1. What information does Vista collect about you?
We may collect different types of information about you, including:
Device Information: When you visit our Website, interact with our Social Media Pages or online ads, or open our emails, we learn about your browser, device type, IP address, internet service provider, and other technical information about your device.
Location Information: We use various technologies to learn your geographic location, including by collecting your IP address or other device information, which may depend on your device’s settings for location services.
Contact Information: We may collect contact information, which includes personal information like name, email address, phone number, and home or business address.
Call and Email Records: If you call or email us, we may keep records of those conversations.
Website Interactions: We collect information about your interactions with our Website including pages visited, links clicked, buttons clicked, mouse movement, and scroll behavior. This information may then be used to replay your interaction, which may be used to troubleshoot Website issues, either individually or in the aggregate, to improve Website functionality and to analyze user interaction. This information could include personal information, depending on what information you provide.
Submitted Content: We collect any content you submit to our Website, Social Media Pages, or to us in person including comments, photos or videos.
Demographic Information: We have access to demographic details about our customers like birthdate, gender, ZIP code, and other similar details.
Job Applications: If you apply for employment, we have access to the content you provide such as your resume, cover letter, and any information contained therein.
Social Media Usage: We receive aggregated information about people who visit and interact with our Social Media Pages. “Aggregated” means information that doesn’t include personal information associated with identified natural persons.
2. How do we collect your information?
We may collect the information described above directly from you, from third parties we partner with, or through cookies or other automated means. These sources may include:
You: We collect information directly from you, whenever you: visit our Website; contact us with questions or comments; engage our services; upload content to our Website or Social Media Pages; complete forms for or provide information in connection with a job application; or fill out any forms on our Website or Social Media Pages.
Your device or browser: Certain information is automatically collected from your device or browser and analyzed when you visit our Website, interact with our Social Media Pages or online advertising, or open our emails.
Third parties: We work with third parties who provide services to us such as analytics or advertising. Your information may be collected and processed independently in accordance with the third party’s own privacy notices. These third parties share information they have collected with us. We may combine this information with any information we collect.
Social media platforms: Social media platforms share information, which is typically aggregated and doesn’t include personal information, with us. You can learn more about how social media platforms collect and use your information by reviewing their privacy policies and settings.
3. How do we use the information we collect about you?
We only use your information for legal and legitimate purposes, such as:
Providing Services: Providing our services to you or to our customers, promoting and marketing our services, improving our services, communicating with you about our services, and complying with our legal obligations relating to those services.
Advertising: Presenting advertising online and via email, or other communication channels, including through partnerships with social media platforms and internet search engines.
Understanding Our Website Users: Analyzing your activity with us (including your interactions with our Website, Social Media Pages, emails, or other forms of communications). We keep track of the pages you visit and the manner in which you use the Website to determine whether to make changes to the Website. We may, from time to time, review your information and information of other Website users to help us analyze trends, preferences, and demographics.
Communications: Communicating with you, including responding to your requests, asking for feedback through surveys or other messages, or sending you information that we think may be of interest to you.
Website Experience: Serving content on our Website and Social Media Pages and developing our services.
Performing a Contract: Processing your information in connection with pre-contract activities and discussions with you, or performing a contract that we have with you.
Recruitment: Recruiting and hiring, including, but not limited to, verifying your eligibility for employment and assessing your suitability for any position for which you may apply at Vista.
Security: Protecting Vista, our customers, and our Website users from fraud, security threats, and other illegal or harmful activity. We and our third party service providers may disclose specific individual information if we or they reasonably believe it is necessary to: (i) investigate any suspected misuse of a Website; (ii) protect or defend the rights, property and interests of Vista, our Website users, or the interests of our third party service providers; or (iii) under exigent circumstances, to protect the personal safety of users of a Website or the public.
Legal Obligations: Complying with legal and regulatory requirements and responding to requests from courts or other government bodies.
Other Legitimate Interests: Processing your information for any of our other legitimate interests not described above.
4. How long do we keep your information?
We will retain your information for as long as is necessary to fulfil the purpose for which your information was collected and in accordance with our internal retention procedures, or as otherwise necessary to satisfy our legal obligations. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.
In some circumstances we may anonymize your information for research or statistical purposes in which case we may use such anonymized information indefinitely.
