1. Introduction
This Privacy Policy ("Policy") governs the handling of personal information by VA WORKS, LLC ("VA WORKS™," "Consultant," "we," "us," or "our"). This Policy forms an integral part of the Master Service Agreement ("MSA"), the MSA Terms and Conditions (https://vaworks.com/MasterServiceAgreement), the applicable Scope of Work Terms and Conditions (https://vaworks.com/SOWSelection), and the Governing Policies referenced therein. By engaging Consultant's services, Company acknowledges and agrees to this Policy.
2. Scope of This Policy
This Policy applies to all services provided by Consultant. Consultant complies with applicable federal and state privacy laws, including but not limited to:
- Health Insurance Portability and Accountability Act (HIPAA)
- Gramm-Leach-Bliley Act (GLBA)
- Fair Credit Reporting Act (FCRA)
- California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA)
- Virginia Consumer Data Protection Act (VCDPA)
- Colorado Privacy Act (CPA)
- Connecticut Data Privacy Act (CTDPA)
- Utah Consumer Privacy Act (UCPA)
- Illinois Biometric Information Privacy Act (BIPA)
3. Information We Collect
Consultant does not intentionally collect or retain highly sensitive information such as Social Security Numbers, banking credentials, payroll data, or government-issued identification.
Any personal information accessed by Virtual Assistants (whether employees of record or independent contractors) is accessed solely through Company-controlled systems in the course of services and is never stored in Consultant's systems.
Consultant may maintain only limited business contact information (e.g., names, business emails, and business phone numbers of Company's designated representatives) for account setup, invoicing, and service administration.
4. Collection and Use of Information
Consultant does not collect, store, or maintain personal information in its own systems. All work performed by Consultant's Virtual Assistants is conducted exclusively within Company-provided platforms, virtual desktops, and systems that are owned, operated, and controlled solely by Company.
Any personal information accessed, entered, or processed by Virtual Assistants is recorded, stored, and maintained entirely within Company's systems. Consultant does not act as a data controller or processor for purposes of storing or maintaining such information.
Consultant's use of information is limited to:
- Providing personnel to deliver services as defined in the MSA and applicable SOW;
- Communicating with Company and its authorized contacts;
- Maintaining compliance with applicable laws;
- Administrative functions such as invoicing and service oversight.
5. Sharing of Information
Consultant does not sell personal information. Information is disclosed only as necessary to perform services, comply with law, or as expressly authorized by Company. If shared in the context of a transaction (e.g., real estate or mortgage-related engagement), disclosure is limited to the minimum information required.
6. State-Specific Privacy Rights
Residents of certain states may have additional rights, including the right to access, correct, or delete their personal information, the right to opt out of sale or targeted advertising, and the right not to face discrimination for exercising such rights. Requests to exercise such rights may be submitted as described in Section 11.
7. Federal Compliance Requirements
Consultant complies with all applicable federal privacy laws, including HIPAA (medical data), GLBA (financial data), and FCRA (consumer report use). Where services are provided to regulated clients (e.g., lenders, real estate brokerages), Consultant's obligations are limited to providing administrative personnel, while Company remains the data controller of record.
8. Data Security
Consultant implements administrative, technical, and physical safeguards designed to protect business contact information.
Where Consultant's personnel access Company systems (e.g., Company-provided virtual desktops), Company remains solely responsible for the security, protection, and insurance of its systems and data. Consultant shall not be liable for any breach, incident, or unauthorized access that occurs within Company's virtual desktop, systems, or third-party software.
9. Retention of Information
Consultant retains business contact information only as long as necessary to fulfill administrative purposes or as required by law. No personal information from Company's systems is retained by Consultant.
10. Cookies and Online Tracking
Consultant's websites may use cookies and similar technologies to enhance user experience and analyze site performance. Users may manage cookies through their browser settings.
11. Your Privacy Choices
To exercise your privacy rights or to make inquiries regarding this Policy, you may contact us at:
- Email: privacy@mxworks.com
- Phone: +1 (417) 34-WORKS (96757)
- Mail: VA WORKS, LLC, 7726 Winegard Road, 2nd Floor, Orlando, FL 32809
12. Changes to This Privacy Policy
Consultant reserves the right to amend this Policy at any time. Updates will be posted at https://vaworks.com/PrivacyPolicy and, where material, will be communicated with at least fifteen (15) days' prior notice in accordance with the MSA Terms and Conditions. Continued use of services after such notice constitutes acceptance of the updated Policy.
13. Website Analytics and User Behavior Tracking
We partner with Microsoft Clarity and Microsoft Advertising to capture how users interact with our website through behavioral analytics, including session recordings, heatmaps, and engagement metrics. This data helps us improve user experience, optimize our website, and enhance our marketing efforts.
Clarity collects data using first-party and third-party cookies and similar technologies to analyze site usage, identify patterns of interaction, and improve performance. This may include information such as page interactions, scrolling behavior, and general device/browser data.
We use this information for:
- Website optimization and usability improvements
- Marketing and advertising performance analysis
- Fraud detection and security monitoring
For more information on how Microsoft collects and processes data, please visit the Microsoft Privacy Statement.
14. Acknowledgment
By executing the MSA and applicable SOW(s), and by engaging Consultant's services, Company acknowledges and agrees to this Privacy Policy, as updated from time to time in accordance with Section 12.