyone who has a Virtual Doorman username and password. Other users may not be Registered Users but may use our services as a visitor to our public website. We act as the custodian of each Customer’s data and each Customer determines its own policies regarding information collection, access, sharing and retention. Please contact your building manager if you have any questions regarding their privacy practices.

The Information we collect

In order for you to use the Virtual Doorman Service, we need to collect and process certain information (i.e. your name or address, your IP address, etc. as well as error reports or use cookies (see below)) which is provided by you or your building management when using the Virtual Doorman Service.

Some additional information may be obtained from other Registered Users such as family members, roommates, or other guests or visitors (i.e. housekeepers, cleaners, caretakers, etc.) who are given authorization and/or access through Virtual Doorman.

The types of information we collect depend on your level of access and engagement with the Virtual Doorman Service and can include:

• Contact information such as names, email addresses, mailing addresses, phone numbers
• Unique identifiers such as usernames, passwords, Virtual Doorman account numbers
• Other information submitted by you (or on your behalf) such as details regarding maintenance and/or service requests
• Information or documents that you upload related to your Virtual Doorman Service
• Your communications with us, for example your contact with customer support
• Usage data such as IP addresses, browser type, date/time stamp and clickstream data
• Employment information for building employees and/or vendors (including title, name, phone number)
• Photographs uploaded by you (of residents, employees, pets, visitors, maintenance request attachments)
• Scans of certain credentials for vendors (license, business card, etc.)
• Incident details and information
• Any instructions provided by residents, such as permissions to enter, access protocols for authorized visitors, etc.

Cookies

Cookies are small amounts of data that are sent to a user’s browser from a website and stored on a user’s hard drive for record-keeping purposes. This information does not necessarily identify the user, but identifies the user’s computer. We use cookies on this site to provide users with customized and personalized services. The cookies used will not collect any personal information like name, address or telephone number.

Legal Bases for Collecting Information

We process personal data for, or based on, one or more of the following legal bases:

Why We Collect Your Information

Virtual Doorman uses the information we collect for the following purposes:

How we use the information

For users of the Virtual Doorman Service, we use the information we receive to:

• Provide the services your building requested
• Notify you of activity related to your account, such as when a package is delivered or a visitor arrives
• Administer your account
• Keep your account secure (including to verify your identity and prevent fraud)
• Respond to customer service and support requests
• Create and provide better and improved products and services based on your use of the site and your feedback
• Conduct research and analysis
• Send you our customer communications materials, which you may opt out of at any time

California Residents’ Privacy Notice

The following user access and choice rights are obligations of Virtual Doorman where we are the “business” under the CCPA (i.e., with respect to the personal information described above under the caption “Personal information we process as a controller or business”). With respect to all other personal information described herein, the access and choice rights are properly addressed between you and our relevant Customer subject to such Customer’s privacy policy.

Residents of the State of California may request information regarding the categories of personal information we gather about you, the categories of sources from which we obtain the personal information, the business purposes for which the personal information is gathered, and the categories of third parties with which we share or, in the event we ever sell personal information, by category of personal information sold to such parties, respectively.

Upon verifiable request or when required or otherwise appropriate, and within periods (if any) set by applicable law, we will grant you reasonable access to or copies or other compilations of the specific items of personal information that we hold about you provided that you establish to our reasonable satisfaction that you are the person whose personal information is requested. We may deny such access where the denial is permitted by applicable law and every request from an individual will be assessed on a case by case basis. In the event a request is denied, we will notify you regarding the reasons for the denial in writing. Consistent with how your personal information is maintained in the ordinary course of our business, we will provide the information in an understandable form, and to the extent feasible in a format that permits you to use the information on other systems. We may impose a reasonable charge when a request is made (e.g., for photocopying or postage) to the extent permitted under applicable law.

We will take reasonable steps to permit you to correct or amend personal information that is demonstrated to be inaccurate or incomplete. We also will delete personal information we have gathered about you when you make a verifiable request that we do so, except to the extent applicable law permits or requires us to maintain that information.

To guard against fraudulent requests for access, we will require sufficient information to allow us to confirm the identity of the individual making the request before granting access or deleting the information. We will not discriminate against consumers who exercise their rights under California law. However, we may charge different prices or provide a different quality of goods or services if the difference is reasonably related to the value provided by your personal information.

California’s Do Not Track Notice: At this time, there is no worldwide uniform or consistent industry standard or definition for responding to, processing, or communicating Do Not Track signals. Thus, like many other websites and online services, we are currently unable to respond to Do Not Track signals. To find out more about “Do Not Track”, you may wish to visit http://www.allaboutdnt.com.

Service Providers

We share your personal information only with your consent or as necessary to complete any transaction or provide any product you have requested or authorized. We may provide your personal information to companies that provide services to help us deliver our services such as processing payments, hosting applications or fulfilling other functions of the website. These third-party service providers are limited to accessing or using this information solely for the purpose of providing services to us and to you and must provide reasonable assurances that they will appropriately safeguard all information. For example, we transfer anonymous phone numbers to our communications provider TELNYX, which completes calls and text messages for our Virtual Doorman service and building notifications. You can view the TELNYX Privacy Policy here.

Aggregated Information

Your personal information is neither sold nor rented to third parties without your express permission. We do retain the right to share non-identifying aggregated demographic and/or statistical information with partners, advertisers and sponsors. We may use non-identifying and aggregated information to improve your experience on the website and to share with partners, advertisers and sponsors. For example, any personal information will remain with us, however, your visit may be counted to demonstrate the number of visitors to a particular page or area of the site.

Links to Third Party

Our Virtual Doorman Service may include links to other Web sites whose privacy practices may differ from those of Virtual Doorman. If you submit personal information to any of those sites, your information is governed by their privacy policies. We encourage you to carefully read the privacy policy of any Web site you visit.

Legal Disclaimer

We may disclose your personal information:

• As required by law, such as to comply with a subpoena, or similar legal process
• When we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request
• If Virtual Doorman is involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via email and/or a prominent notice on our Web site of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information

Virtual Doorman will only retain personal data we process on behalf of our Customers for as long as needed to provide services and as necessary to comply with our legal obligations, resolve disputes and enforce our agreements.

User Access and Choice

You may access, correct, update, amend or remove certain personal information by making the change on your user account settings page or by requesting that your property manager (or other administrator) make such change on your behalf. Your account is protected by a password. We encourage you to choose your password carefully and keep it secure. If you have trouble accessing your account or your information, you can contact Virtual Doorman by emailing our customer support team at support@virtualdoorman.com.

Opt-out Choices

Virtual Doorman offers you choices regarding the collection, use and sharing of your personal information. Under the Privacy Shield Principles, you have the right to opt-out of i) disclosures of your personal information to third party vendors not identified at the time of collection or subsequently authorized, or ii) uses of your personal information since you are not required to provide any personal data. If you no longer require our services or wish to request your personal information be deleted/removed, please contact us using the aforementioned direct methods.

Our commitment to children’s privacy

Protecting the privacy of the very young is especially important. For that reason, we never collect or maintain information at our website from those we actually know are under 13, and no part of our website is structured to attract anyone under 13.

Data Protection Officer

To contact our Data Protection Officer, please email privacy@virtualdoorman.com.

Changes to this policy

We may update this privacy policy to reflect changes to our information practices. If we make any material changes, we will notify you by email (sent to the e-mail address specified in your account or by means of a notice on this page prior to the change becoming effective). We encourage you to periodically review this page for the latest information on our privacy.

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