VIQTORY (“VIQTORY”, “Company”, “Our”, “We”, or “Us”), a subsidiary of Neptune Holdings, Inc. (“Neptune Holdings”), respects your privacy and is committed to protect it through our compliance with this policy.

This Privacy Policy applies to information we collect on the VIQTORY website, as well as the websites of VIQTORY brands, including GI Jobs® and Military Friendly® (collectively “the Sites”) and through your mobile device. It does not apply to information collected offline or by any third-party, including through any application or content (including advertising) that may link to or be accessible from or on the Sites.

Please read this Privacy Policy carefully to understand our policies and practices regarding your information and how we treat it.  If you do not agree with our policies and practices, you may choose not to use our Sites.  By accessing the Sites, you agree to this Privacy Policy.

CHANGES TO THE PRIVACY POLICY

This policy may change from time to time.  All changes are effective immediately when we post them.  Your continued use of the Sites after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

CHILDREN UNDER THE AGE OF 16

Our Sites are not intended for children under 16 years of age.  No one under 16 may provide any personal information to or on the Sites.  We do not knowingly collect or sell personal information from children under 16.  If you are under 16 years of age, do not provide any information about yourself on the Sites or through any mobile device such as your name, address, telephone number or e-mail address.

INFORMATION WE COLLECT AND HOW WE COLLECT IT

We collect several types of information from and about users of our Sites, including:

  • personal identifying information such as name, gender, postal address, e-mail address, telephone number (including mobile devices), date of birth, education and information on your military service (”Personal Information”);
  • information which is about you, but does not identify you individually (“Aggregate Information”).

We collect this information from you in the following ways:

  • Voluntarily from you when you (1) register or create an account on one or more of our Sites or become a Client or Sponsor; (2) communicate with us via telephone, e-mail or text, including our SMS Service; (3) enter a contest, sweepstakes or other promotion on one of our Sites; (4) interact with us through Public Areas such as forums, bulletin boards, discussion groups, chat rooms or other methods of communication that may be offered on our Sites (“User Contributions”); and/or (5) otherwise provide information in connection with services you choose to utilize on our Sites;
  • As described in the section immediately below, as you navigate through our Sites, information is collected automatically, which may include usage details, IP addresses and information collected through cookies, web beacons and other tracking technologies.

INFORMATION COLLECTED AUTOMATICALLY THROUGH COOKIES, WEB BEACONS AND OTHER TRACKING TECHNOLOGIES

As you use our Sites, we may use automatic data technologies to gather and log information about your equipment and navigation patterns, including:

  • Details of your visits to our Sites, including the resources that you access and use;
  • Your IP address, browser type, operating system and internet service provider

The technologies used for this automatic data collection may include:

  • Cookies are small bits of data written to your hard drive when you visit our Sites that contain information such as a user or session ID to track the pages you have visited so you do not have re-enter your ID information throughout your visit;
  • Flash Cookies. Certain features of our Sites may use local stored object (or Flash cookies) to collect and store information about your preferences and navigation to, from and on our Sites.
  • Web Beacons. Pages on our Sites may contain small electronic files known as web beacons that permit, for example, statistics on the number of users who have visited those pages and the popularity of certain content on our Sites.

We do NOT collect Personal Information automatically. Information and data collected automatically is used in aggregate form only.

Some content or applications on our Sites, including advertisements, are served by third-parties such as ad networks, advertisers, servers, content providers and application providers.  These third-parties may use tracking technologies to collect information about you when you use our Sites. We do not control these third-parties or their use of information they may collect through such tracking technologies.  If you have questions or concerns about an advertisement or other targeted content, you should contact the responsible provider directly.

WHY WE COLLECT INFORMATION ABOUT YOU

VIQTORY collects Personal Information and Aggregate Information from you for a number of reasons, including:

  • To provide you with information about the products and services offered on our Sites that we believe will be of interest to you;
  • for system maintenance, to perform surveys and to gain a better understand how our Sites are used;
  • to help us develop new products and services;
  • to improve the services we offer on our Sites by customizing the advertising and content you see on the Sites;
  • for those services on our Sites that require you to register, to create and manage your account;
  • to contact you to secure additional information that is needed to better serve you;
  • when you use our SMS Service, to respond to your request for information about our services and products;
  • to notify you about changes to our Sites and/or any new products or services offered on the Sites, including opportunities we may offer on a co-branded or cross promotional basis with our partners;
  • to detect or resolve problems with our Sites, to assist with customer support, to provide security and to protect against fraud

SALE OF ASSETS

In the event that Viqtory is involved in a merger, acquisition, or sale of all or a portion of its assets, including in bankruptcy, we reserve the right to include, disclose and transfer any or all stored Personal Information and other data among the assets transferred to the acquiring company. If this occurs, you will be notified via email and/or a prominent notice on our Site of any change in ownership or material changes in uses of your Personal Information, as well as any choices you may have regarding your Personal Information.

