VRBC Privacy Policy

Last modified: 6/11/2021

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Introduction

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The Virginia Rural Broadband Coalition ("VRBC") is a group of organizations that seek to expand rural broadband in the Commonwealth of Virginia. The focus of Virginia Rural Broadband Coalition’s work is to: (i) champion efforts to connect rural Virginians to the internet (business, government and residential customers); (ii) educate national, state and regional officials about success stories in Virginia that are being deployed to connect rural communities; (iii) identify funding pools for greater deployment of broadband in rural Virginia; (iv) engage business and civic leaders as champions for coalition initiatives; and (v) educate coalition members on broadband types that can be provided in rural Virginia. To that end, the VRBC has begun collecting data to determine where broadband is needed the most.

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Paladyn Group, LLC, a limited liability company ("Partner”) is assisting the Coalition with the collection of this data.  We respect your privacy and are committed to protecting it through our compliance with this policy.

What does the Virginia Rural Broadband Coalition do with the data I provide?

The data you submit on our website, or the website of any member that donates their time, equipment, and / or expertise in assisting the VRBC in collecting said data, is used as follows:
 

• To promote awareness of the lack of true broadband in rural and even suburban areas by presenting it in a generalized form such as a heat maps, statistics, or graphs and other data charts to various entities, including but not limited to the General Assembly of Virginia, as well as other various State and Federal Agencies that fund or affect rural broadband funding.
   

• To communicate with you about VRBC efforts to expand broadband across the Commonwealth (if you opt-in) possibly including communication in the event a VRBC member organization expands or begins to examine the expansion of broadband services in your area.

 

• To comply with any legal or regulatory obligations

 

How Do We Protect Personal Data?

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Personal data shall be subject to additional safeguards to ensure this data is processed securely. For example, we and our partners work hard to ensure data is encrypted when in transit and storage, and access to this data will be strictly limited to a minimum number of individuals and subject to confidentiality commitments.  

 

We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Policy. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to any of our websites; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access. When possible, encryption is used, both in transit and storage. Access controls within the organization limit who may access information.

The VRBC and any member assisting in the collection of data on behalf of the VRBC take your protection seriously. It will never be sold or given away and will be used for the express purposes listed in this privacy policy.

 

Is there an opt-out option?

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There is an option at the point you submit your address to us to opt out. If you change your mind later, you may also contact us to be removed from the list at any time or select “unsubscribe” from any future email you receive from us.

What is your policy?

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This policy describes the types of information we may collect from you or that you may provide when you visit the website varuralbroadband.org (our “Website”) and our practices for collecting, using, maintaining, protecting, and disclosing that information.

 

This policy also describes the types of information we may collect from you or that you may provide when you visit the website paladyngroup.com (the “Partner Website”) and our practices for collecting, using, maintaining, protecting, and disclosing that information.

 

This policy applies to information we collect:

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• On this Website and Partner Website(s).

• In email, text, and other electronic messages between you and this Website and Partner Website(s) [Through mobile and desktop applications you download from this Website and Partner Website(s), which provide dedicated non-browser-based interaction between you and this Website and Partner Website(s).]

• [When you interact with our advertising and applications on third-party websites and services, if those applications or advertising include links to this policy.]
   

It does not apply to information collected by:
 

• us offline or through any other means, including on any other website operated by Partner or any third party  or

• any third party other than Partner Website(s) that may link to or be accessible from the Website
   

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Website. By accessing or using this Website, you agree to this privacy policy. This policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of this Website 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

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Our Website is not intended for children under 16 years of age. No one under age 16 may provide any personal information to or on the Website. We do not knowingly collect personal information from children under 16. If you are under 16, do not use or provide any information on this Website or on or through any of its features/register on the Website, make any purchases through the Website, use any of the interactive or public comment features of this Website or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received personal information from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us at ConnectRuralVA@gmail.com .
 

Information We Collect About You and How We Collect It
 

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

• by which you may be personally identified, such as name, postal address, e-mail address, telephone number,  or ANY OTHER INFORMATION THE WEBSITE COLLECTS THAT IS DEFINED AS PERSONAL OR PERSONALLY IDENTIFIABLE INFORMATION UNDER AN APPLICABLE LAW or any other identifier by which you may be contacted online or offline ("personal information");

• that is about you but individually does not identify you, such as anonymous data submissions by you; and/or

• about your internet connection, the equipment you use to access our Website and usage details.
   

We collect this information:

• Directly from you when you provide it to us.

• Automatically as you navigate through the site. Information collected automatically may include usage details, IP addresses, and information collected through cookies,web beacons, and other tracking technologies.

• From third parties, for example, our business partners.
   

