If you are a data subject in the United Kingdom or any part of the European Economic Area, please see the "Additional Disclosures for Data Subjects in Europe" section.
1. PLATFORM OVERVIEW
2. THE INFORMATION WE COLLECT ABOUT YOU
We may collect and use the following information when providing certain functionality of our Platform. Such information may be provided to us by you voluntarily, collected by us automatically, or provided to us from third parties.
A. Information You Voluntarily Provide To Us
When you engage with us through our Platform, including by directly contacting us or otherwise signing up to newsletters or otherwise to be kept up-to-date about upcoming events, we will collect certain information about you that you voluntarily provide to us. This information includes the following:
- Contact Data, including your first and last name, email address, postal address, and phone number.
- Account Information, including username which may be in the form of an email address, and the associated password.
- Content, including content within any messages you send to us (such as feedback and questions to customer support).
- Employer/Company Information: including company name and job title.
You may choose to voluntarily provide other information to us that we do not request, and, in such instances, and in such situations we have no control over what categories of personal information such disclosure may include. Any additional information provided by you to us is provided at your own risk.
B. Information We Collect Automatically
Whenever you interact with the Platform, we may collect certain information about your use and device automatically, as well as use various tracking technologies that automatically collects information about how you access and use the Platform, which may include the following categories of information:
- Platform Use Data, including data about features you use, pages you visit, emails and advertisements you view, the time of day you browse, and your referring and exiting pages.
- Device Data, including data about the type of device or browser you use, your device’s operating software, your internet service provider, your device’s regional and language settings, and device identifiers such as IP address and Ad Id.
- Location Data, including imprecise location data (such as location derived from an IP address or data that indicates a city or postal code level) and, with your consent, precise location data (such as latitude/longitude data).
- Log Files, which are files that record events that occur in connection with your use of the Platform.
- Cookies, which are small data files stored on your device that act as a unique tag to identify your browser. For more information about the cookies we use, please see the Section entitled “Cookies” below.
For further information on how we use tracking technologies for analytics and advertising, and your rights and choices regarding them, see the “Advertising/Behavioral Targeting” and “Your Rights and Choices” sections below.
C. Information We Receive From Third Parties
We also collect information from other sources. The following are the categories of sources we collect information from:
- Social networks when you engage with our content, reference our Service, or grant us permission to access information from the social networks.
- Business Partners that offer services connected to the Platform by you.
- Publicly-available sources, including data in the public domain.
3. HOW WE USE THE INFORMATION WE COLLECT ABOUT YOU
We use the information we collect from and about you for a variety of business purposes, including:
- To provide, maintain, improve, and enhance our Platform;
- To personalize your experience on our Platform such as by providing tailored content and recommendations;
- To understand and analyze how you use our Platform and develop new products, services, features, and functionality;
- To communicate with you, provide you with updates and other information relating to our Platform, provide information that you request, respond to comments and questions, and otherwise provide customer support;
- To generate anonymized, aggregate data containing only de-identified, non-personal information that we may use to publish reports; and
- To find and prevent fraud, and respond to trust and safety issues that may arise;
- For compliance purposes, including enforcing our legal rights, or as may be required by applicable laws and regulations or requested by any judicial process or governmental agency.
Not with standing the above, we may use information that does not identify you (including information that has been aggregated or de-identified) for any purpose except as prohibited by applicable law. For information on your rights and choices regarding how we use information about you, please see the “Your Rights and Choices” section below.
4. SHARING OF PERSONAL AND NON-PERSONAL DATA
- Third Parties Providing Services On Our Behalf: In order to make various features, services and materials available to you through the Platform, perform analytics, host the Platform, and respond to your requests and inquiries, we may share your Personal Data with third parties that perform functions on our behalf.
- Business Transfers: We share information in connection with, or during negotiations of, any proposed or actual merger, purchase, sale or any other type of acquisition, business combination of all or any portion of our business or assets, change of control, or a transfer of all or a portion of our business or assets to another third party (including in the case of any bankruptcy proceeding).
- Facilitating Requests: We share information at your request or direction, such as when you choose to share information with a social network about your activities on the Platform.
- Consent: We share information with notice to you and your consent.
Not with standing the above, we may share non-personal data, such as aggregate user statistics, demographic information, and anonymized usage information with third parties without your consent.
Types of cookies we use. We use the following types of Cookies:
- Strictly Necessary Cookies: These are cookies that are essential to enable you to use the Platform, for example moving around our websites and using their features (e.g. cookies that enable you to log into the Platform).
- Performance Cookies: These are cookies which collect information about how and when you and other visitors interact with our Platform (e.g. pages viewed most often) and the information collected by these cookies is used to improve how our Platform works.
- Functionality Cookies: These are cookies that allow our Platform to remember choices you have made (such as your login information) and provide you with content and features which are customized to you. For example, providing you with relevant content by using a cookie to remember which region you are in.
- Advertising Cookies: These are cookies which are used to deliver adverts to you which are more relevant to you and your interests. We may also share this type of information with third parties for these purposes.
The types of cookies described above may be “session cookies” or “persistent cookies”. Session cookies are only stored on your device whilst you are using the Platform, and are deleted when you log off from the Platform or close your browser. Persistent cookies remain on your device for a period of time after you log off from the Platform or close your browser.
7. YOUR RIGHTS AND CHOICES
A. Account Information
You may access, update, or remove certain information that you have provided to us through your account by visiting your account settings or sending an email to the email address set out in the “Contact Us” section below. We may require additional information from you to allow us to confirm your identity. Please note that we will retain and use information about you as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
- E-mails: You can opt-out of receiving promotional emails from us at any time by following the removal instructions in the specific communication that you receive, or emailing us at the email address set out in the “Contact Us” section below with the word UNSUBSCRIBE in the subject field of the email. Please note that you cannot opt-out of non-promotional emails, such as those about your account, transactions, servicing, or VersaFeed’s ongoing business relations.
