The Virtue System is the property of Virtue Therapy and Research is a limited liability company registered in Dubai International Financial Centre (DIFC), Dubai, UAE, with registration number CL6339 (“Virtue”) and its licensors. These terms of service (the “Terms of Service”) apply to your use of the Virtue System along with all associated apps and sites linked to the Virtue System by Virtue, its subsidiaries and affiliates (collectively, “Virtue System”, “we”, “us” or “our”). By accessing and using the Virtue System, you agree to these Terms of Service; if you do not agree, do not use the Virtue System.
Virtue reserves the right, at its sole discretion, to change, modify, add or remove portions of these Terms of Service, at any time. It is your responsibility to check these Terms of Service periodically for changes. Your continued use of Virtue System following the posting of changes will constitute your express consent to the changes to these Terms of Service. As long as you comply with these Terms of Service, Virtue grants you a personal, non-exclusive, non-transferable, limited privilege to enter and use the Virtue System, subject to the terms and conditions of the respective sellers.
Nothing in these Terms of Service affects your statutory rights, either as a consumer of services or otherwise.
At VirtuE we are committed to the responsible use of technology and ethical data processing.
VirtuE enables you to manage personalised experiences based on the psychological profiles and emotions of your end users. This is done by creating psychological profiles on the spot while complying with all applicable privacy regulations.
VirtuE provides its services on a user-entity basis: end-users’ individualised information is processed without ever identifying them. Anonymisation techniques consist of the encryption and tokenisation of data that can identify those end users. VirtuE only knows that each identity is unique and that the associated information belongs to a different individual, but it does not know who that individual is.
This means that no personal data enters VirtuE systems before undergoing an anonymisation process and that VirtuE does not process any personal data derived from the provision of its services. Only you, as a VirtuE’s client, can access and process the personal data of your end users, being able to identify the individual behind each end-user entity.
All information provided to VirtuE is subject to strong confidentiality agreements that are signed before the start of the provision of any services. These confidentiality agreements protects you from any non-consensual disclosure of sensitive information.
From the beginning of the provision of services and from your first contact with end users through VirtuE, no data that could identify an end user is ever processed. All information collected and managed by VirtuE is previously anonymised according to the principles explained in question #2.
The techniques used are robust and reliable enough to avoid re-identification. State-of-the-art security measures are applied to prevent unauthorised access to information and ensure that the anonymisation process remains reliable throughout VirtuE's Information management process.
You, as VirtuE’s client, are solely responsible for complying with the obligations derived from the data protection regulations that may apply to you and for analysing to what extent these regulations affect you according to the country in which you provide your services to your end users.
When processing end-user data through VirtuE technology, you must consider whether it will comply with the reporting obligations established by the applicable data protection regulations (in Europe, the General Data Protection Regulation ), as well as obtain the end-user’s consent to process their psychological profile data to generate personalised experiences.
Information obligations may include:
No, VirtuE does not process any personal data. All data that VirtuE has access to is previously anonymised in accordance with European privacy standards, even when using VirtuE's white-label front-end. This does not imply that you, as a VirtuE’s client, stop processing personal data.
The activity carried out by VirtuE has no implications for the processing of personal data. All processed information is previously anonymised. However, once anonymised information is processed in our systems, the customer receives a result that may contain behavioral patterns, personal data that reveals the physical or psychological characteristics of an individual, and data that may be classified as sensitive.
As a VirtuE’s client, you must ensure that you obtain and manage this personal data legally and in accordance with the data protection regulations of the country in which you provide your services to your users.
The Client and Tenant Relationship Under the VirtuE System
Certain features or Products offered on or through the Virtue System may require you to open an account (including setting up a Virtue ID and verifying your one-time password (“OTP”)).
Virtue may terminate or suspend your access to all or part of the Virtue System, without Court order and without prior notice, if it believes that your conduct is in violation of these Terms of Service, applicable law, or otherwise harmful to the interests of the Virtue or any third party. Notwithstanding, such termination or suspension, you agree that you will continue to be subject to the obligations which, by their nature, survive such termination or suspension.
