Veridify's Privacy Policy
TABLE OF CONTENTS
1. SCOPE
2. COLLECTION OF INFORMATION
A. Information Provided
B. Information Automatically Collected
C. Tracking Technologies: Cookies; and Other Tracking Technologies
D. Information Received from a Third Party
E. Social Media Applications
3. USES OF PERSONALLY IDENTIFIABLE OR PERSONAL INFORMATION
4. SHARING OF INFORMATION
A. Affiliates
B. Third Party Service Providers
C. Business Transactions
D. Legal Protections and Law Enforcement.
E. Other Third Parties.
5. LINKS TO OTHER WEBSITES
6. NOTICE TO CALIFORNIA RESIDENTS
A. California Privacy Rights Notice
B. California Online Privacy Protection Act Notice
7. NOTICE TO EU / EEA RESIDENTS
8. SECURITY
9. CONSENT TO PROCESSING
10. POLICY GOVERNS USE
11. QUESTIONS
1. SCOPE
This privacy policy applies to the personally identifiable information or personal information (separately and together, Personal Information) collected by VERIDIFY SECURITY INC (VERIDIFY) off-line and on-line through the VERIDIFY website and through interactive features, applications, widgets, blogs, social networks, and on-line or wireless offerings that refer to this policy, whether accessed through a computer, mobile device, or other technology.
Review this policy and the terms as applicable to your interaction with VERIDIFY. A third-party website linked to and/or from a VERIDIFY website or application or other means may have different policies; as a result of the foregoing, review the applicable privacy policy for that website. This policy does not cover the use of Personal Information directly obtained by a third party from you; use of such Personal Information is covered by the relevant party's privacy policy, not this Privacy Policy.
2. COLLECTION OF INFORMATION
A. Information Provided
In General. While VERIDIFY does not generally require the provision of Personal Information to visit and use a VERIDIFY Website or to participate in certain VERIDIFY Website and application activities, such as sweepstakes, contests and other promotions (collectively, Promotions) and blogs, chat rooms, VERIDIFY may ask you to provide Personal Information through its website or its applications that could reasonably be used to contact you, provide the services contemplated by the website or application, or to identify you personally (such as first and last name, e-mail address, mailing address and telephone number). VERIDIFY may also ask you to provide other information about yourself, such as demographic information (such as gender, geographic region, age, etc.) or certain information about your preferences and interests. If you choose not to provide such Personal Information or other information, you may not be able to participate in certain activities offered by VERIDIFY. If VERIDIFY combines demographic or other information VERIDIFY collects about you with your Personal Information, VERIDIFY intends to treat the combined information as Personal Information.
Individuals Under 13. A VERIDIFY Website is open to all individuals, though some Promotions may have age restrictions. VERIDIFY does not knowingly collect or permit the collection, storage or use of any Personal Information from anyone under 13. If you are a parent or guardian who knows or has discovered that your child under the age of 13 has submitted his or her Personal Information or other information without your consent, permission or authorization, VERIDIFY will promptly, upon request: (a) provide direct notice to you indicating what, if any, Personal Information of your child has been collected and how it has been used and/or disclosed; (b) remove your child's Personal Information or other information from the production database, cease the use of such information and direct any other party with access to such information to do the same; and (c) by notice to you, confirm compliance with the foregoing.
For Promotions. VERIDIFY may offer opportunities to enter into Promotions, on its own or jointly with or on behalf of a third party. Such Promotions may require registration and the disclosure of both Personal Information and non-Personal Information. In the event that a Promotion is offered jointly or on behalf of with a third party, as a result of your participation in such Promotion, your Personal Information and non-Personal Information may be shared with such third party, which sharing VERIDIFY will disclose to you at the time you provide your information. By entering a Promotion, you are agreeing to the official rules that govern that Promotion, which may contain specific requirements, including, except where prohibited by law, allowing the sponsor and/or other third parties connected to the Promotion to use your name, voice and/or likeness in advertising and marketing materials. Therefore, read the rules of the Promotion before entering.
B. Information Automatically Collected
In addition to any Personal Information or other information that you choose to provide to VERIDIFY via a VERIDIFY Website or application, whenever you visit or interact with VERIDIFY, VERIDIFY directly or through a third-party analytics provider may automatically collect certain information such as your IP address and/or another unique identifier ("Device Identifier") for the computer, mobile device, or other device ("Device") you use. (A Device Identifier is a number that is automatically assigned to your Device when you access a website or its servers through other means. VERIDIFY computers identify your Device by its Device Identifier.) Some mobile service providers may also provide VERIDIFY or our third-party service providers with information regarding the physical location of the Device used to access a VERIDIFY Website or data repository that stores such information.
