Date of Last Update: July 09, 2020


By visiting, viewing, accessing, browsing, surfing, making any purchase or using our website including its sub-domains, website pages, hyperlinks or mobile optimized version, if any (“Website”) and/or using any of our Website Services (as defined in Terms and Conditions), you (hereinafter referred to as “you”, “your” or “User”) consent to the information collection, disclosure and use practices as described in this Privacy Policy. The Website is operated by Viaflash LLC, a limited liability company based in the US bearing Registration No. L19000193607 and having its registered address located at __________________________________ (hereinafter referred to as “we,” “us” or “our”). This Privacy Policy also sets out how we may collect, use and disclose information in relation to Users of the Website.


Information We Collect

Your privacy is important to us and we have taken steps to ensure that we do not collect more information from you than what is necessary for us to provide the Website Services.

For visiting, viewing, accessing, browsing, surfing or using the Website, you may be asked to submit the following types of personal data:

We may use Personal Data, Communication Data, Technical Data and Marketing Data (collectively the “Data”) as provided herein.


Name and Address of the Data Controller

Data Controller for the purposes of the General Data Protection Regulation (GDPR), other data protection laws applicable in Member States of the European Union (“EU”) and other provisions related to data protection is:


Data Protection Officer: Jean E. Fenton

Address: ____________________________

Phone: ______________________________




Consent and its Withdrawal 

  1. When you visit, view, access, browse, surf, make any purchase or use the Website, you provide us with your consent to use your Data as per this Privacy Policy. In order to provide you with the Website Services, it is necessary for us to collect all relevant and necessary Data from you. In addition, by filling the forms available on the Website, you give us your express consent and permission to use your Data.
  2. We will process the Data only after taking written instructions/consent from you mostly in electronic form in the form of Clickable button or a checkbox.
  3. If you change your mind, you may withdraw your consent for us to contact you, for the continued collection, use or disclosure of your information, at any time, by contacting us at


Promotional Emails

You agree that we may from time to time send e-mail messages to you which offer products and services, promotions, subscriptions or registration-based services or other material. If you wish to discontinue receiving such email, you may opt-out by writing us through email at Your preferences will then be updated.


How We Use and Process the Data

  1. The Data collected by us from you may be used to provide you the Website Services and better understand your needs in relation thereto, to correspond with you and reply to any of your questions relating to the Website Services.
  2. We will not rent or sell your Data to others. We may store the Data in locations outside our direct control (for instance, on servers or databases co-located with hosting providers).
  3. If you provide any Data to us, you are deemed to have authorized us to collect, retain and use that data for the following purposes:
  4. verifying your identity;
  5. sending you a welcome e-mail;
  6. providing you with customer service and responding to your queries, feedback or disputes;
  7. conducting marketing analysis, sending surveys or newsletters, contacting you about the Website Services, products, activities, special events or offers from us or our partners and for other marketing, information, product development and promotional purposes;
  8. making such disclosures as may be required for any of the above purposes or as required by law, regulations and guidelines or in respect of any investigations, claims or potential claims brought on or against us;
  9. sending you notices (for example, in the form of e-mails, mailings and the like) regarding products or services you are receiving and for billing and collection purposes;
  10. provide and maintain the Website Services;
  11. notifying you about changes to the Website Services;
  12. sending you information we think you may find useful or that you have requested from us;
  13. enhancing and improve the Website or the Website Service such as through personalized features and content;
  14. analysing the use of the Website and the Website Services and the people visiting to improve our content and Website and the Website Services;
  15. investigating, preventing or taking action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of our policies or as otherwise required by law;

We shall ensure that:


Disclosure of Data

We shall not be able to keep your Data private in response to legal process, i.e. a court order or a subpoena or a law enforcement agency’s request. If, in our view, it is deemed appropriate to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of our terms of use or as otherwise required by law, we may be compelled to disclose the Data. Moreover, in case of takeover, merger or acquisition, we reserve a right to transfer your Data to new platform.