5. How does Vista share information with Service Providers and Third Parties and for what purposes?
Vista may share personal information with third parties for certain purposes. For example, we may share personal information with:
Service Providers: We partner with third parties to assist with many aspects of our business, including our professional advisors and other IT and administrative service providers who help us communicate with you. These third parties may provide services related to any of the purposes described in How do we use the information we collect about you?, and we may share with them any types of information described in What information does Vista collect about you? We may also receive information collected by these third parties and combine it with the information we have collected. Some of these third parties may be located outside the United States. Your information may also be collected and processed by third parties who will process your information independently in accordance with their own privacy notices.
Marketing Providers: We partner with third parties to assist with the advertising and marketing of our business. We may share with them the types of information described in What information does Vista collect about you? We may also receive information collected by these third parties and combine it with the information we have collected.
Operations: We operate our Website from the United States of America and store the information we collect through our Website in the United States of America. We market and provide services, however, in countries throughout the world. Accordingly, we may disclose information collected through our Website, as well as other information, across geographical boundaries, within and outside of Vista, for legal and legitimate purposes.
Other Third Parties: We will disclose information about you, including to government bodies or law enforcement agencies, when we believe it to be necessary for compliance with the law or to protect our Website users, our Website, or the public.
If you are a resident of California, Virginia, Colorado, Connecticut, Utah, the EEA, UK, or Switzerland you can learn more about your privacy rights below.
6. What are my privacy choices?
You can control the information we collect and use in the following ways:
Location Information: You can disable location-based services on your mobile device or web browser by adjusting the settings on your device or browser. This will prevent our Website from accessing your location information. Note that some services may not be available if you disable location-based services.
Emails: You may opt-out of our marketing emails by following the instructions listed in any email communications that you receive or by contacting us using the contact details provided under the How may I contact Vista? section, below. If you are a data subject in the EEA, for email marketing to an individual (that is, a non-corporate email address), we need your consent to send you unsolicited email marketing. Where you provide consent, you can withdraw your consent at any time, but without affecting the lawfulness of processing based on consent before its withdrawal.
Online Advertising: For information about opting out of third party advertising, visit: NAI Opt-Out or DAA. You will leave this Website for a separately managed online site where you can specify your preferences. You can also click on the icon that may appear on some of our advertising served through this technology. We may use more than one third party company for placing this advertising, which would require you to opt out of each company.
Google Analytics: Depending on your location, we may utilize Google Analytics. You can opt out of Google Analytics across all websites you use. To do so, visit this website.
Postal Marketing: To opt-out of other forms of marketing (such as postal marketing), please contact us using the contact details provided under the How may I contact Vista? section below.
7. How does Vista address children’s privacy?
Our Website and Social Media Pages are not intended for children under 16. No one under 16 should share any personal information with us. We do not knowingly collect any personal information from children under 16. To request deletion of personal information relating to a child under 16, please email firstname.lastname@example.org.
8. How does Vista secure personal information?
We employ physical, technical, and administrative procedures to safeguard the personal information we collect online. While we use these security measures on our Website, you should be aware that 100% security is not always possible.
9. How does our Website interact with third-party websites and content?
For your convenience, we may enable you to navigate to third-party sites through links on our Website. We do not endorse these third-party sites, do not have any affiliation with these third-party sites, and we do not control and are not responsible for their Internet and web practices. Whether the third-party content appears within our Website environment (like a map frame), or you leave our Website for another website to view it, the terms, conditions, and privacy policies of those other websites govern your online experience. Please review their separate terms of service and privacy policies if you have any questions about their practices.
10. Where is personal information stored and processed?
The global nature of our business means that your information may be transferred outside the jurisdiction in which you provide it, including, potentially, to countries that do not require organizations by law to look after your personal information in the way in which you have come to expect in your own country. The European Commission has not made an adequacy determination with respect to data transfers to the United States, and if you live in the EEA, the UK, or Switzerland, United States privacy laws may not provide you the same rights you may have in your own country.
Where we transfer your personal information across national boundaries, we will protect your information by ensuring that those transfers are made in compliance with all relevant data protection laws.
11. What other terms govern my use of the Website?
Your use of the Website is also governed by the Disclaimer & Disclosures.
13. Your U.S. State Privacy Rights
Residents of California, Virginia, Connecticut, Colorado, and Utah have certain rights concerning the processing and use of their Personal Data. The rights described herein are subject to exemptions under applicable law. For purposes of this section, the term “Personal Data” includes both “Personal Information” and “Personal Data” as defined by applicable law.
If your Personal Data is subject to a privacy law in your state, you may have certain privacy rights with regard to that information. You may have the right to:
Know, access, and confirm your Personal Data.
Delete the Personal Data we have about you, subject to exceptions under applicable law.
