PRIVACY POLICY

 

  1.   Virtual Internships Partners Limited Privacy Policy

Virtual Internships Partners Limited (“VI”) is committed to ensuring the privacy of confidential information, accuracy of personal data, and compliance with international, federal, and state laws and regulations concerning the use of personal information.  Other than as required or permitted by law, Personal Data or Personally Identifiable Information (“PII”) is not shared.  In particular, and regardless of how the information was collected, VI does not sell PII and it does not re-distribute PII for any non-VI purpose.  The instances in which VI will share PII with third parties are described below.

  1.   People from whom VI Collects PII

The majority of PII comes from VI program participants, employees and suppliers, alumni, friends, and people who apply to be program participants or employees. 

  1.   What PII do we Collect from Participants and Applicants?

Prior to participating on one of our programs, we collect information from you when you complete our online form.

When submitting your application, you may be asked to enter your: name, e-mail address, nationality, place of residence, phone number, and degree/university, and to provide a copy of your resume/CV. You may, however, visit our website anonymously.

After you submit your application, you will be asked to take part in a video application process. We will collect your video responses and review them to determine your suitability for the VI program. If you are accepted on our program, your video application will be made available to host companies via a secure portal, which will only be accessible to host companies using a password protected link.

If you are accepted onto the program, we will ask for a copy of a government issued ID card in order to verify your identity and for you to disclose any medical conditions you have that might impair your ability to undertake a remote internship program (e.g. a learning disability or a hearing or visual impairment), so that we can best support you during your program.

We may also process financial information when you make a payment to VI, although as explained below, we do not retain this PII once the transaction has been completed.

We may obtain further PII about you during the course of your internship program. For example, if you are involved in an incident while on the program, we will collect information about the incident in order to handle it appropriately. This information may be obtained from you directly or from third parties, such as your host company. 

  1. Lawful Bases for Processing and Use of Collected Information

PII collected from program participants or program applicants is processed where necessary to perform our contract with an individuals, to take steps necessary for entering into a contract for an individual, or for VI’s legitimate interests.  The ways in which VI uses your PII in accordance with these legal bases include: (a) to register or enroll persons in VI programs, (b) assist our staff with host company placements, (c) to manage participant accounts, (d) to provide program advising, develop and deliver internship and other education programs, (e) to track participant progress, analyze and improve VI programs, recruitment, and retention, and (f) to deal with any health and safety issues that might arise, and (g) for regulatory reporting, legal compliance, auditing, and other related VI processes and functions. 

VI collects and processes PII from individuals who are employees or applicants for employment for our legitimate interest of administering various employment benefits and functions.  

The email address you provide may be used to send you information (including information about third-party promotions that we believe would be of interest to you), respond to inquiries, and/or other requests or questions.  In each such communication, you will be given an option to unsubscribe from our mailing list.

VI also uses PII for its legitimate interest to conduct general demographic and statistical research to improve VI programs, to identify appropriate support services or activities, and enforce VI policies. 

As set out below, PII may be shared by VI with third parties who have entered into contracts to perform functions on behalf of VI, but only when the third parties agree to protect PII and prevent unauthorized disclosure.

Special Category PII Data

VI only processes special category PII on the basis of explicit consent. The only special category PII that we collect is information on any medical conditions, which might impair your ability to undertake an onine internship, such as a learning disability or visual or hearing impairment.  We will only ask you to disclose medical conditions that might affect your internship and will only use this information for the purpose of finding you a suitable placement that can accommodate your condition and for assisting you during your internship if any issues arise. 

  1. Use of Cookies

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 sites or service provider’s systems to recognize your browser and capture and remember certain information.

We use cookies to compile aggregate data about site traffic and site interaction so that we can offer better site experiences and tools in the future.

The table below explains the cookies we use and why:

Cookie

Name

Purpose

More Details

Google Analytics

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These cookies are used to collect information about how visitors use our site.  We use the information to compile reports and to help us improve the site. The cookies collect information in an anonymous form, including the number of visitors to the site, where visitors have come to the site from and the pages they visited.

