VALUE MANAGEMENT ADVISORS, INC.
PRIVACY POLICY

Summary
The primary business activities of Value Management Advisors, Inc. (“VMA”) are business- to-business advisory. We provide pricing and product strategy advice to other businesses. In operating our business, we collect personal information from individuals who visit our website and who provide their information to us as part of learning about or interacting with our company. The categories of information we collect may include names, email addresses, telephone numbers, company affiliations, job titles, and other information provided to us. We use this Personal Information primarily to communicate with individuals interested in our company. We DO NOT sell consumer personal information to anyone.
1. Policy Scope
This Privacy Policy (“Privacy Policy” or “Policy”) applies to Value Management Advisors, Inc. and its website (“VMA,” “we,” “us,” or “Company”). It governs and explains how we collect and use Personal Information from all individuals (“you” “customer(s),” “consumer(s),” “user(s)”) who visit our website, connect with us via our website, email, or over the telephone, or who otherwise provide their information to us (our “Services”). This Policy applies to all consumers, regardless of where you live.
We understand and use the term “Personal Information” or “Personal Data” to mean information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual. By use of our Services, you are consenting, agreeing, and directing us to collect and use your Personal Information in accordance with this Policy.
If you have questions or concerns regarding this Policy, you should contact us at info@valuemanagementadvisors.com
2. Categories of Personal Information We Collect
In operating our business, we collect User Information. “User Information” refers to information collected about individuals who use our Services and voluntarily provide their information when making an inquiry through our website, emailing us, or contacting us on the telephone. The categories of information we collect may include your name, email address, professional title, company, country, or telephone number. We collect User Information only when individuals voluntarily provide it to us.
We do not collect “sensitive Personal Information” (also known as “special categories”) through our website or otherwise. The term sensitive Personal Information refers to the various categories of personal data identified by certain data privacy laws as requiring special treatment, which may include personal identity numbers, financial account information, gender, race, ethnicity, or national origin, political opinions or affiliations, religious, philosophical or other similar beliefs, membership of a trade union or profession or trade association, physical or mental health, biometric or genetic data, sexual life, or criminal record (including information about suspected criminal activities).
3. How We Collect Personal Information
For individuals who contact us through our website, email, or on the telephone, we will collect whatever information you provide through the medium you use to communicate with us.
We do not collect data from Third Parties.
4. How We Use Personal Information
We use your Personal Information for purposes that we believe to be consistent with your expectations when you interact with us and our Services, including:
• To communicate with you. If you contact us, we will use your email address and other information you provide to us to communicate with you. We may retain your contact and information and copies of our communications for our records.
• To provide announcements and marketing. We may use your name and contact information to provide you with news and other information about our business. You may elect to opt-out of these communications by clicking an unsubscribe link, responding unsubscribe, or placing a check mark beside a statement stating you do not want to receive these communications or to participate in these activities.
• To otherwise provide Services. We use your Personal Information to provide and manage the Services, communicate with you about our Services, and fulfill any contractual obligations we otherwise have with you. In addition, we use your Personal Information to support your use of the Services and to ensure the quality and security of the Services.
• To promote security and appropriate use. We hope everyone who uses our website will do so appropriately and with respect for our community. But we realize that not all online activity is beneficial. Therefore, we will use Personal Information to protect, investigate, and deter against fraudulent, unauthorized, or illegal activity relating to our Services and generally safeguard and maintain the security of our website and business.
• To meet legal requirements. We may be required to use or disclose your Personal Information when necessary to comply with legally mandated reporting, subpoenas, court orders, or other legal process requirements.
• Other purposes. We may use your information for any other legal, business or marketing purposes that are compatible with this Policy.
5. How We Share Personal Information
We DO NOT sell your Personal Information to anyone.
Transfer or Assignment in Connection with Business Transfers or Bankruptcy. In the event of a business transition, such as a merger, acquisition, reorganization, bankruptcy or other sale of all or a portion of our assets, any information owned or controlled by us may be one of the assets transferred to third parties. We shall provide notice of such a business transition via prominent notice on our website. We reserve the right, as part of this type of transaction, to transfer or assign your information and other information we have collected from customers and users of the Services to third parties. Other than to the extent ordered by a bankruptcy or other court, or as otherwise agreed to by you, the use and disclosure of all transferred information will be subject to this Policy. However, any information you submit or that is collected after this type of transfer may be subject to a new privacy policy adopted by the successor entity in compliance with applicable laws and regulations.
Legal Requirements. We may be required to use or discloses your personal information when necessary to comply with legally mandated reporting, subpoenas, court orders, or other legal process requirements.
With Your Consent. We may share some of your information with a third party with your affirmative consent. For example, this would be the case if we were to refer you to another service provider.
6. Right to Access Your Information
Under our Policy, you have a right to access the information we have collected during the last 12 months. Specifically, you have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request (see Exercising User Rights, below), we will disclose to you:
• The categories of Personal Information we collected about you.
• The categories of sources for the Personal Information we collected about you.
• Our business or commercial purpose for collecting or selling that Personal Information.
