Effective Date: December 18, 2018
WHAT PERSONAL INFORMATION DO WE COLLECT?
This is how we collect Personal Information from our customers, users, and visitors of our Site:
Account Creation or Requesting A Demo. We will collect your full name and email address when you register into the Services by creating an account. If you schedule a demonstration or free trial of the Services (“Demo”), we’ll collect certain Personal Information about you, such as your name, business email, type of business and information about your company, job title, physical address of your company, and phone number.
Communications with Us. We may collect Personal Information from you such as email address, phone number, or other contact information when you request information about our Services, register for our newsletter, request customer or technical support, or otherwise communicate with us.
Security Credentials Data. We collect user IDs, passwords, password hints, and similar security information required for authentication and access to our users’ accounts.
Financial Information. We may collect the financial information and other Personal Information such as your name, business phone number, business email, company address, and other information that you provide via purchase orders or other ordering documents so that we can process your company’s payment for access to the Services.
Surveys. We may contact you to participate in surveys (including via third parties). If you decide to participate, we may ask you for certain information which may include Personal Information.
Information from Other Sources. We may obtain information about you from other sources, including through third party services and organizations to supplement information provided by you. This supplemental information allows us to verify information that you have provided to us and to enhance our ability to provide you with information about our business, products, and Services.
Registration for Sweepstakes or Contests. We may run sweepstakes and contests. Contact information you provide may be used to reach you about the sweepstakes or contest and for other promotional, marketing and business purposes, if permitted by law. In some jurisdictions, we are required to publicly share information of winners.
Automatic Data Collection. We may collect certain information automatically when you use the Services. This information may include your Internet protocol (IP) address, user settings, IMEI, cookie identifiers, Wi-Fi BSSIDs, mobile carrier, mobile advertising and other unique identifiers, details about your browser, operating system or device, location information, Internet service provider, pages that you visit before, during and after using the Services, information about the links you click, and other information about how you use the Services. Information we collect may be associated with accounts and other devices. We also automatically collect some information regarding your use of the Services by placing cookies and other technologies on our Site. For more information on Cookies, please see below.
HOW DO WE USE YOUR INFORMATION?
We Process Personal Information about you for a variety of business purposes, including:
To Provide Services, and Other Information Requested including to:
- provide Services, demonstrations, or free trials, and communicate with you;
- manage your information and accounts;
- respond to certain queries you send to the Services;
- respond to questions, comments, and other requests;
- answer requests for customer or technical support, and troubleshoot problems;
- allow you to register for events.
For Administrative Purposes including to:
- measure interest and engagement in our Site and Services;
- conduct research and development;
- improve our products and Services;
- develop new products and services;
- ensure internal quality control;
- verify individual identity and for fraud prevention;
- communicate with you about your account, our Services, and any policy changes;
- process your financial information and other payment methods for products or Services purchased;
- prevent potentially prohibited or illegal activities;
- enforce our Terms, and send you notices and alerts;
- network and information security;
- comply with the law; and
- any other legitimate purpose.
To Market Our Products and Services. We may use Personal Information to provide you with materials about offers, products, and Services that may be of interest to you, including:
- To tailor content, advertisements, and offers;
- To notify you about offers, products, and services that may be of interest to you;
- For direct marketing and research (including marketing research); and
- Other purposes disclosed to you, or that you consent to, when you provide Personal Information.
You may contact us at any time to opt out of the use of your Personal Information for marketing purposes as described below.
De-identified and Aggregated Information Use. We may use Personal Information and other information about you to create de-identified and aggregated information, such as de-identified demographic information, de-identified location information, information about the computer or device from which you access our Site and Services, or other analyses we create. We may use information in a number of ways, including research, internal analysis, analytics, and any other legally permissible purposes.
Other Uses. We may use Personal Information to pursue legitimate interests, such as direct marketing, research (including marketing research), network and information security, and fraud prevention, or any other purpose disclosed to you at the time you provide Personal Information or with your consent.
WITH WHOM DO WE SHARE YOUR INFORMATION?
We may share your information as follows:
Vendors and Service Providers. We may share your information with our vendors and service providers. The types of service providers (processors) to whom we entrust Personal Information include service providers for: (i) provision of IT and related services; (ii) provision of information and services you have requested; (iii) payment processing; (iv) customer service activities; and (v) the provision of the Site and Services.
