1. Scope and applicability
This Notice applies to California residents whose personal information VSPO collects for its own website, client-prospect, recruitment, employment, Academy, social-impact, marketing, feedback, account, security, and governance purposes. It does not change a client’s responsibilities for information VSPO processes only as the client’s service provider or contractor.
The CCPA applies only when its statutory requirements are met. VSPO’s publication of this Notice does not concede that VSPO meets every coverage threshold in every period. Where the CCPA does not legally apply, VSPO may still route a reasonable privacy request under its general Privacy Policy, subject to identity, security, law, contract, technical feasibility, and the rights of others.
Terms such as “personal information,” “consumer,” “business,” “service provider,” “contractor,” “sell,” “share,” and “sensitive personal information” have the meanings given by California law.
2. Notice at collection
In the preceding 12 months, VSPO may have collected the categories below for the stated business or commercial purposes. The exact data depends on the person’s relationship and chosen feature. VSPO does not use every example in a statutory category.
| California category | VSPO examples | Sources | Purposes | Categories disclosed for a business purpose | Sold or shared |
|---|---|---|---|---|---|
| Identifiers | Name, email, phone, country, account and internal references, IP address, sign-in attributes. | You; identity provider; authorized personnel; clients or partners when lawful; systems and providers. | Authentication, communication, routing, relationship and records administration, security. | Hosting, identity, communications, support, security, advisers, relevant clients/partners, authorities when required. | No |
| California customer-record information | Contact, employment, education, service, billing, account, and relationship information. Public forms prohibit full payment credentials and unnecessary government IDs. | You; your organization; authorized sources. | Requested service, contract, learning, employment, support, finance, legal compliance. | Providers and authorized recipients needed for the applicable workflow. | No |
| Commercial information | Services considered or purchased, quote details, work scope, volumes, preferences, account and transaction history. | You; your organization; VSPO service and finance records. | Discovery, quoting, contracting, service delivery, support, invoicing, relationship improvement. | Client-service, finance, payment, accounting, hosting, and professional-adviser categories. | No |
| Internet or electronic activity | Device/browser attributes, page and feature use, session, authentication, permission, error, security, and audit events. | Browser/device; identity, hosting, application, database, and security services. | Deliver, secure, troubleshoot, audit, and improve the Site; enforce access. | Hosting, identity, infrastructure, security, support, and legal/audit recipients. | No |
| Geolocation | Approximate region inferred from IP where a provider makes it available; country or location supplied by you. The Site does not intentionally collect precise geolocation. | You; network or security provider. | Security, fraud prevention, time-zone and service coordination. | Hosting, identity, security, and authorized service teams. | No |
| Audio, electronic, visual, or similar information | Approved corporate photo, media consent record, interview or training recording only when separately disclosed, uploaded evidence. | You; authorized VSPO activity or provider. | Identity, training, quality, accessibility, portfolio or communications with separate controls. | Approved hosting, media, learning, quality, client, or public recipients within the stated permission. | No |
| Professional or employment information | Employer, title, role, experience, availability, CV, assessment, interview, work status, assignments, manager, training, and performance-related records. | You; employers/clients; referees; authorized recruiters/managers; verification providers where permitted. | Recruitment, employment, workforce planning, client delivery, access, training, quality, legal duties. | Authorized HR, managers, clients where applicable, providers, advisers, and authorities. | No |
| Education information | Course, cohort, experience, goals, attendance, assessments, completion, funding, support, and credentials. | You; trainers; sponsors; learning and assessment systems. | Eligibility, learning delivery, support, assessment, credentials, programme improvement, funding. | Learning providers, trainers, sponsors or clients within approved scope, advisers, authorities. | No |
| Inferences | Service fit, workflow status, role or course alignment, risk or quality flags based on submitted and operational information. No sensitive-trait marketing profile is intended. | Information described above and authorized human review. | Route work, support human review, improve quality, manage risk and capacity. | Authorized teams and providers supporting the relevant process. | No |
| Sensitive personal information | Account credentials held by the identity provider; limited accommodation, emergency, verification, complaint, incident, or legally required data when specifically requested. Do not submit sensitive data through general forms. | You; authorized high-control sources and providers. | Authentication, security, accommodation, safety, legal compliance, investigation, or claims. | Only restricted personnel and providers necessary for the disclosed purpose or law. | No |
Retention is based on the relationship or request lifecycle; the stated purpose; legal, contractual, tax, employment, safety, audit, complaint, dispute, and claims needs; consent status; security risk; legal holds; and the approved Website Records Retention Schedule. VSPO does not retain a category longer than reasonably necessary for the disclosed purpose.
3. Sensitive personal information
VSPO does not use or disclose sensitive personal information to infer characteristics about a California resident or for purposes outside those permitted by law without giving any required right to limit. Ordinary forms prohibit full financial credentials, government IDs, health records, passwords, live client data, and unrelated sensitive content.
If a relationship requires sensitive information, VSPO should provide a specific notice and secure route, limit access, verify authority, use only what is necessary, and delete verification copies when no longer needed. If VSPO begins using sensitive information beyond permitted purposes, it will update this Notice and provide the required “Limit the Use of My Sensitive Personal Information” method before that use.