We may disclose the Data in the good faith belief that such action is necessary to:


When necessary, we may also disclose and transfer your Data to our professional advisors, law enforcement agencies, insurers, government and regulatory and other organizations.


Data Storage

  1. Your Data may be stored and processed at the servers in the United States, Europe or any other country in which we or our subsidiaries, affiliates or service providers maintain facilities.
  2. We may transfer your Data to affiliated entities or to other third parties across borders and from your country or jurisdiction to other countries or jurisdictions around the world. Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.
  3. We will take all steps reasonably necessary to ensure that your Data is treated securely and in accordance with this Privacy Policy and no transfer of your Data will take place to an organization or a country unless there are adequate controls in place including the security of your Data.
  4. We will only retain your Data preferably for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any record retention or reporting requirements under applicable laws. When deciding what the correct time is to keep the Data, we look at its amount, nature and sensitivity, potential risk of harm from unauthorised use or disclosure, the processing purposes, if these can be achieved by other means and legal requirements.


How We Protect Your Information

  1. We store all the Data submitted by you through the Website at a secure database.
  2. We are concerned with protecting your privacy and Data, but we cannot ensure or warrant the security of any Data you transmit or guarantee that your Data may not be accessed, disclosed, altered or destroyed by breach of any of our industry standard physical, technical or managerial safeguards.
  3. No method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Data, we cannot guarantee its absolute security. If you have any questions about security of the Website, you can contact us at
  4. Any Data supplied by you will be retained by us and will be accessible by our employees, any service providers engaged by us and third parties.


Compliance with the GDPR

For users based in the EU, the Website shall make all reasonable efforts to ensure that it complies with the General Data Protection Regulation (GDPR) (EU) 2016/679 of the EU regarding the collection, use, and retention of Data from the Users based in Member States of the EU. The Website shall make all reasonable efforts to adhere to the requirements of notice, choice, onward transfer, security, data integrity, access and enforcement.


The Rights of Users:

  1. You may exercise certain rights regarding your Data processed by us. In particular, users based in the EU may do the following:


Right of confirmation:

  1. You shall have the right granted by the EU legislator to obtain from us the confirmation as to whether or not personal data concerning you are being processed.


Right of Access:

  1. You shall have the right granted by the EU legislator to obtain from us free information about your personal data stored at any time and a copy of this information. Furthermore, the EU directives and regulations grant you access to the following information:
  2. the purposes of the processing;
  3. the categories of personal data concerned;
  4. the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organizations;
  5. where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;
  6. the existence of the right to request from us rectification or erasure of personal data or restriction of processing of personal data concerning the data subject or to object to such processing;
  7. the existence of the right to lodge a complaint with a supervisory authority;
  8. where the personal data are not collected from you, any available information as to its source;
  9. the existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) of the GDPR and, at least in those cases, meaningful information about the logic involved as well as the significance and envisaged consequences of such processing for you.
  10. Furthermore, you shall have a right to obtain information as to whether personal data are transferred to a third country or to an international organisation. Where this is the case, you shall have the right to be informed of the appropriate safeguards relating to the transfer.


Right to rectification: 

Right to erasure (Right to be forgotten): 

Right of restriction of processing:

Right to data portability:

Right to object:


Automated individual decision-making, including profiling:


If the decision (1) is necessary for entering into, or the performance of, a contract between you and us, or (2) it is based on your explicit consent, we shall implement suitable measures to safeguard your rights and freedoms and legitimate interests, at least the right to obtain human intervention on our part, to express your point of view and contest the decision.


Right to withdraw data protection consent: You shall have the right granted by the EU legislator to withdraw your consent to processing of your personal data at any time. You may initiate request with us at to exercise any of the above mentioned rights. We shall review your request and, in our own discretion, honour your request, if deemed necessary by us, within reasonable time.


