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PRIVACY POLICY
EPro Virtual Assistant Solutions

Last Updated: February 23, 2026

EPro Virtual Assistant Solutions (“EPro,” “we,” “us,” or “our”) is committed to protecting personal data in a manner consistent with our managed agency operating model, our Master Services Agreement (MSA), Independent Contractor Agreement (ICA), Training Agreement, and Non-Disclosure Agreement (NDA). This Privacy Policy explains how we collect, use, process, disclose, transfer, and protect personal data.

1. Scope of This Privacy Policy


This Policy applies to:
• Website visitors
• Prospective clients
• Clients (for pre-contractual and website-related data)
• Business partners and vendors
• Individuals communicating with us

Service-delivery data processing obligations are governed by the MSA.

2. Data Controller and Processor Roles


Website & Marketing Data: EPro acts as Data Controller.

Client Service Data: EPro typically acts as Data Processor under the MSA,
while Clients act as Data Controllers.

EPro Specialists are independent contractors bound by confidentiality and data protection obligations.

3. Categories of Personal Data We Collect


• Identifiers (name, email, phone)
• Professional details (company, title)
• Billing and transaction data
• Communications (emails, notes, call summaries)
• Technical data (IP, device, browser, cookies)
• Limited client operational data (under contract)

4. Lawful Bases for Processing (GDPR)


• Contract necessity
• Legitimate interests (business operations, security)
• Consent (marketing, cookies where required)
• Legal obligations

5. Purposes of Processing


• Responding to inquiries and scheduling calls
• Preparing proposals and onboarding clients
• Delivering managed virtual assistant services
• Maintaining security and fraud prevention
• Financial accounting and compliance
• Improving website functionality

6. Data Retention Periods


• Prospect data: retained up to 24 months unless relationship begins
• Client contractual data: retained for contract duration + 7 years for accounting compliance
• Website analytics: typically retained 12–26 months depending on provider
• Training & contractor records: retained as required for legal and operational protection

7. International Data Transfers


EPro operates from the Philippines and serves international clients.
Where cross-border transfers occur, we rely on contractual safeguards and appropriate security measures.

8. Use of Subprocessors and Service Providers


We use trusted third-party providers for hosting, scheduling, CRM, analytics, payment processing, and communications.
Subprocessors are contractually required to implement appropriate security safeguards.

9. Data Sharing and Disclosure


We may disclose data to:
• Service providers
• Clients (as required for service delivery)
• Legal authorities when required by law

We do not sell personal data.

10. Security Measures


We implement:
• Access control policies
• Confidentiality agreements
• Escalation-first protocols
• Contractor training on data handling
• Documentation and audit discipline

No system is 100% secure, but we apply reasonable safeguards aligned with our agency model.

11. Data Breach and Incident Response


In the event of a suspected breach, we:
• Immediately escalate internally
• Contain and assess impact
• Notify affected Clients where contractually required
• Notify authorities where legally required

12. GDPR Rights (EEA Residents)


You may have the right to:
• Access, rectify, or erase data
• Restrict or object to processing
• Data portability
• Lodge a complaint with a supervisory authority

Requests may be sent to admin@eprovasgo.com.

13. CCPA Rights (California Residents)


You may have the right to:
• Know categories and purposes of data collected
• Request deletion (subject to exceptions)
• Request disclosure of sources
• Opt out of sale (we do not sell personal data)
• Non-discrimination for exercising rights

14. Automated Decision-Making and Profiling


We do not use personal data for automated decision-making that produces legal or significant effects.

15. Cookies and Tracking Technologies


We use cookies for:
• Essential website functionality
• Analytics and performance measurement
• Security monitoring

Users may manage cookie preferences through browser settings.
Disabling cookies may affect functionality.

16. Children’s Privacy


Our website and services are not directed to individuals under 18.
We do not knowingly collect personal data from minors.

17. Changes to This Privacy Policy


We may update this Policy periodically.
The “Last Updated” date reflects revisions.
Continued use of our website constitutes acceptance.

18. Contact and Data Protection Inquiries

 


For privacy inquiries or rights requests:

EPro Virtual Assistant Solutions
Email: admin@eprovasgo.com

We may verify identity before processing requests.