VERIDIFY, as well as certain third-party analytics and other service providers, may use a variety of technologies that automatically or passively collect information about how you use a VERIDIFY Website or other application ("Usage Information"). Usage Information may include, in part, the application used to interact with VERIDIFY, browser type, operating system, the page served, the time at which a page was accessed and/or the time spent on a page, and the preceding pages views. Usage Information is generally non-identifying, but if VERIDIFY associates it with you as a specific and identifiable person, VERIDIFY intends to treat it as Personal Information.
C. Tracking Technologies: Cookies; and Other Tracking Technologies
The technologies such as a VERIDIFY application and/or a VERIDIFY Website used to collect Usage Information, including Device Identifiers, may include:
Cookies. "Cookies" (which may be html files, Flash files or other technology) are small text files that help store user preferences and activity. A Cookie is placed on a Device when it is used to visit the VERIDIFY Websites or otherwise access our online offerings. Cookies may be used for many purposes, such as remembering you and your preferences, tracking your visits to our web pages and customizing your VERIDIFY Website experience. If you choose to disable cookies on your Device, some features of our Websites or our online offerings may not function properly.
Embedded Scripts. An embedded script is programming code that is designed to collect information about your interactions, such as a link you may click on. The code is temporarily downloaded onto your Device from our server or a third-party service provider, is active only while you are connected, and is deactivated or deleted thereafter.
GEO Location Services. GEO Location Services allows access to geo-location data obtained from the Device (e.g., GPS) such as the conversion of addresses to coordinates and vice versa (geocoding and reverse geocoding).
Web Beacons. Web beacons (also known as image tags, pixel tags, GIFS or web bugs) are small pieces of code used to collect advertising data, such as counting page views, promotion views or advertising responses. Web beacons or similar technologies may be used for a number of purposes, including, without limitation, to count visitors, to monitor how users navigate a VERIDIFY Website or VERIDIFY application, to count how many sent e-mails were actually opened or to determine whether content sent was actually viewed.
D. Information Received from a Third-Party
VERIDIFY may receive information about you from a third-party. In addition, if you are on another website and you opt-in to receive information from VERIDIFY, the third party will forward to VERIDIFY your e-mail address and other information about you so that VERIDIFY may contact you as requested. VERIDIFY may also supplement the information it collects about you with outside records from third parties in order to enhance its ability to serve you, to tailor its content to you and to offer you opportunities to purchase products or services that VERIDIFY believes may be of interest to you. When VERIDIFY obtains Personal Information from a third-party, VERIDIFY will apply this Privacy Policy to the Personal Information received, unless disclosed otherwise.
E. Social Media Applications
Functionality on a VERIDIFY Website or application may permit interactions with a third-party, such as enabling you to like a product or share content to a third-party website. If you choose to like or share content or to otherwise post information, that information may become public and the third-party may have access to information about you and your use of a VERIDIFY Website or application.
You may also choose to participate in a third-party application or feature (such as one of our Google Play, Facebook applications, or a similar application or feature on a third-party website) through which you allow VERIDIFY to collect and share (or the third party to share) information about you, including Personal Information. The third-party may allow VERIDIFY to remove the application or feature, in which case VERIDIFY will no longer collect information about you through the application or feature, but VERIDIFY may retain the information previously collected. In addition, VERIDIFY may receive information about you if other users of a third-party website give VERIDIFY access to their profiles and you are one of their connections, or if information about you is otherwise accessible through your connections web page, profile page, or similar page on a social networking or other third-party website or interactive service.
VERIDIFY will never request your Personal Information through e-mail. You understand that any message or information you send to VERIDIFY through a VERIDIFY website or application may be read or intercepted by others. VERIDIFY does not ensure or warrant the security of any information you transmit to VERIDIFY. Your use of the VERIDIFY website or application, or provision of any Personal Information is done so at your own risk.
3. USES OF PERSONALLY IDENTIFIABLE OR PERSONAL INFORMATION
VERIDIFY will use the information it collects, including your Personal Information as specifically disclosed at the time the information is provided, for legitimate business interests; such use may be in anonymized form, or in the aggregate with other user information, e.g., demographic information, usage information:
- To tailor your interactive experience with VERIDIFY;
- To market, provide information, and determine which VERIDIFY products and services, or related products and services that may be of interest to you or your company;
- To provide you with support and answer questions or other requests;
- To deliver functionality on VERIDIFY sites and for its technical and functional management;
- To engage in transactions with customers, suppliers, and business partners and to process orders;
- To analyze, develop, improve and optimize the use, function, and performance of VERIDIFY sites, products and services;
- To manage security of VERIDIFY sites, networks and systems;
- To comply with applicable laws and regulations, and to operate VERIDIFY business; and/or
- For other purposes disclosed to you at the time you provide the Personal Information
VERIDIFY may also use the information it collects to improve VERIDIFY products and services, for internal business purposes, and to contact you with regard to your use of a VERIDIFY Website or any product of service, or any other related application and, in our discretion, changes to any policies.