Additional terms and conditions apply to purchases of Products and to specific portions or features of the Virtue System, including promotions or other similar features, all of which terms are made a part of these Terms of Service by this reference. You agree to abide by such other terms and conditions, including where applicable representing that you are of sufficient legal age to use or participate in such service or feature. If there is a conflict between these Terms of Service and the terms posted for or applicable to a specific portion of the Virtue System or for any service offered on or through the Virtue System, the latter terms shall control with respect to your use of that portion of the Virtue System or the specific service.
The Virtue System may contain links to other independent third-party apps and websites (“Linked Sites”). These Linked Sites are provided solely as a convenience to our visitors. Such Linked Sites are not under Virtue’ control, and Virtue is not responsible for and does not endorse the content of such Linked Sites, including any information or materials contained on such Linked Sites. You will need to make your own independent judgement regarding your interaction with these Linked Sites.
Virtue does not promise that the Virtue System or any Content, service, product or feature of the Virtue System will be error-free or uninterrupted, or that any defects will be corrected, or that your use of the Virtue System will provide specific results. The Virtue System and its Content are delivered on an “as-is” and “as-available” basis. All information provided on the Virtue System is subject to change without notice. Virtue cannot ensure that any files or other data you download from the Virtue System will be free of viruses or contamination or destructive features. To the extent permitted by law Virtue disclaims all warranties, express or implied, including any warranties of accuracy, non-infringement, merchantability and fitness for a particular purpose.
You agree to hold harmless and indemnify Virtue, its parents, subsidiaries, affiliates, and their respective suppliers, and any of their owners, officers, directors, managers, members, agents, and employees, from and against any claims, liabilities, suits, judgments, litigation costs, causes of action, demands, recoveries, losses, damages (actual and consequential), fines, penalties, and attorneys’ fees or other costs or expenses of any kind or nature arising from or in any way related to your use of the Virtue System, including, but not limited to those brought by you or on your behalf in excess of the liability described above, or by third parties as a result of your breach of these Terms of Service, your violation of any law or the rights of a third party, or your use of the Virtue System.
These Terms of Service (as amended from time to time in accordance with its terms) and Privacy Policy sets out the entire understanding and agreement between you and Virtue with respect to the use of the Virtue System.
To fulfil our obligations to you under these Terms of Service, we may wish to communicate with you by email and/or by posting notices on the Virtue System. You agree to receive communications from us electronically and these electronic communications will satisfy any legal requirement for communications which need to be in writing.
These Terms of Service shall be governed by the laws of Dubai International Financial Center (“DIFC”). Any dispute regarding these Terms of Service shall be subject to the exclusive jurisdiction of the Courts in DIFC. If any portion of these Terms of Service is held to be unenforceable, invalid or illegal by any court of competent jurisdiction, the remainder of the Terms of Service shall not be affected.
We reserve the right to change or correct any errors or omissions on the Virtue System, and to alter, limit or discontinue the provision of any of the services provided through Virtue System at any time without prior notice to you. Virtue will use reasonable efforts to include up-to-date and accurate information on Virtue System, but it reserves the right to delete, modify, or supplement the content of the Virtue System at any time for any reason without prior notification.
We’re here for you! If you’ve got a question you’d like us to answer, contact us.
We and our Clients and/or licensors may make available various information, descriptions, reviews, and other information, data, content, and materials on the Platform related to the Services (“Materials”). The Materials are for educational and informational purposes only, and errors may appear from time to time. Before you act in reliance of any Materials, you should confirm any facts that are important to your decision. We make no warranty as to the reliability, accuracy, timeliness, usefulness, or completeness of any Materials. If you find an error or notice something that does not look quite right on the Platform, we would appreciate it if you let us know by submitting this form.
The Platform is provided on an “as is” and “as available” basis. Virtue, its parents, subsidiaries, affiliates, and their respective suppliers, and any of their owners, officers, directors, managers, members, agents, and employees, expressly disclaim (to the fullest extent permitted by applicable law) any and all express, implied, and statutory warranties, including, without limitation, any warranties of merchantability, fitness for a particular purpose, freedom from computer, mobile or internet device virus, title, and non-infringement of proprietary rights.
You agree to hold harmless and indemnify Virtue, its parents, subsidiaries, affiliates, and any of their owners, officers, directors, managers, members, agents, and employees, from and against any claims, liabilities, suits, judgments, litigation costs, causes of action, demands, recoveries, losses, damages (actual and consequential), fines, penalties, and attorneys’ fees or other costs or expenses of any kind or nature arising from or in any way related to your use of the Platform, including, but not limited to those brought by you or on your behalf in excess of the liability described above, or by third parties as a result of your breach of these Terms, your violation of any law or the rights of a third party, or your use of the Platform.
