Last updated: 16 May 2018
Effective date: 25 May 2018
We at Vero Holdings Australia Pty. Ltd. and its group companies (collectively “Vero”, “we”, “us”, and “ours”) know that our users (“you,” “your”) care about how your personal information is used and shared, and we take your privacy seriously. Please read the following to learn more about our Privacy Notice.
We recommend that you read this Notice in full to ensure you are fully informed.
However, to make it easier for you to review those parts of this Notice which apply to you, we have divided up the document into the following sections:
- Section 1. What does this Privacy Notice cover?
- Section 2. Privacy for our Services
- Section 3. Privacy for our Websites
- Section 4. General Information
- Will Vero share any of the personal information it receives?
- Legal basis for processing information (EEA visitors only)
- Where we store your information
- Is the personal information secure?
- What personal information can I access?
- What choices do I have?
- Data retention and deletion
- Changes to this Privacy Notice
- Questions or concerns
- “Website” means veropublic.wpengine.com.
- “Services” means the software product that Vero provides website operators and other individuals encompassing a variety of tools and resources (including some elements of our Website) to enable them to collect user and usage data and send email and other messages efficiently to consumers based on their behavior.
- “End User” means any of our Customers’ customers.
- “End User Data” means data relating to our customers’ customers.
- “Personal Information” means personally identifiable information as defined by applicable data protection laws, including where applicable, EU data protection law.
1. What does this Privacy Notice cover?
This Privacy Notice covers our treatment of personally identifiable information (“Personal Information”) that we gather when you are accessing or using our Website (see section 2 ) and Personal information that we gather when you access or use our Services.
For the purposes of this Privacy Notice, “Services” means the software product that Vero provides website operators and other individuals encompassing a variety of tools and resources (including some elements of our Website) to enable them to collect user and usage data and send email and other messages efficiently to consumers based on their behavior (see section 3 ).
This Notice does not apply to the practices of companies that we do not own or control.
2. Privacy for our Website
This section describes how we collect and use information from users of and visitors to our Website.
2.1 What information do we collect?
We gather various types of Personal Information from our users and website visitors, as explained in 2.1a below. We may use this Personal Information to analyze how users interact with the Website and for other purposes set forth in this Privacy Notice.
a. Information you provide to us
Your Personal Information: we receive and store any information you knowingly provide to us. For example, we collect Personal Information such as your name and email address. You can choose not to provide us with certain information, but then you may not be able to register with us or to take advantage of some of our features. We may anonymize your Personal Information so that you cannot be individually identified.
b. Information collected automatically
Whenever you interact with our Website, we automatically receive and record information on our server logs from your browser including your IP address, browser version and type, “cookie” information, and the page you requested.
Usage Data: When you visit the Website, whether as a Vero customer or a non-registered user just browsing, our servers automatically record information that your browser sends whenever you visit a website (“Log Data”). For example, Log Data may include information such as your computer’s IP address, browser type or the webpage you were visiting before you came to our Website, pages of our Website that you visit, the time spent on those pages, information you search for on our Website, access times and dates, and other statistics. We use this information to monitor and analyze use of the Website and the Services and for the Website’s technical administration, to increase our Website’s functionality and user-friendliness, and to better tailor it to our visitors’ needs.
3. Privacy for our Services
This section describes how we collect and use information we receive when you use our Services.
3.1 What information do we collect and how do we use it?
We gather various types of Personal Information from our users, as explained more fully below. We may use this Personal Information to personalize and improve the Services, to allow our users to set up a user account and profile, to contact users, to fulfill your requests for the Services and as otherwise set forth in this Privacy Notice. We may share certain types of Personal Information with third parties (described in this Section and in Section 4.1 below).
a. Information you provide to us:
Your Personal Information: We receive and store any information you knowingly provide to us. For example, we collect Personal Information such as your name and email address. You can choose not to provide us with certain information, but then you may not be able to register with us or to take advantage of some of our features.
Your Customers’ Personal Information: In order to provide you with the Services, we also receive and store any information you choose to provide us with in respect to your customers (“End Users”). The End User information (“End User Data”) we receive and store typically includes names and email addresses of your customers, but will consist of any information you choose to provide us with.
b. Information collected automatically:
Usage Data: we automatically collect certain data relating to the performance and configuration of our Service and our customers’ and our customers’ end users’ consumption and use of, and interaction with, the Service (“Usage Data”). Usage Data is generally technical information or data obtained from APIs, product software or systems hosting the products and services, devices accessing these products and services and solutions and/or log files generated during such use but may also include information such as IP addresses (which may in some jurisdictions be considered personal information). Such Usage Data is used for Vero to maintain and operate the Service and separately, to analyze and improve the Service. Usage Data does not include any customer or end user content stored in the Service.
End User Data: as part of our provision of the Services to you, if you install the API libraries and other software code provided by us on your website, we will also track and collect End User usage information on your website.
c. Information we obtain from third parties
We also use third parties to collect information relating to you using Clearbit, CRM and similar services. For more information on how we share information, please see section 4.1 below.
4. General Information
4.1 Will Vero share any of the personal information it receives?
We neither rent nor sell your or your End User Customers’ Personal Information in personally identifiable form to anyone. We share such Personal Information in personally identifiable form with third parties as described below.
a. Trusted Third Parties:
We employ other companies and people to perform tasks on our behalf and need to share your information with them to provide the Services to you. Unless we tell you differently, such third parties do not have any right to use the Personal Information we share with them beyond what is necessary to assist us. This includes third party companies and individuals employed by us to facilitate our Services, including the provision of maintenance services, database management, web analytics and general improvement of the Services. A list of our current Trusted Third Parties can be found here.
b. Business transfers:
We may choose to buy or sell assets. In these types of transactions, customer information is typically one of the business assets that is transferred. Also, if we (or substantially all of our assets) are acquired, or if we go out of business, enter bankruptcy, or go through some other change of control, Personal Information would be one of the assets transferred to or acquired by a third party, in which case such party will use your Personal Information in line with this Privacy Notice.
c. Protection of Vero and others:
We reserve the right to access, read, preserve, and disclose any information that we reasonably believe is necessary to comply with law or a court order; enforce or apply our conditions of use and other agreements; or protect the rights, property, or safety of Vero, our employees, our users, or others. This includes exchanging information with other companies and organizations for fraud protection and credit risk reduction.
d. With your consent:
Except as set forth above, you will be notified when your Personal Information may be shared with third parties, and will be able to prevent the sharing of this information.
