This privacy policy has been compiled to better serve those who are concerned with how their Personally Identifiable Information (PII) is being used online. PII, as defined by US privacy laws, and information security best practices is information that can be used on its own or with other information to identify, contact, locate a person, or to identify an individual in context. Please read this privacy policy carefully to get a clear understanding of how we will collect, use, protect, or otherwise handle your PII in accordance with our websites and related online services.
Please be advised that if you provide information via a third-party site or platform, the information you provide may be separately collected by that third-party site or platform and that information would be subject to the third-party site or platform privacy policy. Privacy choices made on that third-party site or platform will not apply to the use of information collected directly through this site. In the event this site contains any links to other sites, we are not responsible for the privacy practices of those sites. We encourage you to be aware when you leave this site and to read the privacy policies of other sites that may collect your PII.
Who are we and how to contact us? 
VPP LLC
30 Wall Street, 8th Floor
New York, NY 10005, USA
+1 212-840-5050

MARKUS WESAW® is a service mark registered with the United States Patent and Trademark Office (USPTO) and the company is an authorized licensee of this trademark.
What personal information do we collect from the people that visit our blog, website, or app? 
When using our websites, you may be asked: 

* Your legal name
* Email address
* Physical and/or mailing address
* Location information and IP address
* Phone number
* Credit card information
* Transaction information
* Usage, viewing, technical and device data
* HIPAA protected health information
* Work environment
* Social security number or other tax identification number
* Financial information
* Educational information including training, professional credentials, and/or licensures
* Employment details such as position, length of employment, work experience, and other employment information
* Other information as needed or required to provide a service to you or your organization