These Terms, as supplemented by any additional documents referred to in them and any policies or rules posted on the Platform (including any amendments made from time to time as contemplated by these Terms) sets out the entire understanding and agreement between you and Virtue with respect to the use of the Platform and our Services.
If we believe that your conduct is in violation of these Terms, applicable law, or otherwise harmful to the interests of Virtue or any third party, we may terminate or suspend your access to all or part of the Platform, without Court order and without prior notice. Notwithstanding, such termination or suspension, you agree that you will continue to be subject to the obligations which, by their nature, survive such termination or suspension, including the obligations relating to intellectual property rights.
We reserve the right to change or correct any errors or omissions on the Platform, and to alter, limit or discontinue the provision of any of the services provided through the Platform at any time without prior notice to you.
To fulfil our obligations to you under these Terms, we may wish to communicate with you by email. Other electronic messaging and/or by posting notices on the Platform. You agree to receive communications from us electronically and these electronic communications will satisfy any legal requirement for communications which need to be in writing.
VirtuE's solution requires User management to grant Customer and Tenant users portal access with an email address and password. As users log in, the VirtuE Portal hashes the password entry and compares it to the hashes in the VirtuE databases. The hashing process cannot be reverted.
Creating users in this way is intended to gain the privilege of managing configurations, viewing dashboards, and generating reports. VirtuE does not require data collection for portal users since this type of user accesses the Portal acting as an Administration Panel. Therefore, even if there is a way to identify the user by their emails and names, VirtuE does not hold any personal information as part of the EDAA™ processes.
Some interactions within the VirtuE solution require users’ Biometric data as part of EDAA™'s recognition processes.
When capturing any Biometric Data (including face recognition), the Interaction module prompts the user to allow VirtuE to capture or record that data using the user’s device. Then, the captured or recorded biometric data is encrypted using AES 128 bit directly on the user’s device and transmitted to any server or computing instance. The Encryption key must be random, 128-bit (16 characters) in length, and built as a combination of numbers, alphabets, and symbols. This encryption key is stored on the user’s device, so VirtuE or the Client/Tenant’s party will never be able to decrypt their Biometric Data if the user is not online or interacting with the VirtuE system.
Since with each interaction we will attach the key to decrypt in real-time (online training), during the process we will be able to decrypt the Biometric Data and return the result of the interaction, if any, to the user.
When a user logs in through the front-end, the interactions module decrypts their information to start with the personalised interaction based on the client's encryption key. Then, the VirtuE system requires the user to allow data capturing via the anonymising protocol. The VirtuE system deletes the captured data or re-encrypts it and waits for the end user to log in again, allowing them to use their data during their session at their convenience and with privacy.
The data protection approach is divided into multiple layers to increase the difficulty of breaking through. To connect and begin using the VirtuE system, you must receive secure keys to authenticate your requests. Keys are limited to a particular data set and cannot be used to access the entire system.
VirtuE's computing and storage models are separate—the backend is restricted to the use of internal instances.
Throughout the processing lifecycle of the system, models will be securely stored on decentralised storage units, such as managed blockchains, which will only be accessible by the chain owner (end user) by providing the key to decrypt it. If an attack occurs, attackers will be able to reach only one block of this blockchain, granting them access to minimal information, which will be useless since it is completely anonymized.
Our foundational multi-model prioritises the interest of end users and identifies their individual needs as the artificial intelligence learns through continuous generative iterations. To generate real-time responses fully adapted to the psychological profile of each end user, EDAA only uses the end user’s psychological profile and any input that they enter into the system. Since no predictive models built with big data are involved in data processing, potential unconscious biases are prevented and user engagement increases, leading to an exceptional user experience.
Although Virtue is not subject to the European GDPR (the “Regulation”), we have considered including the following observations based on what is indicated in this Regulation, as it is one of the most thorough for those companies developing a solution on top of Virtue’s infrastructure. The GDPR sets out the following principles in connection with the processing of personal data:
For the purposes of the applicable data protection laws, which include the DIFC’s Data Protection Law (DIFC Law No. 5 of 2020) ("DPL") and the European Union’s General Data Protection Regulations (EU general data protection regulation 2016/679) (“GDPR”), the ‘data controller’ processing your personal data is:
Virtue Therapy and Research, a company incorporated in the DIFC, United Arab Emirates under license number CL6339 LTD, whose registered office is at Gate District Precinct Building 04, Dubai International Financial Centre, Dubai, United Arab Emirates.