Compliance with CalOPPA

  1. We are also committed to complying with the California Online Privacy Protection Act (“CalOPPA”) which requires commercial websites and online services to post a privacy policy. The law requires any person or company in the United States (and conceivably the world) that operates websites collecting ‘personally identifiable information’ from California consumers to post a conspicuous privacy policy on its website stating exactly the information being collected and those individuals or companies with whom it is being shared. As required under CalOPPA, we agree to the following:
  2. Users can visit our site anonymously.
  3. Our Privacy Policy link includes the word ‘Privacy’ and can easily be found on the page specified above.
  4. We endeavour to fulfil requirements of the CalOPPA under this Privacy Policy in line with our policy for user data collection, storage, and disclosure as outlined for GDPR compliance.


Compliance of California Privacy Act 2018

  1. This Privacy Policy is also applicable on California residents and explains how we collect, use, and share your Personal Information and how you may exercise your rights under the California Consumer Privacy Act of 2018 (“CCPA”).


Your rights under the CCPA:

  1. Under the CCPA, you have the right to access the Personal Information we’ve collected about you during the past 12 months and information about our data practices. You also have the right to request that we delete the Personal Information that we have collected from you.
  2. To request manual access or deletion of your Personal Information, please contact us at
  3. Please note, for all manual requests, you will need to verify your identity by providing us with the all the information as we may require from you for this purpose.
  4. You have the right to be free from any discrimination for exercising your rights to access or delete your Personal Information. We will not discriminate against you for exercising any of these rights.
  5. If you have additional questions about this or how to exercise your rights under the CCPA, please contact us at



  1. We use technologies such as cookies to make better users experience, customise content, to provide social media features and to analyse traffic to the Website. Where applicable the Website uses a cookie control system allowing the user on their first visit to the Website to allow or disallow the use of cookies on their computer / device.
  2. Cookies are small files saved to the user's computers’ or mobile devices’ hard drive or memory that track, save and store information about the user's interactions and usage of the Website. This allows the Website, through its server to provide the users with a tailored experience within the Website.
  3. Users are advised that if they wish to deny the use and saving of cookies from the Website on to their computers hard drive they should take necessary steps within their web browsers security settings to block all cookies from the Website and its external serving vendors.
  4. We may gather certain information automatically and store it in log files. This information includes Internet protocol (IP) addresses, browser type, Internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and click stream data. We may use this information, which does not identify individual users, to analyse trends, to administer the Website, to track users’ movements around the Website and to gather demographic information about our user base as a whole.
  5. We may track the referring URL (the web page you left before coming to the Website) and the pages, links, and graphics of the Website you visited. We do so because it allows us to evaluate the reputation and responsiveness of specific web pages and any promotional programs we may be running.
  6. Managing Cookies: Many web browsers allow you to manage your preferences. You can set your browser to refuse cookies or delete certain cookies. You may be able to manage other technologies in the same way that you manage cookies using your browser’s preferences.
  7. Please note that if you choose to block cookies, doing so may impair the Website Services or prevent certain elements of it from functioning.

Third-Party Service Providers

  1. We may employ third party companies and individuals to facilitate the Website Services ("Third Party Service Providers"), to provide the Website Services on our behalf, to perform Website Services-related services or to assist us in analysing how the Website Service is used.
  2. These third parties have access to your Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.


Changes to this Privacy Statement

  1. We may modify these this Privacy Policy from time to time and any such change shall be reflected on the Website with the updated version of the Privacy Policy and you agree to be bound to any changes to the updated version of Privacy Policy when you use the Website or the Website Services.
  2. You acknowledge and agree that it is your responsibility to review the Website and this Privacy Policy periodically and to be aware of any modifications. Updates to this Privacy Policy will be posted on this page.
  3. Occasionally there may be information on the Website that contains typographical errors, inaccuracies or omissions that may relate to service descriptions, pricing, availability, and various other information, and we reserve the right to correct any errors, inaccuracies or omissions and to change or update the information at any time, without prior notice.


Contact US

If you have questions about our Privacy Policy, please contact us via email:


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