Information You Provide to Us
 

The information we collect on or through our Website may include:

• Information that you provide by filling in forms on our Website. This includes information provided at the time of [registering to use our Website,] [subscribing to our service,] [posting material,] [or requesting further services]. We may also ask you for information [when you enter a campaign or promotion sponsored by us, and] when you report a problem with our Website.

• Records and copies of your correspondence (including email addresses), if you contact us.

• Your responses to surveys that we might ask you to complete for research purposes.

 

Although we limit access to certain pages, please be aware that no security measures are perfect or impenetrable. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.

Information We Collect Through Automatic Data Collection Technologies 

As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:
 

•  Details of your visits to our Website, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Website.

• Information about your computer and internet connection, including your IP address, operating system, and browser type.
   

The information we collect automatically is statistical data and does not include personal information but it may be aggregated to:
 

• Estimate our audience size and usage patterns.

• Recognize you when you return to our Website.
   

The technologies we use for this automatic data collection may include:
 

• Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.

• Flash Cookies. Certain features of our Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Website. Flash cookies are not managed by the same browser settings as are used for browser cookies. For information about managing your privacy and security settings for Flash cookies, see Choices About How We Use and Disclose Your Information.

• Web Beacons. Pages of our the Website [and our e-mails] may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the VRBC or Partner, for example, to count users who have visited those pages or [opened an email] and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
   

We do not collect personal information automatically, but we may tie this information to personal information about you that we collect from other sources or you provide to us.
 

Third-Party Use of Cookies and Other Tracking Technologies
 

Some content or applications, including advertisements, on the Website are served by third-parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies [alone or in conjunction with web beacons or other tracking technologies] to collect information about you when you use our website. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.
 

We do not control these third parties' tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For information about how you can opt out of receiving targeted advertising from many providers, see Choices About How We Use and Disclose Your Information.
 

How We Use Your Information
 

We use information that we collect about you or that you provide to us, including any personal information:
 

• To determine, in the aggregate, locations in need of broadband services.

• To highlight the disparity of broadband services across the Commonwealth.

• To present our Website and its contents to you.

• To provide you with information, products, or services that you request from us.

• To fulfill any other purpose for which you provide it.

• To provide you with notices about efforts to expand broadband in Virginia, including providers who may be interested in serving your community.

• To notify you about changes to our Website.

• To allow you to participate in present and future interactive features on our Website.

• In any other way we may describe when you provide the information.

• For any other purpose with your consent.
   

We may also use your information to contact you about our own and third-parties goods and services that may be of interest to you, including but not limited to rural broadband availability. If you do not want us to use your information in this way, please check the relevant box located on the form on which we collect your data. 

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We may disclose aggregated information about our users, and information that does not identify any individual, without restriction. For example, we may disclose that twenty people in a particular neighborhood have expressed an interest in service.
 

We may disclose personal information that we collect or you provide as described in this privacy policy:
 

• To our partners or affiliates who express a viable interest in supplying broadband services to you.

• To contractors, service providers, and other third parties we use to support our goals and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.

• For any other purpose disclosed by us when you provide the information.

• With your consent.
   

We may also disclose your personal information:
 

• To comply with any court order, law, or legal process, including to respond to any government or regulatory request.

• To enforce or apply our terms of use

• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the VRBC, our partners, or others.

• Choices About How We Use and Disclose Your Information
   

We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:
 

• Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe's website. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly.

• [Disclosure of Your Information for Third-Party Advertising. If you do not want us to share your personal information with unaffiliated or non-agent third parties for promotional purposes, you can opt-out by checking or unchecking the relevant box located on the form on which we collect your data. You can also always opt-out by sending us an email stating your request to ConnectRuralVA@gmail.com .
   

Accessing and Correcting Your Information
 

You may send us an email at ConnectRuralVA@gmail.com to request access to, correct, or delete any personal information that you have provided to us. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.
 

If you request that we delete your User Contributions from the Website, copies of your User Contributions may remain viewable in cached and archived pages, or might have been copied or stored in backup systems.
 

Data Security
 

We utilize partners and vendors that implement measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. All information you provide to us is stored on our secure servers. Any payment and data submission transactions will be encrypted using SSL technology.

The transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website. 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 or Partner(s) Website.
 

Changes to Our Privacy Policy
 

It is our policy to post any changes we make to our privacy policy on this page [with a notice that the privacy policy has been updated on the Website home page]. If we make material changes to how we treat our users' personal information, we will notify you by email to the email address specified in your submission or through a notice on the Website home page. The date the privacy policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Website and this privacy policy to check for any changes.
 

Contact Information
 

To ask questions or comment about this privacy policy and our privacy practices, contact us at:

ConnectRuralVA@gmail.com