Business Partners. We may provide Personal Information to our business partners with whom we jointly offer products or services. In such cases, our business partner’s name will appear along with ours.
Friends or Colleagues. Our referral services may allow you to forward or share certain content with a friend or colleague, such as an email inviting your friend and/or colleague to use our Services. Email addresses that you may provide for a friend or colleague will be used to send your friend or colleague the content or link you request, but will not be collected or otherwise used by Versa or any other third parties for any other purpose.
Marketing – Interest-Based Advertising and Third Party Marketing. Through our Services, Versa may allow third party advertising partners to set Technologies (defined below) and other tracking tools to collect information regarding your activities and your device (e.g., your IP address, mobile identifiers, page(s) visited, location, time of day). We may also combine and share such information and other information (such as demographic information and past purchase history) with third party advertising partners for targeted advertising or interest-based advertising. You will be able to opt out of such sharing by following the instructions below.
Disclosures to Protect Us or Others. We may access, preserve, and disclose your Personal Information and other Account information, and content if we believe doing so is required or appropriate to: (i) comply with law enforcement or national security requests and legal process, such as a court order or subpoena; (ii) respond to your requests; (iii) protect your, our or others’ rights, property, or safety; (iv) to enforce our policies or contracts; (v) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation or prosecution of suspected or actual illegal activity; or (vi) if we, in good faith, believe that disclosure is otherwise necessary or advisable.
Merger, Sale, or Other Asset Transfers. If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, then your information may be sold or transferred as part of such a transaction as permitted by law and/or contract.
COOKIES, PIXEL TAGS/WEB BEACONS, ANALYTICS INFORMATION, AND INTEREST-BASED ADVERTISING
Cookies. Cookies are small text files placed in visitors’ computer browsers to store their preferences. Most browsers allow you to block and delete cookies. However, if you do that, the Services may not work properly.
Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded on the Site that collects information about users’ engagement on that web page. The use of a pixel allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement.
Analytics. We may also use various analytics service providers such as Google Analytics to collect information regarding visitor behavior and visitor demographics on our Site and Services. For more information about Google Analytics, please visit www.google.com/policies/privacy/partners/. You can opt out of collection and Processing of data by Google Analytics services by using the following link: http://tools.google.com/dlpage/gaoptout. See below for more information under Your Choices: Cookies and Interest-Based Advertising.
We use such Technologies for these purposes:
- Operationally Necessary. This includes Technologies that allow you access to our Site, Services, applications, and tools that are required to identify irregular site behavior, prevent fraudulent activity and improve security or that allow you to make use of our functions such as saved search, or similar functions;
- Performance Related. We may use Technologies to assess the performance of our Services, including as part of our analytic practices to help us understand how our visitors use the Services and so we can improve our Services;
- Functionality Related. We may use Technologies that allow us to offer you enhanced functionality when accessing or using our Site and Services. This may include identifying you when you sign into our Site or Services or keeping track of your specified preferences, interests, or past items viewed;
- Advertising or Targeting Related. We may use first party or third party Technologies to deliver content, including ads relevant to your interests, on our Site and Services or on Third Party sites.
THIRD PARTY WEBSITES, SOCIAL MEDIA PLATFORMS AND SDKs
The Services may contain links to other websites and other websites may reference or link to our Site or other Services. We do not control such third party websites or resources. So please read the privacy policies of each such website before you provide any information on it.
The Services may include publicly accessible blogs, forums, social media pages, and private messaging features. By using such services you assume the risk that the Personal Information provided by you may be viewed and used by Third Parties for any number of purposes.
We may use third party APIs and software development kits (“SDKs”) as part of the functionality of our Services. APIs and SDKs may allow third parties including advertising partners to collect your Personal Information to provide content that is more relevant to you. For more information about our use of APIs and SDKs, please contact us as set forth below.
INTERNATIONAL DATA TRANSFERS
All information Processed by us may be transferred, Processed, and stored anywhere in the world including in the European Union, the United States or other countries. Personal Information may be stored in the cloud, on our servers, on the servers of our affiliates or the servers of our service providers. Accordingly, your Personal Information may be transferred to, and maintained on, computers located outside of your state, province, country or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction.