4. Sale, sharing, advertising, and Global Privacy Control
VSPO does not sell personal information for money or other valuable consideration and does not share personal information for cross-context behavioral advertising. The current Site does not activate advertising pixels or non-essential advertising cookies. Therefore, VSPO does not currently display a “Do Not Sell or Share My Personal Information” link.
VSPO does not use a financial incentive or loyalty programme based on the collection, sale, or sharing of personal information. If these practices change, VSPO must update this Notice, provide the required links or mechanisms, and honor valid opt-out preference signals before the new practice begins.
When California law applies, VSPO will treat a valid, technically received Global Privacy Control signal as an opt-out request for the browser or device to the extent relevant. Because the current Site does not sell or share personal information, no sale/sharing state should be active to change.
5. California privacy rights
Subject to eligibility, verification, exceptions, and applicable law, a California resident may have the right to:
- Know and access: request categories and specific pieces of personal information, sources, purposes, categories of recipients, and sale, sharing, or business-purpose disclosures.
- Delete: request deletion of personal information collected from the resident, subject to lawful exceptions.
- Correct: request correction of inaccurate personal information.
- Data portability: receive eligible information in a portable and, where technically feasible, readily usable format.
- Opt out of sale or sharing: direct a covered business not to sell or share personal information. VSPO states that it does not currently do so.
- Limit sensitive information: limit certain uses or disclosures outside permitted purposes. VSPO states that it does not currently use sensitive information in a manner that triggers this right.
- Non-discrimination: exercise rights without unlawful discrimination or retaliation.
- Information about automated decisionmaking: receive disclosures or exercise rights where current California law and regulations apply to a covered use.
6. How to submit a request
Use either of these methods:
- Submit the privacy or data-rights request form and select the relevant right in the subject and message.
- Email privacy@virtualsupportplusoutsourcing.net with the subject “California privacy request.”
Describe your relationship with VSPO, the right you want to exercise, the relevant account, application, course, client, activity, or date range, and a safe contact method. Do not include passwords, access codes, full government IDs, or unrelated sensitive data. These methods are also available in an accessible format; request an accommodation through the Contact page.
7. Verification and authorized agents
VSPO will use a reasonable verification method based on the request, sensitivity, relationship, risk, and available records. It may confirm through an authenticated account, a previously verified email or telephone channel, a known reference, or limited additional evidence. VSPO will not demand a full government ID by default.
An authorized agent may submit a request. VSPO may require signed authority and may verify the resident directly unless law provides another method. For a parent, guardian, executor, or person acting under legal authority, VSPO will request evidence proportionate to the role and request. Verification data is restricted and removed when no longer needed, except for minimal evidence that the request was handled properly.
VSPO may deny or limit a request it cannot reasonably verify, but will explain the result and allow additional information where appropriate. Information about another person, privilege, trade secrets, investigation integrity, security details, and records subject to lawful retention may be redacted, restricted, or withheld as allowed by law.
8. Response timing and appeals
For covered requests to know, access, delete, or correct, VSPO will aim to confirm receipt within 10 business days and respond within 45 calendar days. Where allowed, it may extend by up to another 45 days after giving notice and explaining the reason. Opt-out and limitation requests, if they become relevant, will be handled within the period required by current law.
Requests are ordinarily free. A fee or refusal for a manifestly unfounded, excessive, or repetitive request requires documented legal and privacy review. If you disagree with the result, reply to the response or submit a new request asking for Data Protection Officer or management review. You may also contact the California Privacy Protection Agency or California Attorney General.
9. Minors
The general Site is not directed to children under 13. VSPO does not knowingly sell or share the personal information of residents under 16. If a future feature involves a practice requiring opt-in consent for a minor, VSPO must implement age-appropriate notice, verified authorization, withdrawal, safeguarding, and data-minimization controls before the practice begins.
10. Applicants, workers, and business contacts
Where the CCPA applies, this Notice includes California applicants, current and former workers, contractors, emergency contacts, beneficiaries, and business-to-business contacts. VSPO may process professional, employment, payroll/benefit, access, performance, safety, complaint, investigation, training, and offboarding records for employment administration, legal duties, security, workplace management, service delivery, and claims.
Employment-related rights may be limited by legal obligations, privilege, another person’s rights, security, investigations, or records needed to establish, exercise, or defend claims. A privacy request will not by itself change a recruitment or employment decision, except to correct verified information or enforce a lawful right.
11. Changes and official sources
VSPO will review this Notice at least annually and after a material change to categories, purposes, sale or sharing, sensitive-information use, automated decisionmaking, request methods, or law. The revision date appears at the top. Material changes will receive appropriate notice before the new practice begins.
This Notice is informed by the California Privacy Protection Agency consumer guidance, the California Attorney General CCPA page, and the current CPPA regulations. Official law and regulations control if this summary conflicts with them.
Controlled completion items: VSPO must confirm each year whether it meets CCPA coverage thresholds, approve the California request workflow, train request handlers, document category and recipient mapping, test verification and deletion/correction, and obtain Legal/DPO approval. Publication provides a route for requests but is not a substitute for that governance evidence.