Please note that your opt out is limited to the email address, device, and phone number used and will not affect subsequent subscriptions.
We use analytics services, such as Google Analytics, to help us understand how users access and use the Service. You can opt out of Google analytics by using the Google Analytics Opt-out Browser Add-on found here.
D. Tracking Technology Choices
- Cookies. Although most browsers automatically accept cookies, you can change your browser options to stop automatically accepting cookies or to prompt you before accepting cookies. However, if you don’t accept cookies, you may not be able to access all portions or features of the Platform.
- Do Not Track. Your browser settings may allow you to automatically transmit a “Do Not Track” signal to online services you visit. Note, however, there is no industry consensus as to what website and app operators should do with regard to these signals. Accordingly, unless and until the law is interpreted to require us to do so, we do not monitor or take action with respect to “Do Not Track” signals. For more information on “Do Not Track,” visit http://www.allaboutdnt.com.
- App and Location Technologies. You can stop all collection of information via an app by uninstalling the app. You can also reset your device Ad Id at any time through your device settings, which is designed to allow you to limit the use of information collected about you. You can stop all collection of precise location data through an app by uninstalling the app or withdrawing your consent through your device settings.
Please be aware that if you disable or remove tracking technologies some parts of the Platform may not function correctly.
8. DATA SECURITY
VersaFeed uses reasonable security measures designed to prevent unauthorized intrusion to the Platform and the alteration, acquisition or misuse of personal information. Nevertheless, transmission via the internet is not completely secure and we cannot guarantee the security of information about you, collected from you, or submitted by you. We will not be responsible for loss, corruption or unauthorized acquisition or misuse of information that you provide or that we collect through the Platform that is stored by us or our service providers, or for any damages resulting from such loss, corruption or unauthorized acquisition or misuse.
9. CHILDREN’S PRIVACY
Our Platform is not directed towards, nor was it designed to attract the attention of any children, and we do not knowingly collect or maintain personal information from any person under the age of thirteen.
10. CONTACT US
11. ADDITIONAL DISCLOSURES FOR DATA SUBJECTS IN EUROPE
Data protection laws in Europe distinguish between organizations that process personal data for their own purposes (known as “controllers”) and organizations that process personal data on behalf of other organizations (known as “processors”).
B. Lawful Basis for Processing
Data protection laws in Europe require a “lawful basis” for processing personal data. Our lawful bases include where:
- Contract with customers whom you work for. In order to fulfill our obligations with respect to providing the Platform to our business customers, we have to collect certain information about the devices and users of such systems to ensure security support and functionality of the Platform.
- Processing is necessary for the purposes of the legitimate interests. As a general matter, we rely on legitimate interests pursued by us to process your information, including understanding how our Platform is functioning, improving our Platform, and preventing fraud. Where we solely rely on legitimate interest, our use will never override your fundamental rights and freedoms.
- Consent. In certain situations where you provided consent, we may process your information.
- To comply with law. In limited circumstances we may process information in order to comply with legal obligations. To the extent we have received such information from third parties where we have agreed to contractual requirements such as standard contractual clauses, we will use our reasonable efforts to dispute making such disclosures unless legally required to do so.
C. Controller Is Located In The United States of America
VersaFeed and its affiliates are located in the United States and our Platform is generally intended for visitors located within the United States, but can be accessed internationally. If you choose to use the Platform from the United Kingdom or the European Economic Area or other regions of the world with laws governing data collection and use that may differ from U.S. law, then please note that you are transferring your personal information outside of those regions to the United States for storage and processing. Also, we may transfer your data from the U.S. to other countries or regions in connection with storage and processing of data, fulfilling your requests, and providing the Platform.
D. Data Transfer
If your data is collected in United Kingdom or the European Economic Area and transferred outside such respective country to the United States or any other country that has not received an adequacy decision by the European Commission on the basis of article 45 of Regulation (EU) 2016/679, we will transfer your personal data subject to appropriate safeguards, such as Standard Contractual Clauses under applicable law.
E. Your Data Subject Rights
If you are a data subject in Europe, you have the right to access, rectify, or erase any personal data we have collected about you. You also have the right to data portability and the right to restrict or object to our processing of personal data we have collected about you. In addition, you have the right to ask us not to process your personal data (or provide it to third parties to process) for marketing purposes or purposes materially different than for which it was originally collected or subsequently authorized by you. You may withdraw your consent at any time for any data processing we do based on consent you have provided to us.
You may exercise your rights by submitting a written request to us at the address set out in the “Contact Us” section above. We will respond to your request within 30 days. We may request specific information from you to help us confirm your identity and process your request. Applicable law may require or permit us to decline your request. If we decline your request, we will tell you why, subject to legal restrictions.
Please note that we retain information as necessary to fulfil the purposes for which it was collected, and may continue to retain and use information even after a data subject request for purposes of our legitimate interests, including as necessary to comply with our legal obligations, resolve disputes, prevent fraud, and enforce our agreements.
If your personal data has been processed by us on behalf of a customer and you wish to exercise any rights you have with such personal data, please inquire with our customer directly. If you wish to make your request directly to us, please provide the name of our customer on whose behalf we processed your personal data. We will refer your request to that customer, and will support them to the extent required by applicable law in responding to your request.
If you have a complaint about our use of your personal data or response to your requests regarding your personal data, you may submit a complaint to the data protection regulator in your jurisdiction. We would, however, appreciate the opportunity to address your concerns before you approach a data protection regulator, and would welcome you directing an inquiry first to us.