LAST UPDATED: 5/8/2019
In compiling this Policy, we have taken steps to ensure we have incorporated the standards and principles outlined in data collection and privacy frameworks, including the European Union’s General Data Protection Regulation (“GDPR”). This Policy describes:
- The types of information we may collect from you or that you may provide when you visit the website https://www.viacharacter.org/ (the “Website”) as well as any websites and blogs directly owned by VIA (“our websites”)
- Our practices for collecting, using, maintaining, protecting, and disclosing that information.
Please read this Policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, then please do not use our websites. By using our websites, you agree to the terms of this Policy. This Policy may change from time to time (see below, “Changes to this Policy”). Your continued use of our websites after we make changes is deemed to be acceptance of those changes, so please check the Policy periodically for updates.
Your responses to questionnaires on the Website are entirely voluntary and will be used, anonymously, in ongoing research by VIA, the creators of the questionnaires, and other researchers with VIA’s permission. By visiting the Website and completing the questionnaires, you are accepting and consenting to the practices described in this Policy.
What We Collect and How We Collect It
To ensure that we provide you with the best possible experience, we will store, use, and share information about you in accordance with this Policy. For example, when you request information, subscribe to our emails, complete a survey, or register yourself with the Website, we will ask you to provide Personal Information to complete these transactions.
You are not required to give us your real email address or name, but providing your real email address and name will help us assist you with your account. If we receive a request for information about your account, the response will be sent to the registered address, not the one making the request, unless we can verify that the registered address is an invalid or defective address and that the person making the request is the person who created the account.
Some of the questions presented in our surveys and questionnaires will ask for potentially sensitive information relating to your political opinions, or religious, spiritual, and philosophical beliefs. By answering these questions, you consent to the processing of that personal data for the purpose of providing results about your character strengths.
You are not required to provide us with any of this data, but if you choose to submit the registration form or any of the questionnaires, you must answer all of the questions to receive your scores.
Automatic Information Collection
In addition to the information that you provide us through registration, questionnaires, or elsewhere, we may also collect information about you during your visit to our Website or while you engage with one of our marketing campaigns. We collect this information using automated tools that are detailed below. These tools may collect information about your behavior and your computer system: information like your internet address (IP address), the pages you have viewed, the type of browser you used, and the actions you have taken while on our websites. This helps us understand usage of the website and allows us to produce aggregate statistics on usage.
We may also use these tools in connection with our email marketing campaigns to allow us to understand what links you click on and what content is of interest to you. VIA may also collect information from commercial sources to enrich and verify the information that you have provided or that we have collected about you. This information will help us to ensure that we have accurate records, and will provide us with the ability to keep your information up to date. In some cases, we may use this commercial information to determine something about you. For example, we may use your IP address to calculate your approximate geographic location. Some of the tools we use to automatically collect information about you, include:
Embedded Web Links. Links provided in our emails and in some cases on third party websites may include tracking embedded in the link. The tracking is accomplished through a redirection system. The redirection system allows VIA to understand how the link is being used.
Web Beacons. A Web Beacon is an electronic image. Web Beacons can track certain things from your computer and can report activity back to a web server allowing us to understand some of your behavior. If you choose to receive emails from VIA, we may use Web Beacons to track your reaction to our emails. We may also use them to track if you click on the links and at what time and date you do so. Some of our marketing partners may use Web Beacons to track your interaction with online advertising banners.
Do Not Track Disclosure. We do not track website visitors over time and across third party websites to provide targeted advertising. Therefore, our Website does not operate any differently when it receives Do Not Track (DNT) signals. The information we collect automatically is statistical data and does not include personal data.
How We Use Your Information
The information we gather and you provide is collected and used to complete the services you have requested. We may also use this information to improve our service to you and your experience when engaging with our websites and our services.
During registration, we ask you to tell us about yourself, including the month/year of your date of birth and your sex. We also ask you, during registration, to give us your email address, and a name that you would like to use. These are for your benefit. They make it easier for you to remember how to log in to the Website. They make it possible for us to provide you with your password if you forget it. And they help you be sure that you are looking at your own records if you share your computer with another user of this site. We display your name when you log in and include it in your printable report. If you do not want to share your real name, you can make up a name.
After completing a questionnaire we ask optional demographic questions, such as your zip code (or your country, if you live outside the U.S.), how much formal education you have received, and your occupation. We use this information to tell you how your scores on the questionnaires compare to others who are like you in age, gender, geographic location, education, and occupation. We also use them to compute statistics for our research on how these factors affect happiness and strengths. These are completely optional.
