INTRODUCTION
Last Updated March 11, 2024

VLS Environmental Solutions and its subsidiaries and affiliates (collectively, “VLS”) appreciate your interest in the VLS website located at https://www.vlses.com/ and https://myvlsstore.com/ and other related or linked VLS sites (collectively, “Site”). Your privacy is important to us, and we want you to understand our practices with respect to the gathering and handling of your personal information. This Privacy Policy (the “Privacy Policy” or “Policy”) describes those practices.

This Privacy Policy sets forth general Personal Data privacy principles that VLS follows with respect to Personal Data being processed in our business operations. The information contained in this Privacy Policy is subject to any further information contained in any relevant supplementary privacy notice, including the California Privacy Notice supplement (the “California Privacy Notice”) set forth in Section 12 below.

All terms defined in this Privacy Policy and our General Terms¹ shall have the meaning ascribed to them in the respective document and, if such term is not defined in the relevant document, it shall be ascribed the meaning given to it in this Privacy Policy and our General Terms, as applicable.

SECTION 1 | THE PRIVACY POLICY IS FOR THE FOLLOWING:

This Privacy Policy is addressed to:

• visitors of the Site;
• recipients of electronic or other communications which contain or refer to this Privacy Policy;
• Individuals with whom VLS has business relationship, such as customers, representatives of customers, and external stakeholders and their representatives;
• Individuals with whom VLS has a relationship, in terms of current team members or prospective team members, recruits.

Information from Children

VLS does not seek through the Site to gather personal data from or about minors (as this term is defined by applicable law), nor does VLS sell or share the personal information of minors without affirmative authorization.

SECTION 2 | VLS'S COMPLIANCE WITH DATA PROTECTION LAWS

VLS is committed to collecting and using personal data in a lawful manner. VLS will ensure that, when it collects or uses personal data, such collection or use is allowed under applicable data protection law, including, for example, the EU General Data Protection Regulation (GDPR), the Virginia Consumer Data Protection Act, or California Consumer Protection Act, where such laws govern. For more information on particular data processing activities, the purposes of this processing, and a description of the specific personal data, please review the table in Section 3. Individuals may object to the processing of their personal data, and we will consider such objections carefully where required by law. For more information about your rights with respect to how we process your personal data, please refer to Section 8 and/or contact the VLS Data Privacy Office via data.privacy@vlses.com.

SECTION 3 | COLLECTION OF PERSONAL DATA

In this table we describe the categories of information that we gather via the Site and in connection with our Services. We also describe the purpose for using and processing the information.

SECTION 4 | COOKIES AND TARGETED ADVERTISING

Information placed on your computer when visiting the Site

We use cookies and other local storage technologies or files such as pixels, tags, web beacons and Local Shared Objects (sometimes called “flash cookies”) which we store on your computer or mobile device when you visit the Site. The cookies and files stored on your computer or mobile device facilitate customizing your use of the Site and help to avoid the need to re-enter your details every time you visit. You can erase or block this information from your computer. Flash cookies may use parts of your device other than your browser, which means that you may not be able to control their use using browser tools and settings. For more information about managing Flash cookies, please visit the Adobe Flash Player website (note: you will be taken to a third-party website).

You may refuse to accept browser cookies by activating the appropriate setting on your browser. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to the Site. To learn more about how to opt-out from cookies please click here (note: you will be taken to a third-party website).

We use vendors to monitor usage of our site and to provide site usage analytics. These vendors may use such information for business purposes in accordance with our contracts with them.

Note that some goods or services may not be available if you choose not to accept browser cookies.
Targeted advertising, and our use of social media sites

Our Site provides links to others’ websites. This may include social plug-ins to Facebook, Twitter, YouTube and other social media. In case we receive certain statistical information regarding the click-through via these links or social plug-in, we will treat such statistical information in accordance with applicable laws. By clicking on such links or social plug-ins, an online connection will be established between your browser and the servers of the relevant websites and as a result certain personal data may be collected by these websites. VLS does not own, control or maintain these websites. We recommend that you review the privacy policy of these other sites carefully and contact the operator if you have concerns or questions. VLS is not responsible for the way others handle personal data and makes no representations or warranties about the privacy practices and accuracy of the content of those sites.

