Data Protection Policy

1. Our Commitment to Data Protection

VIV53 IT Services is committed to protecting your personal data and respecting your privacy rights. This policy explains how we comply with applicable data protection laws, including the General Data Protection Regulation (GDPR), California Consumer Privacy Act (CCPA), and other relevant regulations.

2. Data Controller Information

3. Legal Basis for Processing

We process your personal data based on the following legal grounds:

• Consent: When you provide explicit consent for specific processing activities
• Contract: To perform our contractual obligations or enter into contracts
• Legitimate Interest: For our legitimate business interests, balanced against your rights
• Legal Obligation: To comply with legal requirements and regulations
• Vital Interest: To protect health, safety, or other vital interests

4. Data Subject Rights

Under GDPR and other data protection laws, you have the following rights:

4.1 Right of Access

• Request copies of your personal data
• Understand what data we process and why
• Know who we share your data with

4.2 Right to Rectification

• Correct inaccurate personal data
• Complete incomplete personal data
• Update outdated information

4.3 Right to Erasure ("Right to be Forgotten")

• Request deletion of your personal data
• Withdraw consent for processing
• Object to unlawful processing

4.4 Right to Restrict Processing

• Limit how we use your data
• Contest accuracy of data
• Object to processing while we investigate

4.5 Right to Data Portability

• Receive your data in a structured format
• Transfer data to another service provider
• Export data for your own use

4.6 Right to Object

• Object to processing for legitimate interests
• Opt out of direct marketing
• Object to automated decision-making

5. Data Security Measures

We implement comprehensive security measures to protect your personal data:

5.1 Technical Safeguards

• Encryption: Data encrypted in transit (TLS/SSL) and at rest (AES-256)
• Access Controls: Multi-factor authentication and role-based access
• Firewalls: Network security and intrusion detection systems
• Monitoring: 24/7 security monitoring and logging

5.2 Organizational Safeguards

• Staff Training: Regular data protection training for all employees
• Data Minimization: Collect only necessary data for specified purposes
• Regular Audits: Security assessments and compliance reviews
• Incident Response: Procedures for handling data breaches

6. Data Retention Periods

We retain personal data for different periods based on the type and purpose:

Data Type	Retention Period	Legal Basis
Contact Inquiries	3 years from last contact	Legitimate interest
Service Contracts	7 years after contract end	Legal obligation
Marketing Data	2 years or until withdrawal	Consent
Website Analytics	2 years	Legitimate interest

7. International Data Transfers

When we transfer personal data outside the European Economic Area (EEA), we ensure adequate protection through:

• Adequacy Decisions: Countries recognized by the EU Commission
• Standard Contractual Clauses: EU-approved contract terms
• Binding Corporate Rules: Internal data protection policies
• Certification Schemes: Industry-recognized security standards

8. Data Breach Notification

In the event of a data breach, we will:

• Assess the Risk: Evaluate potential impact on individuals
• Notify Authorities: Report to supervisory authorities within 72 hours
• Inform Individuals: Notify affected persons without undue delay
• Mitigate Impact: Take immediate steps to contain and remedy the breach

9. Children's Data Protection

We take special care to protect children's personal data:

• We do not knowingly collect data from children under 16 without parental consent
• Enhanced security measures for any children's data we may process
• Regular reviews of age verification procedures
• Immediate deletion of improperly collected children's data

10. Automated Decision-Making

We may use automated processing for:

• Website Analytics: Understanding user behavior and preferences
• Security: Detecting and preventing fraudulent activity
• Service Delivery: Optimizing IT service recommendations

You have the right to opt out of automated decision-making that significantly affects you.

11. Exercising Your Rights

To exercise any of your data protection rights:

1. Submit a Request: Contact us using the information below
2. Verify Identity: We may need to confirm your identity
3. Response Time: We will respond within 30 days
4. No Cost: Requests are generally free of charge

12. Complaints and Supervisory Authority

If you believe we have not handled your personal data properly, you can:

• Contact us directly to resolve the issue
• File a complaint with your local data protection authority
• Seek legal remedies through the courts

EU Residents: You can contact your local supervisory authority or the European Data Protection Board (EDPB).

13. Updates to This Policy

We may update this Data Protection Policy to reflect changes in laws, regulations, or our practices. Significant changes will be communicated through:

• Website notification and updated "Last updated" date
• Email notification for substantial changes
• Prominent website banner for material modifications

14. Contact Information

For questions about data protection or to exercise your rights: