For purposes of this Policy, the following definitions apply:
“Aggregate Data” is de-identified information, learnings, logs, and data We collect about a group or category of services or users.
“Client” means a current or past customer of Vareto.
“Data Controller” – Vareto acts as a Data Controller when We collect and define the purpose for and control the means by which Personal Data is processed. For example, Vareto acts as a Data Controller when collecting contact information when a customer registers for the Services or to participate in an event.
“Data Processor” – Vareto acts as Data Processor when We provide our Services to our Clients. When acting as a Data Processor, Vareto will only process Personal Data in accordance with a Client’s instructions and this Policy.
“Personal Data” means any information or set of information that directly or indirectly identifies or could be used by Vareto or its agents to identify an individual, such as a name, address, location data, online identifier, one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that individual, and also includes information referred to as “personally identifiable information” or “personal information” under applicable data privacy laws, rules, or regulations. Personal Data does not include Aggregate Data or publicly available information that has not been combined with non-public Personal Data.
“Vareto”, “we”, “us” or “our” means Vareto Inc., a Delaware corporation, and all its related, affiliated or subsidiary companies.
“You” and “your”’ means the natural person using the Services or an entity using the Services and any natural person using the Services and acting on the entity’s behalf.
We collect information You share with us and when You register for and use our Services or participate in Vareto events.
Automatically Collected Information from the Services.
We automatically receive certain types of information when You interact with Our Services. Your Web browser may automatically send information to every site You visit, including Ours. That information includes Your computer’s IP address, access times, Your browser type and language, Internet service provider (ISP), and referring site addresses. We may also collect information about the type of operating system You use, Your account activity, and files and pages accessed or used by You. We do not link this automatically-collected information to Personal Data.
Local Storage (HTML5)
We and Our third-party partners use Local Storage (HTML5) to provide certain features on Our Services, display advertising based on Your Web browsing activities, or store content information and preferences. Various browsers may offer their own management tools for removing HTML5.
Cookies and Tracking Technologies.
Information collected From Vareto Sponsored events:
When You register for Vareto sponsored events (e.g. product demos)You may be required to provide Personal Data, such as Your first and last name, Company name, business email, Your job title, billing information (such as billing name, billing address, and credit card number), dietary restrictions and preferences.
Information collected when You Register as Vareto’s Client:
Registration and Profile Information.
When You register to use the Services, We may collect information about You, such as Your name, email address, title, company and other information You provide.
If You are Our Client, You will be providing Us with Your payment information to pay for the Services, including Your credit card and/or banking information and billing address.
Submissions and Customer Service.
From time to time, We may use surveys, contests, or sweepstakes requesting Personal Data or demographic information and Client feedback. Participation in these surveys or contests is completely voluntary and You have a choice whether to disclose this information. We may also use Personal Data to provide customer support, resolve customer issues, and apply fixes to bugs.
Information collected when You Apply to Vareto’s Job Postings:
When You apply to work at Vareto, We collect personal identifiers and contact information from You, such as Your first name, last name, mailing address, email address, and phone number.
Employment History and References.
When You apply to work at Vareto, We collect information about Your current and previous employment information, such as Your job title, name of the employer, and employment history. You may also be asked to provide professional references, which includes disclosure of the following Personal Data of Your references: the first and last name, job title, email address, and phone number.
Protected Classifications Under State and Federal Law.
As part of Your employment application, We may also collect data regarding Your gender, veteran status, race, and disability status. The provision of this data by You is optional.
No Sensitive Data
Vareto does not generally collect sensitive Personal Data, which includes Personal data such as racial or ethnic origins, religious, political, or philosophical beliefs, health or medical information, genetic or biometric data, bank account information (except when required to process your purchases), or other sensitive Personal Data as defined by applicable law. Vareto will obtain Your consent should We need to collect Your sensitive Personal Data.
Although you don’t have to supply any of the personal information we request, we may not be able to provide access to certain features of the Services to you or you may not be able to interact with our Services if you do not.