General. You may opt out of certain uses of your Personal Information, or even withdraw your previously provided consent at any time and prevent further Processing by contacting us as described below. Please note, however, that the opt out does not apply to, and we may still collect and use, any non-Personal Information regarding your activities on our Site, Services and/or information from the advertisements on third party websites for other legal purposes as described above.
“Do Not Track”. Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. Sorry- we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.
Cookies and Interest-Based Advertising. You may stop or restrict the placement of Technologies on your device or remove them by adjusting your preferences as your browser or device permits. You may opt out of receiving targeted ads from data partners and other advertising partners that participate in self-regulatory programs via the following links: www.aboutads.info/choices/, www.networkadvertising.org/managing/opt_out.asp, http://www.youronlinechoices.eu/, and https://youradchoices.ca/choices/.
Please note you must separately opt out in each browser and on each device. Advertisements on third party websites that contain the AdChoices link may have been directed to you based on information collected by advertising partners over time and across websites. These advertisements provide a mechanism to opt out of the advertising partners’ use of this information for interest-based advertising purposes.
HUMAN RESOURCES DATA
The following section applies to Versa’s Processing in the context of human resources, recruitment, and applicant consideration.
Versa collects Personal Information from current, prospective, and former employees, their contact points in case of a medical emergency, and beneficiaries and dependents under any insurance or benefits policy (“Human Resources Data”). The Human Resources Data we collect may include title, name, address, phone number, email address, date of birth, passport number, driver’s license number, Social Security number or other government-issued identification number, financial information related to credit checks, bank details for payroll, information that may be recorded on a CV or application form, language abilities, contact information of third parties in case of an emergency and beneficiaries under any insurance policy. We may also collect Sensitive Human Resources Data such as details of health and disability, including mental health, medical leave, and maternity leave; information about national origin or immigration status; and optional demographic information such as race, which helps us achieve our diversity goals.
We Process Human Resources Data for a variety of business purposes including:
- Workflow management, including assigning, managing and administering projects;
- Human Resources administration and communication;
- Payroll and the provision of benefits;
- Compensation, including bonuses and long-term incentive administration, stock plan administration, compensation analysis, including monitoring overtime and compliance with labor laws, and company recognition programs;
- Job grading activities;
- Performance and employee development management;
- Organizational development and succession planning;
- Benefits and personnel administration;
- Absence management;
- Helpdesk and IT support services;
- Regulatory compliance;
- Internal and/or external or governmental compliance investigations;
- Internal or external audits;
- Litigation evaluation, prosecution, and defense;
- Diversity and inclusion initiatives;
- Restructuring and relocation;
- Emergency contacts and services;
- Employee safety;
- Compliance with statutory requirements;
- Processing of Employee expenses and travel charges; and
- Acquisitions, divestitures, and integrations.
RIGHTS OF ACCESS, RECTIFICATION, ERASURE, AND RESTRICTION
In accordance with applicable law, you may have the right to: (i) request confirmation of whether we are processing your Personal Information; (ii) obtain access to or a copy of your Personal Information; (iii) receive an electronic copy of Personal Information that you have provided to us, or ask us to send that information to another entity (the “right of data portability”); (iv) restrict our uses of your Personal Information; (v) seek correction or amendment of inaccurate, untrue, incomplete, or improperly Processed Personal Information; and (vi) request erasure of Personal Information held about you by Versa, subject to certain exceptions prescribed by law. If you would like to exercise any of these rights, please contact us as set forth below.
We will process such requests in accordance with applicable laws. To protect your privacy, Versa will take steps to verify your identity before fulfilling your request.
SECURITY OF YOUR INFORMATION
We may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Services. If we learn of a security system’s breach, we’ll attempt to notify you electronically by posting a notice on the Services, by mail or e-mail.
The Site and Services are not directed to children under 13 (or other age as required by local law), and we do not knowingly collect Personal Information from children. If you learn that your child has provided us with Personal Information without your consent, you may contact us as set forth below, and we’ll promptly take steps to delete such information and terminate the child’s account.
CALIFORNIA PRIVACY RIGHTS
If you are located in the European Economic Area, you have the right to lodge a complaint with a supervisory authority if you believe our Processing of your Personal Information violates applicable law.
“Personal Information” is any information relating to an identified or identifiable natural person.
“Process” or “Processing” means any operation which is performed upon Personal Information, whether or not by automatic means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction.
Versa, 6001 America Center Drive, Suite 400, San Jose, CA 95002 or firstname.lastname@example.org