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V DEVELOPMENT GROUP LLC'S PRIVACY POLICY
V Development Group LLC's General Privacy Policy
Version: 1.0 | Date: 18 November 2021
Thank you for visiting VDevelopmentGroupLLC.com. V Development Group LLC's General Privacy Policy sets out how V Development Group LLC, together with its subsidiaries and affiliates (collectively, “Vdevgroupllc”, “we” or “us”), process the personal information of our website visitors, clients, sub-consultants and other third parties. It is not the exclusive description of how V Development Group LLC processes personal information of individuals.
If you are an employee, information on how V Development Group LLC handles your personal data has been notified to you and is set out in V Development Group LLC's Corporate Integrity Handbook and your local Employee Handbook available on V Development Group LLC's intranet. If you are a prospective employee or job applicant, information on how V Development Group LLC handles your personal data is set out in V Development Group LLC's Recruitment Privacy Statement. If you are a third-party vendor or sub-consultant, information on V Development Group LLC's rights and your obligations regarding personal data provided to you by us is set out in V Development Group LLC's Third-Party Data Protection Addendum. Collectively, these policies form V Development Group LLC's Global Privacy Policy. For questions about HOK’s Global Privacy Policy, please contact us by email at privacy@vdevgroupllc.com or by mail at 4052 S. Montgomery Ave, Chicago, IL 60643Attention: Corporate Compliance Officer.
V Development Group LLC DOES NOT SELL PERSONAL INFORMATION TO OTHERS.
1.0 HOW INFORMATION IS COLLECTED
V Development Group LLC typically collects personal information directly from the individual to whom it relates, except where that individual has consented to HOK collecting the personal information from a third-party or the law otherwise permits V Development Group LLC to do so.
V Development Group LLC will collect and store your personal information when you interact with vdevgroupllc.com. We collect information, some of which may contain personal information, by online applications as follows: (i) limited information is automatically collected about you when you visit vdevgroupllc.com through the use of Google Analytics or Log Data (as discussed below); or (ii) you may voluntarily provide information, including personal information, to us by: (a) emailing V Development Group LLC about our services, employment or internship opportunities, marketing, media requests, and other business matters; (b) by registering online to attend an V Development Group LLC-sponsored event; or (c) downloading one of our online publications.
Google Analytics is a free third-party service that uses “cookies” to measure, collect, analyze and report web data for purposes of optimizing the experience of users of vdevgroupllc.com. Cookies are files with small amounts of data, that are sent to your browser from a website and stored on your computer's hard drive. You can opt-out and prevent your data from being used by Google Analytics with the Google Analytics Opt-Out Browser Add-on.
Log Data is information your browser sends us whenever you visit vdevgroupllc.com. Log Data may include information such as your computer's browser type, the browser version, the pages of our site that you visit, the time and date of your visit, the time spent on those pages, and other statistics.
V Development Group LLC does not make any attempt to use Google Analytics or Log Data to find out the identities of those visiting vdevgroupllc.com. It is your responsibility to adjust your browser settings to accommodate your personal privacy preferences and, by your use of hok.com without configuring your browser to opt-out from Google Analytics or Log Data, you have consented to V Development Group LLC's collection of information as discussed above.
Risk Intelligence Data is data obtained by V Development Group LLC to assess risk that may arise from a new business relationship. When considering a new business relationship, we may request additional information about a person or entity seeking to do business with V Development Group LLC such as: (i) details on the business entity (including date and place of incorporation, tax identification number, legal status, authorized representative, and other similar information); (ii) details on beneficial ownership interests (including identify of ultimate parent company and details on the identity of individual shareholders in the ultimate parent with significant ownership interests); and (iii) details on the relationship of the person or entity seeking to do business with V Development Group LLC to any official, officer, legislator, director, employee, or agent of any government of any tier or any state-owned entity. V Development Group LLC' will process this information through World-Check by Thomson Reuters® to obtain risk intelligence data associated with new business relationships. Risk intelligence data may include sensitive personal information on companies and individuals such as political activities, criminal allegations or convictions, regulatory inquiries or penalties, precise geolocation information, financial and banking information, reputational information, government issued identification numbers, relationships to sanctioned or otherwise politically exposed persons and organizations, and other similar information. V Development Group LLC's uses risk intelligence data to analyze potential risks associated with new business associates. We will take reasonable steps to ensure all risk intelligence data that we store is current, accurate, complete, and confidential.
