LAST REVIEWED AND UPDATED: JANUARY 11, 2023

Information collected

The types of personal data that may be collected and received while you use the Vervantis Website are described in this section and include both data that has been provided and data that is collected automatically by the Vervantis Website.

For purposes of this Privacy Notice, “Personal Data” means any data related to an identified or identifiable natural person. Examples of Personal Data include name, address, telephone number, and email address.

Information provided

Vervantis collects Personal Data provided, for example, through a contact form in order to enquire about services, through a job application, or to contact Vervantis. This could include:

• Name
• Other contact data such as company name, designation, address, phone number, or email address
• Registration data such as username and password
• Employment history, education and other background data when inquiring about employment

Data that may be collected automatically

When users use Vervantis Website, usage and device data may be collected automatically as described below.

IP Address

Internet Protocol (“IP”) addresses of computers or other electronic devices when visiting the Vervantis Website may be collected.  An IP address identifies the electronic device used to access the site, which support maintaining communications with the user and to customize content on the Website.

Cookies and other tracking technologies

Vervantis uses cookies (and equivalent technologies) to collect and analyze information on our Website’s performance and to enable the Website to function. Cookies allow third parties to see when you visit our Website and other third-party websites in the same online network, including social networks.

More information about cookies and other tracking technologies, including how to disable them is available at http://www.allaboutcookies.org/ or http://youronlinechoices.eu/.  Some cookies are essential to the function of websites and deleting or disabling them will reduce the sites’ functionality.

Data collected from other sources

Vervantis may combine data about users through the Vervantis Website with data that has been collected offline, as well as with data provided by third parties.  Vervantis Inc. may obtain personal information from third parties and sources other than the individual, via partners, advertisers, and marketing agencies.  If personal data is combined with associated information from third-party sources, Vervantis will treat the combined information as Personal Information in accordance with this Policy.

How data is used

Personal Data is used to provide the services users request, communication, improving user experiences, processing job applications, and for other internal business purposes, as described in more detail below.

Providing services requested

When users contact Vervantis, the Personal Data submitted allow for the services requested and offers an optimal customer experience on the basis of consent.

Communicating with users

When a user submits details through the Website, the user may be added to marketing list and may be contacted about. The user may unsubscribe from such communications at any time using the link provided in emails.

Use of information for new purposes

A Notice is provided to the individual about Vervantis Inc.’s Data Privacy Policy and newly proposed purposes for processing personal information before their personal information is used for new purposes not previously identified.

Customized user experiences

Vervantis may use IP addresses and the data obtained automatically through the use of cookies or similar tracking technologies to make our Vervantis Website easier to use and navigate as well as to personalize the content provided on Vervantis Website by anticipating the information and services that may be of interest. In some cases, this information is collected pursuant to consent. In other cases, this information is collected for legitimate business interest to optimize and customize user experiences.

Business and product improvement

In order to discover new facts that could help Vervantis better understand customer needs and help improve, develop, and evaluate services, and materials, Vervantis analyses information provided for legitimate interests in business and marketing improvement.

Service analytics and improvement

Information provided and collected automatically about use of the Website will be used to monitor user traffic patterns and preferences for legitimate business interests.  Vervantis aims to improve analytics and optimization of the Website.

Data use and retention

Personal Data will be kept as long as necessary for the fulfillment of the purposes outlined above, except if otherwise required by applicable laws or legal orders.

Sharing personal information with third-parties.

Data that is shared with third parties like vendors and business partners, hereinafter also referred to as “sub-processors”, to provide services.  Third-party service providers are required to take appropriate security measures to protect your data in line with existing policies. Third parties are not permitted to use data for their own purposes. We permit processing of data for only specified purposes. We require third parties to handle your Personal Data collected through the Vervantis Website in accordance with appropriate contractual privacy and security provisions and this Privacy Notice.  Personal data may be shared with third parties if there is duty to disclose or share personal data in order to comply with any legal obligation, or to protect the rights, property or safety of the Website, users, and others.  When data is shared with third parties, for the purposes as mentioned in this policy, the minimum amount necessary will be used for such purposes.