4. SHARING OF INFORMATION
A. Affiliates
VERIDIFY may share your Personal Information with companies affiliated with VERIDIFY (Affiliates), so that those Affiliates can (i) assist with fulfilling requests or improving products, content, services or advertising; and/or (ii) contact you about products, content, services or other offerings that may be of interest to you. For purposes of this Privacy Policy, Affiliates means any company with respect to which VERIDIFY owns, directly or indirectly, 50% or more of its outstanding shares.
B. Third-Party Service Providers
VERIDIFY may from time to time employ a third-party to perform functions on VERIDIFY's behalf, and thus, VERIDIFY may also share your Personal Information with third party service providers that assist with providing content, fulfilling your requests, improving our products, content, services or advertising, or otherwise performing services for VERIDIFY. Additionally, VERIDIFY may share your information in order to host or operate a VERIDIFY Website or other application, for data analysis purposes, and for the administration of Promotions, such as in connection with winner selection and prize fulfillment or issuance of a discount coupon or code.
C. Business Transactions
VERIDIFY may share your Personal Information with other entities affiliated with it for internal reasons, primarily for business and operational purposes including any corporate reorganization, restructuring or other corporate change. In addition, VERIDIFY or any of its assets, including a VERIDIFY Website or application, may be sold, or other transactions may occur in which your Personal Information is one of the key business assets in the transaction. In such a case, your Personal Information may be one of the business assets VERIDIFY transfers. Hence, VERIDIFY reserves the right to disclose and transfer user information, including Personal Information, in connection with any activity and/or transaction described above.
D. Legal Protections and Law Enforcement.
VERIDIFY may transfer and disclose information, including your Personal Information, Usage Information and Device Identifier (including IP address), to third parties: (i) to comply with legal obligations; (ii) when it believes in good faith that the law requires it; (iii) at the request of governmental authorities conducting an investigation; (iv) to verify or enforce VERIDIFY terms and conditions or other applicable policies; (v) to respond to an emergency; or (vi) to otherwise protect the rights, property, safety or security of third parties, users of VERIDIFY applications, and visitors to a VERIDIFY Website or the public. VERIDIFY may also use Device Identifiers to identify users, and may do so in cooperation with copyright owners, Internet service providers, wireless service providers or law enforcement agencies, in its sole discretion. Such disclosures may be carried out without notice to you.
E. Other Third-Parties.
VERIDIFY may offer you the opportunity to consent to the sharing of your information with third parties. Such reasons include, without limitation, so that you are able to receive information and/or marketing offers from third parties. Additionally, you may request, sometimes through your use of an interactive feature or third-party application, that VERIDIFY shares Personal Information about you with a third-party, and VERIDIFY will typically do so in those circumstances. If you agree or request to have your Personal Information shared (either by opting in, choosing not to opt-out or using a specific feature of the VERIDIFY Website(s)), your Personal Information will be disclosed to the applicable third party(s) and the Personal Information you disclose will be subject to the privacy policy and business practices of such third-party(s); therefore, please consult the respective privacy policies of each third-party. If you consent or request to receive communications from third-parties, you will need to communicate with them directly if you later decide that you no longer wish to receive their communications.
5. LINKS TO OTHER WEBSITES
This VERIDIFY website or application may contain links to other websites that are operated and controlled by a third party. These links may connect to advertisers, sponsors and partners, which may use VERIDIFY's logo(s) as part of a co-branding agreement. In addition, VERIDIFY content or widgets may be included on web pages and websites that are not associated with it and over which VERIDIFY has no control. These other third-party websites may send its own cookies to your Device, and such a third party may independently collect data or solicit Personal Information. A link from VERIDIFY's website or application to any other website does not mean that VERIDIFY approves of, endorses, or recommends that website. VERIDIFY provides such links for your convenience and is not responsible for the content of any website linked to or from any VERIDIFY Website. Moreover, VERIDIFY is not responsible for the privacy practices of any third-party, and it disclaims all warranties, express or implied, as to the accuracy, legality, reliability, or validity of any content on any other website.
