Privacy Policy


VW Privacy Policy And Code of Conduct

Commitment to Privacy

It is the policy of VW to combine the highest-quality products and services with the highest level of integrity in dealing with our clients and partners. Our Privacy Policy is designed to assist you in understanding how we collect, use and safeguard the personal information you provide to us and to assist you in making informed decisions when using our site and our products and services. We continually reassess our business practices, technologies and customer needs in order to meet our privacy commitment.

What Information Do We Collect?

Two types of information are generally collected on our Web Site. Customer information, which you knowingly provide, and Web site use information collected on an aggregate basis as you and others browse our Web site.

Personal Information

If you choose to purchase products or services from us or our partners, you may need to give personal (Company) information, debtor information and/or authorization to obtain additional information. All information received is only disclosed as necessary and/or required to complete the business transaction by our partners or us. We provide a secure environment and the same protections for these electronic communications that we employ in the maintenance of information received by mail and telephone.

Web Site Use Information

Similar to other commercial Web sites our Web server logs information about how our Web site is used. Information gathered through our Web server logs may include the date and time of visits, the pages viewed, time spent at our Web site, and the Web site visited just before and just after our Web site. This information is collected on an aggregate basis. None of this information is associated with you as an individual.

How we handle the information we gather when you visit our web site

We collect and store only the following information about you: The name of the domain from which you access the Internet (for example, XYZ.com, if you are connecting from your company’s XYZ Corporation network.); the date and time you access our site; the item you requested from the server; and the Internet address of the web site from which you linked directly to our site. If your browser accepts cookies we may use a cookie to determine if you are a repeat or new visitor, or to understand how many different visitors come to our sites. When we examine this data, it is always presented in an aggregate form.

If you identify yourself by sending an E-mail:

When you send us personally identifying information, (e.g., in an electronic mail message containing a question or comment), or by filling out a form that E-mails us this information, we use this information to respond to your request. We may also forward your E-mail to other employees within our organization who are better able to answer your questions.

We want to make it clear that we will not obtain personally identifying information about you when you visit our site, unless you choose to provide such information to us. Except for authorized law enforcement investigations, or as otherwise required by law, we do not share any information we receive with any outside parties.

Links to other sites:

The documents posted on our Website may contain hypertext links or pointers to information created and maintained by other public and private organizations. These links and pointers are provided for visitors’ convenience. VW does not control or guarantee the accuracy, timeliness, or completeness of any linked information from non-VW sites.

The inclusion of links or pointers to Web sites is not intended to assign importance to those sites or the information contained therein, nor is it intended to endorse or recommend any views expressed, or products or services offered on these sites.

What is a Cookie?

A cookie is a small piece of information that is sent to your browser– along with a Web page– when you access a Web site. There are two kinds of cookies. A session cookie is a line of text that is stored temporarily in your computer’s RAM. Because a session cookie is never written to a drive, it is destroyed as soon as you close your browser. A persistent cookie is a more permanent line of text that gets saved by your browser to a file on your hard drive. Depending on your browser settings, you may receive notification that a given site is requesting cookie information, possibly with an expiration date. Persistent cookies have an expiration date in the future. Session cookies have no date associated with them.

VW’s Use of Cookies

Our site creates a session cookie whenever you access www.VWinc.com. The session cookie is destroyed as soon as you close your browser. VW does not create any persistent cookies.

Security:

For site security purposes and to ensure that this service remains available to all users, VW’s web servers employ industry-standard methods to monitor network traffic to identify unauthorized attempts to upload or change information, or otherwise cause damage. Unauthorized attempts to upload information or change information on VW’s servers are strictly prohibited and may be punishable by law, including the Computer Fraud and Abuse Act of 1986 and the National Information Infrastructure Protection Act.

In the specific context of this security monitoring, there is no expectation of privacy. However, only in the case of actual law enforcement investigations, will we attempt to identify individual users.

How Do We Secure Information Transmissions?

Any confidential information sent to us on our Web site is transmitted using Secure Socket Layer (SSL) 128-bit encryption protocol. We utilize encryption/security software to safeguard the confidentiality of personal information we collect from unauthorized access or disclosure and accidental loss, alteration or destruction.

Data Loss Protection:

VW uses the best commercially available products to back up our databases and stores these backups both locally and offsite. We also perform a backup of the SQL data multiple times throughout the day to protect against data loss due to catastrophic system failure. Your data will be as secure on our system as it is on your own, with redundant backups.

Data Privacy / Use of Information:

It is a prime responsibility of VW and each of its employees to responsibly manage customer data. We work with banks, financial institutions and municipal governments, all of who regard their data as highly confidential. In addition to strict company policies regarding the protection of client data, VW has extensive experience with non-disclosure and other partnering agreements that protect our customer organizations.

Data Privacy Protection:

VW has implemented commercially accepted and prudent network security measures that are designed to prevent unauthorized access to our systems. These security measures are a combination of the platforms, commercial applications and network operating systems in use, customized hardware in use, an intricate LAN/WAN configuration and our own system code.

System Uptime:

VW’s goal is 100% uptime, with the exception of scheduled maintenance. Toward this end, we have selected premium business partners and built redundancies into our network operations to address the most common causes for unscheduled downtime.

How Do We Use the Information That You Provide to Us?