4.2 Legal basis for processing Personal Information (EEA visitors only)
If you are a visitor/customer located in the European Economic Area (“EEA”), Vero Holdings Australia Pty Ltd is the data controller of your Personal Information.
Our legal basis for collecting and using the Personal Information described above will depend on the Personal Information concerned and the specific context in which we collect it. However, we will normally collect Personal Information only where we have your consent to do so, where we need the Personal Information to perform a contract with you, or where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms.Â In some cases, we may also have a legal obligation to collect Personal Information from you.
If we ask you to provide Personal Information to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your Personal Information is mandatory or not (as well as the possible consequences if you do not provide your Personal Information). Similarly, if we collect and use your Personal Information in reliance on our legitimate interests (or those of a third party), we will make clear to you at the relevant time what those legitimate interests are.
For more information on the legal basis for processing your information please contact us at firstname.lastname@example.org .
4.3 Where we store your personal information
Vero has its headquarters and the majority of its operations in Australia.Â If you interact with, join or share your data with Vero in any of the ways explained in this Privacy Notice then, if you are not also in Australia, your Personal Information may be transferred to, and processed in, countries other than the country in which you are resident. These countries may have data protection laws that are different to the laws of your country and, in some cases, may not be as protective.
Specifically, our servers are located in the United States, and our group companies and service providers operate in the United States, Australia and Singapore. This means that when we collect your Personal Information we may process it in any of these countries.
However, we have taken appropriate safeguards to require that Personal Information will remain protected in accordance with this Privacy Notice.
4.4 Is the personal information secure?
Your account is protected by a password for your privacy and security. You must prevent unauthorized access to your account and Personal Information by selecting and protecting your password appropriately and limiting access to your computer or device and browser by signing off after you have finished accessing your account.
We use appropriate technical and organisational measures to protect the Personal Information that we collect and process. The measures we use are designed to provide a level of security appropriate to the risk of processing your Personal Information. Specific measures we use include encrypting Personal Information in transit and at rest, the implementation of an internal security policy and access control measures for all team members, the use of firewalls and other threat detection technologies, regular backups for data recovery. Whilst we endeavor to protect the privacy of your account and other Personal Information we hold in our records, we cannot guarantee complete security. The transmission of information via the Internet is not completely secure. Unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of user information at any time.
4.5 What personal information can I access?
a. Non-EEA Privacy Rights
Through your account settings, you may access, and, in some cases, edit or delete the following information you’ve provided to us:
- Email address
- Billing address
The information you can view, update, and delete may change as the Website or Services change. If you have any questions about viewing or updating information we have on file about you, please contact us at email@example.com.
Under California Civil Code Sections 1798.83-1798.84, California residents are entitled to ask us for a notice identifying the categories of Personal Information which we share with our affiliates and/or third parties for marketing purposes, and providing contact information for such affiliates and/or third parties. If you are a California resident and would like a copy of this notice, please submit a written request to: firstname.lastname@example.org.
b. EEA Privacy Rights
If you are a resident of the EEA you have the following data protection rights:
- If you wish to access, correct, update or request deletion of your Personal Information, you can do so at any time.
- You can object to processing of your Personal Information, ask us to restrict processing of your Personal Information or request portability of your Personal Information.
- If we have collected and process your Personal Information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your Personal Information conducted in reliance on lawful processing grounds other than consent.
- You have the right to complain to a data protection authority about our collection and use of your Personal Information. Contact details for data protection authorities in the EEA are available here.
If you wish to exercise any of these rights or want further information please contact us via email@example.com
4.6 What choices do I have?
You can always opt not to disclose information to us, but keep in mind some information may be needed to register with us or to take advantage of some of our special features.
You may be able to add, update, or delete information as explained in Section 4.5 above. When you update information, however, we may maintain a copy of the unrevised information in our records.
You may request deletion of your account by contacting us at firstname.lastname@example.org Â Please note that some information may remain in our private records after your deletion of such information from your account.
We may contact you, by email or other means; for example, we may communicate with you about your use of the Website or Services. If you do not want to receive email or other mail from us, please indicate your preference by adjusting the settings using our Preference Center.
4.7 Data retention and deletion
We retain Personal Information we collect from you where we have an ongoing legitimate business need to do so, (for example, to provide you with a service you have requested or to comply with applicable legal, tax or accounting requirements). When we have no ongoing legitimate business need to process your Personal Information, we will either delete or anonymise it or, if this is not possible (for example, because your Personal Information has been stored in backup archives, then we will securely store your Personal Information and isolate it from any further processing until deletion is possible.
4.8. Changes to this Privacy Notice
We may amend this Privacy Notice from time to time. Use of information we collect now is subject to the Privacy Notice in effect at the time such information is used. If we make changes in the way we use Personal Information, we will notify you by posting an announcement on our Website or sending you an email.
4.9. Questions or concerns?
Email it to us at email@example.com or call us on +61 (2) 8505 8607 or +1 (650) 643 9866.
Our address is:
Vero Holdings Australia Pty Ltd.
Level 1, 251 Riley Street