Information with third parties

Personal Data is only shared with third parties as described below. No information is sold or rented to third parties for their own marketing purposes.

Legal rights and obligations

In certain limited circumstances, Vervantis may need to disclose Personal Data in order to comply with a legal obligation or demand, such as to comply with reporting obligations to governing regulatory authorities, or in connection with the sale or transfer of product lines or divisions, which includes the services provided through one or more of the Vervantis Website. In such instances, measures will be taken to protect your Personal Data to the maximum extent possible. Vervantis reserves the right to use Personal Data to investigate and prosecute users who violate rules or who engage in behavior that is illegal or harmful to others.

Privacy of children

Vervantis does not knowingly collect or use any Personal Data directly from children on Vervantis Website. Vervantis do not knowingly allow children to communicate, or to use online services.  Parents that become aware that their child has provided information, should contact Vervantis to address and issues.

Privacy choices

Users have options regarding the personal data Vervantis Inc. collects, as described below. For California consumers, some of these options are rights provided by the California Consumer Privacy Act (CCPA).  Individuals in the European Union region, some of these choices are privacy rights granted by the General Data Protection Regulation (EU-GDPR).

 Users may contact Vervantis to ask questions, discuss concerns, or report privacy concerns. If communication results with requested information from Vervantis, users may be prompted to provide contact information as well as any Personal Data that is relevant to the request.

Vervantis has appointed a privacy officer who can be contacted through a dedicated email address (privacy@vervantis.com).

Vervantis will have 30-days to respond to inquiries.  If Vervantis will not be able to provide the requested information, users will be provided with reasons for such decision.  Under local law users are entitled to lodge complaints with their local data protection authority.

Users should submit requests and privacy inquiries as described in Privacy Choices.

Choices include:

Access: Users may request access to the specific portions of personal data that have been collected and may also request additional details about information practices, including the categories of personal data that has been collected, business or commercial purposes for collecting or selling personal data, the sources where personal data is collected, types of third parties where personal data is shared, the types of personal data disclosed for business purposes, and details about personal data that has been sold and to whom.

Correction: Clients can choose to modify personal contact information, in the case where incorrect information is on file.

Deletion: Clients may request that personal data is deleted.  Vervantis may retain certain personal data as required or permitted by applicable law. If a request is made to delete personal data, certain services may no longer be available.

Clients may submit requests to privacy@vervantis.com

“Do Not Sell” choice (For California consumers)

Vervantis Inc. does not sell your personal data to anyone, and hence complies with the CCPA’s privacy rights.

Marketing communications choice

Vervantis may communicate with clients through various channels about Products and Services or products and services that partners offer. Clients may choose to opt-out of some or all marketing communications, at the time of providing personal information. For example, submitting contact information through the Website, clients have a choice to opt-out of receiving marketing communications. However, customers will continue to receive invoices, service and transactional notices, and similar communications.

Advertising choice

Clients can opt-out of targeted ads that may be seen on the internet after visiting the Website. To exercise this choice, clients can disable the advertising related cookies from the cookie banner.  Clients will not be discriminate against if they choose to exercise options related to  personal data. However, exercising some of the choices available may have some consequences related to communication. For example, if a prospective customer chose not to receive marketing communications.

Data protection principles

Vervantis is committed to processing data in accordance with its responsibilities under the GDPR.  Article 5 of the GDPR requires that personal data shall be: processed lawfully, fairly and in a transparent manner in relation to individuals

• collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall not be considered to be incompatible with the initial purposes
• adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed
• accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay
• kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes subject to implementation of the appropriate technical and organizational measures required by the GDPR in order to safeguard the rights and freedoms of individuals
• processed in a manner that ensures appropriate security of the personal data, including protection against unauthorized or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organizational measures.”

General provisions

• This policy applies to all personal data processed by the Vervantis.
• The Responsible Person shall take responsibility for the Vervantis ongoing compliance with this policy.
• This policy shall be reviewed at least annually.