In general, we use personal/Company information for purposes of administering our business activities, providing customer service and making available other products and services to our customers and prospective customers.

VW will only send personal information about you to others when: • we have your consent to share the information; or • we need to share your information to provide the product or service you have requested; or • we are authorized to do so by law (e.g., to respond to subpoenas, court orders, legal process, or to requests pursuant to a statute requiring or permitting disclosure. We do not use these technologies to capture your individual email address or any personally identifying information about you although they do permit us to send focused responses to you.

Sharing Information with Affiliates/Partners

We only share information with Affiliates or Strategic partners as required to perform the services we have been engaged to provide. We have Confidentiality Agreements with all our Affiliates and Partners, which restrict the use of confidential information. We take measures to select product or service providers that are responsible and afford privacy protections to their customers. However, we cannot make any representations about the practices and policies of these companies.

Notice of New Services and Changes

Occasionally, we may also use the information we collect to notify you about important changes to our Web site, new services and special offers we think you will find valuable.

How Do We Secure Active Identifiable Information?

We secure your personal information submitted by you by using reasonable efforts to prevent unauthorized access or disclosure, or accidental loss or destruction of identifying Information. Communications you may have with VW via email may not be secure unless VW advises you that security measures are in place prior to your sending information. Therefore, if you choose to communicate with VW through this means, you are assuming the risk of doing so and VW requests that you do not send or post sensitive information through these means unless authorized to do so.

Evaluation of Information Protection Practices.

We periodically review our operations and business practices for compliance with corporate policies and procedures governing the security, confidentiality and quality of our information.

Employee Access, Training and Expectations.

Our corporate values, ethical standards, policies and practices are committed to the protection of customer information. In general, our business practices limit employee access to confidential information, and limit the use and disclosure of such information to authorized persons, processes and transactions.

How Can You Access and Correct Your Information?

You may request access to all your identifiable information that we collect online and maintain in our database by emailing Privacy@vwinc.com

Do We Disclose Information to Outside Parties?

We may provide aggregate information about our customers, sales, Web site traffic patterns and related Web site information to our affiliates or reputable third parties, but this information will not include personally identifying data, except as otherwise provided in this Privacy Policy.

What is Spam?

In simple terms Spam (a.k.a. unsolicited commercial e-mail, unsolicited bulk e-mail, mass e-mail, junk e-mail) is a message that advertises goods or services that you send to someone without their prior consent or in the absence of a previous relationship. Spam is defined as including, but not limited to, the following: • Email messages that are addressed to a recipient with whom the sender does not have an existing business or personal relationship with or is not sent at the request of, or with the express consent of, the recipient. • Messages posted on Usenet and message boards, which are unrelated to the topic of discussion, unrelated newsgroups or sent/posted excessively. • Solicitations posted on chat rooms, or to groups or individuals by Instant Messaging system, such as ICQ.

Anti-Spam Policy

VW appreciates your privacy and minimizes the sending of unsolicited mass e-mails of any kind. We respond to your request for information and only send emails, which outline a service or provide information for which we believe you shown an interest. We will not sell, trade or give your email or other contact details (except that which is required under our partnership agreements) to anyone without your permission.

Opting-Out

VW users may opt-out of receiving regular e-mails by one of the following methods: Click the “Unsubscribe” link we include in our marketing emails and request that we do not send you this type of material in the future or contact our Customer Service at Privacy@vwinc.com.

Client Dispute Resolution Process

Upon notification of any Client concern or issue in relation to a particular file(s), the Customer Service Agent receiving the notification will immediately relay the issue to the appropriate Departmental Manager for resolution. Dependent upon the severity of the notification, the Agent may escalate the issue to the National Client Relations Manager, Regional Manager and Sales Executive responsible for the account. The Client will then be given a response within 24 hours of corrective action taken, where necessary.

Debtor Dispute/Resolution Process

Upon notification of any Debtor concern or issue in relation to a particular file(s), the Agent receiving the notification will immediately relay the issue to the appropriate Departmental Manager and Compliance Officer. If the dispute concerns the validity of the debt, the process will follow the Customer Service Process for relaying the information to the Client in order to determine the validity of the dispute.

Customer Service Complaints

Any client complaints or comments must be documented and tracked. It is the responsibility of the Customer Service Representative that receives the complaint to email the Sales Executive and copy the CSO immediately.

The Sales Representative will contact the client within 24 hours to ensure that the clients concerns are addressed. The Sales Representative will be responsible to follow up with the various departments effected.

The CSO will track and monitor to spot trends and evaluate the Sales Representative and Customer Service Departments effectiveness in resolving the issues brought to their attention. The CSO will also work with the various department managers and the COO to work on solutions to enhance the service provided in the future.

Children and Privacy

The Federal Trade Commission has issued rules to implement the Children’s Online Privacy Protection Act of 1998 (COPPA). We are in compliance with that Act and we do not collect or disclose to any Partner or Affiliate any personal information from children under 13 without first obtaining parental consent.

Security/Financial/Information

Financial information that is collected is used solely to charge the user for products and services or collect information from a debtor for purposes of paying on a client account. Credit Card and Bank Account information is collected only over secure SSL Encrypted Internet connections. Credit card data is not stored after completing the transaction.

Changes to this Privacy Policy

VW may amend this policy from time to time. If we make any substantial changes in the way we use your personal information we will make that information available by posting a notice on this site.