VCU Investment Management Company Privacy Policy
Last Updated: May 1, 2024
Your privacy is important to VCU Investment Management Company (“VCIMCO,” “we,” “us” or “our”). This privacy policy (“Privacy Policy”) describes the online collection of personal information by VCIMCO, and how we use that information. By using our website, https://www.vcimco.com/ (the “Site”) or connecting with us, you acknowledge you have read and understood the terms and conditions of this Privacy Policy. If you do not agree to the terms and conditions of this Privacy Policy, please do not use the Site.
For purposes of this Privacy Policy, unless otherwise required by applicable law, “personal information” means information that identifies, relates to, or is reasonably capable of being associated with an identified or identifiable individual or household. “Personal information” does not include information related to employees, job applicants, or information that is considered publicly available, aggregated, or deidentified under applicable law.
CATEGORIES AND SOURCES FROM WHICH WE COLLECT PERSONAL INFORMATION
Depending on the nature of your interactions with us, we and the third parties that perform services on our behalf may collect the following categories of personal information from you:
· Personal identifiers and personal details. VCIMCO collects personal identifiers (such as your name, email, phone number, and address) and relevant personal characteristics directly from you when you communicate with us or otherwise interact with us.
· Internet, Cookies, and Network Activity Information. We may collect your IP address when you visit our Site.
· Communications information. We may collect information concerning the content of discussions you may have with VCIMCO staff, including meeting transcripts. We collect this information when you participate in a meeting using supported videoconferencing software.
· Audio and visual information. We may monitor, record, and collect activity and communications made using VCIMCO communications and computing devices and systems (such as our phone devices, third party videoconferencing software, and email systems).
· Sensitive personal information. For example, we may collect your social security number for the purposes described in this Privacy Policy.
We collect these categories of personal information to carry out the purposes described in the “USE OF YOUR PERSONAL INFORMATION” section below.
USE OF YOUR PERSONAL INFORMATION
We may use your personal information to provide services and to support our business functions, to ensure compliance with local legal and regulatory requirements and for the purposes of our legitimate business interests, including the following:
· to operate and improve our Site, products and services;
· to provide you with more effective customer service;
· to process transactions and to maintain your accounts;
· to keep you informed about our products and services;
· to assess your creditworthiness and background history; and
· for legal and compliance purposes, including to comply with anti-money laundering laws.
Videoconferencing software: When you participate in a videoconference session with VCIMCO staff, you acknowledge that the content of our discussions, including any personal information, may be recorded, captured, and temporarily stored in transcripts that are created and stored by the software provider. You have the option to opt-out of the collection of this information by leaving the videoconference session or by following the instructions provided prior to or during the session. We retain these recordings and transcripts in accordance with this Privacy Policy. We encourage you to carefully review any disclosures provided before or during a videoconferencing session regarding recording and/or transcription and to review the privacy policies of the software providers to understand how your personal information is collected and used.
CATEGORIES OF PERSONAL INFORMATION DISCLOSED TO THIRD PARTIES
We disclose personal information to our service providers, affiliates, and partners to enable them to fulfill the purposes described in the “Use of Your Personal Information” section of the Privacy Policy above, and without limitation, for the following business purposes:
· Performing services on our behalf, including maintaining or servicing accounts, providing customer service, providing videoconferencing capabilities, providing recordings and transcriptions of meetings, processing or fulfilling orders and transactions, verifying your information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services on our behalf.
· As part of any actual or contemplated merger, sale, transfer of assets, acquisition, financing and/or restructuring of all or part of our business, bankruptcy or similar event, including related to due diligence conducted prior to such event where permitted by law.
· In response to a valid court order, subpoena, government investigation, or as otherwise required by law. We also reserve the right to report to law enforcement agencies any activities that we, in good faith, believe to be unlawful. In addition, we may share certain personal information when we believe that doing so is reasonably necessary to protect the rights, property, and safety of our company and/or others.
We will only use your personal information as reasonably necessary and proportionate to achieve these purposes. Where we provide your personal information to third-party service providers, they are contractually required to keep your personal information confidential and secure and must only use your personal information as instructed by us.
THIRD PARTY SERVICES, LINKS AND SOCIAL MEDIA PLUG-INS
Our Site contains links to other sites. In general, we are not responsible for the privacy practices or content of such other sites. Once you leave our Site or are redirected to a third-party website or application, you are no longer governed by this Privacy Policy unless the third-party website says that the collection of personal information is subject to our Privacy Policy.
SECURITY OF YOUR PERSONAL INFORMATION
VCIMCO is committed to protecting the security of your personal information. We take reasonable steps (including appropriate technical and organizational measures) in an effort to ensure your personal information is processed securely to protect the confidentiality, integrity and availability of your personal information in accordance with this Privacy Policy. The nature of the internet is such that we cannot guarantee or warrant the security of any information you transmit to us via the internet and any transmission is at your own risk.
California Shine the Light
Although we do not currently share your information for other companies’ direct marketing purposes, California residents have the right to request information from us regarding other companies to whom we have disclosed certain categories of personal information during the preceding year for the other companies’ direct marketing purposes. If you are a California resident and would like to make such a request, please email info@vcimco.com or write to us at the mailing address provided under the "Contact Information" section below.
Nevada Opt-Out of Sales
Although we do not sell personal information to third parties, Nevada residents have the right to opt-out of the sale of certain personal information to third parties who intend to license or sell that personal information. If you are a Nevada resident and would like to make such a request, please email info@vcimco.com or write to us at the mailing address provided under the "Contact Information" section below Please note that we do not currently sell your personal information as sales are defined in Nevada Revised Statutes Chapter 603A.
RETENTION OF YOUR PERSONAL INFORMATION
VCIMCO will store your personal information for as long as we have to by law, and where there is no legal requirement, we will only store your personal information for as long as necessary to fulfill the purpose for which the personal information was collected.
CHILDREN
Our Site is not intended for children and we do not knowingly collect personal information from children under 16. If you are a parent or legal guardian and think your child under 16 has given us personal information, you can email us at info@vcimco.com.
CHANGES TO THIS PRIVACY POLICY
We reserve the right to modify this Privacy Policy at any time, so please review it frequently. Changes and clarifications will take effect immediately upon their posting on the Site. If we make material changes to this policy, we will update the “Effective Date” below and notify you here that it has been updated, so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we use and/or disclose it.
CONTACT INFORMATION
For more information, contact us via email at info@vcimco.com, or by mail at 413 Stuart Circle, Suite 210, Richmond, Virginia 23220.