Vareto may collect Personal Data about You from third parties from whom Vareto purchased business contact information. Vareto may also use publicly accessible Websites, such as professional network sites, press releases, or Your employer’s Website to collect such information. The Personal Data that Vareto may collect from Third Parties includes: first and last name, email address, phone number, company’s mailing address, job title, employment history, company name, and online identifier.
- To provide You with Services and customer support;
- To contact You about Your use of the Services or to contact You with promotional content, including but not limited to telemarketing calls, marketing emails, newsletters, whitepapers, and information on upcoming events. We also use it to send administrative information, such as notices related to the Services or policy changes;
- To administer Your account and Your use of the Services;
- To respond to Your requests for information, including product documentation and other resources, and to update You on our events, promotions, products or services We believe will be of interest to You;
- To request Your feedback to enable Us to develop, customize, and improve the Services and Services;
- To manage events sponsored by Vareto, including registration and billing;
- To Process Your Application for Employment with Us;
- Accomplish other purposes about which We notify You.
- Enforce our terms and conditions and otherwise protect our rights and operations.
Aggregate Data helps us understand trends in our users’ needs, so that We can consider new features or better tailor our services. This Policy in no way restricts or limits our collection and use of Aggregate Data. We may share Aggregate Data about our users with third parties for various purposes, including to help us better understand our Customers’ needs, improve our services, and for advertising and marketing purposes.
If You are a resident of the European Union, United Kingdom, Lichtenstein, Switzerland, Iceland, or Norway, You have the data subject rights under the GDPR as described below. You have a right to restrict processing of Your Personal Data by Vareto. Please send Your request to firstname.lastname@example.org. Even if You request that We delete Your Personal Data, We may still retain data collected from you in an aggregated and anonymized form.
The right to access - You have the right to request Our Company for copies of your personal data. We may charge you a small fee for this service.
The right to rectification - You have the right to request that Our Company correct any information you believe is inaccurate. You also have the right to request Our Company to complete information you believe is incomplete.
The right to erasure - You have the right to request that Our Company erase your personal data, under certain conditions.The right to restrict processing - You have the right to request that Our Company restrict the processing of your personal data, under certain conditions.
The right to object to processing - You have the right to object to Our Company's processing of your personal data, under certain conditions.
The right to data portability - You have the right to request that Our Company transfer the data that we have collected to another organization, or directly to you, under certain conditions.
Please note that We may process Your Personal Data in connection with our provision of Services to our Clients, in which case We may not be able to respond to You request. As such, please contact the data controller to address your rights with respect to such data.
If You have questions whether any of the following applies to you, please contact Us at email@example.com and we will respond to Your questions as soon as practicable.
When We process Your Personal Data, We do so on the following grounds:
We may process Your Personal Data as part of Our contractual obligations to You or a Client.
We may process Personal Data based on the consent You expressly grant to us at the time we collect such data. You can withdraw Your consent at any time, which will not affect the lawfulness of the processing before Your consent was withdrawn.
We process Personal Data for the legitimate interests of Vareto and that Our partners, affiliates, and Clients. These legitimate interests include, investigating illegal activities, detecting security issues, improving and maintaining the Services and the Services, contacting You to provide support, sending you relevant marketing information (subject to applicable laws). We will balance our interests and rights against the impact of the processing on data subjects.
We may need to process Your Personal Data to comply with a legal obligation, such as a lawful subpoena, court order, law-enforcement request, or to fulfill the lawful instructions of Our Clients (when they are acting as the data controller). We may also need to process Your Personal Data to protect vital interests and defend legal claims.
If You are a California resident, You have the following rights with regards to Your Personal Data. If You have any questions about this section, whether any of the following applies to You, or to exercise Your rights, please email firstname.lastname@example.org.