User-Supplied Personal Information. V Development Group LLC may request your name, email address, affiliated company and other contact information upon your request to contact individuals within V Development Group LLC or to download information from vdevgroupllc.com. This information will be stored by V Development Group LLC and may be used by us to respond to your inquiry or to inform you of V Development Group LLC's services or sponsored events. Users providing V Development Group LLC with this information consent to use of their personal information for marketing purposes.
2.0 TYPES OF PERSONAL INFORMATION COLLECTED
Personal information means any information relating to a person or their household that enables that person to be identified either directly or indirectly. Personal information that we hold about you may include your contact details (e.g. name, phone number, address and email address), IP address, language, gender and geolocation.
If you are a client, vendor or subconsultant, personal information that we hold about you may include the same information listed above, along with your date of birth, social media/network accounts, business address, email address, phone number and fax number, function/job title, company, types of services provided, and financial compensation. V Development Group LLC may request that you provide additional information such as your company’s legal status, date of incorporation, place of incorporation, your company’s related entities, your company’s shareholding details, your relationship to any government official, your company’s tax identification numbers, country of origin, business and professional licenses, your company’s insurer, broker and insurance policies, and other information you consent to provide us for purposes of performing contracts or services.
We will take reasonable steps to ensure the personal information that we store is current, accurate, complete, and confidential.
3.0 HOW PERSONAL INFORMATION IS USED
We will use your personal information, and may share your personal information with other parties acting on our behalf, for one or more of the following: (i) to conduct research about the use of our website; (ii) to improve services provided by V Development Group LLC; (iii) to assess and respond to a complaint you might make to us; (iv) for our own administrative purposes, including training our staff, conducting internal audits, improving our services or transferring assets as part of a sale, purchase or investment in the business; (v) if you are a client, vendor or subconsultant, to perform services or carry out our contract with you; (vi) for market research purposes; (vii) to make informed decisions about business relationships and to prevent inadvertent engagement in illegal or corrupt practices; (ix) to conduct investigations of suspicious or harmful activity; (x) to comply with V Development Group LLC's regulatory and legal obligations; (xi) to manage risks related to V Development Group LLC's contracts and services; and (xii) for marketing V Development Group LLC's services or sponsored events. If we wish to use your personal information for a purpose beyond that for which it was originally provided, we will ask for your consent or seek to rely on another valid legal ground to process your personal information in accordance with the applicable law.
4.0 INFORMATION FOR MARKETING PURPOSES
Where you have consented to us using your personal information for marketing purposes, we may use your information to conduct marketing and data analysis or to send you updates and news concerning V Development Group LLC and its business partners. If at any time after you have consented to us using your information for marketing purposes and you wish us to stop using your information for these purposes, please contact us by email at privacy@vdevgroupllc.com or by mail at V Development Group LLC's 4052 S. Montgomery Ave, Chicago IL, 60643 Attention: Corporate Compliance Officer.
5.0 GROUNDS FOR PROCESSING
To process your data lawfully we will rely on one or more valid legal grounds. The grounds we may rely upon include:
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Your consent to a particular processing activity. For example, where you have consented to us using your information for marketing purposes;
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Our legitimate interests as a business (except where your interests or fundamental rights override these). For example, it is within our legitimate interests to use your information to prevent or detect fraud or abuses of our website;
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Our compliance with a legal obligation to which V Development Group LLC is subject. For example, we have a duty to investigate and respond to complaints made against us and may need to process your personal information as part of such investigation; or
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If you are a client, vendor or subconsultant, because processing your personal information is necessary for the performance of a contract or services.