6. NOTICE TO CALIFORNIA RESIDENTS, IF APPLICABLE
A. California Privacy Rights Notice
Pursuant to California Civil Code Section 1798.83 (Shine The Light Law), this Code authorizes California residents to request and obtain a list of the categories of Personal Information, if any, disclosed to a third party for direct marketing purposes for the preceding calendar year as well as the name and address of such third party. A request may be made only once a year. VERIDIFY shall fulfill the request for no charge. Under Section 1798.83, VERIDIFY does not currently share any Personal Information with a third party for such third party's direct marketing purposes; such information is only for the benefit of VERIDIFY as provided by this policy.
B. California Online Privacy Protection Act Notice
VERIDIFY's Website may not currently interpret, respond to or alter its practices when the Website receives Do Not Track signals from certain web browsers. Please note that a third party may collect Personally Identifiable Information or Personal Information regarding your online activities over time and across different websites when you visit our website or other online websites and services. To find out more about "Do Not Track," you may wish to visit http://www.allaboutdnt.com.
7. NOTICE TO EU/EEA RESIDENT
Pursuant to E.U. General Data Protection Regulation (“GDPR”) and other applicable laws and regulations, individuals in the EU/EEA and other jurisdictions may have certain data rights enabling them to request to access, delete, correct, remove or limit the use, or receive a copy of their Personal Information in VERIDIFY’s possession or for which VERIDIFY is otherwise responsible. In the event an individual seeks to exercise its data rights related to Personal Information that may be stored in repositories that are not available or on portals, if any, that do not have functionality that enables you to take the desired action(s), you may make the request by providing VERIDIFY either in writing to the Office of Regulatory Affairs at VERIDIFY Corporation, 100 Beard Sawmill Road, Shelton, Connecticut 06484 or in electronic form to privacy-at-veridify.com with your name and contact information along with the nature of your request. Specifically, you may request the following:
- Erase or delete of all or some of your Personal Information;
- Edit, change, update, or fix your Personal Information;
- Cease use of all or some of your Personal Information or limit our use of such information;
- Receive a copy of your Personal Information in machine readable form, if you reside in the EU or other country that provides you with this right as a matter of law; or
- Withdraw your previously provided consent to the use of your Personal Information.
In some cases, your request may not be fulfilled if it is not consistent with VERIDIFY’s obligation to comply with its applicable legal or operational requirements, for example, if the data is necessary for the performance of a contract between you and VERIDIFY.
8. SECURITY
VERIDIFY uses commercially reasonable safeguards to protect and secure Personal Information, the object of which is to safeguard the confidentiality, security and integrity of such information. In addition, VERIDIFY uses similar efforts to obtain the agreement of its third-party service providers to take comparable steps to protect any such information VERIDIFY may share with such third parties. Notwithstanding these precautions, no electronic data transmission or storage of information can be completely secured or maintained as private and, therefore, VERIDIFY cannot ensure or warrant the security of any information transmitted to VERIDIFY, including that the information may not be accessed, disclosed, altered, or destroyed by breach of any of VERIDIFY physical, technical, or managerial safeguards. It should be understood that electronic communications, e.g., e-mail, instant messaging, and other similar means of communication, may not be encrypted and, thus, it is advised that use of such forms of communication not contain confidential information.
9. CONSENT TO PROCESSING
A VERIDIFY website or the data repository for Personal Information derived from the VERIDIFY Website or application is operated and stored in the United States. If you are located in the European Union, Canada or any other place outside of the United States, be aware that information VERIDIFY may collect will be transferred to and processed in the United States. By using the VERIDIFY website, or providing VERIDIFY with any information, you fully understand and unambiguously consent to this transfer, processing and storage of your information in the United States, a jurisdiction in which the privacy laws may not be as comprehensive as those in the country where you reside and/or are a citizen.
10. POLICY GOVERNS USE
The terms of this Privacy Policy will govern the use of any information collected while it is in place. VERIDIFY reserves the right to change this Privacy Policy at any time, without prior notice to you, and any changes will become effective immediately upon posting. Your continued use of this website or any application after posting of any changes to this policy will constitute acceptance of, and agreement to be bound by, those changes. Review this Privacy Policy carefully and periodically.
11. QUESTIONS
If you have any questions or comments regarding our practices pertaining to the use or treatment of Personal Information, or about this Privacy Policy, please write to the office of Regulatory Affairs at VERIDIFY SECURITY, 100 Beard Sawmill Road, Shelton, Connecticut 06484, or submit an electronic request to regulatoryaffairs-at-veridify.com.
Last Revised: December 12, 2019