Generally, we do not request or require unnecessary personally identifiable information. That is, we will always have a reason and purpose for collecting and gathering your information.
What non-personal data do we collect from the people that visit our blog, website, or app? 
We may collect non-personal data from you for tracking, analytics, insights, and other business-related reasons including security. Non-personal data to be collected for these purposes includes, but is not limited, to the following:
* The device and/or computer you used to access our website
* The browser you used
* Your IP address and DNS records
* Your geographical location
* Demographical information
* Webpages visited with timestamp and duration
* Other similar information and analytics
Who we share your data with? 
We do not sell private personal information.
We will disclose personally identifying information only to employees and contractors that:
* Have a need to know and use that information
* Have agreed in writing not to disclose the information to others
Some of these employees and contractors may be located outside of your country and you hereby grant consent to the transfer of such information. When your information is transferred, your information becomes subject to that third party or contractor’s own privacy policy. 
We may be required to disclose personally identifying information in response to a lawful request by legal authorities having jurisdiction, this includes, but is not limited to, a lawful subpoena issued by a court of competent jurisdiction or other court order. 
When and how do we collect information? 
We collect personally identifiable and non-personal information from you when you visit our domains, websites, applications, blogs, or other electronic or online resources.
We also collect personally identifiable and non-personal information in order to provide professional services. PII may be collected through secure email, paper files, web portals, online forms, or electronic file formats. In addition, PII may be collected when a user registers for any course available through this site. 
How do we use your information?
We may use the information that we collect from you for the following reasons:
* To improve our website, online content, or to improve marketing of our services
* To process payment transactions
* To respond to your request for information
* To perform our services that have been contracted by you or your employer
How do we protect visitor information?
Protecting your data is of the utmost importance to us. Our servers are scanned on a regular basis for security vulnerabilities in order to make your visit to our site as safe as possible as well as to protect your PII. We ensure that our servers are maintained and serviced by professionals with the necessary training, background, and education.
We use malware, ransomware, and virus scanning software.
Your personal information is contained behind secured networks and is only accessible by a limited number of persons who have special access rights to such systems and are required to keep the information confidential. In addition, all sensitive/credit information you supply is encrypted via Secure Socket Layer (SSL) technology and in accordance with industry best practices.
We implement a variety of security measures when a user enters, submits, or accesses their information to maintain the safety of your personal information.
All payment transactions are processed through a payment gateway provider and are not stored or processed on our servers. You can make online payments with confidence. We have partnered with Authorize.Net, a leading payment gateway since 1996, to accept credit and debit cards safely and securely for our clients.
The Authorize.Net Payment Gateway manages the complex routing of sensitive customer information through payment card processing networks. See an online payments diagram to see how it works.
The company adheres to strict industry standards for payment processing, including:
* 128-bit Secure Sockets Layer (SSL) technology for secure Internet Protocol (IP) transactions;
* Industry leading encryption hardware and software methods and security protocols to protect customer information; and,
* Compliance with the Payment Card Industry Data Security Standard (PCI DSS).
For additional information regarding the privacy of your sensitive cardholder data, please read the Authorize.Net Privacy Policy
Do we use ‘cookies’?
Yes. Cookies are small files that a site or its service provider transfers to your computer’s hard drive through your Web browser (if you allow) that enables the site’s or service provider’s systems to recognize your browser and capture and remember certain information. For instance, we use cookies to help us remember and process the items in your shopping cart. They are also used to help us understand your preferences based on previous or current site activity, which enables us to provide you with improved services. We also use cookies to help us compile aggregate data about site traffic and site interaction so that we can offer better site experiences and tools in the future.
We may also use trusted third-party services that track this information on our behalf.
You can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies. You do this through your browser (i.e. Internet Explorer, Google Chrome, Safari, and Firefox) settings. Each browser is a little different, so look at your browser’s help menu to learn the correct way to modify your cookies. It is your responsibility to disable cookies if you choose. 
If you disable cookies off, some features will be disabled. It won’t affect the user’s experience that make your site experience more efficient and some of our services will not function properly. 
Do we retain your data? 
For users that are registered on a company owned website, we store personal information provided in the user profile. All users can see, edit, or delete their personal information at any time. Website administrators can also see and edit that information. 
What rights you have over your data?
For users that are registered on a company owned website, or have left comments, you can request to receive an exported file of the personal data we hold about you including any data you have provided to us. You can also request that we erase your personal data from our servers. This does not include any data we are obliged to keep for administrative, legal, or security purposes.
If you wish to receive an exported file of the data you have provided us, please use the form here. Please be advised that you, or any other person to whom you have authorized may have archived this data by saving it locally, taking screenshots, or otherwise transmitting it. 
California Online Privacy Protection Act
California Online Privacy Protection Act (CalOPPA) is the first state law in the nation to require commercial websites and online services to post a privacy policy. You can find CalOPPA here. The law’s reach stretches well beyond California to require a person or company in the United States (and conceivably the world) that operates websites collecting PII from California consumers to post a conspicuous privacy policy on its website stating exactly the information being collected and those individuals with whom it is being shared and to comply with this policy. 
Can I use this site anonymously?
Yes. Users can visit this site anonymously. 
Will I be notified of any changes to this privacy policy?
From time to time we may change this policy to accommodate new technologies, industry practices, regulatory requirements, or for other purposes. You will be provided notice of these changes if they are material and when notice is required by applicable law. If required, we will obtain your consent to these changes. Notice of any change to this policy may be given by email at the last email address provided by you, by posting notice of such changes on our site and/or by other means, consistent with applicable law. 
How do I update my personal information? 
Users can change their personal information by contacting us and making this request via email or telephone. 
Do you honor “Do Not Track” signals?
Yes. We honor “Do Not Track” signals and do not track, plant cookies, or use advertising when a Do Not Track (DNT) browser mechanism is in place. 
Do your websites allow third-party behavioral tracking?
Yes. We do track, monitor, and analyze website traffic for insights and analytical purposes. 
 Children Online Privacy Protection Act (COPPA)
When it comes to the collection of personal information from children under 13, the Children’s Online Privacy Protection Act (COPPA) puts parents in control. The Federal Trade Commission, the nation’s consumer protection agency, enforces the COPPA Rule, which spells out what operators of websites and online services must do to protect children’s privacy and safety online. You can find information about COPPA here.
We do not specifically market to children under 13. 
Fair Information Practices
The Fair Information Practices Principles form the backbone of privacy law in the United States and the concepts they include have played a significant role in the development of data protection laws around the globe. Understanding the Fair Information Practice Principles and how they should be implemented is critical to comply with the various privacy laws that protect personal information.
In order to be in line with Fair Information Practices we will take the following responsive action, should a data breach occur we will notify the users via email and/or telephone within 1 business day.
We also agree to the Individual Redress Principle, which requires that individuals have a right to pursue legally enforceable rights against data collectors and processors who fail to adhere to the law. This principle requires not only that individuals have enforceable rights against data users, but also that individuals have recourse to courts or government agencies to investigate and/or prosecute non-compliance by data processors. 
CAN-SPAM Act
The CAN-SPAM Act is a law that sets the rules for commercial email, establishes requirements for commercial messages, gives recipients the right to have emails stopped from being sent to them, and spells out tough penalties for violations.

We collect your email address in order to:
* Send information, respond to inquiries, and/or other requests or questions.
* Process task orders and to send information and updates pertaining to task orders.
* We may also send you additional information related to service.

To be in accordance with CAN-SPAM we agree to the following:
* To NOT use false or misleading subjects or email addresses
* Identify the message as an advertisement in some reasonable way
* Include the physical address of our business or site headquarters
* Monitor third-party email marketing services for compliance, if one is used
* Honor opt-out/unsubscribe requests quickly
* Allow users to unsubscribe by using the link at the bottom of each email

If at any time you would like to unsubscribe from receiving future emails, you can use the Contact page for your request and we will promptly remove you from all correspondence. 
Revision date
January 21st, 2020.

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