Correct inaccuracies in your Personal Data.
Obtain your Personal Data in a portable and readily usable format.
Opt-out of the use or processing of your Personal Data for profiling or targeted advertising.
Opt-out of the sale of your Personal Data.
Under certain state laws, you may also have the right not to receive discriminatory treatment for the exercise of any of these privacy rights. We will not discriminate against you because you have exercised any of your rights.
Certain state laws may also provide you the right to appeal our decisions regarding your rights requests if we do not respond to your requests or do not take action regarding your requests. Additionally, if you are a resident of the state of California, you may have a right to pursue legal action for improper handling of your Personal Data.
How to Submit a Request
If you wish to exercise the rights listed above, and are a resident of a state that provides such privacy rights, you may submit a request by emailing email@example.com, by calling us toll-free at 888.254.7312, or by using this form. We will provide your Personal Data to you in writing in a readily usable format. If you choose to submit your request via email, you must include “Privacy Rights Request” in the subject line and clearly provide us with the following information: what type of request you are making, your full name, email address, and valid physical address. You may only make one request per email.
We are required to provide you with access to your Personal Data or delete your Personal Data only in response to verifiable consumer requests. We will compare the information you provide to us in your request to any information we may have in our possession in order to verify your request. You may be asked to provide us with information such as your home address, email address, and telephone number. We may also contact you to request additional information in relation to your request. Please promptly respond to any follow-up inquiries so that we may verify your identity. If you request that we provide you with specific pieces of information about you, or that we delete sensitive Personal Data, we may apply heightened verification standards than what we would apply to other types of requests. The information you provide must match the information we have in our possession. This measure is in place to help ensure that Personal Data is not disclosed to any person who does not have the right to receive it. The information collected through this process will be used for verification purposes only.
Please note that you may authorize an agent to exercise any of these rights on your behalf by contacting us at firstname.lastname@example.org, toll-free at 888.254.7312 or by submitting the request via this form. If you use an agent, we will take measures to verify your agent’s authorization similar to the verification described above for fulfilling any access or deletion requests. We may require more information to ensure proper verification of you and your agent’s identity and authorization.
Categories of Personal Data Disclosed for a Business Purpose
We share Personal Data about you with service providers and third parties for business purposes, such as operational purposes and other purposes related to providing you with the services you seek from us. For more information about the business purposes for which we disclose Personal Data, see How do we use the information we collect about you? and see What information does Vista collect about you on our Website? for what types of information may be shared.
“Do Not Sell” Rights; Sharing for Cross-Context Behavioral Advertising, Profiling, or Targeted Advertising
We may disclose your Personal Data for the following purposes, which are not a sale: (i) for reasons mentioned above; (ii) if you direct us to share Personal Data; (iii) to comply with your requests under applicable law; and (iv) as otherwise required or permitted by applicable law.
We do not sell Personal Data or share Personal Data about you for purposes of cross-context behavioral advertising, profiling, or targeted advertising.
You may request that we delete your Personal Data that we have collected directly from you. Under applicable law, we may decline to delete your Personal Data under certain circumstances, for example, if we need the Personal Data to complete transactions or provide services you have requested or that are reasonably anticipated, for security purposes, for internal business purposes (including maintaining business records), to comply with law, or to exercise or defend legal claims. Note also that we are not required to delete your Personal Data that we did not collect directly from you. We require a reasonable or high degree of certainty that the requester is the consumer for which a deletion request is applicable, depending on the sensitivity of the Personal Data.
Additional California Privacy Rights
We do not share Personal Data as defined by California Civil Code Section 1798.83 (“Shine the Light Law”) with third parties for their direct marketing purposes absent your consent. If you are a California resident, you may request information about our compliance with the Shine the Light Law by emailing us at email@example.com with “Shine the Light Request” in the subject line. Any such request must include “California Privacy Rights Request” in the first line of the description and include your name, street address, city, state, and ZIP code. Please note that we are only required to respond to one request per individual each year, and we are not required to respond to requests made by means other than through this form or mail address.
Sensitive Data of Virginia, Colorado, or Connecticut Residents
If you are a resident of Virginia, Colorado, or Connecticut, we will not process your Sensitive Data (as that term is defined under the Virginia Consumer Data Protection Act; the Colorado Privacy Act; and Connecticut’s Act Concerning Personal Data Privacy and Online Monitoring) without your prior consent.