6.0 DISCLOSURE OF YOUR PERSONAL INFORMATION
There are circumstances where we may wish to disclose or are compelled to disclose your personal information to third-parties. This will only take place in accordance with the applicable law, for the purposes listed above, and pursuant to terms consistent with V Development Group LLC's Third-Party Data Privacy Addendum. These scenarios include disclosure to: (i) V Development Group LLC's subsidiaries, branches or associated offices; (ii) outsourced vendors or subconsultants to facilitate the provision of our services (including other professional service providers); (iii) third-party service providers and consultants in order to protect the security or integrity of our business, including our databases and systems and for business continuity reasons (including cloud service providers); (iv) another legal entity, on a temporary or permanent basis, for the purposes of a joint venture, collaboration, financing, sale, merger, reorganization, change of legal form, dissolution or similar event; (v) attorneys in connection with negotiation of a contract, dispute resolution, and other legal advice; (vi) tax advisors for purposes of tax filings, obtaining tax credits, negotiating tax liabilities, and other tax advice; (vii) public authorities where we are required by law to do so; and (viii) any other third-party where you have provided your consent. Further, we may disclose your information to any person as required by law and specifically to any government agency if we believe in good faith that we must do so to comply with the law or that doing so is required to prevent, detect, investigate or remedy improper conduct potentially affecting V Development Group LLC.
7.0 INTERNATIONAL TRANSFER OF PERSONAL INFORMATION
V Development Group LLC has certified to the U.S. Department of Commerce that it adheres to the Privacy Shield Principles regarding the collection, use and retention of personal information transferred from the EU to the United States. V Development Group LLC commits to cooperate with EU data protection authorities and comply with advice given by such authorities with regard to personal information (including human resources data) transferred from the EU in the context of the employment relationship. If there is conflict between the terms of V Development Group LLC's Global Privacy Policy and the Privacy Shield Principles, the latter shall govern. V Development Group LLC's Privacy Shield certification is subject to enforcement by the U.S. Federal Trade Commission. To learn more about the Privacy Shield program, please visit privacyshield.gov.
Participating organizations are deemed to have “adequate” privacy protection for the transfer of personal information outside of the EU under the General Data Protection Regulation (“GDPR”). For Privacy Shield purposes, V Development Group LLC refers to V dev Group LLC and “Other Covered Entities” refers to each of the following:
V Development Group International, Ltd.
V Development Group Architects, Inc.
V Development Group International Holdings, Inc.
V Development Group, Inc.
V Development Group Overseas, LLC
V Development Group Blue Box Ventures, LLC
As a result, EU member state requirements for prior approval of international data transfers to V Development Group LLC and its Other Covered Entities are waived. In cases of onward transfers of data, received pursuant to the EU-U.S. Privacy Shield, V Development Group LLC is potentially liable under the GDPR.
Questions and complaints regarding V Development Group LLC's Global Privacy Policy or its Privacy Shield compliance should be directed to us by e-mail at privacy@vdevgroupllc.com or by mail at V Development Group LLC 4052 S. Montgomery Ave., Chicago, IL 60643 Attention: Corporate Compliance Officer. If V Development Group LLC does not timely acknowledge a complaint, or if we have not satisfactorily addressed a complaint, EU residents may: (i) submit their complaint to their local data protection authority for referral to the U.S. Department of Commerce; or (ii) seek a non-monetary remedy through binding arbitration administered by the International Centre for Dispute Resolution® - American Arbitration Association® (“ICDR-AAA”) in accordance with the Privacy Shield Principles. The services of ICDR-AAA are provided at no cost to EU residents. To learn more about the independent recourse mechanism provided by the ICDR-AAA, please visit go.adr.org/privacyshield.html.