Click here for an overview of privacy at Google

 

  1.   Third Party Use of Personal Information

VI may disclose PII and other information as follows:

    • Consent: We may disclose information if we have an individual’s consent to do so.
    • Employment:  We may share information when necessary for administering employment or social security benefits in accordance with applicable law, subject to the imposition of appropriate safeguards to prevent unauthorized disclosure.
    • Public Information: We may share information if the information already has been made public.
    • Archiving: We may share information for archival purposes in the public interest, and for historical research and statistical purposes.
    • Performance of a Contract: We may share information when necessary to comply with a contractual obligation. This includes sharing your PII with host companies in order to place you in an appropriate internship..
    • Legal Obligation: We may share information when the disclosure is required or permitted by international, federal, or state laws and regulations. VI will comply with lawfully issued subpoenas.
    • Service Providers:  We use third parties who have entered into a contract with VI to support the administration of VI operations. In particular we may disclose PII to VI’s affiliate company CRCC Asia, which may support VI in the delivery of your program.  In such cases, we share information with such third parties subject to the imposition of appropriate safeguards to prevent unauthorized disclosure.
    • University Partners: If an individual is a student at one of VI’s partner universities, VI may need to share information with the university in order to comply with our contract with them.  In such cases, we share information with such partners subject to the imposition of appropriate safeguards to prevent unauthorized disclosure.
    • De-Identified and Aggregate Information: We may use and disclose information in de-identified or aggregate form without limitation.

  • Data Processors: VI uses data processors, including Zoho which hosts VI’s CRM, Interviewstream which hosts VI’s video application system, and Talent LMS, which hosts VI’s CareerBridge platform. VI has vetted these processors to ensure that they have appropriate technical measures in place to keep personal data secure.

 

  1. Children’s Online Privacy Protection Act Compliance

VI complies with the requirements of the COPPA (Children’s Online Privacy Protection Act).  We do not collect any information from anyone under 13 years of age.  Our website, products and services are all directed to people who are at least 13 years old or older.

  1.   Notification of Changes

The VI Privacy Policy is reviewed periodically and may be modified at the discretion of VI.  Changes to the privacy policy will be incorporated and posted on VI’s web site.  Information will be handled according to the privacy policy in effect at the time the information is used. The privacy policy was last updated on 16 April 2020.

  1. Security

VI will implement appropriate technical and organizational security measures to protect PII collected by VI, regardless of the method of collection.

We implement a variety of security measures to maintain the safety of your personal information when you enter, submit, or access your personal information.

We offer the use of a secure server.  All supplied sensitive/credit information is transmitted via Secure Socket Layer (SSL) technology and then encrypted into our payment gateway provider’s database only to be accessible by those authorized with special access rights to such systems, and a requirement to keep the information confidential.

After a financial transaction, your private information (credit cards, social security numbers, financials, etc.) will not be stored on our servers.

  1. Contacting Us

    If you have any questions or comments about this Privacy Policy, would like to exercise your rights or would like us to update information we have about you or your preferences, you may contact us at: hello@virtualinternships.com

EUROPEAN UNION PRIVACY NOTICE

  1. GDPR

The purpose of the General Data Protection Regulation (“GDPR”) is to protect all European Union (“EU”) citizens from privacy and data breaches by allowing citizens to maintain control of the personal information retained and processed by organizations, which includes VI.  The GDPR also protects the personal information of individuals, regardless of citizenry, conducting business in the EU.

VI is committed to safeguarding the privacy of personal information.  The privacy policy above outlines the collection, use, and disclosure of personal information provided to VI by VI program participants and applicants, staff, alumni, other members of the VI community, and third parties.  When information is submitted to VI, or you use VI’s websites and services, you consent to the collection, use, and disclosure of that information as described in this policy.

VI will not share personal information with any third party for the purpose of direct marketing without your consent.

  1. Access to Your Own Information

You have the right to request access to, a copy of, modification, restriction in the use of, or erasure of your information in accordance with all applicable laws.  The erasure of your information shall be subject to applicable retention periods of international, federal, and state laws.  If you have provided consent to the use of your information, you have the right to withdraw consent without affecting the lawfulness of VI’s use of the information prior to receipt of your request.

  1. 3. Transfers outside the European Economic Area (EEA)

    As noted in the privacy policy above, VI’s affiliate CRCC Asia may assist VI in the delivery of certain aspects of your program. CRCC Asia has companies and operations located outside the EEA and so PII created or collected in the EEA may be transferred to affiliate entities located outside the EEA in order to provide our services to you.  All CRCC Asia entities located outside the EEA have signed specific approved contracts with VI that give your personal data the same protection it has in the EEA  VI also has some contractors located outside the EEA. These contractors have all entered into agreements, confirming that they will comply with the data protection laws of the UK.

We may also make occasional transfers of your personal data to service providers, host companies, or staffing agencies located outside the EEA where necessary in order to perform our contract with you.  If you believe VI has not complied with applicable foreign laws regulating such information, you have the right to file a complaint with the appropriate supervisory authority in the European Union.

  1. Retention and Destruction of Your Information

Your information will be retained by VI in accordance with applicable retention periods of international, federal and state laws.  Your information will be destroyed upon your request unless applicable law requires destruction after the expiration of an applicable retention period, or VI operations necessitate its retention.  The manner of destruction shall be appropriate to preserve and ensure the confidentiality of your information given the level of sensitivity, value and criticality to VI.