14. Your International Privacy Rights
We may transfer your Personal Data (as that term is defined by applicable law) to organizations located in countries other than the one in which the Personal Data was collected. If you are located in the EEA, the United Kingdom, or Switzerland, you may have certain rights and protections under applicable laws regarding the processing of your Personal Data. Each of these laws generally affords data subjects the right to:
Know whether we’re processing your Personal Data.
Request a copy of the Personal Data we hold about you.
Request that we correct inaccurate or incomplete Personal Data we hold about you.
Request that we erase your Personal Data, subject to exceptions under applicable law.
Request that we transfer any Personal Data we hold about you to another company.
Under certain circumstances, restrict certain types of processing.
Object to having decisions made about you by automated processes or profiling.
Withdraw your consent.
Lodge a complaint with the supervisory authority.
We do not use profiling (where an electronic system uses Personal Data to try and predict something about you) or automated decision making (where an electronic system uses Personal Data to make a decision about you without human intervention).
How to Submit a Request
If you are located in the EEA, the United Kingdom, or Switzerland and you wish to exercise any of your rights, please submit your request by emailing us at firstname.lastname@example.org.
There are exceptions to the rights of individuals in relation to their Personal Data, meaning that your rights may be limited. We will, at all times, respect your Personal Data and seek to be as transparent as possible.
If you would like to make a complaint about how we handle your Personal Data, or make a complaint about a breach of data protection laws, please contact us using the contact information described above. Complaints will be investigated and the outcome of the investigation will be communicated to you after the complaint is made in accordance with applicable law. You may have a right in some locations to file a complaint with your local data protection authority.
Legal Basis for Processing
We will process your Personal Data only where we have a lawful basis for doing so. These “lawful bases” for processing are set forth in applicable data protection law and, depending on the relevant circumstances and jurisdiction, our processing will be on the basis of one or more of the following: (a) the performance of a contract to which you are a party or in order to take steps at your request prior to entering a contract; (b) compliance with our legal obligations; (c) for our legitimate interests (this includes carrying out the business of providing legal services and pursuing our general business interests); (d) the establishment, exercise or defense of legal claims; (e) to carry out tasks in the public interest/reasons of substantial public interest; or (f) to comply with laws relating to anti-money laundering or counter-terrorist financing obligations or the prevention, detection, or prosecution of any crime.
In addition, in some circumstances we may process your information if you have provided your consent for us to do so. Please note that you have the right to withdraw any such consent by contacting us using the contact details below.
We store Personal Data for as long as necessary to carry out the purposes for which we originally collected it and for other legitimate business purposes, including to meet our legal, regulatory, or other compliance obligations.
Data Protection Principles
When processing your Personal Data, Vista adheres to the following principles:
Lawfulness, Fairness and Transparency: Personal Data must be processed lawfully, fairly, and in a transparent manner.
Purpose Limitation: Personal Data must be collected for specified, explicit, and legitimate purposes and not further processed in a manner that is incompatible with those purposes.
Data Minimization: Personal Data must be adequate, relevant, and limited to what is necessary in relation to the purposes for which it is processed.
Accuracy: Personal Data must be accurate and kept up to date.
Storage Limitation: Personal Data must be kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data is processed.
Integrity and Confidentiality: Personal Data must be processed in a manner that ensures appropriate security of the data, including protection against unauthorized or unlawful processing and against accidental loss, destruction or damage by using appropriate technical or organizational measures.
We may process additional Personal Data provided by you for marketing purposes, for example in relation to an event, when you let us know what services you are interested in, and when you wish to be contacted by us. We will not use your Personal Data to send you marketing materials if you have requested not to receive them. Your Personal Data may also be collected in our relationship management system when you register online to receive information, or when we otherwise receive your contact details. You can update or request, however, to have your Personal Data removed from our relationship management at any time by contacting us at email@example.com. You also will be provided with the option to unsubscribe or opt-out from receiving further marketing communications by following the instructions at the bottom of each communication.
Data Protection Authority
If you have a concern about our processing of Personal Data that we are not able to resolve, you may have the right to lodge a complaint with the Data Protection Authority where you reside. Contact details for your Data Protection Authority can be found using the links below:
For individuals in the EEA: https://edpb.europa.eu/about-edpb/board/members_en
For individuals in the UK: https://ico.org.uk/global/contact-us/
For individuals in Switzerland: https://www.edoeb.admin.ch/edoeb/en/home/the-fdpic/contact.html
15. How may I contact Vista?
You may also contact:
Vista Site Selection, LLC
52 East Gay Street
Columbus, Ohio 43215
Effective Date (last updated): February 13, 2023