• The categories of other businesses or persons with whom we share that personal information.
• The specific pieces of Personal Information we collected about you.
• If we disclosed your Personal Information for a business purpose, the Personal Information categories that each category of recipient obtained.
7. Right to Request Deletion
Under our Policy, you have the right to request that we delete any of your Personal Information that we collected from you, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising User Rights, below), we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for to:
• Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
• Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
• Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
• Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
• Comply with a legal obligation.
• Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
8. Correcting and Updating Personal Information
You can always contact us to request that we change your Personal Information if you believe the Personal Information we have for you is incorrect. We will review your request but may be restricted in our ability to change your Personal Information.
9. Rights for EEA Citizens
In addition to your rights under this Policy, depending on your residency, you may have certain rights that you may exercise in relation to your Personal Information, subject to applicable lawful exemptions. Where the EU General Data Protection Regulation (“GDPR”) applies, your rights consist of:
1. The right to be informed;
2. The right of access;
3. The right to rectification;
4. The right to erasure;
5. The right to restrict processing;
6. The right to data portability;
7. The right to object; and
8. The rights in relation to automated decision making and profiling.
You may also have a right to lodge a complaint with a supervisory authority or other regulatory agency if you believe that we have violated any of the rights concerning personal data about you. We encourage you to first reach out to us, so we have an opportunity to address your concerns directly before you do so. You may also contact us with your Personal Information inquiries or for assistance in modifying or updating your Personal Information and to exercise your rights. Our contact details are provided below.
10. Exercising User Rights
To exercise the rights described above, please submit a verifiable consumer request to us by one of the following methods:
• Emailing us at info@valuemanagementadvisors.com, or;
• Submitting a request through our Contact Us form on our website.
Only you, or, if you are a California resident, a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. You may only make a verifiable consumer request for access or data portability twice within a 12-month period.
To verify the identity of an individual making a request, a two-step process will need to be completed. A verifiable consumer request must:
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
• Separately provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.
Making a verifiable consumer request does not require you to create an account with us. We will use Personal Information provided in a verifiable consumer request only to verify the requestor’s identity or authority to make the request.
11. Response Timing and Format
We will endeavor to provide an initial response to a verifiable user request within 10 days of receipt and will attempt to fulfill a verifiable user request within 45 days of its receipt (30 days if you are a resident of a country in the European Union, European Economic Area, or United Kingdom). If we require more time, we will inform you of the reason and extension period in writing.
We will deliver our written response by mail or electronically, at your option.
Any disclosures we provide will cover only the 12-month period preceding our receipt of a verifiable user request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily usable and should allow you to transmit the information from one entity to another entity without hindrance.
12. Non-Discrimination
We will not discriminate against anyone for exercising any of their rights under this Policy or any applicable information privacy or data protection law. Unless otherwise permitted, we will not:
• Deny you goods or services;
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties;
• Provide you a different level or quality of goods or services; or
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
13. Opt-Out & Unsubscribe
We respect your privacy and give you an opportunity to opt-out of receiving announcements of certain information. Users may opt-out of receiving any or all communications from VMA by:
• Emailing us at info@valuemanagementadvisors.com, or;
• Submitting a request through our Contact Us form on our website.
14. Personal Information of Minors Under 18
VMA does not knowingly collect personally identifiable information from children under the age of eighteen. If you think we have collected Personal Information from a minor under 18 years of age for whom you are the parent or guardian, please contact us at the notice address provided below.
15. Security
We maintain administrative, physical, and technical safeguards to reasonably and appropriately protect the confidentiality, availability, and integrity of your Personal Information. Our employees receive training on our security practices and obligations. Only authorized employees and contractors have access to any personal information provided by you, and that access is limited by need. Each employee or contractor having access to any personal information is obligated to maintain its confidentiality. While we strive to safeguard your Personal Information, we cannot completely ensure the privacy of certain communications such as email to and from us because they are not encrypted. Given the nature of the internet and the fact that network security measures are not infallible, we cannot guarantee the security of your Personal Information. In the event we become aware of a data security breach, we will provide you with notice as required by applicable federal, provincial and state laws.
16. Cookies and Other Tracking Technologies
VMA does not use cookies or other tracking technologies on our website or in our communications with you.
17. Changes to Our Policy
If we change this Policy, we will post the updated Policy and its effective date on our website, and such updates will be accessible through the app.
If the Privacy Policy changes materially so that we are going to use your Personal Information in a manner different from that stated at the time of collection, we will notify you by either sending you an email to an address provided to us, through the app, or in a notice on our website’s main page. We reserve the right to make the changes to the Privacy Policy applicable to all previously collected Personal Information.
18. Contact Information – Questions, Accessing, Correcting and Updating your Personal Information, Marketing
Please contact us if you:
• Have a query or concern about this Privacy Policy or our Personal Information handling processes;
• Wish to make a complaint about our activities;
• Would like to access your Personal Information held by us;
• Would like to opt out of marketing emails; or
• Would like to correct your Personal Information held by us,
We will promptly investigate and respond.