Virtue has appointed a Privacy Officer who will respond to any queries, requests or clarifications regarding the processing of personal data that may be made at the postal address indicated at the beginning of this document and or by submitting this form.
The personal data processed will be those that you provide to us through the various channels that Virtue makes available to you. For example, when you use the Virtue services or create a new user for the use of these services.
Depending on the relationship maintained with Virtue, we will process your personal data for the following purposes, indicating which data will be processed (type of data) and for what reason or on what basis (legal basis).
This list has been compiled considering that the data processing carried out corresponds to data subjects related to web users, social networks, web, and corporate contacts.
We may also process any additional data that you provide to us or that is generated during your relationship with Virtue for the purposes described above.
| REQUESTS, QUERIES, COMPLAINTS | ||
|---|---|---|
| TYPE OF DATA | PURPOSE | LEGAL BASIS |
The data requested in each personal data collection form and at least the following:
| To deal with requests, queries or complaints through the sections and contact forms on the Site or through other channels such as e-mail for general information about the Website. | This data processing activity is based on the contractual or pre-contractual relationship with the user and Virtue by offering the client enquiry service. |
| LEGAL OBLIGATIONS | ||
| TYPE OF DATA | PURPOSE | LEGAL BASIS |
| Any personal data that you provide to us and that is generated during the relationship. | Compliance with our civil, commercial, tax and accounting legal obligations, as well as those relating to compliance with personal data protection regulations, among others that may be applicable. | Compliance with a legal obligation. |
| CORPORATE CONTACTS OF VIRTUE | ||
| TYPE OF DATA | PURPOSE | LEGAL BASIS |
| Maintaining relations of any kind with the company, entity or organisation for which you work or collaborate, or with you if you are an independent professional, when you contact Virtue through the Website or any form, communication channel or email inbox. Even through the delivery of business cards to Virtue staff. | Virtue’s legitimate interest derived from contact with data subjects for corporate purposes, which is expressly recognised by privacy regulations. Virtue has carried out the analyses required by privacy regulations, which confirm that Virtue’s interests prevail over the privacy rights of its customers and users. If you wish to access these reports, you may request them at the email addresses indicated in the Your Rights section of this Privacy Policy. |
| JOB APPLICATIONS | ||
| TYPE OF DATA | PURPOSE | LEGAL BASIS |
The data deposited by data subjects in the entry channel of the Website, as well as other data that may be made available to them and as a minimum:
| To deal with incoming applications for employment through the Website and to carry out the relevant actions to process the application and proceed with the assessment of your suitability to join Virtue. | The processing of your personal data is legitimate because it is necessary for the implementation of pre-contractual measures at your request or because you intend to conclude a contract. |
| STATISTICAL STUDIES | ||
| TYPE OF DATA | PURPOSE | LEGAL BASIS |
| To carry out statistical studies on the use of the Website, and the reception of Virtue products and services. | Virtue’s legitimate interest in improving its functionalities and the service provided. Virtue has carried out the analyses required by privacy regulations, which confirm that Virtue’s interests prevail over the privacy rights of its customers and users. If you wish to access these reports, you may request them at the email addresses indicated in the Your Rights section of this Privacy Policy. |
| SENDING OF COMMERCIAL COMMUNICATIONS | ||
| TYPE OF DATA | PURPOSE | LEGAL BASIS |
| Sending commercial communications, including by electronic means, such as SMS and push notifications, about Virtue products, services, activities, news, offers and promotions. Virtue contracts email marketing services with third-party providers to collect information about campaigns, i.e., to track email opens and clicks on the content or links included in emails. This information is collected to prepare statistical reports on the behaviour of the recipients to optimise the campaign. | Virtue’s legitimate interest in improving its functionalities and the service provided. Virtue has carried out the analyses required by privacy regulations, which confirm that Virtue’s interests prevail over the privacy rights of its customers and users. If you wish to access these reports, you may request them at the email addresses indicated in the Your Rights section of this Privacy Policy. |
| REGISTRATION/SUBSCRIPTION TO VIRTUE OFFICIAL USER PAGES AND PROFILES ON SOCIAL NETWORKS | ||
| Virtue has active profiles on different social networks, the following processing of personal data applies to individuals who become data subjects of Virtue by being a member, following or being part of these profiles: | ||
| TYPE OF DATA | PURPOSE | LEGAL BASIS |
| The personal data permitted by the privacy policy of the social network in which you have an account/user profile, as well as the privacy settings you have as a user of that social network. This data depends on your own privacy settings of the social network and the privacy policy of that social network. | Interaction of your profile on the relevant social network with Virtue, including responding to queries or comments posted on public profiles. | Virtue will carry out this processing of personal data in compliance with the obligations arising from your status as a registered user of the social network and the terms of use of that social network. |
We will store your personal data for as long as it is necessary for the purposes for which it has been collected, and to comply with legal, financial, business or reporting requirements. In some circumstances, we may anonymize personal data so that it is no longer identifiable, and we may continue to use it. When we no longer need the personal data, we will securely delete or destroy it.
