Information We Collect About You and How We Collect It
We collect two basic types of information—personal information and —and we may use personal and anonymous information to create a third type of information, aggregate information. For example, we collect:
Our goal is to collect only that information that we believe is required for our legitimate business interests, which include but are not limited to collecting, de-identifying, aggregating and selling information related to your financial transactions, operating the Site, authenticating and verifying your identity, preventing fraud, and improving your experience of using the Site.
How We Use Your Information
We may also use anonymous, statistical or aggregated information (in other words, information that does not identify you) collected on or through the use of the Website, for any purpose. Some examples of how we use this information are: to properly operate the Website, to improve the quality of the Website, to enhance your experience, to create new services and features, including customized services, to change or cancel existing content or service, and/or for further internal, commercial, and statistical purposes.
Disclosure of Your Information
We may also disclose your personal information:
Cookies and Tracking Technologies
During some visits we may use software tools to measure and collect session information, including page response times, download errors, time spent on certain pages and page interaction information.
The technologies we use for data collection may include:
Do Not Track
VMB does not track its customers over time and across third party websites to provide targeted advertising and therefore does not respond to Do Not Track (DNT) signals. However, some third-party sites do keep track of your browsing activities when they serve you content, which enables them to tailor what they present to you. If you are visiting such sites, your web browsing platform allows you to set the DNT signal on your browser so that third parties (particularly advertisers) know you do not what to be tracked.
User Access and Choice
We strive to provide you with choices regarding the personal information you provide to us. However, you may not opt-out of administrative emails, messages, or phone calls (for example, about your transactions or policy changes) for your enrolled profile.
You may access your account on the Website and edit, delete or amend your personal information. You can review and change your personal information by logging into the Website and visiting your account profile page. You can update your User profile and registration information, including your financial account, personal information and email addresses/mobile numbers.
If you find that the personal information in your account is not accurate, complete or updated, then you should make all necessary changes to correct it. Please keep in mind that false, incorrect, or outdated information may prevent you from registering with the Website and impair our ability to provide you with services through the Website. If you are unable to edit, delete or amend any personal information via your Website account, you may submit an access request to us by sending an email to firstname.lastname@example.org. Your email should include adequate details of your request.
Your California Privacy Rights
California Civil Code Section § 1798.83 permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. VMB has not and does not transfer information to third parties for direct marketing purposes. In the event we decided to do so in the future, we would provide further information.
At all times we may review, retain and disclose any information as we deem necessary to satisfy any applicable law, regulation, legal process or governmental request. However, by doing so we do not either expressly or impliedly endorse, affirm or in any manner assume any responsibility for such information.
When your account is terminated, VMB will delete your personal information and discontinue any connection with your financial institution regarding your account. Naturally, once disconnected, you will no longer have access to your VMB account. However, due to periodic backups and safety mechanisms meant for your information protection and/or for our administrative and legitimate business purposes, certain aggregated data and/or personal information from your account may remain in our systems for as long as commercially necessary. We will not knowingly keep this information in a way that could identify you. If you have a query about any such personal information that we may be storing, please email us at email@example.com. Your email should include adequate details of your query.
To help us protect the privacy of your data, we maintain technical, physical, and administrative security measures to protect against loss, misuse, unauthorized access, disclosure, or alteration. Some of the safeguards we use are firewalls, data encryption, physical access controls to our data centers and information access authorization controls. It is your responsibility to make sure that your personal information is accurate and that your password(s) and profile registration information are secure and not shared with third parties.
Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.
European Territory Citizens
In compliance with European privacy laws, in particular the European General Data Protection Regulation (GDPR), VMB provides specific additional rights for citizens of the European Territories, such as the right to access, rectification, right to object, to complaint, erasure and blockage. More specifically:
Please email firstname.lastname@example.org with any questions about exercising any of the above rights.
Data Controller for Personal Data
The Data Controller for the personal data processed by us is the Client Company of VMB (the financial institution of the person whose data is collected, or data subject). The Data Controller will pass personal data of their users to VMB to manage financial transaction data on behalf of those users. VMB, as Data Processor acting on the instructions of the Data Controller under a written contract with them, will subsequently use that personal data to manage financial transaction data. It is this contract which forms the “Legal Basis””for the processing of personal data carried out by VMB in these circumstances.
VMB will also become a Data Controller if, and when, it collects additional personal data directly from a data subject. In these circumstances VMB will be acting under a “Legitimate Interest” to legally process the data for the management of the data subject’s financial account and to fulfil the contractual requirements for its Client.
Grounds for Processing
The GDPR requires that companies processing the personal data of EU users do so on the basis of specific legal grounds. As described below, VMB processes the information of EU users based on one or more of the grounds specified under the GDPR:
The End User Service Agreement defines eligibility requirements to use the VMB Website and related services. Our Site is not intended for children. For information about the Children’s Online Privacy Protection Act (COPPA), visit the FTC website: www.ftc.gov.
Links to Third Parties
Our website may contain links to other third-party websites, such as your Financial Institutions. When you leave our website and visit those websites, you are bound by the privacy policies of those websites. We are not responsible for the privacy practices of these third-party websites, which are governed by their own privacy policies and practices.
Territorial Scope and Processing