Privacy
Policy

This Privacy Policy describes the online data policies and practices for Vale Group LLC (fka Vulcan LLC and its affiliates (“Vale Group” or “we”/“us”), and applies to the information we collect on paulallen.com (the “Site”).
 
By accessing or using the Site, you consent to this Privacy Policy and Vale Group’s collection, storage and use of your information as described herein. Please carefully review the terms below, as if you do not agree, your sole and exclusive remedy is to discontinue your use of the Site.
 
Vale Group may amend, modify, update, supplement or remove portions of this Privacy Policy in its sole discretion, and will provide notice of any changes using the last updated date above.

“Personal information” is information that can personally identify you, such as your name or email address. Personal information also includes other data that can reasonably be linked to your personally identifiable information. You can directly or indirectly provide your personal information through your use of the Site. The following describes the types of personal information we may collect:
 

1. Browsers and devices: Vale Group collects certain information about the browsers and devices you use to access the Site, including unique identifiers. Unique identifiers are cookie files used to uniquely identify a browser or device. Please see the section below on “Cookies” for more information.

 

2. IP address. Vale Group collects your Internet Protocol (IP) address whenever you access the Site, which is a number automatically assigned to your computer or device when you browse the internet. These numbers are usually assigned based on geography, so an IP address can often be used to identify the general geographic area of where a device is connecting to the internet. Vale Group uses your IP address to administer and address technical issues with the Site. You may be able to disallow certain location data through your device or browser settings.

 

3. Use Statistics. Vale Group collects information about how your browsers and devices interact with the Site, including crash reports, system activity, and the date, time and referrer URL (the webpage you came from if you clicked a link to access the Site). Vale Group also collects statistical information about visitor activity on the Site, including web traffic, and the date, time, duration and number of visits.

 
Submissions: Vale Group may store any messages, content, feedback and other submissions you provide through the Site or to Vale Group (as applicable), whether directly or through a third party service (collectively, “Submissions”). If you provide any Submissions, you are solely responsible for its contents and any personal information you may disclose therein. Providing any Submissions is at your own risk. Vale Group does not knowingly collect or monitor Submissions for personal information, and may use Submissions in any manner without any obligation, confidentiality, notice or liability to you.  If Vale Group discovers it has received any personal information in error, it will take steps to delete the data as soon as possible without notice.

“Cookies” are small pieces of data (text files) that are stored in the web browser cache on your device in order to remember information about you. Cookies are used to compile anonymous, aggregate statistics based information collected through the Site (“Aggregate Data”). Vale Group uses cookies to administer and operate the Site, including site configuration and IT security. Vale Group also uses cookies with Google Analytics and Google Tag Manager (referred together as “Google Web Tools”) for feedback and usage statistics to operate and improve the Site. Vale Group uses use both “first party cookies” (cookies set by us) and “third party cookies” (cookies from another domain) as follows:
 

• Strictly Necessary Cookies. “Strictly Necessary Cookies” are cookies that are necessary for the Site to function and cannot be switched off in our systems. We use Strictly Necessary Cookies to manage actions made by you, such as setting your privacy preferences or filling in forms. You can set your browser to block or alert you about these cookies, but some parts of the Site will not function properly. These cookies do not store any personally identifiable information.  

 

• Performance Cookies. “Performance Cookies” are cookies that allow us to count visits and traffic sources so we can measure and improve the performance of the Site. They help us know how Site visitors move around the Site. Performance Cookies collect Aggregate Data.

 

• Functional Cookies. “Functional Cookies” are cookies that enable the Site to provide enhanced functionality and personalization. They may be set by us or by third party providers whose services we have added to the Site’s pages.

 

• Targeting Cookies. “Targeting Cookies” are third party cookies that may be set through the Site by our advertising partners to build a profile of your interests and show relevant advertisements. Targeting cookies do not store your personal information directly, but track the unique identifier from your browser and internet device to log your browsing history over time. We employ Targeting Cookies with Google Analytics. For more information about how Google Analytics uses cookies, please review the Google Analytics Cookie Guide.

 

• Social Media Cookies. “Social Media Cookies” are set by the third party social media services we have added to the Site. Social Media Cookies enable you to share our content through your social media channels and networks. These cookies are capable of tracking your browser across other sites to build a profile of your interests and may impact the content and messages you see on other websites you visit. If you do not allow these cookies, you may not be able to see or use these sharing tools.

 

• Tags. We use third party JavaScript tags (code elements), to set the Performance Cookies. We manage the tags using Google Tag Manager, which is a tag management tool that integrates with Google Analytics to derive usage statistics and performance analytics.

 
In order to provide the Site, Vale Group may use and share Aggregate Data with third parties. For example, Google Web Tools interact with other Google Inc. products and services in accordance with Google’s Privacy Policy. Please see the section below on “Managing Your Information” for ways to manage how your information is shared via Google Web Tools.

 

Please see below on the circumstances where Vale Group may share your personal information with others without further notice, obligation or liability to you:
 

1. Service Providers: Vale Group may use third party providers to provide or support some of the features or services that are available through the Site, including without limitation, communications and hosting services, network security, technical and user support, tracking and reporting, quality assurance testing, and other functions. Vale Group may share your information with these third party providers so that they can perform their services or complete your requests. These third party providers may share information with us that they obtain from or about you in connection with providing their services or completing your requests. Third party providers may also share this information with their related entities, subsidiaries, joint ventures, or other companies under common control.

 

2. Business Transfers: Vale Group may share your information with its affiliated entities, prospective buyers, partners or joint ventures, in which case Vale Group will require them to honor this Privacy Policy. If another company acquires Vale Group or all or substantially all of its assets (e.g. merger, acquisition or sale), that company will possess the same information, and will assume the rights and obligations with respect to that information as described in this Privacy Policy.