Provided you have consented, we may also use your email address and name to send you email messages with information on how to utilize your strengths and links to resources.
We collect your responses to the questionnaires on this site and store these, along with your scores, on our database server. We will never report your individual responses or scores to others, except as described below. We will include your scores and responses in reports, publications, lectures, and websites only in summaries of groups of site users. We will not include your responses in the comparisons we provide on this site until there are at least 50 surveys from people in the same category (a geographic area, age range, occupational group, etc.).
We may also use your information for the following purposes:
- Prevent malicious activity and provide you with a secure experience;
- Provide service and support for your use of the Website;
- Provide marketing communications that are effective and optimized for you;
- Keep you up-to-date with the latest benefits available from VIA;
- Avoid sending you something that will not be of interest;
- Define what content you might be interested in;
- Personalize your Website experience;
- Measure performance of marketing programs;
- Learn about your behavior and try to improve what we do for your benefit;
- Contact you about services that are relevant to you; and
- Display testimonials, reviews, or recommendations on our websites with the express consent of the owner of that statement.
Although we use your name and email address to inform you about future products and services, you can always unsubscribe from receiving any marketing emails via the unsubscribe option in any such marketing email you receive from us.
How We Share Your Information
VIA does not sell or lease your information to any third party. We may disclose your Personal Information to our partners in accordance with this Policy. We may share your information depending upon your use of our services.
- General Users Completing a VIA Survey. Many website visitors participate in our questionnaires to learn more about his or her character strengths. After completing the survey and entering optional Personal Information, you will go to your results. You may receive a notification allowing you to opt-in to a research study. If you have not opted-in to participate in a study but have completed the survey on the Website at some point, we may share de-identified results without your name or email address to a Researcher, as defined below, who has contacted us to get a sample of data with specific guidelines that you fit (for example, you are between the ages of 21 and 40 and are within the United States). If you register and complete a survey using a consultant's unique professional link, your information (name, email address and survey results/responses) will be shared with that professional. Your registration through the professional link will serve as permission to do so.
- Researchers. Researchers are users who wish to use VIA’s surveys and questionnaires in their own research studies. To the extent that you provide us with data and results pertaining to your own research studies, we will not share any of that information with anyone without your explicit consent.
- Research Participant. If you choose to take a survey as part of a research study, then you will take it through a unique Researcher Site link that is given to you by the Researcher. Alternatively, you may take the survey through the Website and enter a research code that was given to you by the Researcher. As a Research Participant, you will take the survey and you will be asked to give your consent to have your information and your survey responses and results shared with the Researcher. Upon providing your consent, VIA will provide the Researcher with all of the information that you entered when registering and taking the survey. This may include your name, email address, gender, data of birth, and any optional demographic information that you choose to enter.
Your Choices and Selecting Your Privacy Preferences
VIA wants to provide you with relevant information that you have requested.
If we provide subscription-based services, such as email newsletters, we will allow you to make choices about what information you provide at the point of information collection or at any time after you have received a communication from us while you are subscribed to the service. This assumes that any transactional or service-oriented messages are excluded from your preference, as they are not intended to be for the purposes of marketing communications, and rather to fulfill a service you have requested.
Email newsletters and marketing emails will not be sent to you unless you consent to receive such marketing information. After you request to receive these emails, you may opt-out of them at any time by selecting the “unsubscribe” link at the bottom of each email. Please note that by opting-out or unsubscribing you may affect other services which you have requested we provide to you where email communication is a requirement of the service provided.
The communication that you receive from VIA will be in accordance with your preferences and this Policy. Some of the communications you receive could include automatic information collection tools.
Access to and Accuracy of Your Information
VIA strives to maintain and process your information accurately. We have processes in place to maintain all of your information in accordance with relevant frameworks and take steps to monitor its accuracy. We employ technologies designed to help us maintain information accuracy on input and processing.
Where we enable you access to your Personal Information, we will always ask you for a username and password to help protect your privacy and security. We recommend that you keep your password safe, that you change it periodically, and that you do not disclose it to any other person or allow any other person to use it.
To view and change the Personal Information that you have directly provided to VIA you can return to the webpage where you originally submitted your information and follow the instructions on that webpage or contact us directly for assistance. In some cases, depending upon the type of questionnaire or research study you have participated in, we may be unable to change the Personal Information you provided due to the research study having concluded. In these cases, we will make every effort to inform the facilitator of the study of your desire to change Personal Information you provided.