Lawful, fair and transparent processing

• To ensure its processing of data is lawful, fair and transparent, Vervantis shall maintain a Register of Systems.
• The Register of Systems shall be reviewed at least annually.
• Clients shall have the right to access their personal data and any such requests made to the Vervantis shall be dealt with in a timely manner.

Lawful purposes

• All data processed by the Vervantis must be done on one of the following lawful bases: consent, contract, legal obligation, vital interests, public task or legitimate interests.
• Vervantis shall note the appropriate lawful basis in the Register of Systems.
• Where consent is relied upon as a lawful basis for processing data, evidence of opt-in consent shall be kept with the personal data.
• Where communications are sent to individuals based on their consent, the option for the individual to revoke their consent should be clearly available and systems should be in place to ensure such revocation is reflected accurately in the Vervantis systems.

Data minimization

• Vervantis shall ensure that personal data are adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.

Accuracy

• Vervantis shall take reasonable steps to ensure personal data is accurate.
• Where necessary for the lawful basis on which data is processed, steps shall be put in place to ensure that personal data is kept up to date.

Archiving / removal

• To ensure that personal data is kept for no longer than necessary, Vervantis shall put in place an archiving policy for each area in which personal data is processed and review this process annually.
• The archiving policy shall consider what data should/must be retained, for how long, and why.

Security

• Vervantis shall ensure that personal data is stored securely using modern software that is kept-up-to-date.
• Access to personal data shall be limited to personnel who need access and appropriate security should be in place to avoid unauthorized sharing of information.
• When personal data is deleted this should be done safely such that the data is irrecoverable.
• Appropriate back-up and disaster recovery solutions shall be in place.

Processing Activities 

• Any operation or set of operations that is performed on Personal Data.
• Can be automatic or non-automatic means.
• Including (but not limited to)
  • obtaining, developing, producing, collecting, recording, organizing, structuring, accessing, using, adapting, altering, modifying, retrieving, consulting, copying, reproducing, analyzing, disclosing, disseminating, making available, aligning, combining, blocking, restricting, transmitting, transferring, selling, renting, storing, retaining, destroying, deleting, or erasing such Personal Data.

Breach

In the event of a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data, Vervantis shall promptly assess the risk to people’s rights and freedoms and if appropriate report this breach to the appropriate authorities in accordance with Vervantis Breach Notification Policy.

Data security

Vervantis maintains reasonable technical, administrative, organizational and physical security measures and controls to secure any Personal Data collected through the Vervantis Website. However, there is always some risk that an unauthorized third party could intercept an Internet transmission, or that someone will find a way to thwart security systems. Vervantis urges clients to exercise caution when transmitting Personal Data over the Internet, especially any sensitive Personal Data. Vervantis cannot guarantee that unauthorized third parties will not gain access to client Personal Data.

Links to third-party sites and social media plug-ins

This Privacy Notice does not apply to third-party websites to which Vervantis Website may link. Vervantis Website may use social media plug-ins (e.g., the Facebook “Like” button, “Share to Twitter” button) to enable the ability to share information with others. When visiting the Vervantis Website, the operator of the social plug-in can place a cookie on the users computer or other electronic device that enables that operator to recognize individuals who have previously visited the Website. If logged into the social media websites (e.g., Facebook, LinkedIn, Twitter) while browsing the Vervantis Website, the social media plug-in may allow that social media website to receive information about visiting the Vervantis Website. The social media plug-in may allow the social media website to share information about activities on the Vervantis Website with other users on social media websites. These sharing settings are managed by the social media website and governed by its privacy policy.

Changes to our privacy notice

Vervantis will only use Personal Data in the manner described in the Privacy Notice in effect when the information was collected from the client or as authorized by the client. However, and subject to any applicable consent requirements, or if required by law, Vervantis reserves the right to change the terms of this Privacy Notice at any time. Any changes to this Privacy Notice will be reflected on this page with a new effective date. Vervantis encourages clients to review the Privacy Notice regularly for any changes. Any Personal Data collected upon continued use of the Vervantis Website will be handled in accordance with the currently posted Privacy Notice.

If you have a specific question about the above, please send it to us.