Effective July 19, 2019
Information We Collect
When you activate your account, we collect the personal information you give us, such as your name, organization and position, address, and email address. If you purchase materials or a subscription from us, we also collect your payment information such as your credit card number. We use this information to establish and maintain your account, create your user profile, provide and improve the services you request, process payments and communicate with you about your account. We share it under limited circumstances described below.
As is true of most websites, we gather certain information automatically. This information may include internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, the files viewed on our site (e.g., HTML pages, graphics, etc.), operating system, date/time stamp, and/or clickstream data. We use this information to analyze trends in the aggregate and administer the site.
User Data Supplementation
We may receive information about you from other sources, including publicly available databases or third parties from whom we have purchased data, and combine this data with information we already have about you. This helps us to update, expand and analyze our records, identify new customers, and provide products and services that may be of interest to you. If you provide us personal information about others, or if others give us your information, we will only use that information for the specific reason for which it was provided to us.
Examples of the types of personal information that may be obtained from public sources or purchased from third parties and combined with information we already have about you may include: Address information about you from third party sources, such as the U.S. Postal Service, to verify your address so we can properly ship your order to you and to prevent fraud; and/or marketing data that is combined with information we already have about you, to create more tailored advertising and products.
Sharing with Service Providers
We use service providers to help us provide and support the Service or certain features of the Service. These include cloud hosting and service providers. We share information with these companies in order to enable them to provide their services to us and to you. These companies are authorized to use your personal information only as necessary to provide these services to us. We also use data analytics services from third parties to help us understand how visitors use our site and to improve our services. For example, we use Google Analytics to measure and analyze Service usage. You can read more about how Google uses such data at www.google.com/policies/privacy/partners/. When you navigate or are redirected to a third-party’s website, your activities and information will be governed by the terms and policies of such third-party.
Onward Transfers of Personal Data
In cases of onward transfers, we are responsible for transferring your personal data to third parties only for limited and specified purposes. We will take reasonable and appropriate steps to ensure that the third party effectively processes the personal information in a manner consistent with our own obligations. We require third parties to notify us if it makes a determination that it can no longer to provide the same level of protection we require.
Clear and Conspicuous Notice
We will provide clear and conspicuous notice when users are first asked to provide personal information or as soon thereafter as is practicable, but in any event before we use such information for a purpose other than that for which it was originally collected or processed by the transferring organization or discloses it for the first time to a third party.
We may disclose your personal information as required by law, such as to comply with a subpoena or other legal process, when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request. If we are involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via email and/or a prominent notice on our website, of any change in ownership, uses of your personal information, and choices you may have regarding your personal information. We may also disclose your personal information to any other third party with your consent.
Email or Newsletter Preferences
You may sign up to receive emails about our content, new products and services, and other updates. If you would like to discontinue receiving this information, you may update your email preferences by using the “Unsubscribe” link found in the emails we send to you or at your member profile on our website or by contacting us at email@example.com.
Basis for Use; Consent
The security of your personal information is important to us. We take reasonable technical and organizational precautions to protect your personal information from unauthorized or unlawful use and against accidental loss, destruction or damage. We also follow generally accepted standards to protect the personal information submitted to us, both during transmission and once it is received. You acknowledge, however, that no method of transmission over the Internet or electronic storage is fully secure. If you have any questions about the security of your personal information, you can contact us at firstname.lastname@example.org.
Verrah has further committed to cooperate with the panel established by the EU data protection authorities (DPAs) with regard to unresolved Privacy Shield complaints concerning data transferred from the EU.
Access; Other Rights; Data Retention
Upon reasonable request, we will provide you with information about any of your personal information in our possession, and you may view, correct, or request deletion of your personal information. You may send your request to email@example.com. We will respond to your request within a reasonable timeframe. In most cases, Verrah has no direct relationship with the individuals whose personal data it processes. If you are a customer of one of our clients and would no longer like to be contacted by that client, please contact the client directly.
Verrah is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC). You may have additional rights under applicable data protection laws, including the EU General Data Protection Regulation. For example, you may have the right to lodge a complaint with the data protection supervisory authority in your country. You may also have the right to request access to and rectification or erasure of personal information or restriction of processing of your personal information, or to object to processing, as well as the right to data portability. Under certain conditions, you may have the right to invoke binding arbitration.
We will retain personal data we process on behalf of any of our clients for as long as needed to provide services to such client. We will retain such personal data as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
Age of Consent
We do not knowingly collect personal information from minors without a written agreement. By using this site, you represent that you are at least the age of majority in your state or province of residence. If you or your organization wish to use the Service or any Verrah content in connection with activities involving minors, such as applying our methodologies in a school, you must enter into a special, written agreement with us specifying the terms of such use.
Changes to This Policy
We may update this Policy to reflect changes to our information practices or applicable law. If we make any material changes, we will notify you by means of a notice on this website prior to the change becoming effective. Please periodically review this page for the latest information on our privacy practices.
Questions and Contact Information
If you have questions or comments about this Policy, please contact us at firstname.lastname@example.org or by conventional mail at:
Attn: Privacy Compliance Officer
228 Park Ave S
New York, NY 10003