HEALTH TARGETING

We partner with third parties to provide customers with health targeting options. If you would like to view the current list of third-party health and wellness interest segments available through Viqtory, please contact us.

POLITICAL TARGETING

We partner with third parties to provide customers with political targeting options. If you would like to view the current list of third-party political interest segments available through Viqtory, please contact us.

DISCLOSURE OF YOUR INFORMATION

Aggregate Information is shared with third-parties for research or marketing purposes.  You understand that Aggregate Information does not identify you individually and can be used and shared by us without restriction.

We may disclose Personal Information that we collect about you as follows:

  • to third-parties with whom we partner for co-branded or cross-promotional shopping opportunities, games, services or other applications that we believe will interest and provide benefits to you or who wish to contact you to promote their own goods and services;
  • to contractors and service providers that we use to perform specific functions for our business and our Sites. Such third-parties are authorized to use your Personal Information only for the purpose of providing the specific services requested by us;
  • to potential employers, recruiters and educational institutions by providing access to our databases and/or selling information from our databases to such recruiters, educational institutions and employers;
  • to a buyer or other successor in the event of a sale or transfer of some or all of the Company’s assets, if the Personal Information held by the Company is among the assets sold or transferred;
  • to comply with a court order, law or legal process, including any government or regulatory request;
  • to enforce our Terms of Service;
  • where such disclosure is needed to protect the rights, property or safety of the Company, our users, Clients or others.

LINKS TO OTHER SITES

Our Sites may contain links to the sites of our sister companies, Clients, Partners and Advertisers and to other sites that are owned and operated by VIQTORY, Neptune Holdings or third-parties.  These other sites may have their own privacy policies and are not governed by this Privacy Policy.  We are not responsible for the privacy practices owned and operated by these third-parties.  These sites may collect and treat information differently so we encourage you to carefully review and read the privacy policy for any site you visit.

YOUR CHOICES

Opting Out of Viqtory Targeted Advertising on Your Browser

Viqtory engages in interest-based advertising activities, including cross-device linking, as described above. If you would like to stop receiving interest-based advertising from Viqtory on your browser, click here. By doing so, Viqtory will replace your unique cookie with an “opt-out” cookie that will prevent us from serving you interest-based advertising. An opt-out choice means that we no longer use or transfer data from the opted out device for targeted advertisements, and we no longer use data collected on other devices to inform advertisements on that device. We will still collect and store information through such cookies for other purposes such as metrics and analytics and we may still serve you advertising, but it will not be tailored for you. Because cookies are browser specific, if you use more than one browser or device, you will need to make your opt-out choice on each browser or device that you use. To do so, point each browser that you use to this page, and click on the disable link above. Please note that you will need to set the Viqtory opt-out cookie again in some cases, for example, under the following circumstances: You buy a new computer, delete cookies from your browser, or upgrade the browser of your existing computer.

Viqtory DSP partner is a member of the Network Advertising Initiative (NAI) and adheres to the NAI Code of Conduct. Additional information on the NAI and its code can be viewed at http://www.networkadvertising.org/code-enforcement/code.

Viqtory also licenses the AdChoices icon from the Digital Advertising Alliance (“DAA”) at http://digitaladvertisingalliance.org/ and the DAAC at http://youradchoices.ca for the purpose of providing enhanced notice and to inform users when they are being behaviorally targeted and to provide an opportunity to opt out.

Viqtory makes every effort to ensure adherence to the self-regulatory principles of the DAA and the DAAC.

To opt-out of interest-based advertising by other companies participating in the following consumer choice mechanisms, please visit:

— Digital Advertising Alliance (DAA)’s self-regulatory opt-out page (http://optout.aboutads.info/) and mobile application-based “AppChoices” download page ( https://youradchoices.com/appchoices)

— European Interactive Digital Advertising Alliance (EDAA)’s consumer opt-out page (http://youronlinechoices.eu)

— Network Advertising Initiative (NAI)’s self-regulatory opt-out page (http://optout.networkadvertising.org/).

Do Not Track

We currently honor Do Not Track signals transmitted by browsers by treating this signal as an opt out of interest-based advertising.

OPTING OUT FROM VIQTORY’S LOCATION-BASED ADVERTISING

You may opt out of our collection, use, and transfer of precise location data for location-based advertising purposes, by using the location services controls in your mobile device’s settings.

 

ACCESSING YOUR INFORMATION

You may request to access your Personal Information that we hold, as well as to correct, amend or delete information when it has been processed in violation of the Privacy Shield Principles or when otherwise required by law. To make such requests, please contact us at privacy@viqtory.com. We will respond to these requests in accordance with the laws that apply to you and within a reasonable timeframe. You can help us maintain the accuracy of your information by notifying us of any changes to your information. We may deny a request in some cases when permitted by law, such as when the burden or expense of providing access would be disproportionate to the risks to the individual’s privacy in the case in question, or where the rights of persons other than the individual would be violated.