Virtue will store the data collected for the above purposes for the duration of your relationship with Virtue and thereafter until any legal liability arising from that relationship expires.
Virtue does not make decisions that may affect you based solely on the automated processing of your personal data. All decision-making processes related to the purposes of processing described above are carried out with human intervention.
Due to the international nature of the Virtue Services and the markets in which the we operate, your personal data may be transferred outside the DIFC to any of the different categories of recipients described in table below, who could be located anywhere in the world, including, without limitation, Bermuda, British Virgin Islands, Canada, Cayman Islands, Europe, Hong Kong, Singapore, and the USA.
Where we share your personal data with recipients who are located outside the DIFC or European Economic Area (EEA), we will take appropriate steps to ensure that such overseas transfer of your personal data takes place in accordance with any legal restriction that applies to cross-border transfer of personal data under the DPL/GDPR. Additionally, if we agree to restrict the cross-border transfer of your personal data in any particular way with the recipients, we will comply with such restriction.
| RECIPIENTS | PURPOSE | LEGAL BASIS |
|---|---|---|
| Public administrations; Courts and tribunals; Law enforcement agencies. | For compliance with the legal obligations to which Virtue is subject for the performance of its activity, and in the cases provided for in the applicable data protection laws. | Comply with a legal obligation. |
| Vendors | Third parties that will act as service providers, for example, IT providers, such providers may have access to your personal data so that they can provide the services and/or comply with the obligations arising from the legal relationships maintained between the aforementioned third parties and Virtue, within the framework of the provision of contracted services. In any case, Virtue has signed the corresponding confidentiality and data protection agreements with said suppliers, in full compliance with the provisions of the current regulations on data protection. | The execution of the contractual relationship maintained between Virtue and the supplier in the confidentiality and data protection contracts signed with them. |
| Accounting audit companies | For compliance with the legal obligations of auditing accounts to which Virtue is subject for its activity. | To comply with a legal obligation. |
| Other Companies belonging to Virtue. | We may communicate the data to the other companies that belong to Virtue, for internal organizational purposes. | The legitimate interest of Virtue recognized by the applicable data protection legislation. |
| Third Parties interested in the acquisition of all or part of the Virtue’s share capital. | Analysis and execution of commercial operations in which Virtue may become involved due to structural modifications. | The legitimate interest of Virtue recognized by the applicable data protection legislation. |
Virtue does not make automated decisions that may affect you solely based on the automated processing of your personal data. All the aforementioned data processes involve human intervention.
The development of profiles, as indicated in the candidate management purpose, will under no circumstances be used for making decisions by Virtue that may have legal consequences for you or significantly affect you.
You have the following rights, where provided under applicable law, regarding your information (each of which are subject to various exceptions and limitations):
Virtue reserves the right to revise this information text at any time it deems appropriate, to reflect regulatory changes, and good practices or update the activities of processing personal data. You will be informed of such updates in accordance with regulatory requirements if your rights are appreciably affected as a result of such a change or update. We will post an updated copy on our Website. Please check our Website periodically for updates. Your continued use of Virtue Services means that you consent to the collection, use and disclosure of your personal data as set out in the updated Privacy Policy.