Similarly, VLS is not responsible for the policies and practices of any website from which you visit that are linked to our Site. 

We use cookie files and other storage technologies on our Site in accordance with this Privacy Policy. In case you visit one of our websites and you wish to opt-out from targeted advertising via cookies, you can do so by following the cookie-banner instructions.

Do-Not-Track Signals and Similar Mechanisms, such as Global Privacy Control on VLS US websites: Some web browsers transmit “do-not-track” signals. We act in response to these signals: If the browser has Do Not Track enabled, cookies in this group will be disabled until explicit consent is received. We detect and honor your Global Privacy Control signal if the website browser add-in or extension is enabled at your end.

SECTION 5 | DISCLOSURE OF PERSONAL DATA TO EXTERNAL PARTIES

We contract with other companies and persons to perform functions on our behalf. They have access to personal data needed to perform these business purposes but may not use it for other purposes.

For example, VLS may share the personal data it collects automatically, directly from you, or from vendors or via social media with (other) vendors in order to allow VLS to respond to quote requests and make deliveries, to send postal mail, and e-mail, to manage customer lists, analyze data, provide marketing assistance, host websites, process card payments, and provide and improve customer service. Furthermore, communicating via the Internet and sending information, products, and services to you by other means necessarily involves your personal data passing through or being handled by third-parties.

In some circumstances, VLS may disclose any of the categories of personal data it collects to vendors, including competent authorities, legal advisors and other contracted parties. These vendors process the personal data on their own behalf, for instance: if required by law, to defend VLS’s rights, or to handle individuals’ complaints and requests. We may also share your information in connection with a transfer of assets, or if we are otherwise involved in a merger or transfer.
 
SECTION 6 | ACCURACY OF PERSONAL DATA

VLS endeavors to keep personal data that it collects accurate and complete. VLS relies on the individuals to maintain the accuracy and completeness of the personal data. Please inform VLS if your personal details change, including the context in which the personal data was provided, e.g., in connection with a specific product or service.

HOW TO SUBMIT A DATA SUBJECT REQUEST

California residents can exercise their rights under the CCPA via the 877-861-8588 toll free number. Please note, all the calls through the 877-861-8588 phone number will be recorded and your participation is voluntary. If you call us, you consent to the recording of the conversation, which includes voice, your name, contact details and the details of your specific request. You may withdraw your consent to participate in the recording by exiting from the call at anytime with no adverse consequence. If you do not want to participate in the recorded call, you will have the opportunity submit your request via our Data Subject Request webform, which is available here.

When you submit a data privacy request, VLS will verify your identity by requesting you to provide your name, email address or other contact information, VLS account information (in case it is applicable). Use of an authorized agent: You may be entitled, in accordance with applicable law, to submit a request through an authorized agent. To designate an authorized agent to exercise your rights and choices on your behalf, please provide your authorized agent with signed, written permission demonstrating that they have been authorized by you to act on your behalf.

You also have a right to lodge a complaint to the data protection supervisory authority in your country.
For more information about the specific mechanisms available to exercise these rights, please submit a data privacy request on our landing page or contact the data.privacy@vlses.com.

To facilitate our efforts to address your request, please let us know the circumstances in which you initially provided VLS with your personal data, e.g., in connection with a specific product or service.

SECTION 7 | RECORD RETENTION

VLS retains personal data as long as necessary to meet the purposes for which the data was collected, to exercise its legal rights and as required to comply with applicable law.

SECTION 8 | QUESTIONS AND COMPLAINTS

VLS is committed to protecting your personal data as described in this Privacy Policy and as required by applicable laws. To make any privacy requests, to ask if you have any questions about this Privacy Policy or our handling of your personal data, or if you would like additional information, please contact:
Data Privacy Office

c/o VLS

19500 Hwy 249, Suite 440

Houston, TX 77070

data.privacy@vlses.com

The Data Privacy Office strives to respond to all privacy requests and other communications in a timely manner.