Children’s Information and Privacy
VIA does not market its services to children under the age of thirteen (13). We do market the survey and reports to teachers and parents who could use it with children under the age of thirteen. No one under the age of thirteen may create an account on the Website. For Website visitors in the European Union, no one under the age of sixteen may create an account on the Website. We include one questionnaire that is suitable for children between the ages of ten (10) and seventeen (17). It assesses a child’s character strengths and provides the results in a rank order list. Those who are under the age of thirteen may only complete the assessment under the account of a parent, guardian, or other adult authorized by a parent or guardian. For Website visitors in the European Union, those who are under the age of sixteen (16) may only complete the assessment under the account of a parent, guardian, or other adult authorized by a parent or guardian. We present sample questions before beginning the survey to help parents decide if it is appropriate for their child.
After you log on, we ask you to enter a first and last screen name for the child, month and year of birth, and gender. The screen name given for the child is used only to properly distinguish the different children’s scores on your account. You do not have to use the child’s real name. We do not ask for the child’s address, geographic location, email address, or other information that could be used to identify or locate a child, except through you.
For Website Visitors in the European Union (“EU”)
Under the GDPR, our visitors in the EU are provided additional rights concerning their Personal Information, or “personal data” as defined under the GDPR. For the purposes of this Policy and any personal data processed for Website visitors or individuals in the EU, VIA operates as a data controller unless otherwise determined by agreement or law. Any personal data we collect from you is processed in the United States and under the terms of this Policy, and in the legitimate interest of our business and providing our services to you as the lawful means for such processing. You may always withdraw your consent to our use of your personal data, as described below. We will only retain your personal data for the time necessary to provide you the information and marketing services to which you have consented, and in accordance with your rights below and in this Policy.
You can exercise any of the following rights by notifying us as described below:
Access: You may email us at email@example.com to request a copy of the personal data our Website currently contains.
Correction or Rectification: You can correct what personal data our Website currently contains by signing in to your account and clicking the Account Settings tab or emailing us at firstname.lastname@example.org to request that we correct or rectify any personal data that you have provided to us. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause information to be incorrect.
Restrict Processing: When applicable, you may restrict the processing of your personal data by submitting a request via email to email@example.com. In your email, please explain how you wish VIA to restrict processing of your personal data. When such restrictions are not possible, VIA will advise you accordingly. You can then choose to exercise any other rights under this Policy, to include withdrawing your consent to the processing of your personal data.
Object to Processing: When applicable, you have the right to object to the processing of your personal data by submitting a request via email to firstname.lastname@example.org. When such objections are not possible, VIA will advise you accordingly. You can then choose to exercise any other rights under this Policy, to include withdrawing your consent to the processing of your personal data.
Portability: Upon request and when possible, VIA can provide you with copies of your personal data. You may submit a request via email to email@example.com. When such a request cannot be honored, VIA will advise you accordingly. You can then choose to exercise any other rights under this Policy, to include withdrawing your consent. Where applicable, VIA will ensure such changes are shared with any trusted third parties.
Withdraw Consent: At any time, you may withdraw your consent to VIA’s processing of your personal data through this Website by notifying us via email at firstname.lastname@example.org. Using the same email address associated with your Website account, simply type the words “WITHDRAW CONSENT” in the subject line of your email. Upon receipt of such a withdrawal of consent, VIA will confirm receipt and proceed to stop processing your personal data. Where applicable, VIA will ensure such changes are shared with trusted third parties.
Erasure: If you should wish to cease use of our Website and have your personal data deleted from our Website, then you may submit a request by emailing us at email@example.com. Upon receipt of such a request for erasure, VIA will confirm receipt and will confirm once your personal data has been deleted.
Submit Complaints or Questions: If you wish to raise a complaint on how we have handled your personal data, you can contact us as described below. If you reside in a European Union member state, you may also lodge a complaint with the supervisory authority in your country.
Safeguarding the Data We Collect
We take reasonable technical, administrative, and physical precautions to keep both your Personal Information and non-Personal Information secure against accidental loss and from unauthorized access, use, alteration, and disclosure. You may utilize a username and password to enjoy our websites. It is your responsibility to keep confidential your username and password.
Changes to this Policy
How to Contact Us
We value your opinions and welcome your feedback. To contact us about this Policy or your Personal Information, please contact us at: firstname.lastname@example.org