Right to Disclosure & Access
You have the right to request certain information about our collection and use of your Personal Data over the past 12 months. We will provide you with the following information: (i) categories of Personal Data that We have collected about You; (ii) categories of sources from which that Personal Data was collected; (iii) categories of third parties with whom We have shared Your Personal Data; (iv) the business or commercial purpose for collecting or selling Your Personal Data; (v) the specific items of Personal Data that We collected about You; and (vi) if We disclosed/sold Your Personal Data over the last 12 months, We will identify the categories of Personal Data shared/sold with each category of third-party recipient.
Right to Correction
You have the right to request that We correct Your Personal Data.
Right to Deletion
You have the right to request that We delete the Personal Data that we have collected from You.
Right to Data Portability.
You may request to receive the specific pieces of Your Personal Data, including a copy in a portable format.
Right to Opt-Out of Sales or Sharing.
You can ask that we do not “sell” or “share” your Personal Data as “sell” and “share” are explicitly defined under the CCPA. For more information, please refer to the section titled “Sale and Sharing of Personal Data under California Law” below.
Right to be Free from Discrimination.
You may freely exercise these rights without fear of being denied our Services. We will not charge You different prices or rates or provide You with a lower quality of services if You exercise Your rights under CCPA.
Sale and Sharing of Personal Data under California Law
We do not sell Personal Data in the conventional sense. However, when You use Vareto’s websites, Vareto’s authorized third parties may collect information on you by using web cookies or similar technologies and use such data for their own purposes. Making your Personal Data available to these third parties may qualify as “sale” or “sharing” of Your Personal Data under CCPA. For more information on sharing of Your Personal Data, please refer to the Section “How We Share Your Personal Data”.
Sensitive Personal Data under California Law
As stated in the Section “Information that We Collect from You”, we generally do not collect sensitive Personal Data. We may collect Your Driver’s License, Passport, or another form of identification to verify your identity in certain instances, such as an employment application. If We collect Your sensitive Personal Data, We will not disclose it to third parties and only use it for purposes permitted under CCPA and CPRA such as performing the Services, ensuring physical safety of persons, and preventing, detecting, and investigating security incidents. We do not collect Your sensitive Personal Data to infer any characteristics about You.
Exercising Your Rights.
All requests pursuant to this section must be addressed to email@example.com. In compliance with CCPA We will require certain identifying information from You to verify Your request. We will make best efforts to respond to Your valid request within 45 days from the receipt. In some instances, We may be required to continue to retain or share portions of your Personal Data to comply with regulatory or legal obligations.
In addition to the federal laws concerning the collection and use of personal information, some states have privacy laws and regulations that supplement these federal laws and provide additional rights to citizens of those states.
Vareto does not knowingly collect or solicit Personal Data from anyone under the age of 16. If We learn that We have collected Personal Data from a child under age 16, We will delete the information We have stored as quickly as possible. If You believe that We might have any information from or about a child under 16, please contact us at firstname.lastname@example.org.
Vareto, Inc. uses industry standard security measures to protect against the loss, misuse and alteration of the Personal Data under Our control. Although We make good faith efforts to store the Personal Data collected by Vareto, Inc. in a secure operating environment that is not available to the public, Vareto, Inc. cannot guarantee complete security. Further, while We take reasonable steps to ensure the integrity and security of our network and systems, We cannot guarantee that our security measures will prevent third-party “hackers” from obtaining this information.
This Policy may be amended from time to time, consistent with the requirements of the Privacy Shield Principles. Appropriate public notice will be given concerning material amendments or changes to this Policy. If We make any material changes, We will notify You by email (sent to the e-mail address specified in Your account) or by means of a notice on this Website prior to the change becoming effective. We encourage You to periodically review this page for the latest information on our privacy practices.
Any questions or concerns regarding the use or disclosure of Personal Data should be directed to Vareto, Inc. at email@example.com. Vareto, Inc. will investigate and attempt to resolve complaints and disputes regarding use and disclosure of Personal Data in accordance with the principles contained in this Policy.