SECTION 9 | VLS AND AFFILIATES

“VLS” and/or “VLS affiliates” mean (a) VLS Environmental Solutions, LLC, or any parent of VLS Environmental Solutions, LLC, (b) any company or partnership in which VLS Environmental Solutions, LLC, or any parent of VLS Environmental Solutions, LLC now or hereafter, directly or indirectly (1) owns or (2) controls, more than fifty per cent (50%) of the ownership interest having the right to vote or appoint its directors or functional equivalents (“Affiliated Company”) and (c) any joint venture in which VLS Environmental Solutions, LLC, any parent of VLS Environmental Solutions, LLC, or an Affiliated Company has day to day operational control.

SECTION 10 | CHANGES TO THIS PRIVACY POLICY

We reserve the right to change this Privacy Policy at any time without notice. When we make material changes to this Privacy Policy, we will post the changes on this page and update the revision date at the top of the Privacy Policy. We encourage you to review our Privacy Policy regularly for updates.
 
SECTION 11 |CALIFORNIA PRIVACY NOTICE

This notice supplements the Privacy Policy set forth above with respect to specific rights granted under the California Consumer Privacy Act of 2018 (as amended and together with its implementing regulations and guidelines, the “CCPA”) to natural person California residents and provides information regarding how such California residents can exercise their rights under the CCPA. This supplement is only relevant to you if you are a resident of California as determined in accordance with the CCPA.

Categories of Personal Information We Collect

We have collected some or all of the following categories of personal information from individuals within the last twelve (12) months:

<< INSERT TABLE >>

We do not collect or use sensitive personal information other than:

• To perform services, or provide goods, as would reasonably be expected by an average consumer who requests those goods or services;
• As reasonably necessary and proportionate to detect security incidents that compromise the availability, authenticity, integrity, and confidentiality of stored or transmitted personal information;
• As reasonably necessary and proportionate to resist malicious, deceptive, fraudulent, or illegal actions directed at us and to prosecute those responsible for such actions;
• For short-term, transient use (but not in a manner that discloses such information to another third party or is used to build a profile of you or otherwise alter your experience outside of your current interaction with us);
• To perform services on behalf of our business;
• To verify or maintain the quality or safety of a service or to improve, upgrade, or enhance such service or device; and
• To collect or process sensitive personal information where such collection or processing is not for the purpose of inferring characteristics about a consumer.

We collect personal information for the business or commercial purposes and from the sources set forth in Section 3 (Collection of Personal Data)2, in the Privacy Policy above.

Disclosure of Personal Information

Within the last twelve (12) months, we have disclosed personal information collected in connection with this Website for a business purpose to the categories of third parties indicated in the chart below. We may also disclose your information to other parties as may be required by law or regulation, or in response to regulatory inquiries.

<< INSERT TABLE >>

Rights under the CCPA

Deletion of your personal information: You have the right to request that we delete any of your personal information that we retain, subject to certain exceptions, including, but not limited to, our compliance with U.S., state, local and non-U.S. laws, rules and regulations. We will notify you in writing if we cannot comply with a specific request and provide an explanation of the reasons.

Disclosure and Access Rights: You have the right to request that we disclose to you certain information regarding our collection, use, disclosure and sale of personal information specific to you over the last twelve (12) months. Such information includes:

• The categories of personal information we collected about you;
• The categories of sources from which the personal information is collected;
• Our business or commercial purpose for collecting such personal information;
• Categories of third parties with whom we disclose the personal information;
• The specific pieces of information VLS has collected about you; and
• Whether we disclosed your personal information to a third party, and if so, the categories of personal information that each recipient obtained.                        

Correction Right: You have the right to request that we correct of any inaccurate personal information that we retain, subject to certain statutory exceptions, including, but not limited to, our compliance with U.S., state, local and non-U.S. laws, rules and regulations. We will notify you in writing if we cannot comply with a specific request and provide an explanation of the reasons.

Right to Opt-Out From Sale or Sharing of Your Data: 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 the relevant box located on the form on which we collect your data. You can also always opt-out by sending us an email with your request to data.privacy@vlses.com.

No discrimination: VLS will not discriminate against you for exercising your rights under the CCPA, including by denying service, suggesting that you will receive, or charging, different rates for services or suggesting that you will receive, or providing, a different level or quality of service to you.

How to Exercise Your Rights

To exercise any of your rights under the CCPA, or to access this notice in an alternative format, please submit a request using any of the methods described in Section 7 (Individual’s Rights) of the Privacy Policy.