INTERNATIONAL OR CROSS-BORDER TRANSFER OF YOUR PERSONAL INFORMATION AND YOUR EXPRESS AGREEMENT

By providing Personal Information and/or by communicating with us by email, you acknowledge and expressly consent to our processing and disclosure of your Personal Information outside your country. The Personal Information of users who are located outside the U.S. may be transferred outside of each eligible country to the U.S., where our servers are located and where it will be processed and stored on servers in the U.S.

 

EU DATA SUBJECTS: PROCESSING OF PERSONAL INFORMATION

We process Personal Information with your consent. On other occasions, we may process Personal Information when we need to do so to fulfill a contract (for example, for billing purposes) or where required to do this by law. If necessary, we may also process Personal Information when it is in our legitimate interests to do this (e.g., for auditing purposes or for fraud detection) and when these interests are not overridden by your data protection rights.

EU data subjects may have rights to access, portability, to revoke consent, to correct, delete, and/or object to or restrict processing of the Personal Information you provide to us. You can email a request to us at privacy@viqtory.com. We will respond to your request in a reasonable timeframe and in accordance with the law that applies to you. Sometimes a request in relation to your Personal Information may not apply to certain information, such as information we may keep to comply with legal requirements.

Additionally, you have the right to lodge a complaint against us. To do so, contact the supervisory authority in your country of residence.

EU-U.S. PRIVACY SHIELD AND SWISS-U.S. PRIVACY SHIELD

Viqtory and it’s DSP participates in and has certified its compliance with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework. Viqtory is committed to subjecting all Personal Information received from European Union (EU) member countries,the United Kingdom and Switzerland, respectively, in reliance on each Privacy Shield Framework, to the Framework’s applicable Principles. To learn more about the Privacy Shield Frameworks, and to view our certification, visit the U.S. Department of Commerce’s Privacy Shield List, here: https://www.privacyshield.gov.

To learn more about the Privacy Shield principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity & Purpose Limitation, Access & Recourse, Enforcement & Liability, please visit https://www.privacyshield.gov/welcome.

Viqtory is responsible for the processing of Personal Information it receives, under each Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf. Viqtory complies with the Privacy Shield Principles for all onward transfers of Personal Information from the EU and Switzerland, including the onward transfer liability provisions.

With respect to Personal Information received or transferred pursuant to the Privacy Shield Frameworks, Viqtory is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, Viqtory may be required to disclose Personal Information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.

Under certain conditions, you may be entitled to invoke binding arbitration when other dispute resolution procedures have been exhausted, as described more fully on the Privacy Shield website here: https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint.

USER CONTRIBUTIONS

Our Sites may contain Public Areas where User Contributions are posted. Users of these Public Areas should be aware that when they voluntarily disclose Personal Information in content submitted for posting, that information can be read and used by others. We make no representations and undertake no obligations as to the security or use of Personal Information you voluntarily include when submitting such User Contributions.

SECURITY OF PERSONAL INFORMATION

VIQTORY follows generally accepted industry practices to protect the Personal Information you provide through our Sites, including a two-tiered approach which utilizes a database engine that incorporates multiple security protocols and provides access to the information through username and password identification only, which are encrypted.  Additionally, our Sites and databases are deployed on third-party hosting providers that are also protected by network and security monitoring systems that notify the Company of occurrences that might represent security issues.  However, because no method transmission over the internet is 100% secure, there is no guarantee that Personal Information may not be accessed, disclosed, altered or destroyed by a breach of these safeguards.

UNITED STATES ONLY

Our Sites are intended for use by residents of the United States only.  If you are located outside the U.S., please note that any information you provide to us will be transferred to the U.S. and that by submitting information to us you authorize this transfer and the processing of this information within the U.S.

YOUR CALIFORNIA PRIVACY RIGHTS

Pursuant to section 1798.83 of the California Civil Code, users of the Sites who are residents of California can obtain certain information about the disclosure of Personal Information to third parties for their direct marketing purposes during the preceding calendar year.  To make such a request, please contact us at privacy@victorymediainc.com or write to us at: VIQTORY, Inc., P.O. Box 26, Sewickley, PA 15143

YOUR CONTROL OVER YOUR INFORMATION

Except for disclosures required by law or which are needed to enforce our Terms of Use and/or protect our safety and the safety of our partners and other users, you may contact us in the manner described immediately below at any time and ask us to remove your Personal Information from some or all our mailing lists or e-mail lists.  Additionally, if you had previously subscribed to one of our SMS or WAP Services, you may withdraw your subscription to those services in the same manner.  Finally, all e-mails you receive from us contain an “unsubscribe” link that removes your Personal Information from the recipient list for future e-mails or modifies what you wish to receive in the future.

HOW TO CONTACT US

If you have any questions or concerns about this Privacy Policy, please contact us at privacy@viqtory.com or write to us at VIQTORY, 333 Rouser Road, Suite 503, Coraopolis, PA 15108. (412) 269-1663