VOLO, LLC PRIVACY POLICY

VOLO, LLC (VOLO) is committed to protecting your privacy. This Privacy Policy applies to VOLO Recovery® (volorecovery.com), VOLO OSTM (voloos.com) & VOLO Village® (volovillage.com) Web sites as well as our marketing web site (volosaas.com) and governs data collection and usage at all VOLO sites and services.

VOLO Recovery®, VOLO OSTM & VOLO Village® are web sites intended for use by customers of VOLO. Personal information of users and message recipients is collected, used and disclosed as described in this Privacy Policy.

Collection of your Personal Information

VOLO collects personal information, such as your e-mail address, name, home or work address and telephone numbers. Information collected by VOLO is used primarily for the purpose of fulfilling VOLO Recovery®, VOLO OSTM & VOLO Village® services.

VOLO does not collect or use personal financial data or sensitive personal information, such as social security numbers, birth dates, protected health information, race, ethnicity, religious or philosophical beliefs, political opinions, political affiliations or sex life.

This information has typically been received from your employer, your community, or provided by you through VOLO’s client portal.

VOLO may also collect other information, such as IP addresses, browser information and other system information.  This information is used only for the purposes of user validation, communication delivery and providing the optimal user experience.

Use of your Personal Information

VOLO and its operational service partners collect and use your personal information to deliver communications via broadcast voice, SMS, email and push notification to mobile devices. It is possible that VOLO may also use personal information to inform VOLO clients of other products or services available from VOLO and its affiliates. VOLO may also contact clients via surveys to conduct research about opinions VOLO’s current current services or of potential new services that may be offered.

VOLO does not sell, rent or lease its customer lists to third parties. VOLO utilizes third party companies for the delivery of telephonic communications, providing after-hours answering service, or performing statistical analysis of our services. We will only provide those companies the personal information they need to deliver the service. They are required to maintain the confidentiality of your information and are prohibited from using that information for any other purpose.

VOLO may access and/or disclose your personal information if required to do so by law or in the good faith belief that such action is necessary to: (a) conform to the edicts of the law or comply with legal process served on VOLO or any of its sites; (b) protect and defend the rights or property of VOLO, including its Web sites; (c) act under exigent circumstances to protect the personal safety of users of VOLO or the public or (d) respond to lawful requests by public authorities, including to meet national security or law enforcement requirements.

Personal information collected on VOLO’s sites may be stored and processed in the United States or any other country in which VOLO or its  agents maintain facilities, and by using any of VOLO’s sites, you consent to any such transfer of information outside of your country.

Control your Personal Information

VOLO offers its customers and their employees, residents and members the ability to view and update their personal information at https://my.voloos.com and https://portal.volorecovery.com.  If you would like login credentials to either of these sites, please contact the appropriate person at your place of employment or the client community.  If your employer or community have not made portal access available to you, you may make a request by emailing privacy@volosaas.com. Please be sure to provide as much information as possible so we can identify you in our records. You may also stop the delivery of future promotional e-mail from VOLO by responding directly to any email you receive with a request to remove you from the mailing list.

VOLO offers its customers choices for the collection, use and sharing of personal information. You may notify us of your preferences by emailing privacy@volosaas.com. Please be sure to provide complete account information so we can identify you in our records.

You may also stop the delivery of future promotional e-mail from VOLO by clicking the unsubscribe link or responding directly to any email you receive with a request to remove you from the mailing list.

Privacy Shield

VOLO complies with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Frameworks as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States.  VOLO has certified to the Department of Commerce that it adheres to the Privacy Shield Principles.  If there is any conflict between the terms in this Privacy Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern.  The Federal Trade Commission has jurisdiction over VOLO’s compliance with the Privacy Shield. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov.

VOLO commits to resolve any complaints about how your data is used in accordance with the Privacy Shield principles. European Union and/or Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should first contact VOLO at privacy@volosaas.com or VOLO, LLC, Attn: Privacy Complaints, 9 Sunshine Blvd., Ormond Beach, FL  32174.

VOLO further commits to cooperate with the panel established by the EU data protection authorities (DPAs) and/or the Swiss Federal Data Protection and Information Commissioner and comply with the advice given by the panel and/or Commissioner with regard to data transferred from the EU and/or Switzerland, as applicable.

If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, and you are based in the European Union or Switzerland, you may file a complaint directly to the DPA or Commissioner please visit http://ec.europa.eu/newsroom/article29 for a list of the National Data Protection Authorities and their respective contact information.  The services of the DPAs and Commissioner are available to you at no cost. VOLO commits to comply with any advice given by the DPAs and/or Commissioner and take necessary actions to correct any non-compliance with the Privacy Shield Principles.

In the event that after contacting the DPA or Commissioner, your complaint has still not been resolved to your satisfaction, you have the right to invoke binding arbitration by following the procedures of and subject to conditions set forth in Privacy Shield Annex I.

To deliver the critical communications of our clients, VOLO transfers some of your information (i.e. phone numbers) to third party service partners for delivery of voice and SMS messages.  In these instances, VOLO has written agreements with these partners to provide protection in accordance with the Privacy Shield Principles.   VOLO is liable if we or any of our third-party partners process your personal information in a manner that is not consistent with the Privacy Shield Principles.

Security of your Personal Information

VOLO is committed to protecting the security of your personal information. We use a variety of security technologies and procedures to help protect your personal information from unauthorized access, use, or disclosure. For example, we store the personal information you provide on computer systems with limited access that are located in controlled facilities.

Changes to this Policy

VOLO will occasionally update this Privacy Policy to reflect regulatory changes and/or customer feedback. If there are material changes to this Policy or in how VOLO will use your personal information, VOLO will prominently post such changes prior to implementing the change. VOLO encourages you to periodically review this Policy to be informed of how VOLO is protecting your information.