 

3. Investigations: Vale Group may investigate and disclose your personal information if it has a good faith belief that such disclosure (a) is reasonably necessary to comply with legal process and law enforcement instructions and orders, such as a search warrant, subpoena, statute, judicial proceeding, or other legal process served on Vale Group; (b) is helpful to prevent, investigate, or identify possible fraud wrongdoing in connection with the Site; (c) is necessary to act under exigent circumstances to protect the safety of the public or users of the Site, or (d) is reasonably necessary to protect Vale Group’s rights, reputation, property, including that of its users, affiliated entities, partners or the public.

 

4. Links: The Site may contain links to unaffiliated third party services. If you visit any websites through those links, the collection and use of your information will be subject to such third party’s terms and privacy policy. Unless there is a separate basis for sharing your information as expressly set forth in this Privacy Policy, Vale Group will not share your personal information with these third parties and is not responsible for their privacy practices. Vale Group will not be liable for any loss or damage incurred as a result of accessing or using any third party links through the Site.

You may manage your cookies at any time through the cookie settings on the Site. Please note that if you change your settings to opt out of receiving cookies, it will not retroactively delete or remove any previously collected information, but it will prevent your information from being shared through such cookies from that point on.
 

• Within the US. If the Site detects that your IP address is from a location within the United States, you will be prompted to accept or reject cookies when you first visit the platform. If you accept, you accept all of the cookies specified in the “Cookies” section above. If you take no action, you will be  deemed as having accepted the cookies. If you opt out, you will be directed to a settings page where you can select which cookies to opt out of receiving. You cannot, however, opt out of Strictly Necessary Cookies, but you can configure your browser settings to block or alert you about them. If you block Strictly Necessary Cookies, some parts of the Site will have degraded performance or will not work. You can turn off cookies in your browser settings at any time, and delete previously saved cookies and other browsing data by clearing your browsing data and history.  

 

• Outside of the US. If the Site detects that your IP address is from a location outside of the United States, all of the same apply as above, except if you take no action to accept or reject cookies, you will be deemed as having rejected the cookies.

You can manage how your information is shared and used with Google Web Tools as follows:
 

• Google Analytics Opt-out Browser Add-on. Google has developed a browser add-on tool to enable visitors of websites with Google cookies and tags to prevent Google Analytics from receiving their information. This add-on will not prevent websites from collecting information through other first-party or third-party cookies and tags. You can download and install the Google Analytics Opt-out Browser Add-on to begin using this tool.

 

• Google settings. In addition to above, you can manage how Google uses the information obtained through Google Web Tools and other cookies, and how it interacts with other Google products by changing the settings in your Google account. For example, you can restrict personalization features used in Google ads by changing your preference settings in your Google account to prevent use for targeted ads and content. Please review Google’s Privacy Controls for more general information on how you can configure various privacy and share settings through Google.

 

• Third party tools. Third parties have also developed mechanisms for opting out of various cookies that use and share information collected from Google Web Tools and other sources for advertising purposes. For US-based users, the Digital Advertising Alliance (DAA) WebChoices is a tool that enables you to view and manage the cookies used for online advertising. For EU-based users, there is Your Online Choices.

Information collected from the Site will be stored and processed in the United States. If you are located outside of the United States and visit the Site, you permit us to transfer your information outside of your country.
 
Security
Vale Group is committed to protecting the security of your information and follows generally accepted industry standards to protect the personal information it receives. However, no method of transmission over the Internet, devices, or cloud or electronic storage is 100% secure. Therefore, while Vale Group strives to use commercially acceptable means to protect your personal information, Vale Group cannot guarantee its absolute security.
 
Personal Information of Children
Site are intended for a general audience, and Vale Group does not knowingly collect personal information from children under 16. If you become aware that a child has provided Vale Group with personal information without parental consent, please contact us at privacy@vnw.com. If Vale Group becomes aware that a child under 16 has provided personal information without parental consent, Vale Group will take steps to delete such data as soon as possible without notice.
 
California Residents: Your California Privacy Rights
The California Consumer Privacy Act (CCPA) effective as of January 1, 2020 is a law that protects the privacy rights of California residents by putting certain requirements on how businesses collect and use personal information. Vale Group is committed to take the necessary measures to protect your personal information and comply with the CCPA as the specific requirements and application of the rules continue to develop over time. As part of this commitment, the cookie settings are available for you to change your settings any time.
 
European Union (EU) Residents: Your Privacy Rights under the General Data Protection Regulation (GDPR)
If you are located in the EU, we will collect personal information only if Vale Group has one or more legal bases for doing so under the General Data Protection Regulation (GDPR). The legal bases depend on your interaction with the Site. Vale Group will only collect personal information from you where: (i) you have given your consent for one or more specific purposes; (ii) it is necessary to perform a contract we are about to enter into or have entered into with you; (iii) it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests; (iv) it is necessary to protect the vital interests of you or another natural person; or (v) it is necessary to comply with a legal obligation.
 
Data Subject Rights
You can submit a request regarding your personal information through the Data Subject Access Request Form. To submit the form, you must provide certain information such as your first name, last name and email address, your relationship to Vale Group, and details about your request. Vale Group will only use the information you provide to evaluate, process, fulfill or contact you regarding your request (e.g. to follow up or ask for additional details about your request). Vale Group will use commercially reasonable efforts to respond to your request as soon as possible. If the CCPA applies to your personal information, Vale Group will provide an initial response within forty five (45) days of the date you submit your request. If the GDPR applies to your personal information, Vale Group will provide an initial response within one (1) month of your submission date. Please note that if you provide incorrect or insufficient information, Vale Group will not be able to fulfill your request.
 

For any questions about this Privacy Policy, please contact us at privacy@vnw.com.