8.0 RETENTION OF PERSONAL INFORMATION
Your personal information will be retained for as long as it is necessary to carry out the purposes set out in V Development Group LLC's Global Privacy Policy (unless longer retention is required by the applicable law). However, we will not retain any of your personal information beyond this period and the retention of your personal information will be subject to periodic review. We may keep an anonymized form of your personal information, which will no longer refer to you, for statistical purposes without time limits, to the extent that we have a legitimate and lawful interest in doing so.
9.0 CONFIDENTIALITY AND SECURITY
V Development Group LLC is committed to: (i) seeking to safeguard all personal information that you provide to us; (ii) seeking to ensure that it remains confidential and secure; and (iii) taking all reasonable steps to ensure that personal privacy is respected. We maintain physical, electronic and procedural safeguards to protect your personal information from misuse, unauthorized access or disclosure and loss or corruption by computer viruses and other sources of harm. We restrict access to personal information to those staff members, subsidiary companies and third parties who need to know that information for the purposes set out in V Development Group LLC's Global Privacy Policy.
10.0 DATA RIGHTS
Your rights regarding data collected and used by V Development Group LLC are subject to applicable law. V Development Group LLC will comply with a verified request to exercise your rights or provide you with a lawful basis for not doing so when applicable.
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10.2 CALIFORNIA RESIDENTS
The California Consumer Privacy Act of 2018 (“CCPA”) provides California residents (referred to as “Consumers”) with certain rights discussed below. Consumers may contact V Development Group LLC regarding any of these rights by email at privacy@vdevgroupllc.com; by mail at V Development Group LLC 4052 S. Montgomery Ave., Chicago, Illinois 60643 Attention: Corporate Compliance Officer. An online portal for Consumers to submit a request to exercise a right is under development. V Development Group LLC will respond within a reasonable time following receipt of a verified Consumer request, in any event, within the time period specified by law.
Consumers exercising their rights will be required to complete a questionnaire and submit a proof of identity and residency in California. Verification of identity will require, at a minimum, two (2) forms of government issued identification (such as a passport and driver’s license) and (1) form of proof of residency (such as a utility bill) showing residency in California at the time the request is made. V Development Group LLC may request additional information it deems necessary or desirable to verify the identity of a person making a request under the CCPA for specific personal information. All information requested during the verification process shall be used solely for verification of identity and residency.
Consumers have the right to designate an agent to act on their behalf. Consumers wishing to do this and agents acting on behalf of Consumers should contact V Development Group LLC as provided above.
V Development Group LLC does not sell personal information as defined under the CCPA.
Consumers have the right to:
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Request to Know. You have the right to obtain a copy of the personal information and the categories of personal information we hold about you by contacting us as directed above.
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Request to Delete. You have the right to request that we delete your personal information by contacting us as directed above.
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You have the right to receive V Development Group LLC's products and services on equal terms regardless of whether you exercise your rights under the CCPA.
11.0 LINKS
Our website may provide hyperlinks to websites owned and controlled by others. V Development Group LLC is not responsible for the privacy practices of any website that it does not own or otherwise control.
12.0 THIRD PARTIES
Where you submit information on behalf of another person, you confirm that you have made that person aware of how we may collect, use and disclose their information, the reason you have provided it, how they can contact us, the terms of this policy and that they have consented to such collection, use and disclosure.
13.0 COMPLIANCE WITH PRIVACY LAWS
V Development Group LLC complies with the data protection and privacy laws to which it is subject. You should satisfy yourself that you are familiar with those laws, including any exceptions which may apply under them. You should also be aware that privacy laws in various jurisdictions may change from time to time. Notwithstanding contrary terms in V Development Group LLC's Global Privacy Policy, V Development Group LLC's accepts no obligations with respect to the handling of personal information other than those mandated by law in the country which has, or counties which have jurisdiction over V Development Group LLC's in any given circumstances.
14.0 CHANGES TO THIS POLICY
As we strive to improve our practices, we may review V Development Group LLC's General Privacy Policy from time to time. We reserve the right to change this policy at any time and to notify you of those changes by posting an updated version of this policy on our website. It is your responsibility to check our policy each time before you access our website for any changes.